NC0004120_Regional Office Historical File Pre 2018 (3)

INA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
November 21, 2007
Issac Assa
E-flex LLC
1 Industrial Way W
Eatontown, NJ 07724
William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
Subject: Renewal Notice
NPDES Permit NC0004120
E-Flex WWTP
Cleveland County
Dear Permittee:
Your NPDES permit expires on August 31, 2008. Federal (40 CFR 122.41) and North Carolina (15A
NCAC 2H.0105(e)) regulations require that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit. If you have already mailed your renewal application, you may
disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later
than March 4, 2008. Failure to request renewal by this date may result in a civil assessment of at least
$500.00. Larger penalties may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after August 31, 2008, the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If you have any questions, please contact me at the
telephone number or e-mail address listed below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
M. Central Files,
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina.27604 NofthCarohna
Phone: [phone], extension 511 / FAX [phone] / [e-mail]
;Vaturally
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

NPDES PERMIT NC0004120
E-FLEX WWTP
CLEVELAND COUNTY
The following items are REQUIRED for all renewal packages:
O A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
o The completed application form (copy attached), signed . by the permittee or an Authorized
Representative. Submit one signed original and two copies.
O If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part II.B.1 Lb of the existing NPDES permit).
0 A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities discharging
tirocess wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code -of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

02/11/2009 18:45 7045387446 PAGE 01
TOWN OF LAWNDALE
P.O. Box 256
LAWNDALE, NC 28090-0256
FEBRUARY 11, 2009
TO WHOM IT MAY CONCERN:
THE TOWN OF LAWNDALE CEASED TO OPERATE AND
MONITOR THE WASTE TREATMENT PLANT LOCATED
ON THE e -flex, Inc, PROPERTY IN LAWNDALE ON
DECEMBER 15, 2009. THE BUSINESSES AND HOMES THAT
WERE ON THE TREATMENT PLANT ARE NOW ON A PUMP
STATION THAT PUMPS TO THE TOWN OF SHELBY BY WAY
OF THE TOWN OF FALLSTON.
THE TOWN OF LAWNDALE APPRECIATES THE USE OF
THIS FACILITY IN OUR TIME OF NEED.
RICK CARVER, MAYOR

�
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins., Director
Division of Water Quality
December 11, 2008
Honorable Rick Garver, Mayor
Town of Lawndale
P.O. Box 207
Lawndale, NC 28151
Subject: Sampling Inspection
e-flex, inc WWTP
NPDES Permit No. NC0004120
Cleveland County, North Carolina
Dear Mr. Garver:
Enclosed please find the results from the laboatory analyses performed on the wastewater
treatment plant (WWTP) samples collected from the e-flex, inc WWTP. The samples analyzed were
grab samples collected from the equalization and aeration basins by Ms. Donna Hood and Mr. Wes
Bell on November 3, 2008. Please inform the facility's Operator -in -Responsible Charge of our
findings by forwarding a copy of the enclosed report.
The samples cannot be used for compliance determination because the WWTP was not discharging at
the time of the inspectrion.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
c
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
DH
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

ANALYTICAL RESULTS SHEET
11
NAME OF FACILITY: e-flex, inc.
Sample Date(s): 11.03.2008
Grab: X Composite:
NPDES Permit No. NC0004120
Sample Location: equalization basin
County: Cleveland
BOD5, mg/1
<2.0
Phenols, ug/l
<10
COD: High, mg/l
Sulfate, mg/1
61
COD: Low, mg/l
51
Sulfide, mg/1
<0.1
Coliform: Fecal, #/100 ml
9
Biomass: Dry Weight
Coliform: Total, #/100 ml
Biomass: Peri Ash Free
Coliform: Tube Fecal, MPN
NH3-N, mg/l
<0.10
Coliform: Tube Total, MPN
TKN, mg/1
3.2
Residue: Total, mg/l
NOZ + NO3i mg/1
<0.02
Volatile, mg/l
PO4, mg/l
Fixed, mg/1
P: Total, mg/l
1.4
Residue: Suspended, mg/1
12
P: Dissolved, mg/1
Volatile, mg/l
Ag-Silver, ug/l
Fixed, mg/1
Al -Aluminum, ug/l
Settleable Solids, ml/l
Be -Beryllium, ug/l
pH, s.u.
Ca -Calcium, ug/l
TOC, mg/1
Cd-Cadmium, ug/1
Turbidity, NTU
Co -Cobalt, ug/l
Chloride, mg/1
200
Cr-Chromium: Total, ug/l
<10
Oil and Grease, mg/1
Cu-Copper, ug/1
9.6
Cyanide, ug/l
Fe -Iron, mg/1
Fluoride, mg/1
<8.0
Pb-Lead, ug/l
<10
Hardness: Total, mg/l
Hg-Mercury, ug/l
<0.20
MBAS, ug/l
Ni-Nickel, ug/1
Conductivity, umhos/cm
Zn-Zinc, ug/1
<10
Dissolved Oxygen, mg/1
VOC
Temperature, °C
Semivolatiles
* denotes a violation of a permit limitation.
(Grab) denotes that sample was collected by grab method.

ANALYTICAL RESULTS SHEET
NAME OF FACILITY: e-flex, inc. Grab: X Composite:
Sample Date(s): 11.03.2008 NPDES Permit No. NC0004120
Sample Location: equalization basin County: Cleveland
BOD5, mg/1 5.8
Phenols, ug/1
<10
COD: High, mg/1
Sulfate, mg/1
52
COD: Low, mg/1 61
Sulfide, mg/1
<0.1
Coliform: Fecal, 4/100 ml
Biomass: Dry Weight
Coliform: Total, 9/100 ml
Biomass: Peri Ash Free
Coliform: Tube Fecal, MPN
NH3-N, mg/1
<0.02
Coliform: Tube Total, MPN
TKN, mg/1
3.2
Residue: Total, mg/1
NO2 + NO3i mg/l
0.16
Volatile, mg/1
PO4i mg/l
Fixed, mg/1
P: Total, mg/1
0.32
Residue: Suspended, mg/l 20
P: Dissolved, mg/1
Volatile, mg/1
Ag-Silver, ug/l
Fixed, mg/1
Al -Aluminum, ug/1
Settleable Solids, ml/1
Be -Beryllium, ug/1
pH, s.u.
Ca -Calcium, ug/1
TOC, mg/l
Cd-Cadmium, ug/1
Turbidity, NTU
Co -Cobalt, ug/1
Chloride, mg/1 83
Cr-Chromium: Total, ug/1
<10
Oil and Grease, mg/1
Cu-Copper, ug/1
17
Cyanide, ug/1
Fe -Iron, mg/1
Fluoride, mg/1 <8.0
Pb-Lead, ug/l
<10
Hardness: Total, mg/l
Hg-Mercury, ug/1
<0.20
MBAS, ug/1
Ni-Nickel, ug/1
Conductivity, umhos/cm
Zn-Zinc, ug/1
17
Dissolved Oxygen, mg/l
VOC
Temperature, °C
Semivolatiles
* denotes a violation of a permit limitation.
(Grab) denotes that sample was collected by grab method.

'N
Division of Water Quality
November 14, 2008
MEMORANDUM
To: Rob Krebs
Regional Supervisor, Surface Water Protection, MRO
Through: Cindy A. Moore C 1
Supervisor, Aquatic Toxicology Unit
From: Carol HollenkampL Y
Quality Assurance Officer, Aquatic Toxicology Unit
Subject: Whole effluent toxicity test results
E-Flex, LLC WWTP
NPDES Permit # NC0004120/001
Cleveland County
The non-compliance aquatic toxicity test using grab samples of effluent discharged from E-Flex, LLC
WWTP has been completed. E-Flex, LLC WWTP has an effluent discharge permitted that is 0.78 million
gallons per day (MGD) entering First Broad River (7Q 10 of 76 CFS). Whole effluent samples were
collected on November 3 and November 7 by Donna Hood for use in a non-compliance chronic
Ceriodaphnia dubia pass/fail toxicity test. The test using these samples resulted in a pass. Toxicity test
information follows.
Test Type
Test Concentrations
Test Result
Control Survival
Control Mean Reproduction
Test Treatment Survival
Treatment Mean Reproduction
First Sample pH
First Sample Conductivity
First Sample Total Residual Chlorine
Second Sample pH
Second Sample Conductivity
Second Sample Total Residual Chlorine
3-Brood Ceriodaphnia dubia pass/fail
1.6% sample
Pass (non-compliance)
100%
25.5 neonates
100%
25.3 neonates
8.41 SU
948 micromhos/cm
<0.0052 mg/L
8.28 SU
947 micromhos/cm
<0.0052 mg/L
Test results for the above samples indicate that the effluent would not be predicted to have water quality
impacts on receiving water. Please contact us if further effluent toxicity monitoring is desired. We may be
reached at [phone].
Basin: BRD04
cc: Central Files
Donna Hood, MRO
Aquatic Toxicology Unit Environmental Sciences Section

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins., Director
Division of Water Quality
November 14, 2008
Mr. Brad Cornwell
Utilities Director
City of Shelby
P.O. Box 207
Shelby, NC 28151
Subject: e-flex, inc.
e-flex WWTP
NPDES Permit No. NC0004120
Cleveland County, North Carolina
Dear Mr. Cornwell:
This Office has been informed by Mr. David Hux, Assistant Utilities Director for the City of
Shelby, on November 7, 2008, that the Town of Lawndale is in the process of connecting it's
wastewater collection system to the City of Shelby's wastewater collection system. We were also
informed that the completion of the connection is reported to be the end of November 2008. In order
to minimize potential surface water impacts from the e-flex WWTP it is recommended that the City
of Shelby create as much freeboard as practicable in the WWTP basins and take any other measures
necessary to prevent unauthorized discharges.
If you have any questions, please feel free to contact Ms. Donna Hood at [phone].
Sincerely,
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
DH
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

,EFFLUENT,
prNPDES
PERMIT NO. NCO027197 DISCHARGE NO. 001 t jJWH: SEPTEMBER YEAR 2008
FACILITY NAME: CITY OF SHELBY WATER TREAT NT PLANT S: 1 COUNTY: CLEVELAND
OPERATOR IN RESPONSIBLE CHARGE BILLY VpfKIE GRADE I PHONE 704A1846885
CERTIFIED LABORATORIES (1) #= TURBIDITY StAPENDED RESIDUE (2) #40 AL Fe (3) #5340 CL2 SETTABLE MATIIER
CHECK IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLE_ BILLY WILKIE WENDELL LEONARD NOV 0 5 7008
ATTIC: Central Files
DIVISION OF WATER QUALITY (SIGNATURE OF ORC) BY THIS SIGNATURE, I CERTIFY THAT Date
1617 MAIL SERVICE CENTER THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF
RALEIGH, NC 27699-1617 MY KNOWLEDGE.
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0.428
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0.0576
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0.0591
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0.0625
3010700
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0.05725
14
1
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0.084
0.355
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0.07200
41
4.4
0.0
0.140
0.719
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0.02400
0
0.0
0.0
0.050
0.126
Comp.(CuGrab(G)
G
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Monthly Limit
30
0.1

Facility Status: ( please check one of the following )
All monitoring data,andsampling frequencies meet•permit requirements
(Compliant) ..
All monitoring data and sampling frequencies do NOT meet permit requirements ❑
(Noncompliant)
If the facility is noncompliant, please comment on corrective actions being taken in respect
to equipment, operations,. maintenance, etc., and a time table for improvements to be made
"I certify, under penalty of law, that this document and all attachment were prepared under my direction `
or supervision in accordance -with a system designed to assure that qualified personnel properly gather
and information. submitted. based on my inquiry of the person or persons who manage the system, or. .
those persons directly responsible for gathering.the information, the information submitted is,
to the best of my knowledge and, belief, true, accurate, and complete, I am aware that there are
significant penalties for.submitting false information, including the possibility of fines, and
imprisonment for knowing violation."
WANE SANDO
Permittee
Signature of Permittee** Date
801 WEST GROVER ST SHELBY NC 28150 704 484 6885 8 -31 2008
PERMITTE ADDRESS PHONE NUMBER PERMIT EXP.DAT
SQ g Z 13Q
- City of -Shelby, Utilities Dept. MODIFIED, MR 1/REVISED 6t94

1
COUNTY:FACILITY NAME: SHELBY WATER TREATMENT
TRIBUTARY BROAD BROAD
LOCATION: SOUTHWEST LOCATION:
/ DOWNSTREAM
UPSTREAM
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City of Shelby, Utilities Dept. Modified: DEM Form MR-(6/94)

OCT 28 08

OF wArF9
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rDIUVa—
Michael F. Easley, Governor,
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
May 30, 2007
CERTIFIED MAIL #7006 2760 0001 8494 2730
RETURN RECEIPT REQUESTED
Mr. Michael O'Brien, Mayor
Town of Lawndale
Post Office Box 256
Lawndale, North Carolina 28090
Dear Mr. O'Brien:
Alan W. Klimek, P.E. Director
Division of Water Quality
Subject: Notice of Violation - Effluent Limitation
Tracking #: NOV-2007-LV-0295
E-Flex WWTP
NPDES Permit No. NC0004120
Cleveland County
A review of the January 2007 self -monitoring report for the subject facility revealed a
violation of the following parameter at Outfall 001:
Date Parameter Reported Value Permit Limit
1/10/07 Sulfide 8.7 lbs/day (Daily maximum) 4.0 lbs/day (Daily maximum)
1/31/07 Sulfide 4.35 lbs/day (Monthly average) * 2.0 lbs/day (Monthly average)
* Facility incorrectly reported as < 4.51bs/day
Remedial actions, if not already implemented, should be taken to correct any problems.
Since the comments section on the reverse of the relevant Discharge Monitoring Report provided
an explanation for the noted effluent limit violation, it is not requested that a response be
submitted; however, should you have additional information concerning the violations or
comments which you wish to present, please submit them to the attention of Ms. Marcia Allocco.
The Division of Water Quality may pursue enforcement actions for this and any
additional violations. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities then you may wish to
consider applying for a Special Order by Consent. You may contact Ms. Allocco of this Office
for additional information. One
Not hCarol ina
a y
NCDENR
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Mr. Michael O'Brien
NOV-2007-LV-0295
Page 2
If you have questions concerning this matter, please do not hesitate to contact Ms.
Allocco or me at 704/663-1699.
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
cc: Point Source Branch
Cleveland County Health Department
rb/maa

w a rF9Q�
Honorable Rick Garver, Mayor
Town of Lawndale
P.O. Box 207
Lawndale, NC 28151
Dear Mr. Garver:
Michael F. Easley, Gov P
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins., Director
Division of Water Quality
April 8, 2008
Subject: Compliance Evaluation Inspection
E-Flex WWTP
NPDES Permit No. NC0004I2O
Cleveland County, North Carolina
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on March 11, 2008 by Ms. Donna Hood of this Office. Please inform
the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed
report.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
-f'Ur Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

11
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 151 31 NC0004120 111 121 08/03/11 117 181CI 191 sI 201
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------- ------------------- Reserved ----------------------
67I 2.0 169 70I 31 711 I 721 NI 73I I 174 711 I I I I I I 180
I —I —I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
E-Flex WWTP
10:10 AM 08/03/11
04/02/01
Exit Time/Date
Permit Expiration Date
101 W Main St
Lawndale NC 28090
12:15 PM 08/03/11
08/08/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
John E Rhom/ORC/704-484-6850/
Lee Sommers Douglass/ORC/704-484-6850/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Timothy B Brooks,PO Box 68 Lawndale NC 28090//704-538-8511/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory
Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Donn Ho d MRO WQ//704-663-1699 Ext.2193/
L'
ignature of Management Q A Revi er Agency/Office/Phone and Fax Numbers Date _
Marcia'
Allocco MRO WQ//704-663-1699-Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit: NC0004120
Inspection Date: 03/11/2008
Owner -Facility: E-Flex WWTP
Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ Cl ❑ 0
Is the facility as described in the permit? ■ ❑ ❑ n
# Are there any special conditions for the permit? n ■ ❑ Q
Is access to the plant site restricted to the general public? ■ n Q n
Is the inspector granted access to all areas for inspection? ■ n n n
Comment: The e-flex permit expires on 8.31.2008. Lawndale is currently connecting
to the City of Shelby with the expected completion date prior to the permit expiration
date. Isaac Assa, permittee, is in Mexico. Larry Gold of Gold and Delia in Milltown, NJ
is the only contact currently available. Mike McGinnis is currently the person on site
allowing dismantling of the facility.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ n ■ n
Judge, and other that are applicable?
Comment: The facility appeared to be as well maintained as could be expected under
the circumstances.
Record Keeping
Yes
No
NA
N
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
Cl
n
Cl
Are all records maintained for 3 years (lab. reg. required 5 years)?
n
n
n
■
Are analytical results consistent with data reported on DMRs?
I■
n
n
n
Is the chain -of -custody complete?
■
n
n
n
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
n
❑
n
Has the facility submitted its annual compliance report to users and DWQ?
n
n
■
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
n
■
n
Is the ORC visitation log available and current?
■
n
n
Cl
Page # 3

Permit: NC0004120
Inspection Date: 03/11/2008
Owner -Facility: E-Flex VWVrP
Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
❑
1=1
n
Facility has copy of previous year's Annual Report on file for review?
n
n
■
n
Comment: DMRs for January 2007-December2007 were reviewed for the inspection.
Only one discharge event occurred during review period.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
n
n
Are all other parameters(excluding field parameters) performed by a certified lab?
■
# Is the facility using a contract lab?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
❑
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
N
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
■
n
Comment: Shelby WVVFP Lab (#238) and Shealy (#329) perform any necessary
analyses on the effluent.
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
■
n
n
n
Is the basin free of bypass lines or structures to the natural environment?
■
n
n
n
Is the basin free of excessive grease?
■
n
n
n
Are all pumps present?
■
n
n
n
Are all pumps operable?
❑
❑
n
■
Are float controls operable?
n
n
■
n
Are audible and visual alarms operable?
n
n
n
# Is basin size/volume adequate?
■
n
In
n
Comment: Only one aerator works in the equalization basin.
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system Surface
Is the basin free of dead spots? ❑ ■ ❑ ❑
Are surface aerators and mixers operational? ❑ ■ ❑ ❑
Page # 4

Permit: N00004120
Inspection Date: 03111/2008
Owner - Facility: E-Flex VwVTP
Inspection Type: Compliance Evaluation
Aeration Basins
Yes
No
NA
NE
Are the diffusers operational?
n
n
■
n
Is the foam the proper color for the treatment process?
n
❑
■
a,
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
❑
❑
n
■
Is the DO level acceptable?(1.0 to 3.0 mg/1)
n
n
n
■
Comment: Only one aerator is operational.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
n
n
n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
n
n
n
Are weirs level?
n
n
n
■
Is the site free of weir blockage?
■
n
n
n
Is the site free of evidence of short-circuiting?
n
n
n
■
Is scum removal adequate?
n
n
■
❑
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
n
n
n
■
Is the return rate acceptable (low turbulence)?
n
n
■
n
Is the overflow clear of excessive solids/pin floc?
■
n
n
n
Is the sludge blanket level acceptable? (Approximately''/4 of the sidewall depth)
n
n
n
■
Comment: The secondary clarifiers were sealed off at the time of the inspection.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
■
n
n
n
Are pumps operational?
n
Cl
0
■
Are there adequate spare parts and supplies on site?
n
n
n
■
Comment:
Flow Measurement- Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
n
■
o
o
Is the flow meter operational?
■
n
00
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment: The flow meter should be calibrated prior to the next discharge event.
Page # 5

Permit: NC0004120
Inspection Date: 03/11/2008
Owner - Facility: E-Flex WI/VFP
Inspection Type: Compliance Evaluation
14
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
■
n
n
n
Are the receiving water free of foam other than trace amounts and other debris?
■
n
n
n
If effluent (diffuser pipes are required) are they operating properly?
00
■
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
❑
n
Cl
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
❑
■
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
n
n
■
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ❑ fl ■ ❑
Comment: Sampler tubing should be changed prior to the next discharge event.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■
Comment:
Page # 6

Town Of Lawndale
Lawndale,N.C. 28090
704--538-3146
704-538-3145 Fax
April 18, 2007
Our Mayor resigned effective April 9, 2007..Mike O'Brien
was the permittee on the DNR's. This is a request to change
this to be John Lattimore, Mayor ProTem until a new
mayor is chosen to replace Mr. O'Brien
Thank You,
yb,4)rn&JoM
Nancy Marshall, Town Clerk
Vine RODior,
.at 001ce
APR 2 0 2907
NCDEIYR
pubac mrzt.r Stpor

Page 1 of 34
North, Carolina
Department of State Treasurer
Financial Information
Town of Lawridale
Financial Profile I General Fund I Enterprise Funds I Cash, Investments and Financing
Annual Financial Information Report Detail I Water/Sewer Information
Financial Graphs and Comparisons
Download Excel 97 Version of Financial Summary
Institute of Government North Carolina Cities Web Site
Go to North Carolina County and Municipal Financial Information Home Page
Go to Cleveland County Map Page
Note: All data unless otherwise speci red is or the 12 month period ending June, 30th of the designated year
unicipality Revenues and Expenditures
2005
2004
2003
2002
2001
-
2000
Financial Profile
Go to top of pa=
Revenues b Source
roe Tax
$55,511
56,0901
56,778
44,120
70,932
69,175
utility
104,263
44,552
41,530
45,417
52,582
54,097
Sales Tax
24,850
28,458
27,540
26,786
28,869
31,172
Sales & Services
11,002
35,268
4,025
4,090
3,328
2,675
Inter overnmental
84,533
50,307
54,300
57,451
129,740
132,097
Debt Proceeds
-
-
-
-
-
-
Other Miscellaneous
31,432
31,934
90,834
54,938
34,733
37,530
Total
$311,591
246,609
275,007
232,802
320,184
326,746
Expenditures b Function
utility
$84,595
45,711
91,276
67,148
38,583
31,773
Debt Service
-
-
-
-
-
-
Trans ortation
19,794
9,185
123,453
23,224
8,878
42,933
General Government
67,651
55,853
45,645
43,949
50,680
50,350
Public Safety
109,329
93,092
79,099
33,269
104,998
74,974
Other
45,180
57,295
42,789
45,493
67,692
59,829
Total
$326,5491
261,136
382,2621
213,083
270,831
259,859
http://www.treasurer.state.nc.us/Ige/units/D_218.htm 9/5/200

Page '2 of 34
[Expenditures b Object
Salaries & Wa es
$47,030
56,144
52,115
41,706
80,786
70,317
Capital Outlay
9,626
10,828
-
-
50,881
14,694
Other Operating +
Debt Service
269,893
194,164
330,147
171,377
139,164
174,848
Total
$326,549
261,136
382,262
213,083
270,831
259,859
Per Capita Revenues by Source
roe Tax
$87
87
88
69
110
103
utility
163
69
65
71
82
80
Sales Tax
38
45
44
42
45
47
Sales & Services
17
55
6
6
5
4
Intergovernmental
132
781
84
89
201
196
Debt Proceeds
-
-
-
-
-
-
Other Miscellaneous
49
50
141
85
54
56
Total
$486
384
428
362
497
486
Per Capita Expenditures by Function
Utility
$132
71
142
104
60
47
Debt Service
-
-
-
-
-
-
Transportation
31
14
192
36
14
64
General Government
105
88
70
68
79
75
Public Safety
171
145
123
52
163
111
Other
70
89
67
71
105
89
Total
$509
4071
594
331
421
386
Per Capita Expenditures by Object
Salaries & Wages
$73
87
81
65
125
104
Capital Outlay
15
17
-
-
79
22
Other Operating
421
303
513
266
217
260
Total
$509
407
594
331
421
386
opulation Group
No Electric
500 to 999
o Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
Number of
unicipalites in
Group
96
93
94
94
92
92
Average Population In
Grou
731
737
734
724
724
708
Town of Lawndale
o ulation
641
642
643
643
644
673
Group.Average Per Capita Revenues
by Source
roe Tax
279
259
231
227
208
21.5
utility
271
262
260
260
252
282
\http://www.treasurer.state.ne.us/lgc/units/D_218.htm 9/5/2006

Page 3 of 34
Sales Tax
150
138
113
105
120
115
Sales & Services
50
42
42
39
40
35
Intergovernmental
354
365
261
418
556
266
Debt Proceeds
142
104
55
20
41
58
Other Miscellaneous
131
324
93
104
119
134
Total
1,377
1,494
1,055
1,173
1,336
1,105
Group Average Per Capita
Expenditures b Function
Utility
527
482
358
358
415
333
Debt Service
59
77
53
71
71
52
Transportation
110
99
94
148
190
106
General Government
210
263
186
199
182
183
Public Safety
222
197
165
174
187
180
Other
192
180
136
247
224
139
Total
1,320
1,298
992
1,197
1,269
993
Group Average Per Capita
Expenditures b Object
Salaries & Wages
302
279
254
251
246
238
Capital Outlay
420
442
251
339
345
186
Other OperatinE
598
5771
487
607
678
569
Total
1,320
1,298
992
1,197
1,269
993
General Fund
Go to top of page
2005
2004
2003
2002
2001
2000
General Fund revenues
$204,988
201,015
215,753
187,385
279,063
266,554
General Fund expenditures
241,954
215,425
290,986
145,935
232,248
228,086
Operating transfers in
-
-
-
325
25,000
-
OperatinE transfers out
-
-
-
4,000
4,000
4,000
Capital leases and installment
purchase proceeds
Other items
-
-
-
-
-
-
xcess of revenues and other sources
over (under) expenditures and other
uses
(36,966)
(14,410)
(75,233)
37,775
67,815
34,468
Fund balance available (FBA):
n dollars
$185,661
204,1511
247,148
260,531
705,807
636,798
FBA as a % of GF Net
Expenditures:
nit's FBA %
76.73
94.77
84.93
173.76
298.76
274.38
Group weighted
average FBA %
105.23
108.16
116.79
104.17
99.93
102.34
State weighted
average Non -Electric
36.84
36.32
36.42
36.10
38.26
36.08
http://www.treasurer.state.ne.us/lge/units/D_218.htm 9/5/2006

Page 4 of 34
Group
State weighted
avera e FBA %
36.70
36.27
36.06
35.26
37.53
34.79
Enterprise Funds:
Go to top of pa e
Water/Sewer
Combined financial results:
Working capital
$536,065
568,855
595,747
605,751
139,636
150,637
Quick ratio
66.68
1,216.50
1,392.93
165.52
24.52
23.79
Net income
6,849
18,803
32,022
16,185
14,006
12,931
Cashflow from
operations
27,801
3,568
(28,412)
(1,358)
19,157
14,625
Depreciation &
Amortization Expense
19,373
22,743
23,090
22,529
14,096
14,004
Cash, Investments and Financing
Go to top of page
2005
2004
2003
2002
2001
2000
Population at July 1 st
of the Previous Year
641
642
643
643
644
673
Population Group
No Electric
500 to 999
o Electric
500 to 999
o Electric
500 to 999
o Electric
500 to 999
o Electric
500 to 999
o Electric
500 to 999
Cash &Investments
$726,434
772,565
841,855
870,778
904,6191
845,954
Investment Earnin s
2,525
4,862
25,416
19,700
31,165
34,105
Tax Rate Equivalent
0.0106
0.0206
0.0985
0.0623
0.0958
0.1098
Tax Rate Equivalent
Group weighted
average
0.0197
0.0130
0.0213
0.0354
0.0749
0.0564
Tax Rate Equivalent
Statewide weighted
average
0.0415
0.0339
0.0332
0.0386
0.0738
0.1101
Latest year of
Revaluation
2004
2004
2000
2000
2000
1995
January 1, Prior Year
Assessed Valuation
$23 922 135
23,624,896
25 799,442
31,630,814
32,528,312
31,069,044
Tax Rate
0.2300
0.2300
0.2300
0.2300
0.2300
0.2300
Tax Rate Group
ei hted vera e
0.3263
0.3351
0.3430
0.3495
0.3479
0.2908
Tax Rate State Wide
0.4448
0.4566
0.4594
0.4510
0.4625
0.4772
Assessment -to-Sales
Ratio
98.52
85.45
85.10
90.60
91.56
80.75
Assessment -to-Sales
http://www.treasurer.state.ne.us/lge/units/D_218.htm 9/5/2006

Page 5 of 34
Ratio Group weighted
77.84
81.47
86.18
85.10
84.05
87.91
avera e
Assessment -to-Sales
92.35
92.18
89.54
90.62
89.33
87.14
Ratio Statewide
Assessed Valuation
Adjusted for
$24,281,501
27,647,626
30,316,618
34,912,598
35,526,772
38,475,596
ssesment to Sales
Ratio
EffectiveTax Rate
0.2266
0.1965
•0.1957
0.2084
0.2106
0.1857
Group weighted
average Effective Tax
0.2540
0.2730
0.2956
0.2974
0.2924
0.2556
Rate
Statewide weighted
average Effective Tax
0.4108
0.4209
0.4113
0.4087
0.4132
0.4158
Rate
Percent Collected
89.53
87.52
92.38
96.02
93.66
95.16
Percent Collected
Group weighted
96.81
94.77
94.02
94.44
94.47
95.47
average
Percent Collected
97.60
97.31
97.05
97.05
96.98
97.04
Statewide
Percent Collected
Excluding Motor
91.46
96.03
94.86
97.72
96.48
97.92
Vehicles
Percent Collected
Excluding Motor
97.10
96.27
95.35
95.84
96.12
97.45
Vehicles Group
weighted average
Percent Collected
Excluding Motor
98.37
98.26
98.10
98.07
98.17
98.40
Vehicles Statewide
weighted average
Percent Collected
76.11
47.06
76.39
82.28
68.56
72.37
Motor Vehicles Only
Percent Collected
Motor Vehicles Only
84.14
82.54
83.12
81.77
81.43
83.31
Group weighted
average
Percent Collected
Motor Vehicles Only
87.31
87.64
86.77
87.49
86.97
86.32
Statewide weighted
average
Tax Uncollected
1,763
7,179
4,328
1,755
5,239
3,467
Tax Rate Equivalent
0.0074
0.0304
0.0168
0.0055
0.0161
0.0112
Dominant County:
Cleveland
Debt
nformation
Population Group
500 to 999
500 to 999
500 to 999
500 to 999
500 to 999
500 to 999
http://w.ww.treasurer.state.ne.us/lgc/units/D 218.htm 9/5/2006

Page 6 of 34
Ratin s:
Fitch
Mood 's
S&P
General Obligation Debt (GO) where the taxing power
of the entrire municipality is pledged to pay the
obligation
Enterprise GO Debt
$0
0
0
0
0
0
General Government
0
0
0
0
0
0
GO Debt
Total General
0
0
0
0
0
0
Obligation Debt
Per Capita
$0
0
0
0
0
0
Total Per Capita for
227
267
274
201
227
212
he Population Group
Total Per Capita
505
548
590
585
587
619
Statewide
Total per Assessed
Valuation Adjusted
0:0000%
0.0000%
0.0000%
0.0000%
0.0000%
0.0000%
for Current Year Sales
Total per Assessed
Valuation Adjusted
0.1884%
0.2559%
0.3171%
0.2393%
0.2914%
0.2684%
for Current Year
Sales- Grouv Avera e
Total per Assessed
Valuation Adjusted
0.5588%
0.6442%
0.6981%
0.7128%
0.7647%
0.8374%
for Current Year Sales
- Statewide
Total Authorized but
of Issued General
Obligation Debt
Installment Sales
Purchases and Lease
Obligations
--Enterprise
$01
01
0
0
0
0
--General Government
01
01
0
0
0
0
Total*
$01
01
0
0
0
0
* The total only includes the contracts that require Local
Government Commission approval
Revenue Bond Debt
$0
0
0
0
0
0
Annual
Financial Information Deport
Detail
Go to to of a e_
ine
ISection
Descri tion
2005
2004
2003
2002
2001
2000
http://www.treasurer.state.nc.us/lgc/units/D_218..htm 9/5/2006

Page 7 of 34
opulation at July 1 st of the Previous
641
642
643
643
644
673
Year Adjusted for Boundry Changes
lA
Non GASB34
General Fund Assets
255,526
336,839
747,599
657,859
IB
FISCAL
General Fund
15,390
31,067
9,142
Liabilities
2A
SUMMARY
Debt -service Assets
218,000
2B
Debt service
Liabilities
3A
Enterprise Assets
789,939
825,218
365,385
380,063
3B
Enterprise Liabilities
3,685
5,938
6,609
A
Internal Service
Assets
4B
Internal service
Liabilities
5A
Special Revenue
Assets
1.5A
GASB34
Governmental
659,748
709,857
Activities Assets
1.513
FISCAL
Governmental
165,515
193,059
Activities Liabilities
3.5A
SUMMARY
Business Type
Activities Assets
763,044
771,177
3.SB
Business Type
8,162
193,059
Activities Liabilties
6.5A
Fiduciary Funds
468
Assets
6.513
Fiduciary Funds
Liabilties
5B
Special Revenue
Liabilities
6A
Trust & Agency
Assets
6B
Trust & Agency
Liabilities
7A
Capital Project Assets
58,204
52,343
7B
Capital Project
Liabilities
8A
General Fixed Assets
1 1,028,633
695,777
690,114
654,874
9B
General Long term
218,000
10,760
20,944
debt - Liabilities
10
PART 2
Current collections of
49,697
56,090
56,778
44,120
67,312
66,393
nit -wide levy
11
TAX
Current collection of
s ecial tax districts
12
REVENUES
Prior years' levy
4,760
3,036
2,364
collections
13
Penalties and interest
1,054
5841
418
http://www.treasurer.state.nc.us/lgc/units/D_218.htm 9/5/2006

Page 8 of 34
14
Collection of taxes
previously written off
15
Animal tax
16
1% Local government
24,850
28,458
13,393
14,435
15,586
sales and use tax
1/2% Local
17
government sales and
6,697
7,217
7,793
use taxes Article 40
1/2% Local
18
government sales and
6,696
7,217
7,793
use taxes Article 42
1/2% Local
18.5
government sales and
27,540
use taxes Article 44
19
Licenses Privile e
Privilege -
19.1
Occupational &
business licensing &
permit taxes
19.2
Privilege -- All other
privileges and pernits
20
General Municipal
Vehicle Tax
21
Vehicle Tax for
Public Transportation
22
Other licenses -
3,821
37,299
32,087
3,568
3,405
Include CATV
23
Local occupancy tax
24
Prepared food tax
25
911 charges
Gross Receipts Tax on
26
Short Term Vehicles
Leases
27
FEDERAL
FEDERAL Payment
1,245
in lieu of taxes
Equitable sharing of
28
INTERGOV
Federally forfeited
property
29
REVENUES
General Eovernment
30
Public safety
5,100
31
Transportation -
22 088
Streets
'
32
Transportation - All
other
33
Utility franchise tax
34
Housing/community
development
35
All Other
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Human services:
36
Health, mental health,
hospitals
37
All other
38
Culture and recreation
7,328
39
STATE
State Payment in Lieu
1,563
1,515
of Taxes
0
INTERGOV
Controlled substance
tax
Intangibles tax
1
REVENUES
reimbursement +
2,100
2,295
2,392
Transistional Hold
Harmless Revenues
2
Wireless Enhanced
911 Service Charges
43
Piped Natural Gas
Charge Distribution
4
Utility franchise tax
62,463
22,557
19,784
69,488
61,409
45
Beer and Wine tax
6
Powell Bill
22,070
20,052
23,411
24,505
23,243
7Food
stamp purchases
120
134
140
tax reimbursement
8
Inventories tax
16,533
16,634
16,663
reimbursements
49
Senior Citizens
554
553
Exemption - 50%
50
Court fees- Facilities
and arrest fees
51
General Government
52
Public safety
14,042
6,425
18,040
53
Transportation -
Streets
54
Transportation - All
other
55
Environmental
rotection
56
con. & Phys. Dev. -
Housin /Comm. Dev.
57
Econ. & Phys. Dev. -
All Other
Human Services:
58
Health, mental health,
hospitals
59
All Other
370
60
Culture and recreation
61
LOCAL
LOCAL Payment in
lieu of taxes
62
INTERGOV
lGeneral government
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Page 10 of 34
63 IREVENUES
Public safety
64
Trans ortatin - Streets
65
Transportation - All
other
Environmental
66
protection
67
Economic and
physical development
Human Services:
68
Health, Mental Health
& Hos
69
Human Services: All
Other
70
Culture and recreation
7,328
8,142
8,142
71
PERMITS
Buildina permits
72
& FEES
Inspection fees
72.1
Amusements licensing
and permit taxes
73
Other permits
74
SALES &_Parking
revenues
75
SERVICES
Rents and royalties
4,285
3,775
4,025
4,085
3,328
2,675
76
Airport
77
ire protection
charges
78
Solid waste
79
Ambulance and rescue
squad char es
80
Cemeteries
81
Recreation service
revenues
82
Library service
revenues
Other cultural and
83
recreational service
6,717
31,493
revenues
84
Mass transit - city
operated
85
Other sales and
5
services
86
UTILITY
Water and sewer
104,263
44,552
41,530
45,417
52,582
54,097
charges
87
IREVENUES
Electric charges
88
Gas char es
88.1
Storm Water Fees
89
MISC.
On bond proceeds
90
REVENUES
On general and all
2,525
4,862
25,416
19,700
31,165
34,105
other funds
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91
Special assessments
92
Private contribution
and donations
93
Sales of materials and
27,072
fixed assets
94
Sales of real property
ongovernment
95
contributions for
streets and traffic
signals
96
Mixed drink surchar e
97
BC profit
distribution
98
Other miscellaneous
769
20
revenues
99
Proceeds of the sale o
bonds and notes
Proceeds of capital
100
leases and installment
purchases
101
Other
25,086
28,119
2,382
Supplemental schools
102
NON -REV
taxes - current levy
collections
103
RECEIPTS
Prior years' levy
collections
Tax collections for
104
units other than
reporting unit
105
Utilities customers'
deposits
106
Deposits other than
utility
107
Prepaid taxes
108
Prepaid privilege
licenses
109A
PART 4
Governing body -
4,076
4,076
4,388
4,388
Salaries
109B
GENERAL
Governing body - All
22,843
20,011
18,041
18,467
19,860
other Direct
109C
GOVT
Governing body -
Construction
Governing body -
109D
Land, Equipment and
Existing Structures
110A
Administration -
12,875
16,414
21,091
15,496
Salaries
11013
Administration - All
26,764
4,942
4,994
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other Direct
110C
Administration -
Construction
Administration -
110D
Land, Equipment and
Existing Structures
111A
Elections (cost of) -
Salaries
111B
Elections (cost of) -
866
11 other Direct
111 C
Elections (cost of) -
Construction
Elections (cost of) -
111D
Land, Equipment and
Existing Structures
112A
Finance - Salaries
12,500
8,367
112B
Finance - All other
19,547
1,935
9,199
Direct
112C
Finance -
Construction
Finance - Land,
112D
Equipment. and
Existing Structures
113A
Taxes - Salaries
113B
Taxes - All other
Direct
113 C
Taxes - Construction
Taxes - Land,
113D
Equipment, and
Existin Structures
114A
Legal - Salaries
114B
Legal - All other
5 460
Direct
'
114C
Legal - Construction
Legal - Land,
114D
Equipment, and
Existing Structures
115A
Public Buildings -
1,859
40
118
203
Salaries
115B
Public Buildings - All
5,169
5,792
5,264
3,360
1,674
4,459
other Direct
115C
Public Buildings -
Construction
Public Buildings -
115D
Land, Equipment, and
950
Existing Structures
116A
Court Facilities -
Salaries
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Court Facilities - All
116B
other Direct
Court Facilities -
116C
Construction
Court Facilities -
116D
Land, Equipment, and
Existing Structures
Central Facilites -
117A
Salaries
Central Facilities - All
117B
other Direct
Central Facilites -
117C
Construction
Central Facilites -
117D
Land, Equipment, and
Existing Structures
118A
General Government
11 Other - Salaries
General Government
118B
All Other - All other
8,640
Direct
General Government
118C
All Other -
Construction
General Government
All Other - Land,
118D
Equipment, and
ExistinE Structures
Police and
119A
PUBLIC
Communications -
25,664
31,270
23,176
9,563
37,388
38,214
Salaries
Police and
119B
SAFETY
Communications - All
20,547
8,764
2,170
3,101
4,508
other Direct
Police and
119C
Communications -
Construction
Police and
119D
Communications -
25,452
'
Land, Equipment and
Existiniz Structures
Emergency
120A
Communications -
Salaries
Emergency
120B
Communications - All
other Direct
120C
Emergency
Communications -
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Construction
Emergency
120D
Communications -
Land, Equipment and
Existing Structures
Emergency
121 A
Management -
Salaries
Emergency
121 B
Management - All
other Direct
Emergency
121 C
Managment -
Construction
Emergency
121 D
Management - Land,
Equipment, and
Existing Structures
122A
Fire - Salaries
1,680
1,560
7,606
2,280
122B
Fire - All other Direct
53,492
44,329
19,976
19,417
20,047
122C
Fire - Construction
Fire - Land,
122D
Equipment, and
9,626
12,034
9,925
Existing Structures
123A
Inspectors - Salaries
123B
Inspectors - All other
Direct
123C
Inspectors -
Construction
Inspectors - Land,
123D
Equipment, and
Existin Structures
124A
Rescue Units -
Salaries
124B
Rescue Units - All
other Direct
124C
Rescue Units -
Construction
Rescue Units - Land,
124D
Equipment, and
Existing Structures
125A
Animal Control -
Salaries
125B
Animal Control - All
other Direct
125C
Animal Control -
Construction
Animal Control -
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125D
and, Equipment, and
Existing Structures
126A
Public Safety All
Other - Salaries
Public Safety All
126B
Other - All other
49,075
Direct
126C
Public Safety All
Other - Construction
Public Safety All
126D
Other - Land,
10 828
Equipment, and
'
Existing Structures
127A
TRANSPOR
Traffic Engineering -
Salaries
127B
TATION
Traffic Engineering -
All other Direct
127C
Traffic Engineering -
Construction
Traffic Engineering -
127D
Land, Equipment, and
ExistinE Structures
128A
Streets and Highways
- Salaries
128B
Streets and Highways
19,794
123,453
23,224
- All other Direct
128C
Streets and Highways
- Construction
Streets and Highways
128D
- Land, Equipment
and Existing
Structures
129A
Street Cleaning -
Salaries
129B
Street Cleaning - All
other Direct
129C
Street Cleaning -
Construction
Street Cleaning -
129D
Land, Equipment, and
Existing Structures
State Street Aid
130A
Allocation - Powell
Bill - Salries
State Street Aid
130B
Allocation - Powell
9,185
8,878
42,933
Bill - All other Direct
130C
ate Street Aid
r1location
- Powell
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ill - Construction
State Street Aid
Allocation - Powell
130D
Bill - Land,
Equipment, and
Existing Structures
Parking Facilities -
131 A
Salaries
131B
Parking Facilities -
All other Direct
131 C
Parking Facilities -
Construction
Parking Facilites -
131D
Land, Equipment, and
Existing Structures
132A
ass Transit - City -
Salaries
132B
Mass Transit - City -
11 other Direct
132C
Mass Transit - City -
Construction
Mass Transit - City -
132D
Land, Equipment, and
ExistinR Structures
133B
Mass Transit - Private
- All other Direct only
134A
Air -port - Salaries
134B
Airport - All other
Direct
134C
Airport - Construction
irport - Land,
134D
Equipment, and
Existing Structures
135A
Transportation - All
Other - Salaries
Transportation - All
135B
Other - All other
Direct
135C
Transportation - All
Other - Construction
Transportation - All
135D
Other - Land,
Equipment, and
Existing Structures
136A
ENVIRON
Solid Waste - Salaries
136B
MENTAL
Solid Waste - All
32,495
29,851
26,554
27,750
37,302
35,798
other Direct
136C
PROTECTION
Solid Waste -
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Construction
Solid Waste - Land,
13 6D
Equipment, and
ExistinE Structures
Drainage and
137A
Watershed - Salaries
Drainage and
137B
Watershed - All other
Direct
Drainage and
137C
Watershed -
Construction
Drainage and
137D
Watershed - Land,
Equipment, and
Existing Structures
138A
Cemeteries - Salaries
138B
Cemeteries - All other
Direct
138C
Cemeteries -
Construction
Cemeteries - Land,
138D
Equipment, and
Existing Structures
Environmental
139A
Protection - All Other
- Salaries
Environmental
139B
Protection - All Other
8,030
7,981
- All other Direct
Environmental
139C
Protection - All Other
- Construction
Environmental
139D
Protection All Other -
and, Equipment, and
ExistinE Structures
140A
ECONOMIC
Planning and Zoning -
Salaries
140B
& PHYSICAL
Planning and Zoning -
11 other Direct
140C
DEVELOP
Planning and Zoning -
Construction
Tanning and Zoning -
140D
Land, Equipment, and
Existing Structures
Economic
141A
Development -
Salaries
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Economic
141 B
Development - All
other Direct
Economic
141 C
Development -
Construction
Economic
141 D
Development - Land,
Equipment, and
Existing Structures
Community
142A
Development -
Salaries
Community
142B
Development - All
27,444
other Direct
Community
142C
Development -
Construction
Community
142D
evelopment - Land,
Equipment, and
Existing . Structures
143A
Housing and Urban
Renewal - Salaries
Housing and Urban
143B
Renewal - All other
Direct
ousing and Urban
143 C
Renewal. -
Construction
Housing and Urban
143D
Renewal - Land,
Equipment, and
Existing Structures
Special Employment
144A
Programs (JTPA) -
Salaries
Special Employment
144B
Programs (JTPA) -
11 other Direct
Special Employment
144C
Programs (JTPA) -
Construction
Special Employment
144D
Programs (JTPA) -
Land, Equipment, and
ExistinR Structures
Economic and
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Physical Development
145A
- All Other - Salaries
A
Economic and
Physical Development
145B
- All Other - All other
Direct
Economic and
145C
Physical Development
- All Other -
Construction
Economic and
Physical Development
145D
- All Other - Land,
Equipment, and
ExistinE Structures
146A
HUMAN
Health - Salaries
146B
SERVICES
Health - All other
Direct
146C
Health - Construction
ealth - Land,
146D
Equipment, and
xisting Structures
147A
Mental Health -
Salaries
147B
Mental Health - All
other Direct
147C
Mental Health -
Construction
Mental Health - Land,
147D
Equipment, and
Existing Structures
148A
Social Services -
Salaries
148B
Social Services - All
other Direct
148C
Social Services -
Construction
Social Services -
148D
Land, Equipment, and
Existing Structures
Subsidies Paid:
149B
Hospitals - City
Owned - All other
Direct
Subsidies Paid:
150B
Hospitals - Private
Owned - All other
irect
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Other Human
151A
Services: Legal Aid -
Salaries
Other Human
151B
Services: Legal Aid -
11 other Direct
Other Human
151 C
Services: Legal Aid -
Construction
Other Human
151D
Services: Legal Aid -
and, Equipment, and
Existing Structures
152A
Human Services - All
Other - Salaries
Human Services - All
152B
Other - All other
Direct
152C
Human Services - All
Other - Construction
Human Services - All
152D
Other - Land,
Equipment, and
Existing Structures
153A
CULTURE
Recreation and Parks -
10,755
2,169
1,883
Salaries
153B
RECREATION
Recreation and Parks -
16,235
6,988
6,796
10,348
11 other Direct
153C
Recreation and Parks -
Construction
Recreation and Parks -
153D
Land, Equipment, and
13,395
3,819
xistin Structures
154A
Coliseum - Salaries
154B
Coliseum - All other
12 685
Direct
'
154C
Coliseum -
Construction
Coliseum - Land,
154D
Equipment, and
Existing Structures
155A
Museums - Salaries
Museums - All other
155B
Direct
155C
Museums -
Construction
Museums - Land,
155D
Equipment, and
ExistinE Structures
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156A
Libraries - Salaries
156B
Libraries - All other
Direct
156C
Libraries -
Construction
Libraries - Land,
156D
Equipment, and
ExistinR Structures
Culture and
157A
Recreation - All Other
- Salaries
Human Services - All
157B
Other - All other
Direct
157C
Human Services - All
Other - Construction
Human Services - All
157D
Other - Land,
Equipment, and
Existing Structures
158A
UTILITY
Water and Sewer -
8,491
8,460.
8,824
7,345
8,026
7,853
Salaries
158B
Water and Sewer - All
76,104
37,251
82,452
59,803
30,557
23,920
other Direct
158C
Water and Sewer -
Construction
Water and Sewer -
158D
Land, Equipment, and
Existing Structures
159A
Electric Power -
Salaries
159B
Electric Power - All
other Direct
159C
Electric Power -
Construction
Electric Power - Land,
159D
Equipment, and
Existing Structures
160A
Natural Gas - Salries
160B
Natural Gas - All
other Direct
160C
Natural Gas --
Construction
Natural Gas - Land,
160D
Equipment and
Existing Structures
160.1A
Storm water salaries
160.1B
Storm water other
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operating
160.1 C
Storm water
contruction
Storm water land,
160.1 C
equipment and
existin structures
Water and Sewer -
161B
DEBT
Debt Service Interest
Payments
Water and Sewer -
161D
SERVICE
Debt Service Principal
Payments
Electric - Debt
162B
Service Interest
Payments
Electric - Debt
162D
Service Principal
Payments
Gas - Debt Service
163B
Interest Payments
Gas - Debt Service
163D
Principal Payments
School - Debt Service
164B
Interest Payments
School - Debt Service
164D
Principal Payments
Hospital - Debt
165B
Service Interest
Payments
Hospital - Debt
165D
Service Principal
a ments
11 Other - Debt
166B
Service Interest
Payments
All Other - Debt
166D
Service Principal
Pa ments
Direct Benefit
167B
PENSION
Program - Pension
Fund operated by the
Unit
168B
FRINGE
Fringe Benefits
Unallocated - B
Separation Allowance
169B
- Law Enforcement
Officers - B
170B
Separation Allowance
- Other Employees -
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B
Supplemental
Retirement Income
171B
Plan for Law
1,919
1,150
Enforcement Officers
- B
172B
Fringe Benefits Other
- B
Multi -County Library
173A
District, County, or
Other Municipality
Authority
Multi -County Library
173B
INTERGOV
District, County, or
Other Municipality
Item number
Multi -County Library
173C
EXPEND
District, County, or
°
Other Municipality
Amount
General
174A
Governmental
ctitivies shared with
he County Count
General
Governmental
174B
Actitivies shared with
he County (Item
umber
General
174C
Governmental
ctitivies shared with
he County Amount
175A
Highways (Payments
o State) (State
Highways (Payments
175B
to State) (Item
umber
175C
Highways (Payments
o State) (Amount
176A
Others - Name of
Payee # 1
176B
Others - 1 B
176C
Others - 1 C
177A
Others - Name of
Payee #2
177B
Others - 2 B
177C
Others - 2 C
Others - Name of
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178A
Payee #3
178B
Others - 3 B
178C
Others - 3 C
Current Year Levy
179
PART 6
Excluding Motor
48,509
47,509
49,158
39,281
74,229
Vehicles
180
OTHER
Current Year Levy
7,002
10,000
7,620
4,853
8,342
Motor Vehicles Only
Uncollected Taxes -
181
DATA
Current Year's Levy -
4,141
1,885
2,529
895
2,616
1,332
Excluding Motor
Vehicles
Uncollected Taxes -
182
Current Year's Levy -
1,673
5,294
1,799
860
2,623
2,135
Motor Vehicles
Percentage of Taxes
183
Collected - Current
89.53
87.52
92.38
96.02
93.66
95.16
Year All Property
Percentage of Taxes
184
Collected - Current
91.46
96.03
94.86
97.72
96.48
97.92
Year - Excluding
Motor Vehicles
Percentage of Taxes
185
Collected - Current
76.11
47.06
76.39
82.28
68.56
72.37
Year - Motor Vehicles
Total Amount of
186
Expenditures for
Salaries and Wages to
nit's Own Personnal
Capital Reserve or
187A
Available Funds -
Schools - July 1,
Previous Year
Capital Reserve or
18 7B
Available Funds -
Schools - June 30,
Current Year
Capital Reserve or
188A
Available Funds -
ospitals - July 1,
Previous Year
Capital Reserve or
188B
Available Funds -
Hospitals - June 30,
Current Year
Cash on Hand and in
189A
PART 7
Bank, and Securities -
eld in Debt Service
and
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Cash on Hand and in .
Bank, and Securities -
189B
CASH &
Construction Bond
Fund - Unexpended
and proceeds
Cash on Hand and in
189C
INVEST
Bank, and Securities -
726,434
772,565
841,855
870,778
904,619
845,954
11 Other
Appropriations made
190A
PART
during the fiscal year,
pursuant to
subsections b 1- 7
Expenditures made
190B
g
during the fiscal year
pursuant to
subsections b 1- 7
Investment in
191
Property Acquired at
681 468
any .time under G.S.
'
158
Amount Expended
during the fiscal year
192
pursuant to
subsections b (5) and
7
Amount of Tax
193
Revenues taken into
account under G.S.
Amounts - Total
194A
PART 9
Revenues and other
311,591
246,609
275,007
232,802
324,184
326,746
financing sources per .
audit
Amounts - Subtract
194B
FISCAL
proceeds of refunding
debt
194C
SUMMARY
Amounts -Subtract
4,000
interfund transfers in
194D
Amounts -Net
311,591
246,609
275,007
232,802
320,184
326,746
Revenues per AFIR
Calculated amount
311,591
246,6091
275,007
232,802
320,184
326,746
Amounts in
yes
Yes
Yes
Yes
Yes
Yes
AGREEMENT??
Difference
Amounts - Total
195A
Expenditures and
326,549
261,136
382,262
213,083
.274,831
259,859
other financing
sources per audit
195B
Amounts - Subtract
payments to refunding
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debt escrow agent
195C
mounts - Subtract
interfund transfers out
4 000
'
195D
Amounts Net
Expenditures per
FIR
326,549
261,136
382,262
213,083
270,831
259,859
Calculated amount
326,549
261,136
382,262
213,083
270,831
259,859
Amounts in
AGREEMENT??
Yes
Yes
Yes
Yes
Yes
Yes
Difference
PART 10
950
Name of Official Signatory
ancy Marshall
951
Title of Official
Clerk
952
Date Certified
10/31/2005
5/20/2005
l l/5/2003
953
Person to Contact
Nancy Marshall
954
Title of Person to
Contact
Clerk
955
Telephone Number
704-538-3146
956
IFacsimile Number
Go to top of page
Key Ratios of Water and Sewer Systems for
Town of Lawndale
2005
2004
2003
2002
2001
2000
Population
641
642
643
643
644
673
Population Group
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
No Electric
500 to 999
TotalOperating Revenues
$108,477
48,609
41,530
45,417
47,320
45,979
Total Operating Revenues Per
Capita
$169
76
65
71
73
68
Group Weighted Average
Revenues Per Capita
364
367
358
351
340
343
State Weighted Average
Revenues Per Capita:
330
308
294
299
284
283
% to Total Op eratin
Revenues
Operating Expenses
95.84%
140.83%
219.78%
147.85%
87.89%
99.56%
Group Weighted Average
114.29%
109.25%
110.60%
105.48%
106.71%
103.63%
http://www.treasurer.state.nc.us/lgc/Units/D-218.htm 9/5/2006

Page 27 of 34
State Weighted Average
85.55%
89.12%
90.84%
86.27%
87.30%
86.21%
Operating Margin
4.16%
-40.83%
-119.78%
-47.85%
12.11%
0.44%
Group Weighted Average
-14.29%
-9.25%
-10.60%
-5.48%
-6.71%
-3.63%
State Weighted Average
14.45%
10.88%
9.16%
13.73%
12.70%
13.79%
Operating Transfers In/ out
0.00%
0.00%
0.00%
-0.72%
-52.83%
0.00%
GroupWeighted Average
-23.35%
-4.25%
0.57%
2.92%
-0.35%
4.61%
State Weighted Average
-0.79%
-1.21%
-0.99%
-1.19%
0.80%
1.54%
Net Income before capital
contributions
6.31%
-38.68%
-77.11%
35.64%
-29.60%
28.12%
Group Weighted Avera e
-33.24%
59.52%
-9.31%
-3.97%
-4.06%
3.82%
State Weighted Avera e
8.63%
2.88%
0.31%
5.18%
8.61%
13.16%
Key Ratios and Cash Flow
Quick Ratio
66.68
1216.50
1392.93
165.52
24.52
23.79
Group Weighted Avera e
3.32
4.33
4.34
4.10
3.50
10.38
State Weighted Average
2.02
2.82
3.04
3.28
3.05
10.96
Days Sales in Receivables
25.0
27.6
28.6
38.2
37.4
38.5
GroupWeighted Avera e
83.6
129.7
57.5
58.7
48.7
49.3
State Weighted Avera e
60.1
65.7
60.0
64.1
62.1
63.1
Days Cash on Hand
2,316.0
4,516.7
3,173.9
4,946.5
1,868.3
1,750.6
GroupWeighted Average
364.4
422.5
387.4
389.5
386.1
418.2
State Wei hted Avera e
426.1
408.0
414.8
438.9
453.5
484.0
Cash flow from Operations
$27,801
3,568
-28,412
-1,358
19,157
14,625
Debt to Equity
0.00
0.00
0.00
0.00
0.00
0.00
Group Weighted Average
0.20
0.15
0.15
0.15
0.19
0.22
State Weighted Average
0.52
0.52
0.50
0.54
0.54
0.48
Debt per Capita
0
0
0
0
0
0
GroupWeighted Average
656
505
435
380
425
454
State Weighted Average
931
855
852
863
808
706
Ca ital Expenditures:
2005
2004
2003
2002
2001
2000
$0
0
0
0
0
0
1999
1998
1997
1996
$8,971
0
19,523
5,628
Capital Contributions:
http://www.treasurer.state.nc.us/lgc/units/D_218.htm 9/5/2006

Page 28 of 34
Excluded from income above $01 01 01 01 01 01
400.00%
300.00%
200.00%
100.00%
0.00%
Financial Graphs and Comparisons
. Analysis of Available Fund Balance: General Fund
. Analysis of Property Tax Collection %
. Analysis of General Obligation Debt
. Analysis of Revenue (5 years
. Analyis of Revenue (most recent fiscal year)
. Analysis of Expenditures by Function
. Analysis of Expenditures by Object
to
Town of Lawndale
Analysis of Available Fund Balance: General Fund
Fund Bal Avail %
2001 2002 2003 2004 2005
Unit's FBA %
Group average FBA %
State average Electric/Non Electric Group FBA %
State average FBA %
— Unit's FBA %
Group average FBA %
State average FBA %
2001 2002 2003 2004 2005
298.76% 173.76% 84.93% 94.77% 76.73%
99.93% 104.17% 116.79% 108.16% 105.23%
38.26% 36.10% 36.42% 36.32% 36.84%
37.53% 35.26% 99.93% 36.27% 36.70%
Municipal Population Group: No Electric 500 to 999
Go to top of page
http://www.treasurer.state.nc.us/lge/units/D_218.htm 9/5/2006

Page 29 of 34
Town of Lawndale
Analysis of Property Tax
Collection Fate %
100.00%
98.00%
96.00°la.
92.00°l0 — Municipality
90.00% Pop. Group
— Statewide
88.00°Ia
06.00%
84.00%
82.00°ia
2001 2002 2003 2004 2005
2001
2002
2003
2004
2005
Municipality
93.66%
96.02%
92.38%
87.52%
89.53%
Pop. Group
94.47%
94.44%
94.02%
94.77%
96.81 %
Statewide
96.98%
97.05%
97.05%
97.31%
97.60%
Municipal Population Group: No Electric 500 to 999
Go to top of page
http://www.treasurer.state.ne.us/lgc/units/D-218.htm
9/5/2606

Page 30 of 34
Town of Lawndale
Analysis of General Obligation Debt
(Excludes Revenue Bonds)
Total General Obligation Debt per Capita
700
—
600
500
— Municipality
400
Pop. Group
300
-—
=-_.
— Statewide
200
-
-
100
0
2001
2002
2003
2004
2005
Municipality
0
0
0
0
0
Pop. Group
227
201
274
267
227
Statewide
587
585
590
548
505
2001
2002
2003
2004
2005
Municipality
0
0
0
0
0
Pop. Group
227
201
274
267
227
Statewide
587
585
590
548
505
Municipal Population Group: 500 to 999
Go to to of page
http://www.treasurer.state.nc.us/lgc/Units/D-218.htm 9/5/2006

Page 31 of 34
Town of Lawndale
Analysis of Revenue
Revenue per Capita
$600
$500
■ Other Miscellaneous
$400
0 Debt Proceeds
■ Intergovernmental
$300
❑ Sales & Services
❑ Sales Tax
$200
IN Utility
$100
o Property Tax
$0
2001
2002 2003 2004 2005
2001
2002
2003
2004
2005
Property Tax
$110
69
88
87
87
Utility
82
71
65
69
163
Sales Tax
45
42
44
45
38
Sales & Services
5
6
6
55
17
Intergovernmental
201
89-
84
78
132
Debt Proceeds
0
0
0
0
0
Other Miscellaneous
54
85
141
50
49
Total
$497
362
428
384
486
Go to to of page
http://www.treasurer.state.ne.us/lgc/units/D_218.htm 9/5/2006

Page 32 of 34
Town of Lawndale
Analysis of Revenue for Fiscal 2006
Revenue
Miscellaneous
10%
Intergovernment
27%
Sales & Seri
4% Sales Tax
8%
Property Tax
400/-
'ater/Sewer
33%
2005
2005
Category
Revenue
Per Capita
Property Tax
$55,511
$87
Water/Sewer
104,263
163
.Electric
0
.0
Other Utilities
0
0
Sales Tax
24,850
38
Sales & Services
11,002
17
Intergovernment
84,533
132
Debt Proceeds
0
0
Miscellaneous
31,432
49
Total
$311,591
$486
Municipal Population Group: No Electric 500 to 999
Go to top of page
http://www.treasurer.state.nc.us/lgc/units/D-218.htm 9/5/2006

Page 33 of 34
Town of Lawndale
Analysis of Expenditures by Function for Fiscal 2005
Expenditures by Function
Other General
14% Government
21%
Public Safety
33% Water/Sewer
26%
Transportation
$%
2005
2005
Category
Expenditures
Per Capita
General Government
$67,651
$105
Water/Sewer
84,595
132
Electric
0
0
Other Utilities
0
0
Debt Service
0
0
Transportation
19,794
31
Public Safety
109,329
171
Other
45,180
70
Total
$326,549
$509
Municipal Population Group: No Electric 500 to 999
Go to top of page
http://www.treasurer.state.nc.us/lgc/units/D_218.htm 9/5/2006

Page 34 of 34
Town of Lawndale
Analysis of Expenditures by Object for Fiscal 2005
Expenditures by Object
Salaries &
iAf_-es
ro
Capital
Outlay
3%
LI ICI
Operating
83%
2005
2005
Category
Expenditures
Per Capita
Salaries & Wages
$47,030
$73
Water/Sewer Capital
0
0
Electric Capital
0
0
Capital Outlay
9,626
15
Other Operating
269,893
421
Total
$326,549
$509
Municipal Population Group: No Electric 500 to 999
Last Updated 6/27/2006 12:40:51 PM
http://www.treasurer.state.ne.us/lge/units/D_218.htm 9/5/2006

Michael F. Easley, Governor
i
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
C Alan W. Klimek, P.E. Director
Division of Water Quality
December 4, 2006
The Honorable Mike O'Brien, Mayor
Town of Lawndale
Post Office Box 256
Lawndale, N.C. 28090
Subject: Town of Lawndale
Wastewater Collection System
Cleveland County
Dear Mayor O'Brien:
This Office is in receipt of your letter dated November 29, 2006 concerning a request for
endorsement of the Town's grant application from the Gold Leaf Foundation who is considering
funding a portion of the subject wastewater collection system project. The Town is currently
sending all wastewater to the former eFlex Mill wastewater treatment plant (WWTP), but has been
actively seeking other wastewater disposal solutions since the eFlex Mill has been closed for some
time and operational costs are excessive.
Given that the existing eFlex WWTP does present both operational and financial
difficulties for the Town, this Office would encourage the Town to explore non -discharge
wastewater disposal options including, but not limited to the connection of the Town to the City of
Shelby sewer collection system.
If you have any questions regarding this matter, please contact Ms. Donna Hood or me at
[phone].
Sincerely,
Michael L. Parker
Acting Regional Supervisor
Surface Water Protection
cc: Donna Hood
h:\gen\gltr.doc
NNA N"orehCarolina
NCDENR ���002 ;Vatumlly
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: «����.nc� airr�u: lil�.c�r 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

11/2e/2006 22: 11 S264SOS662 WEST $ ASSOC=ATES
AOp W A Y`o gPF
August 4, 200e
Mr_ Mika O'Brian, 'Mayor
Town of Lawndalo
PO BOX -eSoB
Lawndale, NC 25000
wear Mr. O'Brian:
PAGE 04
Michael F_ Easley. �oyeenor
William O. Raea Jr„ Su:rvrary
NoRh Carolina Dcpertmenr of Envlronmcnr and Nahrral Resouroea
Alen W_ KlimsJc, P_E. Diticror
Division or water Quallq
Subject= Permit No, WQ00306'17
Phases 1
Town of Lawndalo
Wastewater Collection System Extension
Cleveland County, Norttl Carolina
In accordance with your application received on August 4, 2000. we era forwarding herewith
Permit No. W(=t0030eI 7, dated August 4, 2006, to the Town of Lawndalo for the construction and
operation of the subject wastewater epllection system extension. This permit shall be. effective from the
date of lssuance until rescinded. and shall bo subject to the conditions and limitations as specified
ti-lerein_ This cover letter shall be considered a part of this permit and is ttlerefore incorporated therein
by references.
Please pay particular attention to Permit Condition 3 which raqulres that the wastewater
collection facilitles be properly operated and maintained in accordance with Y SA NCAC 2" .0227 or any
individual aiystam-wide collection system permit issued to the Perrrlittee.
Permitting of this project doeffi not constitute an acceptance of any part of the project that does
not meat -1) 'I SA NCAC 2" _0200; 2) the 1:3mtsion of Water Quality's (r>ivision) Gravity Sewer Minimum
C>eslgrl Criteria adopted February 12, 1996, as applicable; 3) ®nd the division's Minimum Cosign
Criteria for the Fast -Track Permitting of Pump Stations and Force Mains adopted June 1, 2000, as
applicable, unless specifically mentioned herein. 04v1s1oru approval is based on acceptance of the.
certification provided by a North Carolina -licensed Professional Engineer In lira application. It shalt be
the Perm ttee'a responsibility to ensure that the as-oonstructed project meets the appropriate deslgn
criteria and rules, Failures to comply may result in penalties in accordance with North Carolina General
Statute §143-275.6A through §•143-2'I S_6C, construction of additional or replacement wastewater
collection facflitles, and/or raferral of the North Carolina -licensed Professional Engineer to the licensing
board.
Mooresville Regional Ofxice 61 o Is—, Ceneer Ave., a— 301 Moorosvine, NC 28115 Phone: [phone] F— (704) 663-60a0
lntamaL-.n.aw.na..�atargvanb-cry e..sm....er ser..:ee: 1-g77-6za-e-ses
An Equal Oppp,tunMylAT aUva Aston Engbyor- 50^f. Rcc •cladl109L Pest Consun�r Paper

11/2S/2006 22. 3.X 82S433SG52 WEST 8..ASSOCIATES PAGE 05
Mr. O'B`ian
Page 2
August 4, 2006
In accordance with the provisions of Artk to 21 of Chapter 1 t3, General Statutes of North
Carolina as anTend®d, and other applicable Laws. Rules, and Regulations, porrtilssion is hereby
granted to the Town of Lawndale for the construction and operation of approximately 463 linear feet of
13-inch gravity sewer, 26,520 linear feet of S-inch force main, and a Soo C3PM pump station (with duplex
pumps, on -site audible and visual high-water alarms. and an an -site generator with automatic transfer
switch) as part of the Yhasa 1 project, and'tha clischarga of S. 175 gallons per day of cotlacted domestic
wastewater into the City of Shelby's existing sewerage system, pursuant to the application received
August 4, 2000, and to conformity with 15A NC --AC 2Fl _0200; the, pivlsion's Gravity Sewor Minimum
peslgn Criteria adopted February 12, 1006, as applicablo; the Division's Minimum Qeslgn Criterla for
the Fast -Track Permitting of Pump Stations and -Porce Mains adopted Juno, 1. 2000, as applicable; and
other supporting data subsequently filed and approved by the popartment of Environment and Natural
Resources and considered o part of thls permit,
The s oe,o and wastewater collected by this system shall ba treatod in the City of Sh®Iby
VWtIrP CNPaES No_ NCOO24538) prior to being discharged into the receiving stream.
if any parts, requirements, cm limitations contained in this permit are unacceptable, you Nava the
right to request on adjudlcatory hearing upon written request within 30 days following receipt of this
permit_ This request must be in the form of a written petition, conforming to Chapter 1506 of North
Carolina Csen®ral Statutes, and filed wlth the CKFPce of Admknistrotive Hearings, 0714 Mail Service
Cantor, Raleigh, NC 27E99-6714_ ""Il s such demands era matle, this permit shall ba final and
binding. .
If you need additional information concerning this matter, please contact Qeo Browder at (704)
f363-1699.
Sincerely,
yor Alan Klimek, P_ E.
cc: Mooresville Raglonol Office, Surface Water Protection_(WVv'rP Permit No_ NCOO245313)
Eipnjamin Thomas. West COnSultantS
Surface Water Protection Central Filers
Marie poklovic, PERCS

11/26/2006 22: 11 8294335662 WEST a ASSOC2ATE5 PAGE 02
Novertlbcr 29, 2006
Mr_ Mike Parker
610 East Center Street
Mooresville, N_ C. 28115
RE: 'town of Lawndale
Wastewater Collection $ystcros Extcasion
Dear Mr_ Parker:
As you lrnow, Lawisdale has been planning for several years to construct s sewer systeta. As
part of this planning, we have discussed interconnecting our system witls Fallston's systems in
order to convey our wastewater to Shelby. In order to finance the project, the toms lies received
a 5400.000 llx> i The NC Rural Center acid an additional $200,000 jcr zn the 4a. ld Leaf
Foundation. Before considering our application, Cold leaF needs a letter Storrs NCl?ENR stating
the plan meets your approval_ We are requesting a letter o£endorserrient £torts your dcporttrsent.
Sincerely,
Mike O'Brien, Mayor
"Town o£Lawndale

Michael F. Easley, vemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E., Director
Division of Water Quality
August 3, 2005
Honorable Mike O'Brien, Mayor
Town of Lawndale
P.O. Box 207
Lawndale, NC 28151
Subject: Compliance Evaluation Inspection
E-Flex WWTP
NPDES Permit No. NC0004120
Cleveland County, North Carolina
Dear Mr. O'Brien:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on July 27, 2005 by Ms. Donna Hood of this Office. Please inform
the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed
report.
The report should be self-explanatory; however, should you have any questions concerning this
report, please do not hesitate to contact Ms. Hood or me at [phone].
Sincerely,
a� D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department
Lin
N. C. Division of Water Quality, Mooresville Regional Office, 610 East Center Avenue, Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

United States Environmental Protection Agency
Form Approved.
Washington, D.C. 20460
EPA
OMB No. 2040-0057
t f Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
20I '
1 U 2 31 NC0004120 1 11 121 05/07/27 117 181C1 191g1 J
, - , L LJ �..J l
Remarks
211111 1111 1111 11111111 1 .1 1 L 111111111111 11111111 11166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIA ------------Reserved--------------
67 1 2.5 1 69 70 U 71 U 72 Lj 73 U 74 751 I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:00 AM 05/07/27
04/02/01
E-Flex WTATP
Exit Time/Date
Permit Expiration Date
101 W Main St
Lawr_da_e NC 28090
02:00 PM 05/C7/27
09/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Lee Sommers Doug_ass/0RC/704-484-6850/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Timothy B Brooks,PO Box 68 Lawndale NC 28090//7C4-538-8511/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Donr. HoodMRO WQ/// F//
/ Y/o's
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Richard M Bridgeman 704-663-1699 Ext.264/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
19

(If the present permit expires in 6 months or less). Has the permittee submitted anew application?
110 ❑
Is the facility as described in the permit?
0 ❑ ❑
❑
Are there any special conditions for the permit?
❑ ® ❑
❑
Is access to the plant site restricted to the general public?
■ ❑ ❑
❑
Is the inspector granted access to all areas for inspection?
0 ❑ ❑
❑
Comment: See attached summary.
Operations & Maint
Yes No NA
NF
.nan ..
Is the plant generally clean with acceptable housekeeping?
❑ ■ ❑
❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge,
❑ ❑
❑
and other that are applicable?
Comment: See attached summary.
Equalization Basins
Yes Nn
Is the basin aerated?
NA
❑ ❑
NF
❑
Is the basin free of bypass lines or structures to the natural environment?
■ ❑ ❑
❑
Is the basin free of excessive grease?
S ❑ ❑
❑
Are all pumps present?
❑ ❑
❑
Are all pumps operable?
❑ ❑
❑
Are float controls operable?
❑ ❑ ❑
0
Are audible and visual alarms operable?
❑ ❑ N
❑
Is basin sizelvolume adequate?
E ❑ ❑
❑
Comment: See attached summary.
SS Qlarifipr
Yea No NA
N
.ccQndary
Is the clarifier free of black and odorous wastewater?
❑ ❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑ ❑
❑
Are weirs level?
❑ ❑
❑
Is the site free of weir blockage?
®❑ ❑
❑
Is the site free of evidence of short-circuiting?
❑ ❑ ❑
Is scum removal adequate?
❑ ❑ ❑
Is the site free of excessive floating sludge?
■ ❑ ❑
❑
Is the drive unit operational?
❑ ❑ ❑
Is the return rate acceptable (low turbulence)?
❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc?
❑ ❑ ❑
0
Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth)
❑ ❑ ❑
Comment: See attached summary.
Aeration Basins
Yes No NA
NF
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑ ❑
❑
Are surface aerators and mixers operational?
i ❑ ❑
❑
Are the diffusers operational?
❑ ❑
❑
Is the foam the proper color for the treatment process?
❑ ❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑ ❑
❑
Is the DO level acceptable?
❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/I)
❑ ❑ ❑
Comment: See attached summary.

Laboratory Yes No NA NF
Are field parameters performed by certified personnel or laboratory? E ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? ®❑ ❑ ❑
Is the facility using a contract lab? ❑ ❑ ❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ® ❑ ❑ ❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ® ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ 0 ❑
Comment:
Flow Measurement - Effluent
Is flow meter used for reporting?
yes No NA NE
® ❑ ❑ ❑
Is flow meter calibrated annually?
❑ ® ❑ ❑
Is the flow meter operational?
No ❑ ❑
(If units are separated) Does the chart recorder match the flow meter?
❑ ❑ ❑
Comment: See attached summary.
No Na NE
Record Keeping
Are records kept and maintained as required by the permit?
Yes
❑ v ❑ ❑
Is all required information readily available, complete and current?
a ❑ ❑ ❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑ ❑ ❑
Are analytical results consistent with data reported on DMRs?
0 ❑ ❑ ❑
Is the chain -of -custody complete?
a ❑ ❑ ❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑ M ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ?
❑ ❑ M ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑ ❑ M ❑
Is the ORC visitation log available and current?
❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑ ❑ ❑
Is a copy of the current NPDES permit available on site?
0 ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review?
❑ ❑ M ❑
Comment: See attached summary.
Is composite sampling flow proportional? 0 ❑ ❑ ❑
Is sample collected below all treatment units? 0 ❑ ❑ ❑
Is proper volume collected? M ❑ ❑ ❑
Is the tubing clean? ■ ❑ ❑ ❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ ❑ ❑ ❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? 0 ❑ ❑ ❑
Comment:
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? 0000
19

Upstream / Downstream Samolina Yes No NA NE
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? S ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ® Q ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ S ❑
Comment:

SECTION D: SUMMARY OF FINDING/COMMENTS
Additional Observations:
Permit
e-flex, llc (Isaac Assa, manager) has signed an agreement with the Town of Lawndale, which
states that the Town is responsible for the operation of the WWTP until the pump station comes on
line. The Town of Lawndale, in turn, has signed an agreement with the City of Shelby to contract
out the running of the e-flex WWTP. Ms. Nancy Marshall, Clerk of Lawndale, supplied the signed
agreement between a -flex and Lawndale. Mr. Jay Stowe, Utilities Director for the City of Shelby,
supplied the signed agreement between Lawndale" and Shelby. Currently the Town Hall, Fire
Department, Washerette, Beauty Parlor, and 6-10 private residences of Lawndale utilize the a -flex
WWTP. Flows into the plant are estimated to be 3,000 gallons a day. Discharges occur infrequently
at the facility. Mr. Lee Douglass is the current ORC. Mr. Douglass was advised to continue
sampling and visitation exactly as required by the permit. Mr. Lee Douglass, ORC, and Mr. Jack S.
Bettis, back-up ORC, were present for the inspection.
Record Keeping
For the inspection, DMRs were reviewed for June 2004-May 2005. Mr. Douglass provided
data from 3/2005 to present. It was noted for 3/2005 that the total nitrogen and phosphorus tests
were performed, but not recorded on the DMR. Please submit an amended DMR for 3/2005 which
includes TN and TP data. No records were found when Shelby took over; therefore, records prior to
3/2005 could not be reviewed at the time of the inspection. Mr. Douglass has begun to keep the
records according to permit requirements.
Operations & Maintenance
The facility consists of an equalization basin, aeration basin, three clarifiers, chlorine contact
chamber, and sludge handling equipment. Some effort has been made to keep up the facility during
this difficult time; however, weeds were thick around the treatment basins and in various areas
throughout the plant. Mowing should be done more frequently and closer to the basins.
The plant appeared to be well operated at the time of the inspection; however, if it would be
desirous to operate the plant at capacity in the future many repairs would have to be made.
Equalization & Aeration Basins
One of three aerators is being utilized in the EQ basin. One of six aerators is being used in
the aeration basin. When Shelby began operation of the facility only two of the six surface aerators
in the aeration basin had motors, all the others were missing. Currently, there are no. back-up
aerators in the EQ basin or the aeration basin. Please provide back-up aerators for the basins.
Secondary Clarifiers
Only one out of three available clarifiers is being utilized at the current time. No flow was
going through the clarifier at the time of the inspection. Sludge judge measurements performed for
process control have never reached above 1 foot. All clarifiers appeared to be in working order.
Disinfection is not currently utilized.

r
Flow Measurement
Flow was measured by an ultrasonic meter and recorded by a totalizer with a flow chart.
Last recorded calibration was on 3/17/2004 by J. Lassiter. Mr. Douglass has KNC, Inc coming the
week of 8/8/2005 to update the calibration.
Effluent Pipe
The outfall is suspected to be buried in the sand on the bottom of the First Broad River. 1VIr.
Douglass will confirm its location during the next discharge. Both the inspector and the ORC
perused the First Broad to confirm its location. The river appeared unaffected by any discharges.
General Summary
The e-flex property is currently for sale. At the present time the facility is being stripped,
with pieces of manufacturing equipment being sold out of the main buildings. No definite future
exists at the present time for the facility. No plans are in place to properly close the on -site WWTP
after Lawndale's flow is piped to Shelby. Some storm water sheet flow will enter the WWTP
facility after it is closed; however, storm water has piping by which it is carried off the property and
directly enters the First Broad River.
Mr. Benji Thomas from West Engineering stated to Mr. Jay Stowe, Utilities Director of
Shelby, that the plans for the pump station and tie in to Shelby should be completed in 4-6 weeks.
Estimated completion of the entire project is expected to be by spring or summer of 2006. It is
commendable that Shelby is such a good neighbor to surrounding towns.

W A �FRQ
Michael F. Easley, Governor
�0F
William G. Ross Jr., Secretary
��
6
North Carolina Department of Environment and Natural'Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
;.; / V, lCES March 1, 2005 ' - - :,+
CERTIFIED MAIL
RETURN RECEIPT REQUESTED ��99
Timothy B. Brooks
E-Flex LLC it
P.O. Box 68 MAR C 4 2n
Lawndale, North Carolina 28090
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NC0004120
Cleveland County
Dear Mr. Brooks:
This is to inform you that the Environmental Sciences Section has not received your toxicity self -monitoring report form for the month
of December 2004. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2, Subchapter 2B, Section .0506
(a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the
report was made."
Your Discharge Monitoring Report for December 2004 indicates that there was limited flow during the month. Please note that your
NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which toxicity testing is
required, regardless of whether a discharge occurs from the facility. The form should be labeled "NO FLOW" and all information at the top of
the report form must be completed. If a toxicity sample cannot be pulled because of limited flow, that information must also be conveyed on the
Aquatic Toxicity Self -Monitoring Form. If a discharge occurs from the facility, then you should perform monitoring according to your NPDES
Permit.
Our office would appreciate a written response to this correspondence addressing current facility status. Your response should be
directed to my attention at the address located at the bottom of this page no later than March 31, 2005.
You will be considered noncompliant with the reporting requirements contained in your NPDES Permit for the month of December
2004 until you make acceptable demonstration to the Environmental Sciences Section that the report form was submitted to this office within the
required 30 day reporting period. In addition if within the next twelve (12) months future reports are not received within the required time
frame, you may be assessed a civil penalty.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting requirements. Please read this one
page summary and if you have any questions concerning this Notice, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at
[phone].
Sincerely,
J verton
Chief, Environmental Sciences Section
cc:}RexGleasoiMaolesvilleeRegionalaO"f_fice
John Lesley- Mooresville Regional Office
Isaac Assa, E-Flex LLC, I Industrial Way, Building B Suite J, Eatontown, NJ 07724
Aquatic Toxicology Unit Files
Central Files
Nne
orthCarolina
Naturally
Phone [phone] Customer Service
FAX [phone]
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621
Intemet: esb.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh, NC 27607
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
reporting information. Please take time to review this information. The items below do not address or include all the toxicity
testing and reporting requirements contained in your NPDES permit., If you should have any questions about your toxicity -
testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone] or another Unit
representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the reporting
period (eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon
failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at
least two multiple concentration toxicity tests (one per month) will be conducted over the following two months. As many analyses as
can be completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure
of any single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will
influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity
testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the
quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I -June 30, then you
must provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six
months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental
Sciences Section at [phone], and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and the
month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal
procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities which
have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT
form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting your
toxicity test results certified mail, return receipt requested to the Environmental Sciences Section.

O� �—�— " — -- --- ----- - --- -_-- Michael F. Easley
�O� QG Governor
Uj r William G. Ross, Jr., Secretary
r Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 10, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Larry Gold, CFO
Grupo Assa, LLC (E Flex)
180 Madison Avenue, Suite 1202
New York, New York 10016
SUBJECT: NOTICE OF DEFICIENCY
Effluent Toxicity Testing
NPDES Permit No. NC0004120
E-Flex, LLC WWTP
Cleveland County
Dear Mr. Gold:
SEP 1 6 2004
This is to inform you that the Environmental Sciences Branch has not received your toxicity self -
monitoring report form for the month of June 2004. This is in violation of Title 15A of the North Carolina
Administrative Code, Chapter 2, Subchapter 213, Section .0506 (a)(1)(A) which states that "monthly
monitoring reports shall be filed no later than 30 days after the end of the reporting period for which the
reportwas made."
Your Discharge Monitoring Report for June 2004 indicated, "No Discharge." Please note that your
NPDES permit requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a
month in which toxicity testingis s required regardless of whether a discharge occurs from the facility. The
form should be labeled "NO FLOW" and all information at the top of the report form must be completed.
If a discharge occurs from the facility, then you should perform monitoring according to your
NPDES Permit. You should also consider whether rescission of the NPDES Permit is in the facility's best
interest. Questions regarding NPDES Permit rescission can be directed to Mr. Mike Templeton at
919.733.5083 ext. 541.
Our office would appreciate a written response to this correspondence addressing current facility
status. Your response should be directed to my attention at the address located at the bottom of this page
no later than September 30, 2004.
'The reverse side of this Notice contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions concerning this Notice,
please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone].
Sincerely,
�D 1
Jimmi Overton
C ' E vironmental Sciences Section
cc: °Rex Gleas�hA_4Mooresv`i1'le Regional Office'
John Lesley- Mooresville Regional Office
Mike Templeton -Point Source Branch
Aquatic Toxicology Unit Files
Central Files
WDEN
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]
800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information. The items below do not address or include
all the toxicity testing and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at (919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period (eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
pemut limit, then at least two multiple concentration toxicity tests (one per month) will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December, then toxicity testing must be conducted during these months).
➢ Should the pemuttee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement, the pernttee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also -write "No Flow" on the AT form, sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Branch.

Michael F. Easley, Governor
o��� W a
C
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Matt McCullen
E-Flex LLC
101 West Main Street
Lawndale, North Carolina 28090
SUBJECT: NOTICE OF DEFICIENCY
Effluent Toxicity Testing
NPDES Permit No. NC0004120
E-Flex, LLC WWTP
Cleveland County
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 26, 2004
AUG 3 0 2004
Dear Mr. McCullen: I It..,hr
L
This is to inform you that the Environmental Sciences Section has not received your toxicity self -monitoring report
form for the month of June 2004. This is in violation of Title 15A of the North Carolina Administrative Code, Chapter 2,
Subchapter 2B, Section .0506 (a)(1)(A) which states that "monthly monitoring reports shall be filed no later than 30 days after
the end of the reporting period for which the report was made."
Your Discharge Monitoring Report for June 2004 indicated, "No Discharge." Please note that your NPDES permit
requires you to submit an Aquatic Toxicity Self -Monitoring Form to this office during a month in which toxicity testing is
required, regardless of whether a discharge occurs from the facility. The form should be labeled "NO FLOW" and all
information at the top of the report form must be completed.
If a discharge occurs from the facility, then you should perform monitoring according to your NPDES Permit. You
should also consider whether rescission of the NPDES Permit is in the facility's best interest. Questions regarding NPDES
Permit rescission can be directed to Mr. Mike Templeton at 919.733.5083 ext. 541.
Our office would appreciate a written response to this correspondence addressing current facility status. Your response
should be directed to my attention at the address located at the bottom of this page no later than September 15, 2004.
The reverse side of this Notice contains a summary of important toxicity monitoring and reporting requirements.
Please read this one page summary and if you have any questions concerning this Notice, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone].
Sincerely,
Jimmie O erton
ironmental Sciences Section
cc: tR- Glaasar� Mooresville.Regtonali Of i e
John Lesley- Mooresville Regional Office
Mike Templeton -Point Source Branch
Aquatic Toxicology Unit Files
Central Files
Dennis Lemmons, 101 West Main St., Lawndale N.C. 28090 NorthCarolina
Naturally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621 Phone [phone] Customer Service
Internet: esb.enr.state.naus 4401 Reedy Creek Rd. Raleigh, NC 27607 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and
---reporting information—. -Please-take -time to -review -this-information. -The -items-below-do -n ot-address- or -include -all-the -toxicity — - - - -
testing and reporting requirements contained in your NPDES permit. If you should have any questions about your toxicity -
testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone] or another Unit
representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report
forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Section no later than 30 days after the end of the
period (eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon
failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at
least two multiple concentration toxicity tests (one per month) will be conducted over the following two months. As many analyses as
can be completed will be accepted. If your NPDES permit does not require use of multiple concentration toxicity testing upon failure
of any single quarterly test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration toxicity testing will
influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring
requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and December, then toxicity
testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the
quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30, then you
must provide written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six
months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental
Sciences Section at [phone] and provide written documentation indicating why the test was invalidated and the date when
follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and the
month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following normal
procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities which
have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT
form must also be signed by the performing lab supervisor.
➢� To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting your
toxicity test results certified mail, return receipt requested to the Environmental Sciences Section.

4 0 wAr�9p0
r
Michael F. Easley, Governor `
William G. Ross Jr.. Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek. P. E. Director
Division of Water Quality
August 11, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Isaac Assa, Manager
e-flex, llc
1 Industrial Way West
Building B, Suite J
Eatontown, NJ 07724
Dear Mr. Assa:
7003 2260 00013550 2578
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NC0004120
e-flex — Lawndale Plant WWTP
Case No. LV-2004-0365
Cleveland County
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$835.04 ($750.00 civil penalty + $85.04 enforcement costs) against a -flex, llc.
This assessment is based upon the following facts: A review has been conducted of the
discharge monitoring report (DMR) submitted by a -flex, llc for the month of May 2004. This
review has shown the subject facility to be in violation of the discharge limitations found in
NPDES Permit No. NC0004120. The violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that a -flex, llc violated the
terms, conditions or requirements of NPDES Permit No. NC0004120 and North Carolina General
Statute (G.S.) 143-215. 1 (a)(6) in the manner and extent shown in Attachment A. A civil penalty
may be assessed in accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment against
e-flex, llc:
tft
Carolina
ra!!y
N. C. Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

i
$ 750.00 For 1 of the one (1). violation of G.S. 143-
215. 1 (a)(6) and,NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Sulfide.
$ 750.00
$ 85.04
$ 835.04
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE _
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally,
(7) The prior record of the violator in complying or &iHng to comply with programs
over which the Environmental Management Commission has regulatory authority,
and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR

2. Submit a written request for remission including a detailed justification for
such request:
Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the
penalty assessed. Requesting remission is not the proper procedure for contesting
whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Because a remission request
forecloses the option of an administrative hearing, such a request must be
accompanied by a waiver of your right to an administrative hearing and a
stipulation that no factual or legal issues are in dispute. Please prepare a detailed
statement that establishes why you believe the civil penalty should be remitted, and
submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors
shall be considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-
282. 1 (b) were wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage
resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous
violations; or
(5) whether payment of the civil penalty will prevent payment for the
remaining necessary remedial actions.
Please note that all information presented in support of your request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review your evidence and inform you of his decision in the matter of your
remission request. The response will provide details regarding case status,
directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions
(Committee). Please be advised that the Committee cannot consider information
that was not part of the original remission request considered by the Director.
Therefore, it is very important that you prepare a complete and thorough statement
in support of your request for remission.
In order to request remission, you must complete and submit the enclosed
"Waiver of Right to an Administrative Hearing and Stipulation of Facts" form
within thirty (30) days of receipt of this notice. The Division of Water Quality also
requests that you complete and submit the enclosed "Justification for Remission
Request." Both forms should be submitted to the following address:

Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
3. File a petition for an administrative hearing with the Office of
Administrative Hearings:
Ifyou wish to contest -any statement in the -attached assessment document you
must file a petition for an administrative hearing. You may obtain .the petition
form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this
notice. A petition is considered filed when it is received in the Office of
Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m.
and 5:00 p.m., except for official state holidays. The original and one (1) copy of
the petition must be filed with the Office of Administrative Hearings. The petition
may be -faxed — provided the original and one copy of the document is received in
the Office of Hdmimcirative Hearings within nve (5) business days iouowiug uic
faxed transmission. The mailing address for the Office, of Administrative Iearings
is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone: [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the
petition.

Failure to exercise one of the options above within thirty (30) days of receipt of this letter,
as evidenced by an internal date/time received stamp (not a postmark), will result in this matter
being referred to the Attorney General's Office for collection of the penalty through a civil action.
Please be advised that additional penalties may be assessed for violations that occur after the
review period of this assessment. If the violations are of a continuing nature, not related to
operation and/or maintenance problems, and you anticipate remedial construction activities, then
You Ma wish to consider appL) j for or a Special Order by Consent. If you have Any questions
about this civil penalty assessment or a Special Order by Consent, please contact the Water
Quality Section staff ofthe Mooresville Regional Office at 704/663-1699.
/Zov�
ate)
ATTACHMENTS
D. Rex Glee n, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

Limit Violations, May 2004
Attachment A
e-flex, llc
e-flex — Lawndale Plant WWTP
NPDES Permit No. NC0004120
Case Number LV-2004-0365
Monthly Average Limit Violations
Parameter
Reported Value
Limit
Units
Sulfide
2.64 *
2.0
lb/day
denotes assessment of civil penalt-y.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
e-flex, Ile )
PERMIT NO. NC0004120 ) FILE NO. LV-2004-0365
Having been assessed civil penalties totaling $ 35.04 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated August 11, 2004, the undersigned,
desiring to seek remission of the civil penalties, does hereby waive the right to an administrative
hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Quality
within 30 days of receipt of the notice of assessment. No new evidence in support of a remission
request will be allowed after 30 days from the receipt of the notice of assessment.
This the day of . 2004
ADDRESS
TELEPHONE

N I'D !'I: I " N I I 'I NO. NC' 000-1 12 (1 IA I\(1I NO 001 M()VI'll I\Iil\ V1 AR
I ACILITY N.,'NN,I[ v-Ilcv I.j ( III ("I'V00110
(11"FRATOT, IN RESPON'SIBLI'Cl IARGI (()]\(') Clif'filiki ( ;in, 6KADI- III PI ION I
CERTIFIED LABORATORIE.S (1) Rcsurcll kK- Inc'
CIILCI"' BOX IF ORC HAS CIIANGEA) PERSON(S) COLLECTINC-i SAMPLES Opumon,
Mail ORIGINAL. and ONE C01"I'lo:
ATTN: CENTRAL FILES 6c
DIVISION OF WATER QUALITY
I W-, MAIL SERVICE CrNTEI%
RALrIGII. NC 27694-1017
(SIGNAll
(A. -
BY THIS SIGNATURE. I CERTIFY THAT TIIIS It
ACCURATE AND CONIPLUIT TO THE REST OYM)
NOWLEIK.U.

Facilily Status: (Please check our of the follo�� ing)
All monitoring, data and sampling frequencies meet permit requirements
C
Compliant
All monitoring data and sampling, frequencies do NOT meet permit requirements v
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, ctc.,
and a time table for improvements to be made.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that a qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons .vho manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there are simificant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
Permittee Address
00010 Temperature .
00076 Turbidity
00080 Color (Pt -Co)
00082 Color (ADMI)
00556 Oil & Grease
00600 Total Nitrogen
00610 Ammonia Nitrogen
00625 Total Pjeldhal
Nitrogen
00095 Conductivity 00630 Nitrates/Nitrites
00300 Dissolved Oxygen
00310 BOD; 00665 Total Phosphorus
00340 COD 00720 Cyanide
00400 pH 00745 Total Sulfide
00530 Total Suspend 00927 Total Magnesium
Residue 00929 Total Sodium
00545 Settleable Matt 00940 Total Chloride
or type)
of Permttee**
Phone Number
PARAMETER CODES
00951 Total Fluoride
01002 Total Arsenic
01027 Cadmium
01032 Hexavalent Chromium
01034 Chromium
01037
Total Cobalt
01042
Copper
01045
Iron
01051
Lead
01062
Molybdenum
01067 Mickel
01077 Silver
01092 Zinc
01105 Aluminum
-4D-
Date
Permit Exp. Date
50060 Total
Residual
Chlorine
01147 Total..Seleniu 71880 Formaldehyde
31616 Fecal Colifor 71900 Mercut-
32730 Total Phenolic 81551 Xvlene
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone], or by visiting
the Water Quality Section's web site at h2o.enr.state.nc.us/wRs and linking to the Unit's information pages.
Use only units designated in the reporting facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required 15A NCAC 8G.0204.
** If signed by other than the Permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B.0506 (b)
(2)(D).

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E

Michael F. Easley, Gove r
William G. Ross Jr., Secretary I/
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 17, 2004
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7003 2260 00013550 1816
Mr. Isaac Assa, Manager
e-flex, llc
1 Industrial Way West
Building B, Suite J
Eatontown, NJ 07724
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NC0004120
e-flex — Lawndale Plant WWTP
Case No. LV-2004-0235
Cleveland County
Dear Mr. Assa:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$585.04 ($500.00 civil penalty + $85.04 enforcement costs) against a -flex, llc.
This assessment is based upon the following facts: A review has been conducted of the
discharge monitoring report (DMR) submitted by a -flex, He for the month. of February 2004. This
review has shown the subject facility to be in violation of the discharge limitations found in
NPDES Permit No. NC0004120. The violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that a -flex, llc violated the
terms, conditions or requirements of NPDES Permit No. NC0004120 and North Carolina General
Statute (G.S.) 143-215.1(a)(6) in the mariner and extent shown in Attachment A. A civil penalty
may be assessed in accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment against
e-flex, llc:
Division of water Quality, Mooresville Regional office, 919 North Main Street, MooresviHe NC 28115 [phone] Customer Service
1-877-623-6748

$ 500.00 For 1 of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Biochemical Oxygen Demand.
$ 0 For 0 of the three (3) violations of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC004120, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent limit
for Biochemical Oxygen Demand.
$ 500.00
$ 85.04
$ 585.04
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
2 82. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).

Please submit payment to the attention of
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
IA
2. Submit a written request for remission including a detailed justification for
such request:
Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the
penalty assessed. Requesting remission is not the proper procedure for contesting
whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Because a remission request
forecloses the option of an administrative hearing, such a request must be
accompanied by a waiver of your right to an administrative hearing and a
stipulation that no factual or legal issues are in dispute. Please prepare a detailed
statement that establishes why you believe the civil penalty should be remitted, and
submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors
shall be -considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-
282. 1 (b) were wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage
resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous
violations; or
(5) whether payment of the civil penalty will prevent payment for the
remaining necessary remedial actions.
Please note that all information presented in support of your request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review your evidence and inform you of his decision in the matter of your
remission request. The response will provide details regarding case status,
directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty Remissions
(Committee). Please be advised that the Committee cannot consider information
that was not part of the original remission request considered by the Director.
Therefore, it is very important that you prepare a complete and thorough statement
in support of your request for remission.

In order to request remission, you must complete and submit the enclosed
"Waiver of Right to an Administrative Hearing and Stipulation of Facts" form
within thirty (30) days of receipt of this notice. The Division of Water Quality also
requests that you complete and submit the enclosed "Justification for Remission
Request." Both forms should be submitted to the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1'
3. File a petition for an administrative hearing with the Office of
Administrative Hearings:
If you wish to contest any statement in the attached assessment document you
must file a petition for an administrative hearing. You may obtain the petition
form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this
notice. A petition is considered filed when it is received in the Office of
Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m.
and 5:00 p.m., except for official state holidays. The original and one (1) copy of
the petition must be filed with the Office of Administrative Hearings. The petition
may be faxed — provided the original and one copy of the document is received in
the Office of Administrative Hearings within five (5) business days following the
faxed transmission. The mailing address for the Office of Administrative Hearings
is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone: [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the
petition.

Failure to exercise one of the options above within thirty (30) days of receipt of this letter,
as evidenced by an internal date/time received stamp (not a postmark), will result in this matter
being referred to the Attorney General's Office for collection of the penalty through a civil action.
Please be advised that additional penalties may be assessed for violations that occur after the
review period of this assessment. If the violations are of a continuing nature, not related to
operation and/or maintenance problems, and you anticipate remedial construction activities, then
you may wish to consider applying for a Special Order by Consent. If you have any questions
about this civil penalty assessment or a Special Order by Consent, please contact the Water
Quality Section staff of the Mooresville Regional Office at 704/663-1699.
7ZC
(Date)
ATTACHN ENTS
Z)
D. Rex G16son, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

Attachment A
e-flex, llc
e-flex — Lawndale Plant WWTP
NPDES Permit No. NC0004120
Case Number LV-2004-0235
Limit Violations, February 2004
Monthly Average Limit Violations
Parameter
Reported Value
Limit
Units
Biochemical Oxygen Demand
93.7 *
66
lb/day
Daily Maximum Limit Violations
Parameter Reported Value Limit Units
Biochemical Oxygen Demand 144, 141, 136 130 lb/day
* denotes assessment of civil penalty.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
e-flex, llc )
PERMIT NO. NC0004120 ) FILE NO. LV-2004-0235
Having been assessed civil penalties totaling $585.04 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated June 17, 2004, the undersigned,
desiring to seek remission of the civil penalties, does hereby waive the right to an administrative
hearing in the above -stated matter and does stipulate that the facts are as alleged in the assessment
document. The undersigned further understands that all evidence presented in support of
remission of this civil penalty must be submitted to the Director of the Division of Water Quality
within 30 days of receipt of the notice of assessment. No new evidence in support of a remission
request will be allowed after 30 days from the receipt of the notice of assessment.
This the day of 3 2004
• 1 -M
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number. LV-2004-0235
Assessed Party: a -fleas, llc
Permit No. (if applicable): NC0004120
County: Cleveland
Amount Assessed: $585.04
Please use this form when requesting remission of this civil penalty. You must also complete the
"Waiver of Right to an Administrative Hearing and Stipulation of Facts" form to request
remission of this civil penalty. You should attach any documents that you believe support your
request and are necessary for the Director to consider in evaluating your request for remission.
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred
or the accuracy of any of the factual statements contained in the civil penalty assessment
document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted
only when one or more of the following five factors applies. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting
documents,. as to why the factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282. lb)
were wron fg_ully applied to the detriment of the petitioner (the assessment factors are
listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) - payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i. e., explain how payment of the civil penalty will prevent you from
performing the activities necessary to achieve compliance).
EXPLANATION:

NI'1>ES PERMIT NC1 NU (M041 '() I!ISCIIAi,6E- N() Hill M(1NT1-I i chruarN 1'liAl: 21101'
FACILITY NAME c-Ilcx. LLC GLASS III C OUNTl CIt-c hold
C1P-, P ,TOI\ IN RESPONSIBLE CHARGE (C1RC , Chf"Ita-(1 Uahl (-R:\11E III 1'IIiINC 7(1i ;ti_i1(I!`'
CERTIFIED LABORATOKIES (1) Rcscarch & Analvllc;J l_;li,::. Inc---
CIIE'CK BOX IF C)RC HAS CHANCED PER'SON(S) COLLECi'INC, SAMPLES ! 11 c r;tlnn:
(\Tail ORIGINAL and ONE COPY W.
AT -IN: CF.N-FIZAL FILES
DIVISION OF NVATEIL QUALITY iSIGNATi1RF.01; OPE1,ATOR IN UiSPONSIIILF. CI IAK(il: \ ? L 2 2004
1617 NI All, SLE.VICl: CEN1 7E:R BYTHIS SIGNATURE. I CIiKTIFY TIIAT TIIIS REPOKT iS
R.•1LEIGII. NC 276913-1617 ACCIIIZATE' AND COMPLL'TF TO THE 1SEST OF �tl' NOR'I,EUGI:.
50050
1111111(I 1
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00340
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32730
003011
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i
FLOW
Lntcr Parameter l'odc
*
Abovr Natuc And t'nits
INt
Below
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Facility Status: (111case check one of the following)
All monitoring data and sampling frequencies meet permit requirements
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that a qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations."
P#jnitteele e or type)
VbAlv
3.�
gnature of Permitee*
Date
Permittee Address
V Phone Number
Permit Exp. Date
PARAMETER CODES
00010 Temperature
00556 Oil & Grease
00951
Total Fluoride
01067 Nickel 50060 Total
00076 Turbidity
00600 Total Nitrogen
01002
Total Arsenic -
-01_077 Silver Residual
00080 Color (Pt -Co)
00610 Ammonia Nitrogen
—01092 Zinc Chlorine
00082 Color (ADMI)
00625 Total Kjeldhal
01027
Cadmium
01105 Aluminum
Nitrogen
_
00095 Conductivity
00630 Nitrates/Nitrites
01032
Hexavalent Chromium
01147 Total Seleniun 71880 Formaldehyde
00300 Dissolved Oxygen
01034
Chromium
31616 Fecal Cohfora 71900 Mercury
00310 BOD5
00665 Total Phosphorus
32730 Total Phenolic 81551 Xylene
00340 COD
00720 Cyanide
01037
Total Cobalt
34235 Benzene
00400 pH
00745 Total Sulfide
01042
Copper
34481 Toluene
00530 Total Suspende 00927 Total Magnesium
01045
Iron
A260 MBAS
Residue
00929 Total Sodium
01051
Lead
39516 PCBs
00545 Settleable Matt, 00940 Total Chloride
01062
Molybdenum
50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone], or by visiting
the Water Quality Section's web site at h2o.enr.state.nc.us/wgs and linking to the Unit's information pages.
Use only units designated in the reporting facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required 15A NCAC 8G.0204.
** If signed by other than the Permittee, delegation of signatory authority must be on file with the state per 15A NCAC 2B.0506 (b)
(2)(D)•

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Outtall 007
Tier 7 - 20,000 lb/dav base production, 0.78 MGD treatment capacity
a. Durinh the period be inning on the effective date of this permit and lastin" until issU,lnCe of ,III
/\uthorization to Operate(l) the sub)ect treatment facility untiCl" all0thCr tlCl', but lasting no l,lter
than permit expiration, the Permittec shall be authorized to discharge treated \vasteNvater from
Outfall 001 SLIb)CCt to the follmving effluent limitations and monitoring regUircrneilts:
EFFLUENT CHARACTERISTICS
Parameter Units parameter
Code
EFFLUENT LIMITATIONS
Monthly Daily
Average Maximum
MONITORING REQUIREMENTS
Measurement Sample Sample
Frequency Type Location I'I
Flow
MGD
50050
0.78
Continuous
Recording
I or E
BOD, 5-day, 20°C
lb/day
00310
66 130
3/week
Composite
E
Total Suspended Solids
lb/day
00530
234 466
3/week
Composite
E
Dissolved Oxygen
mg/L
00300
Monitor & Report
3/week
Grab
E, U, D
Temperature
°C
00010
Monitor & Report
3/week
Grab
E, U, D
COD
lb/day
00340
831 1,661
Weekly
Composite
E
Chromium
ug/L
01034
---
Weekly
Composite
lb/day
1.0 2.0
Weekly
Calculated
`
Phenols
ug/L
32730
111
Weekly
Grab
E
Sulfide
lb/day
00745
2.0 4.0
Weekly
Grab
pH
S.U.
00400
Shall be within the range of 6.0 to
Weekly
Grab
9.0 standard units at all times
Total Residual Chlorine
ug/L
50060
28.0
Weekly
Grab
E
Conductivity
u mhos/
00094
Monitor & Report
Weekly
Grab
U, D
Chloride
ug/L
00940
Monitor & Report
2/Month
Composite
E
Copper, Total
ug/L
01042
Monitor & Report
2/Month
Composite
E
Lead, Total
ug/L
01051
Monitor & Report
2/Month
Composite
E
Mercury, Total
ug/L
71900
Monitor & Report
2/Month
Composite
%inc, Total
ug/L
01092
Monitor & Report
2/Month
Composite
Color H)
Monitor & Report
Monthly
Visual
D
Chronic Toxicity
P/F
THP38
See Footnote (5)
Quarterly
Composite
E
Total Nitrooen
mg/L
00600
Monitor &Report
Semi -Annually
Composite
E
(NO2-N + NO3-N TKN)
Total Phosphorus
mg/L
00655
Monitor & Report
Semi -Annually
Composite
E
b. There shall be no discharge of floating solids or visible foam in other than trace amounts.
Footnotes, A.(1.):
1. See Condition A.(9.), Tiered Production -Based Effluent Limitations.
2. Sample locations: I - Influent, E — Effluent, U — Upstream at NC Highway 182, D — Downstream at NCSR 1809.
3. Monitoring requirements for Total Residual Chlorine apply when chlorine is added to the treatment system.
Y. Downstream monitoring April through October only. See also Condition A.(8.), Color Permitting Requirements.
S. Chronic Toxicity (Ceriodaphnia) P/F at 1.6%; March, June, September, and December; see Condition 5.) of tni_
permit.
PART I - Page 1 of 6

Home Insert
T'ra'cl Enfarc'emp'nt Cod
t
The
-Rernssio�
Payment
Petition—TCollectionrS Related Case
Comments Events
}w
--- GurnMaY
Related Violations
PenaltyAssessed R evi ev
—
P'i'
I —PA
Case Numk gNOV:
I I
Eiive:]
Permit:
SOC: AD:
Monitoring Report: 102-2004 JE:Djtalls_.
Facility: le -flex VNVTP
Region: IMooresville I
County: Cleveland
Owner:
Incident: 1:7 Inspect Dt:
CentralOffice Login Date: =06f21/2004
Comments:
CentralOffice Contact: Sledge, Robert L.
Regional Contact: Bridgeman, Richard
M.
Enforcement Contact:
Salutation for Letter:
Penalty Assessed Date: 0611712004
Remission Request:
EMC Hearing Date:
Letter Date: 106M 7f2004
Remission Acknowledged:
Remission Amount:
Penalty Amount: rs5-0-0
Enf. Conf. Date:
EMC Results Received:
Damages:
Remission Amount:
Enforcement Cost: $85.04
Enf. Conf. Letter Date:
Petition in OAH:
Total Case Penalty: 1$585.04
Facility Rcvd. Enf. Conf. Ltr.:
Remission Amount:
Facility Received F&D: 06121f2004
Total Amount Due:
Case to Collection:
Response Due By: L07:f2:1:f2=00�_1
Total Amount Paid,-
Settlement Requested:
Case Closed: -
I -- Rack N e, t : A Finish I
- ---- -- — — --- ­ - --- - - - - --- / ,Ready -- -
I Cancel
;Page lil
sc'rrh L)G' I h-'P
Lt-n
pe,4- rn . tk C"
iSID: ENCS

DIVISION OF WATER QUALITY
December 5, 2003
MEMORANDUM TO: Bob Sledge
FROM: Rex Gleason
n
PREPARED BY: Wes Bell
SUBJECT: Fast Track Enforcement (MV)
Violation of NCGS 143-215. 1 (a)(6) and
NPDES Permit No. NC0004120
e-flex, LLC WWTP
Cleveland County, N.C.
Attached is an enforcement report which details violations of NPDES Permit No.
NC0004120 and NCGS 143-215. 1 (a)(6). Also enclosed is R & A Laboratories, Inc.'s (contract
operations firm) response letter to the Notice of Recommendation for Enforcement. Based upon
our review of the response, an enforcement action is still recommended.
If you have questions or require additional information, please contact Wes or me.
Attachments n _�
I
WB
Ln t�L Y►/L 5
b� s

STATE OF NORTH CAROLINA
COUNTY OF CLEVELAND
IN THE MATTER OF:
e-flex, LLC
FOR VIOLATIONS OF:
NPDES PERMIT NO. NC0004120
AND NORTH CAROLINA GENERAL
STATUTE 143-215. 1 (a)(6)
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
File No. MV
FINDINGS AND DECISIONS
AND ASSESSMENT OF
CIVIL PENALTIES
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, Alan W. Klimek, P.E., Director of the Division of Water
Quality, make the following:
I. FINDINGS OF FACT:
A. e-flex, LLC (e-flex) is a corporation organized and existing under the laws of the
State of North Carolina.
B. e-flex operates a 0.78 MGD wastewater treatment plant in Cleveland County,
which discharges treated wastewater through Outfall 001 and non -contact cooling
water through Outfall 002 to the First Broad River in the Broad River Basin.
C. e-flex was issued NPDES Permit No. NC0004120 on August 19, 1993, effective
September 1, 1993, with an expiration date of July 31, 1998. a -flex continues to
operate under the requirements of the expired permit pending final approval and
reissuance of the new permit by DWQ.
D. Said permit contains the following relevant monitoring requirements for Outfall
002:
Sample
Parameter Monitoring Requirement Location
Flow monthly E
Temperature monthly E,U,D
PH monthly E
I — Influent U - Upstream
E — Effluent D - Downstream

e-ilex, LLC
Findings and Decisions
Page Two
E. e-flex's self -monitoring reports for the months November 2002 through September
2003, revealed the following violations of the above -cited permit monitoring
requirements: (See Attachment A)
F. e-flex's prior record of compliance with programs over which the Environmental
Management Commission has regulatory authority is as follows:
A civil penalty (Case No. LV 2003-0181) of $1, 335.45 was assessed on March
10, 2003 for violations of permitted total suspended solids limits. The penalty was
remitted on August 14, 2003. A civil penalty (Case No. LV 2003-0234) of
$1,335.45 was assessed on April 23, 2003 for violations of permitted total
suspended solids limits. The civil penalty of $1,335.45 was paid in full on
November 10, 2003.
G. The costs to the State of the investigation and enforcement procedures in this
matter totaled $294.00.
Based upon the above Findings of Fact, I make the following:
Il. CONCLUSIONS OF LAW:
A. e-flex is a "person" within the meaning of G.S. 143-215.6A pursuant to G.S. 143-
212(4).
B. NPDES Permit No. NC0004120 is required by G.S. 143-215.1.
C. The monitoring requirements contained in the subject permit are terms, conditions,
or requirements of said permit.
D. e-flex violated G.S. 143 -215. 1 (a)(6) and NPDES Permit No. NC0004120 on
eleven (11) occasions during the months of November 2002 through September
2003, in the manner and to the extent described in Attachment A, by failing to
monitor the effluent for flow.
E. e-flex violated G.S. 143-215. 1 (a)(6) and NPDES Permit No. NC0004120 on
eleven (11) occasions during the months of November 2002 through September
2003, in the manner and to the extent described in Attachment A, by failing to
monitor the effluent for temperature.
F. e-flex violated G.S. 143-215.1(a)(6) and NPDES Permit No. NC0004120 on
eleven (11) occasions during the months of November 2002 through September
2003, in the manner and to the extent described in Attachment A, by failing to
monitor the effluent for pH.

e-flex, LLC
Findings and Decisions
Page 'Three
G. e-flex violated G.S. 143-215. 1 (a)(6) and NPDES Permit No. NC0004120 on
eleven (11) occasions during the months of November 2002 through September
2003, in the manner and to the extent described in Attachment A, by failing to
monitor the upstream for temperature.
H. e-flex violated G.S. 143-215. 1 (a)(6) and NPDES Permit No. NC0004120 on
eleven (11) occasions during the months of November 2002 through September
2003, in the manner and to the extent described in Attachment A, by failing to
monitor the downstream for temperature.
I. A civil penalty may be assessed in accordance with the maximums established by
G.S. 143-215.6A(a)(2)
J. The State's enforcement costs in this matter may be assessed against e-flex
pursuant to G.S. 143-215.3(a)(9) and G.S. 14313-282.1(b)(8).
K. The Director of the Division of Water Quality, pursuant to delegation provided by
the Secretary of the Department of Environment and Natural Resources, has the
authority to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, e-flex, LLC is hereby assessed a civil penalty of:
$ For of the eleven (11) failures to monitor for.effluent flow
in violation of G.S. 143-215.1(a)(6) and NPDES Permit No.
NC0004120 for the months of November 2002 through September
2003.
$ For of the eleven (11) failures to monitor for effluent
temperature in violation of G.S. 143-215. 1 (a)(6) and NPDES
Permit No. NC0004120 for the months of November 2002 through
September 2003.
$ For of the eleven (11) failures to monitor for effluent pH in
violation of G.S. 143-215. 1 (a)(6) and NPDES Permit No.
NC0004120 for the months of November 2002 through September
2003.
$ For of the eleven (11) failures to monitor for upstream
temperature in violation of G.S. 143-215. 1 (a)(6) and NPDES
Permit No. NC0004120 for the months of November 2002 through
September 2003.

e-flea;, LLC
Findings and Decisions
Page Four
$ For of the eleven (11) failures to monitor for downstream
temperature in violation of G.S. 143 -215. 1 (a)(6) and NPDES
Permit No. NC0004120 for the months of November 2002 through
September 2003.
$ 294.00 Enforcement costs.
$ TOTAL CIVIL PENALTY
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I -have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth in G.S. 143B-
2 82. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health,
or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
(Date) Alan W. Klimek, P.E., Director
Division of Water Quality

Parameter
Flow
Temperature
pH
U - Upstream
D - Downstream
E - Effluent
ATTACID4ENT A
e-flex, LLC WWTP
NPDES Number NC0004120
Monitoring Violations
Monitoring
Sample
Month/yr.
Frequencx
Location
11/02 — 9/03
monthly
E
11/02 — 9/03
monthly
E,U,D
11/02 — 9/03
monthly
E
Number of
Violations
11
33
11
Total: 55

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: (MV) Monitoring Violations
Violator: e-flex, LLC
Address: 101 West Main Street
Lawndale, North Carolina 28090
Registered Agent: Mr. Issac Assa,
Address: 101 West Main Street
Lawndale, North Carolina 28090
Facility: e-flex, LLC WWTP
NPDES Permit No. NC0004120
Regional Office: Mooresville
1. The degree and extent of harm to the natural resources of the State, to the public health,
or to private property resulting from the violations:
No harm has been measured or documented.
2. The duration and gravity of the violations:
The violations occurred during the period from November 2002 through September 2003.
3. The effect on ground or surface water quantity or quality or on air quality:
No adverse effects have been documented.
4. . The cost of rectifying the damage:
No environmental damage has been established.
5. The amount of money saved by noncompliance:
Two contract operations/certified laboratories (Statesville Analytical, Inc. and
Aquasource, Inc.) were contacted regarding their fees to perform the five analyses once a
month as required by e-flex at Outfall 002. Both contract operations/certified laboratories
would charge $50.00 plus mileage costs. a -flex saved $550.00 ($50.00 x I 1 months)
excluding mileage costs.

e-flex, LLC
Assessment Factors
Page Two
6. Whether the violations were committed willfully or intentionally:
There is no evidence to suggest that the violations were committed intentionally.
7. The prior record of the violator in complying or failing to comply with programs over
which the Environmental Management Commission has regulatory authority:
A civil penalty (Case No. LV 2003-0181) of $1,335.45 was assessed on March 10, 2003
for violations of permitted total suspended solids limits. The penalty was remitted on
August 14, 2003. A civil penalty (Case No. LV 2003-0234) of $1,335.45 was assessed on
April 23, 2003 for violations of permitted total suspended solids limits. The civil penalty
of $1,335.45 was paid in full on November 10, 2003.
The cost to the State of the enforcement procedures:
Central Office Review and Processing = $100.00
8.0 hours by investigator for investigating and
drafting report @ $17.38/hour = $139.04
1.0 hour for Supervisory review @ $39.96/hour = $ 39.96
1.0 hour for clerical support @ $15.00/hour = $ 15.00
TOTAL = $294.00
9. Type of violator and general nature of business (i.e. individual vs. large corporation):
The violator is a corporation associated with the production of textile apparel.
10. Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
The ORC/contracted operations firm (R & A Laboratories, Inc. ) indicated that the
previous ORC would be contacted to verify the location of Outfall 002 in order to initiate
the appropriate monitoring.
11. Mitigating Circumstances:
R & A Laboratories, Inc. indicated that the effluent limitations/monitoring requirements
page for Outfall 002 was not attached to the permit copy they had received. The ORC at
this facility (prior to employment of the current ORC/contract operations firm) had
performed the required monitoring at Outfall 002.

e-flex, LLC
Assessment Factors
Page 'Three
12. Assessment Factors:
a. IWC: N/A
b. Receiving Stream: First Broad River
C. DMZ's: N/A
d. Copy of Limits Page in Permit: Attached

CERTIFICATION PAGE
I certify that the information in this report is true to the best of my knowledge.
All violations of self -monitoring data have been verified by hard copy review of the
monthly reports and the appropriate permit.
Signature of Principle Investigator(s):
�v
Wesley N. Bell
Date: _z /� Lo 7j

RESEARCh & ANA1YTICA1
LABORATORIES, INC.
Analytical/Process Consultations
04 November 2003
Mr. Richard Bridgeman
NCDENR, Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
RE: NOV
e-Flex WWTP
NPDES Permit No. NC0004120
Cleveland County, North Carolina
Dear Mr. Bridgeman:
RECEI1V�C
NOV 072W3
HC DEPT OF EIMROWURT
AAID NATURAL RESOURCES
MOORESVILLE REGIOidAL OFFICE
On behalf of e-Flex, LLC, Research & Analytical Laboratories, Inc. (RAL) offers this response to
the above referenced Notice of Violation / Notice of Recommendation for Enforcement dated
October 6, 2003.
Operational procedures have been put in place to prevent future overflows at the influent catch basin.
Facility personnel are regularly checking the basin and removing screenings as needed.
Purchase orders have been issued for repair of the mechanical aerators in the aeration basin.
Procedures have been modified to assure that back-up operator visits will be limited to 20%.
Procedures have been modified to assure that calibration times for meters used in field analyses are
documented on calibration logs.
Facility personnel are in the process of clearing the access route to the effluent diffuser.
Concerning the failure to monitor at outfall 002, unfortunately it appears that e-flex personnel were
not aware of the requirement to monitor nor the location of this outfall. The permit provided to RAL
did not contain a permit limitation page for outfall 002, thus we were unaware of its existence. An
attempt was made to locate the outfall during the inspection but it was not found. RAL will contact
the former ORC, Mr. Tim Brooks, in order to get information concerning the location of the outfall.
As soon as it is possible, self monitoring will be resumed at outfall 002.
P.D. Box 473 • 106 Short Street • Kernersville, North Carolina 27294 • 336-996-2641 • Fax [phone]S

L_
04 November 2003
Mr. Richard Bridgeman
NCDENR, Division of Water Quality
Page-2
The failure to collect chronic toxicity samples for December 2002 and January 2003 was due to e-
flex operating on a very limited schedule during that time period. There was not a time during those
two months when there was five consecutive days of discharge in order to collect the samples in
accordance with appropriate sampling methodology. This problem was noted on the DMR's
submitted to Central Files.
All of the other missing data identified in the inspection report was generated in accordance with the
permit. It was, however, not transcribed to the DMR forms due to a clerical error. Corrected DMR's
are being submitted to Central Files and copies are provided with this response.
E-flex will submit a request for a variance to allow collection of composite samples by the constant
time / constant volume methodology.
We sincerely hope that the above response adequately addresses the concerns raised in the referenced
inspection report. If, however, there are any questions, or if further information is required, please
contact the undersigned, or Mr. Dennis Hodge at [phone].
Sincerely,
Research & Analytical Laboratories, Inc.
James M. Cheshire
President / CEO
cc: Dennis Hodge
encl.

Permit No. NC0004120
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOUR OF
DIVISION OF ENVIRONMENTAL MANAGEMENT °' • M NATURAL
�$4QidRCGS AND
PERMIT COMMUNUT DEVELOPMENT
TO DISCHARGE WASTEWATER UNDER THE g 0 3 1993
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM OF ENVIPMMINTAL MANAUMES
�iaaRES1l1LLE Ru�i9N,�l I;FfI('.E
In compliance with the provision of North Carolina General Statute 143=215.1,
other lawful standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Cleveland Mills Company
is hereby authorized to discharge wastewater from a facility located at
101 West Main Street
Lawndale
Cleveland County
to receiving waters designated as the First Broad River in the Broad River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, H, and III hereof.
This permit shall become effective September 1, 1993
This permit and the authorization to discharge shall expire at midnight on July 31, 1998
Signed this day August 19, 1993
Original Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004120
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 002. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characterlstic. Discharge I-Imltatlont
Lbsldav Units (specify
Mon, Avg. tally- Max Mon. Ava. Daily Max.
Flow
Temperature •
Total Residual Chlorine`•'
Monitoring Reaulrementa
Measurement Sample 'Sample
Frequency Type Locatlon
Monthly Instantaneous E
Monthly Grab E, U, D
Monthly Grab E
THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE TREATMENT SYSTEM EXCEPT AS PRE -APPROVED
ADDITIVES TO BIOCIDAL COMPOUNDS.
* Sample Locations: E - Effluent, U - Upstream, D - Downstream
** The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.8°C and in
no case cause the ambient water temperature to exceed 29°C.
** Monitoring requirements only apply if chlorine is added to the cooling water.
The permittee shall obtain authorization from the Division of Environmental Management prior to utilizing any
Part ilI of this Permit). biocide in the cooling water (See
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored monthly at the effluent by grab
sample:
There shall be no discharge of floating solids or visible foam in other than trace amounts.

r
RESEARCh & ANAL TICAL v
LAbORATORIES, INC.
Analytical/Process Consultations
04 November 2003
Mr. Richard Bridgeman
NCDENR, Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
RE: NOV
e-Flex WWTP
NPDES Permit No. NC0004120
Cleveland County, North Carolina
Dear Mr. Bridgeman:
N OV 0 7 2003
ANC• N.a aL =Ptt
On behalf of e-Flex, LLC, Research & Analytical Laboratories, Inc. (RAL) offers this response to
the above referenced Notice of Violation / Notice of Recommendation for Enforcement dated
October 6, 2003.
Operational procedures have been put in place to prevent future overflows at the influent catch basin.
Facility personnel are regularly checking the basin and removing screenings as needed.
Purchase orders have been issued for repair of the mechanical aerators in the aeration basin.
Procedures have been modified to assure that back-up operator visits will be limited to 20%.
Procedures have been modified to assure that calibration times for meters used in field analyses are
documented on calibration logs.
Facility personnel are in the process of clearing the access route to the effluent diffuser.
Concerning the failure to monitor at outfall 002, unfortunately it appears that e-flex personnel were
not aware of the requirement to monitor nor the location of this outfall. The permit provided to RAL
did not contain a permit limitation page for outfall 002, thus we were unaware of its existence. An
attempt was made to locate the outfall during the inspection but it was not found. RAL will contact
the former ORC, Mr. Tim Brooks, in order to get information concerning the location of the outfall.
As soon as it is possible, self monitoring will be resumed at outfall 002.
P.O. Box 473 • 106 Short Street • Kernersville, North Carolina 27284 • 336-996-2641 • Fax [phone]

PPV
04 November 2003
Mr. Richard Bridgeman
NCDENR, Division of Water Quality
Page - 2
The failure to collect chronic toxicity samples for December 2002 and January 2003 was due to e-
flex operating on a very limited schedule during that time period. There was not a time during those
two months when there was five consecutive days of discharge in order to collect the samples in
accordance with appropriate sampling methodology. This problem was noted on the DMR's
submitted to Central Files.
All of the other missing data identified in the inspection report was generated in accordance with the
permit. It was, however, not transcribed to the DMR forms due to a clerical error. Corrected DMR's
are being submitted to Central Files and copies are provided with this response.
E-flex will submit a request for a variance to allow collection of composite samples by the constant
time / constant volume methodology.
We sincerely hope that the above response adequately addresses the concerns raised in the referenced
inspection report. If, however, there are any questions, or if further information is required, please
contact the undersigned, or Mr. Dennis Hodge at [phone].
Sincerely,
Research & Analytical Laboratories, Inc.
James M. Cheshire
President / CEO
cc: Dennis Hodge
encl.

mlcnaei r. t=asiey, uovernor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
11/13/03
• Issac Assa
E-Flex
101 W Main Street
Lawndale, NC 28090
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
E- Flex
Cleveland County
Permit No: NC0004120
LV-2003-0234
Dear Mr. Assa:
Alan W. Klimek, P.E. Director
Division of Water Quality
This letter is to acknowledge receipt of check No. 070654556 in the amount of $1,335.45 received
from you dated November 10, 2003. This payment satisfies in full the civil assessment levied
against the subject facility and this case has been closed. Payment of this penalty in no way
precludes future action by this Division for additional violations of the applicable Statutes,
Regulations, or Permits.
If you have any questions, please call Robert L Sledge at 919-733-5083 Ext.547.
cc: Enforcement File #: LV-2003-0234
Mooresville Regionah Off ice-S_upervisorv,
Central Files
Sincerely,
/:7 =-
For Coleen Sullins, Deputy Director
Division of Water Quality
l(�IIIAL OFFICE
r
MAYER ��*100 SNOW
1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service 1 800 623-7748

A�
ROY COOPER
ATTORNEY GENERAL
State of North Carolina
Department of Justice
P. O. Box 629
RALEIGH
2 7602-0629
October 21, 2003
MC ClCgn. OF ENVIR00,; "'
nrv��SjgJ�?a,r R:P��s'QI.B��'L�I.1
L t
3 2005
REPLY TO: Francis W. Crawley
Environmental Division
[phone] t�
Mr. Albert E. Guarmer, Registered Agent CERTIFIED MAIL
e-flex, 1 lc RETURN RECEIPT REQUESTED
401 South Tryon Street, Suite 3000 -
Charlotte, North Carolina 20202
RE: Assessment of Civil Penalties Against, a -flex, 11c, LV 2003-0234
Dear Mr. Guarnier:
You will find enclosed the Final Agency Decision of the Environmental Management
Commission assessing civil penalties and investigative costs as set forth in the decision document.
._. C, 2-00
Accordingly, your company must submit payment of the civil penalty assessment anT +a
investigative costs to the Department of Environment and Natural Resources within 30 days of receipt of
this final agency decision by mailing a bank or certified check. The check should be made payable to the
Department of Environment and Natural Resources and the mailing envelope addressed as follows:
Mr. Shannon Langley
Water Quality Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If your company fails to pay the penalty within 30 days of receipt of the final decision document,
the Department will seek to collect the amount due through a civil action commenced in Superior Court.
Very truly yours,
Francis W. Crawley y
Special Deputy Attorney General
Commission Counsel
FWC/dk
Enclosure
cc: FrrrnT'Wn7Ut1'
Jennie Hill
OCT 27203

ST,,ATE OF NORTH CAROLINA
COUNTY OF CLEVELAND
IN THE MATTER OF: )
Assessment of Civil Penalties )
Against )
e-flex, Ile )
BEFORE THE
REMISSION COMMITTEE OF THE
ENVIRONMENTAL MANAGEMENT
COMMISSION
LV 2003-0234
FINAL DECISION
THIS MATTER came before the Committee on Civil Penalty Remissions of the
Environmental Management Commission, pursuant to N.C.G.S. § 143-215.6A and § 143B-282.1,
on 9 October 2003 upon recommendation of the Director of the Division of Water Quality for
entry of a final decision on the assessment of civil penalties and investigation costs against e-
flex, Ile in the amount of $1,335.45 ($1,250.00 plus $85.45 investigative costs). E-flex, lle's
request for remission was presented to the Committee on Civil Penalty Remissions for
consideration. The Division of Water Quality was represented by Rex Gleason, Regional
Supervisor in the Mooresville Regional Office, and e-flex, Ile, after proper notice, did not request
the opportunity to appear and speak before the Committee on Civil Penalty Remissions.
Having considered the record and the factors set forth in N.C.G.S. §143B-282.1(b) and
(c), the Committee on Civil Penalty Remissions finds the facts contained in the Director's
Findings and Decision and Assessment of Civil Penalties as stipulated by e-flex, Ile, that the
Findings of Fact support the Conclusions of Law, and that the Director properly applied the
criteria set forth in N.C.G.S. §143B-282.1 in determining the amount of the civil penalties. The
Committee further finds that there are no grounds shown for remission or reduction of the
penalties assessed by the Director for violation of N.C.G.S. § 143-215.1(a)(6) and NPDES

Permit Nol NC0004120 during December 2002 by discharging wastewater into the water of the
State in excess of the permit monthly average and daily maximum effluent limits for total
suspended solids (TSS).
Upon duly made motion and vote, the Committee finds that the assessment of civil
penalties and costs in the amount of $1,335.45 ($1,250.00 civil penalty plus $85.45 investigation
costs) should be upheld.
THEREFORE IT IS ORDERED:
1. That the assessment of civil penalties and costs in the amount of $1,335.45 against
e-flex, llc is AFFIRMED.
2. That this Final Decision and Order be served upon e-flex, llc and upon receipt
hereof, the amount of $1,335.45 be paid to the Department of Environment and Natural
Resources within thirty days.
This the day of October, 2003.
David .Moreau, Chairman
Environmental Management Commission

-3-
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing FINAL DECISION on
the parties listed below by the methods indicated:
Mr. Albert E. Guarnier, Reg. Agent
e-flex, llc
401 South Tryon Street, Suite 3000
Charlotte, N.C. 20202
Mr. Jeff Enfield, Manager
e-flex, llc
P. O. Bos 68
Lawndale, N.C. 28090
Mr/. Rex Gleason
Regional Supervisor
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
This the day of October, 2003.
CERTIFIED MAIL
RETURN RECEIPT
U.S. MAIL
COURIER MAIL
ROY COOPER
Attorney General
Francis W. Crawley
Special Deputy Attorney General
N.C. Department of Justice
P. O. Box 629
Raleigh, N.C. 27602-0629
919/716-6600

STATE OF NORTH CAROLINA
COUNTY OF CLEVELAND
IN THE MATTER OF:
Assessment of Civil Penalties )
Against )
e-flex, Ile )
BEFORE THE
REMISSION COMMITTEE OF THE
ENVIRONMENTAL MANAGEMENT
COMMISSION NC DEPT. OF ENVIRONMkin .,
LV 2003-0234 AWD NATO IPA; r ECSC�U6�Ot�
MOORESI'
r
FINAL DECISION OCT 2 3 2003
THIS MATTER came before the Committee on Civil Penalty Remissions of the
Environmental Management Commission, pursuant to N.C.G.S. §143-215.6A and §143B-282.1,
on 9 October 2003 upon recommendation of the Director of the Division of Water Quality for
entry of a final decision on the assessment of civil penalties and investigation costs against e-
flex, Ile in the amount of $1,335.45 ($1,250.00 plus $85.45 investigative costs). E-flex, Iles
request for remission was presented to the Committee on Civil Penalty Remissions for
consideration. The Division of Water Quality was represented by Rex Gleason, Regional
Supervisor in the Mooresville Regional Office, and e-flex, Ile, after proper notice, did not request
the opportunity to appear and speak before the Committee on Civil Penalty Remissions.
Having considered the record and the factors set forth in N.C.G.S. §143B-282.1(b) and
(c), the Committee on Civil Penalty Remissions finds the facts contained in the Director's
Findings and Decision and Assessment of Civil Penalties as stipulated by e-flex, Ile, that the
Findings of Fact support the Conclusions of Law, and that the Director properly applied the
criteria set forth in N.C.G.S. §143B-282.1 in determining the amount of the civil penalties. The
Committee further finds that there are no grounds shown for remission or reduction of the
penalties assessed by the Director for violation of N.C.G.S. § 143-215.1(a)(6) and NPDES

-2-
Permit Nol NC0004120 during December 2002 by discharging wastewater into the water of the
State in excess of the permit monthly average and daily maximum effluent limits for total
suspended solids (TSS).
Upon duly made motion and vote, the Committee finds that the assessment of civil
penalties and costs in the amount of $1,335.45 ($1,250.00 civil penalty plus $85.45 investigation
costs) should be upheld.
THEREFORE, IT IS ORDERED:
1. That the assessment of civil penalties and costs in the amount of $1,335.45 against
e-flex, llc is AFFIRMED.
2. That this Final Decision and Order be served upon e-flex, llc and upon receipt
hereof, the amount of $1,335.45 be paid to the Department of Environment and Natural
Resources within thirty days.
This the day of October, 2003.
David ItMoreau, Chairman
Environmental Management Commission

-3-
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing FINAL DECISION on
the parties listed below by the methods indicated:
Mr. Albert E. Guarnier, Reg. Agent
e-flex, llc
401 South Tryon Street, Suite 3000
Charlotte, N.C. 20202
Mr. Jeff Enfield, Manager
e-flex, llc
P. O. Bos 68
Lawndale, N.C. 28090
Mr/. Rex Gleason
Regional Supervisor
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
This the day of October, 2003.
CERTIFIED MAIL
RETURN RECEIPT
L06 '11
COURIER MAIL
ROY COOPER
Attorney General
Francis W. Crawley
Special Deputy Attorney General
N.C. Department of Justice
P. O. Box 629
Raleigh, N.C: 27602-0629
919/716-6600

Michael F. Easley, Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
September 19, 2003
CERTIFIED MAIL 7000 1530 0002 2100 6968
RETURN RECEIPT REQUESTED
Mr. Jeff Enfield
E-Flex, LLC
P.O. Box 68
Lawndale, NC 28090
SUBJECT: Request for Remission of Civil Penalty
Pursuant to N.C.G.S. 143-215.6A(f)
E-Flex, LLC
Case Number LV-2003-0234
NPDES Permit Number NC0004120
Cleveland County
Alan W. Klimek, P.E., Director
Division of Water Quality
3,2903
C/���DEPT. cif? fvssVR-O� ;� i '1
G-:eddY Y. A Ur-! r. RE.201-IrRCES
"J�L OFFICE
SEP 2 6 2003
Dear Mr. Enfield:
A final agency decision on your request for remission of the subject civil penalty will be made
by the Committee On Civil Penalty Remissions (Committee) of the Environmental Management
Commission (EMC) on Thursday, October.9, 2003.
The EMC Chairman has considered the written record and determined that an oral
presentation is necessary. Please come prepared to present your remission request at this
meeting. You will be allowed approximately five (5) minutes to speak. Please be
advised that the Committee cannot consider any information other than that submitted in
the original remission request.
The EMC Chairman has considered the written record and determined that no oral
presentations will be made. You may attend this meeting, but you will not be permitted
to speak regarding your case.
Time and Location of Meeting
The Committee will convene at 11:00 a.m. or immediately following the closing of the regularly
scheduled business meeting of the Environmental Management Commission. The Committee
meeting will be held in the North Carolina Wildlife Resources Commission Conference Room
(Room 332), on the third floor of the Archdale Building, located at 512 North Salisbury Street in
Raleigh, North Carolina (see enclosed map).
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1 800 623-7748 [phone] Fax: [phone]

Other Thins to Know About The Meeting
The length of an Environmental Management Commission meeting is determined by its agenda
of the day and the amount of discussion given to each topic — meetings often extend into the
early afternoon. You should arrive for the Committee meeting no later than 11:00 a.m. in order
to ensure your opportunity to present your case in the event that the Committee begins at its
appointed time. If the Commission meeting runs long and you need refreshment or food,
Division of Water Quality staff can direct you to a canteen/snack bar that is located on the
basement floor of the Archdale Building or to other local eateries.
You or your representative should be available to make your presentation to the Committee on
Civil Penalty Remissions at the above mentioned time and location. Because no facts are in
dispute and only the reasonableness of the amount of the penalty is being debated, you will only
be allowed approximately five minutes for your presentation.
Your cooperation in the matter is greatly appreciated. If you have any questions concerning this
matter, please call Bob Sledge of our Water Quality Compliance/Enforcement Unit at (919) 733-
5083, extension 547.
Sincerely,
- ? ,,-/ J2,
Alan W. Klimek, P.E.
enclosure
cc: ooresvilZRegonalffi�ce
Enforcement File
Central Files

7
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Qualiri
\ MD MAP— ^nL1RCES
h
C'�
CERTIFIED MAIL 7000 1530 0002 2100 6753
RETURN RECEIPT REQUESTED AUG 1 , 20d
Mr. Jeff Enfield
e-flex, LLC
P. O. Box 68
Lawndale, NC 28090
Dear Mr. Enfield:
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NC0004120
e-flex, LLC
Cleveland County
Case Number LV-2003-0234
I have considered the information submitted in support of your request for remission in
accordance with North Carolina General Statute (N.C.G.S.) § 143-215.6A(f) and have found no
grounds to modify the civil penalty assessment in the amount of $1,335.45.
If you choose to pay the penalty, send payment to me at the letterhead address within thirty (30)
days of receipt of this letter. Please make your check payable to the Department of Environment
and Natural Resources (DENR).
If payment is not received within thirty (30) days of receipt of this letter, in accordance with
N.C.G.S. § 143-215.6A(f), your request for remission of the civil penalty (with supporting
documents) and my recommendation to deny the request (with supporting documentation) will
be delivered to the North Carolina Environmental Management Commission's (EMC)
Committee On Civil Penalty Remissions (Committee) for final agency decision.
If you desire to make an oral presentation to the Committee on why your request for remission
meets one or more of the five statutory factors you were asked to address, you must complete
and return the attached form within thirty (30) days of receipt of this letter. Please mail the
completed form to the attention of Bob Sledge at the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
V..
FSr&Fi;. i.t<
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1 800 623-7748 [phone] Fax: [phone]

V'r
Your request for an oral presentation and the documents in this matter will be reviewed by the
EMC Chairman and, if it is determined that there is a compelling reason to require an oral
presentation from you, you will be notified by certified mail of the date, time, and place that your
oral presentation can be made. Otherwise, the final decision on your request for remission will
be made by the Committee based on the written record.
Thank you for your cooperation in this matter. If you have any questions about this letter, please
contact Bob Sledge at [phone], extension 547.
Sincerely,
G( " `
Alan W. Klimek, P.E.
attachment
cc: �1y�1oo-esvilleuRe °i,onal Gffice.-
Enforcement file
Central Files

STATE OF NORTH CAROLINA
County of Cleveland
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST:
e-flex, LLC
ENVIRONMENTAL MANAGEMENT
COMMISSION
DWQ Case Number LV-2003-0234
REQUEST FOR ORAL PRESENTATION
I hereby request to make an oral presentation before the Environmental Management
Commission's Committee On Civil Penalty Remissions in the matter of the case noted above. In
making this request, I assert that I understand all of the following statements:
This request will be reviewed by the Chairman of the Environmental Management
Commission and may be either granted or denied.
• Making a presentation will require the presence of myself or my representative during a
Committee meeting held in Raleigh, North Carolina.
My presentation will be limited to discussion of issues and information submitted in my
original remission request, and because no factual issues are in dispute, my presentation will
be limited to five minutes in length.
This the day of , 20
SIGNATURE
TITLE (President, Owner, etc.)
ADDRESS
TELEPHONE

DWQ- - CIVIL ASSESSMENT REMISSION FACTORS CONSIDERATION
Case Number: LV-2003-0234_ Region MRO
Assessed Entity:_e-flex,LLC
County: _Cleveland
() Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
Notes:
Assessment factors were applied in accordance with established D,WQ policy
() Whether the violator promptly abated continuing environmental damage resulting from the
violation;
Notes
Violations of NPDES permit were not promptly abated. Violations were reported in
October, November and December 2002.
() Whether the violation was inadvertent or a result of an accident;
-Notes:
Company began operation in September 2002. NPDES permit limit violations occurred in
October (no assessment), November (penalty assessed, but remitted in full) and December
(current case). Ample start-up time was allowed for facility to achieve proper
operation/compliance.
() Whether the violator had been assessed civil penalties for any previous violations;
Notes:
na
() Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Notes:
na
Decision (Check one)
Request Denied_ Full Remission Partial remission Amount remitted
Date
Alan Klimek,P.E.

of wH �F9 ICJ
O� QG Michael F. asley, Governor
DIUatWilliam
� G. Ross, Jr.,Secretary
—� North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
April 23, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7001 2510 0004 8287 7392
Mr. Jeff Enfield, Plant Manager
e-flex, llc
101 West Main Street
Lawndale, NC 28090
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1(a)(6) and NPDES Permit No. NC0004120
e-flex, llc WWTP
Case No. LV 03-234
Cleveland County
Dear Mr. Enfield:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$1335.45 ($1250.00 civil penalty + $85.45 enforcement costs) against a -flex, llc.
This assessment is based upon the following facts: A review has been conducted of the
discharge monitoring report (DMR) submitted by e-flex, llc for the month of December 2002.
This review has shown the subject facility to be in violation of the discharge limitations found in
NPDES Permit No. NC0004120. The violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that a -flex, llc violated the
terms, conditions or requirements of NPDES Permit No. NC0004120 and North Carolina General
Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty
may be assessed in accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment against}`
e-flex, llc:
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115
Ag*A
INMFN_t
-HONE [phone]
=AX [phone]
Customer Service
1 800 623-7748

$ l U For Z of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Total Suspended Solids (TSS).
For of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent limit
for Total Suspended Solids (TSS).
$ For / of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent limit
for Sulfide.
0,
TOTAL CIVIL PENALTY
$ 85.45 Enforcement costs.
S-
$ / -7 S, = TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect .on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.

Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of -
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment letter.
Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation that there are no factual or legal issues in dispute: You
must execute and return to this office the attached waiver and stipulation form and
a detailed statement which you believe establishes. whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violations;
(c) the violations were inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violation;
(e) payment of the civil penalty will prevent payment for the remaining
necessary remedial actions.
Please submit this information to the attention of. -
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina. 27699-1617

Please note that all information presented in support of a request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review the information during a bimonthly enforcement conference and inform you
of his decision in the matter of the remission request. His response will provide
details regarding case status, directions for payment and provision for further
appeal of the penalty to the Environmental Management Commission's Committee
on Civil Penalty Remissions. Please be advised that the Committee cannot
consider information that was not part of the original remission request considered
by the Director and therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to
the Office of Administrative Hearings and must conform to Chapter 150B of the
North Carolina General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail. Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within thigy days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter being
referred to the Attorney General's Office with a request to initiate a civil action to collect the
penalty.

Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact the Water Quality Section staff of the Mooresville Regional
Office at 704/663-1699.
(Date)
A
D. Rex Gle/son, P.E.
Water Quality Regional,Supervisor
Mooresville Regional Office
Division of Water Quality
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

Attachment A
e-flex, Ile
NPDES Permit No. NC0004120
Case Number LV 03-234
Limit Violations, December 2002
Monthly Average Limit Violations
Parameter Reported Value Limit
Total Suspended Solids 1378 * 1046.6
Parameter
Total Suspended Residue
Sulfide
Daily Maximum Limit Violations
Reported Value Limit
4075 * 2091.4
21.3 19.2
* denotes assessment of civil penalty.
Units
lbs/day
Units
lbs/day
lbs/day

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN OF
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
e-flex, llc )
PERMIT NO. NC0004120 ) FILE NO. L.V 03-234
Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Division of Water Quality dated
, the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document. The undersigned further
understands that all evidence presented in support of remission of this civil penalty must be
submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
This the day of 2003
ADDRESS
TELEPHONE

EFFLUENT
•
NPDES PERMIT NO. NC 0004120 -DISCHARGE NO. 001 M�INH December
Fes" tETY-NAME E-Flex. LLC CLASS III COUNTY Cleveland
OPERATOR INRESPONSIBLE CHARGE (ORC) Dennis J. Hodee GRADE IV
CERTIFIED LABORATORIES (1) Research & Analytical Labs. Inc. (2)
CHECK BOX IF ORC HAS CHANGED PERSONS) COLL TING SAMPLES Operators
Mail ORIGINAL and ON .tom SAMR LAMENT
ATTN: CENTRAL FH..ES AND NATURAL R;g--:S URCES x
DID ISION OF WATER QLILLE REGIQ1 L OF =liGNATURVOFTP. TORINRESPO\BIBLE CH URGE) =31617 MAIL SERVICE CENTER P r' BY.THIS SII CERTIFY THAT THIS REPORT IS
RALEIGH, NC 27699-16i7 AC iJRATE AND COAIPLETE TO THE BEST OF MY 12 ORI-F _
—1
50050
00010
00400
1 00310
90340
00530
00745
132730
1 00300
1
01034
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«
FLOW
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E.nier Psrsaaeter Code
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y
4hoye Name _-tnd Units
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:.:::::::.::::::.:.:::::.::::::::::::::::.::::::::::::::::::::::::::.:::::::::.::.:::::.::::::.::::.:::::::.::::::::::.:::::::..:::.::.:::::::::..:::.:._::.:::::._:::::.:::.,.::..:::...::::.:,.:.:.
:::::::::::::::.::::.::::::..:::::::::.:::..:::..:.::.:.::::::::::.:
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- ..::-,....:. ,........
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121
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122
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1 1
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_
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......_...._...........
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........ .............._
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........ ............
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. _. ............_
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161
1030
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:::. ....:;
::. .:;::»::
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1 <0.010
• ::
3Q>::iD:'
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:......:
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22
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AN ERAGE
1 0.236
1 6.4
164 1
2.921
1378
9.59 1
<0.008 1
113
1 <0.010 1
0.055 1
c1D211 1 1S-J i 13.0 1 --3-
:
siQ9ti..
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:: .......
>@$
MLN'DILIi
1 0.037
1 5.1 1
7.4
22.5 1
660
279
4.26 1
<0.002 1
9.6
I <0.010
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..:T..il..`x::;::?::E:i'::?=E«
n.�3...............i...........................x..............................................................................................................................
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Monthly Limit
1 0.780
1 1
=>6<9
242\4831
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4.8D.6 1
I 13\D
4.&9.6 1
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Copy DWQ Fotm'vIR-1 (01/00)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
All monitoring data and sampling frequencies do NOT meet permit requirements
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, mairt=�--,
and a time table for improvements to be made.
Plant is still experiencing start-up non -compliances. Should be resolved with January operations. Also. unable to
the chronic toxicity due to erratic production schedule at manufacturing facility. Again- this should be resolved Rjih
January operations
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in w
with a system designed to assure that a qualified personnel properly gather and evaluate the information submitted- Base my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the infotmari^n- be
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that the ar` ,—;„- czlnt
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations-'
Jeff Enfield at Manaa r
Perm- asVor
i
Signaye ' tee Date I
101 West Main Street Lawndale. NC 28090 704-538-0019
Permittee Address Phone Number . E - !;z
00010 Temperature 00556 Oil & Grease
00076 Turbidity 00600 Total Nitrogen
00080 Color (Pt -Co) 00610 Ammonia Nitrogen
00082 Color (ADMI) 00625 Total Kjeldhal
Nitrogen
00095 Conductivity - 00630 Nitrates/Nitrites
00300 Dissolved Oxygen
00310 BOD5 00665 Total Phosphorus
00340 COD 00720 Cyanide
00400. pH 00745 Total Sulfide
00530 Total Suspende 00927 Total Magnesium
Residue 00929 Total Sodium
00545 Settleable Matt 00940 Total Chloride
PARAMETER CODES
00951 Total Fluoride 01067 Nickel 50060 Tc:ai
01002 Total Arsenic 01077 Silver R
01092 Zinc C W�
01027 Cadmium 01105 Aluminum
01032 Hexavalent Chromium 01147 Total Seleniu 71880 For
01034 Chromium 31616 Fecal Coliform 71900 `i-
01037
Total Cobalt
01042
Copper
01045
Iron
01051
Lead
01062
Molybdenum
32730 Total Phenolic 81551 Xvi=z
34235 Benzene
--34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone], or bv -.i&;f c
the Neater Quality Section's web site at h2o.ennstate.nc.us/wes and linking to the Units information pages.
Use only units designated in the reporting facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required 15A NCAC 8G.0204.
** If signed by other than the Permittee, delegation of signatory authority must be on file with the state per 15A NCAC 213.050o
(2)(D).

A. (). EF LULNT LIMITATIONS AND MONITORING IZi:QU11ZI-MI--N'1'S FINAL Permit No. NCUUU�112U
During the period beginning on the cffcclivc elate of the I)c -1 it and laslinl; until exlrutsion above 0.78 MGU, lire Yermillcc is uulhori7cd to
discharge fivnt oulfall(s) serial number(M. Such (lischarges s11a11 be lintiled anti ntonilo(-e(I by the perntillce as shccifled below:
-ELIL!4111 Chorn _InrIp1Ip
Flow
130D, 5 Day, 20 °C
CCU
TSS
Sulfide
Phenols
Chromium
Dissolved Oxygon
Temperature
Total Nitrogen (NO2+NO3+TKN)
Tolal Phosphorus
121� �1t_�r_s�4_l.l.tt>1.1n114u r
L12 a I my Unlls s
-I~POC.liY
��icu• llsllY_INctx Ms�u._._l�Ys>,• 1).ull�Max,
0.70 M.
242.7 403.6
3020.0 7650.0
1040.0 2091.4
9.0 19,2
Co 9.6
4.0 9.6
* Stunple locations; I:: - Lfl'luent, I - luflucnl, U
Moniterinq
ffim 1119llte
Moasurorrionl
�.1I1L14
'�1.I11_GLLO
1'roquor'cy
Tvno
Locullorr
Continuous
Ilocordor
I or E
3/Wools
Composllo
I:
Weekly
Composite
E
3/Week
Cornposlle
E
Wookly
Grab
1_
Weekly
Grab
E
Woolcly
Composllo
1j
3/Wools
Grab
E,U,D
3/Week
Grab
E,U.D
Seml-annually
Cornposlle
L"-"-
Sonrl•annually
Composlie
E
l 1psnctun al N( I lil;hway I tl'L, I) - 1)(MIStrciun at NCSIZ 1809
"* ChroniC'1'oxicily (Cerio(Inl)lrnitl) P/F al 2,4(9); Marcll, Junc, Sclticnlbcr,Intl I)cr.cnthcr; See PillfIll, Condition I:.
The pl I shall not be less than 6.0 stan(lar(I ,,,its nor 1;rcater Than r9.O st;uiclarcl (rails "uul shall he monitored weekly al the cfllucnt b
sample.
y �r;rli
There shall be no (lisClrsu'ge of healing solids or visible fuanl in other Ih;tn Inlet amounts.

Fast Track Worksheet
Case Number L\0 03 234
Facility Name E- Flex
Permit Number INCO004120
Previous Case Statutory Maximun $25,000
in the Last es per violation
two years
Number of Assessments for previous 6 DMRs Total Assessment Factor =
01 • 20 M® 40 C5 6 1°00
1.00 Exit
Total
Number Number Penalty/ Assessment
Violations Assessed Parameter Violation Violation Factor . Total Penalty
Comments
Percent of the Maximum Penalty
Authorized by G.S.143-215.6A. 1.6%
ew month = December 2002
by Richard Bridgeman

�; :;:.
1;� ' ; �

OF \NA%9 Michael F. Easley, G error I&X6
William G. Ross Jr., Secretary
co North Carolina Department of Environment and Natural Resources
r
-i Alan W. Klimek, P. E., Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
October 6, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Jim Avery, Plant Manager
e-flex, LLC
101 West Main Street
Lawndale, North Carolina 28090
Dear Mr. Avery:
7001 2510 0004 8286 5528
Subject: Notice of Violation/Notice of
Recommendation for Enforcement
Compliance Evaluation Inspection
e-flex WWTP
NPDES Permit No. NC0004120
Cleveland County, N.C.
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection conducted at the subject facility on September 23, 2003, by Mr. Wes Bell of this Office.
Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of
the enclosed report.
This report is being issued as a Notice of Violation (NOV) and Notice of Recommendation
for Enforcement because of the monitoring violations (for Outfall 002) of the subject NPDES Permit
and North Carolina General Statute 143-215.1 as detailed in the Self -Monitoring Section of the
attached report. Pursuant to N.C.G.S. 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant to NCGS 143-
215.1.
It is requested that a written response be submitted to this Office by October 20, 2003
addressing the deficiencies noted in the Facility Site Review/Operations & Maintenance, and
Self -Monitoring Sections of the report. In responding, please address your comments to the
attention of Mr. Richard Bridgeman.
AMA
Mooresville Regional Office, 919 North Main Street, Mooresville North Carolina 28115 NCDEh,'R
Phone [phone] Customer Service
Fax [phone]

Mr. Jim Avery
Page Two
October 6, 2003
This letter is also to advise you that this Office is considering sending a recommendation for
enforcement action to the Director of the Division of Water Quality for the monitoring/reporting
violations of N.C.G.S. 143.215.1(a) and the NPDES Permit No. NC0004120. If you have an
explanation for the violations that you wish to present, please include it in the requested response.
The response should include any amended DMRs for the missing parameters that were not transposed
onto the original copies. Your explanation will be reviewed and if an enforcement action is still
deemed appropriate, your explanation will be forwarded to the Director along with the enforcement
package for his consideration.
The report should be self-explanatory; however, should you have any questions concerning
the report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Cleveland County Health Department
Dennis Hodge, R & A Laboratories, Inc.

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Qmpliance InspectiQln Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 u 2 u 31 NC0004120 1 11 121 03/09/23 1 17 18 U 19 U 20 LiRemarks
211111111111111111111111111111111111111111111111166
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA --------Reserved---- —
67I 1. 9 1 69 70 U 71 LJ 72 UN 73 W 74 751 I I I I I I 180
Section B. Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:18 AM 03/09/23
93/08/01
E- Flex
Exit Time/Date
Permit Expiration Date
101 West Mair- Street
Lawndale NC 28090
01:30 PM 03/09/23
98/07/31
Name(s) of Onsite Rep resentative(s)lritles(s)/Phone and Fax Numbers)
Other Facility Data
Clifford Curtis Cair/ORC/336-996-2841/
Dennis Hodge//336-996-2841/
Name, Address of Responsible Offidal/ride/Phone and Fax Number
Jim Avery,l0_ W Main Street Law -dale NC 28090/Plant Contacted
No
Manager/704-536-0019/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Fac_1-tv Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
PERMIT:
The facility is currently operating under the requirements of an expired permit (7/31/98); however, the
facility has submitted the appropriate documentation for a permit renewal. The recently issued revised draft
permit (dated 7/24/03) appears to adequately describe the facility.
RECORDS AND REPORTS:
DMRs, chair of custody forms, laboratory analyses, Operator -in -Responsible Charge (ORC)/da-ly operation and
maintenance log, process control data, flow charts, and calibration data were
(cont.)
Name(s) and Signature(s) of Inspectors) Agency/Office/Phone and Fax Numbers Date
Weslev N Bell MRO WQ//704-663-1699/704-663-6040
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yr/mo/day Inspection Type (cont.) 1
31 NC0004120 111 121 03/09/23 117 18L=J
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
reviewed at the time of the inspection. The records were in-depth and well maintained.
FACILITY SITE REVIEW/OPERATIONS & MAINTENANCE --
According to the comments of the previous ORC on the October 2002 DMR, the wastewater treatment facility was
shut down for eighteen months prior to being placed back into operation (October 2002). A contract
operations firm (Research & Analytical Laboratories, Inc.) was hired to assume the operational duties in
December 2002_ R&A Laboratories Field Services Director (RALFSD) indicated that the firm performs the
operational and sampling duties while the plant maintenance personnel performs the required maintenance.
At the time of the inspection, this office observed evidence of a previous overflow from the influent catch
basin (with rough screening)_ The overflow had entered into a concrete stormwater ditch that discharges into
the First Broad River. According to the facility's maintenance personnel, the overflow resulted from the
screening becoming clogged with debris. The overflow had occurred several days prior to the — spection and
this facility never notified this office. Please be advised that the failure to report overflows that reach
surface waters via ditches, conveyances, etc_ and/or is greater than 1,000 gallons onto the ground can subject
the facility to civil penalties.
Screenings were observed on the ground without proper disposal. Four mechanical aerators were not operable
in the aeration basin. Corrosion/deterioration could be observed on all of the aerators. A large mat of
solids (with vegetation) was observed in one of the corners of the aeratior. basin. Please be advised that
the NPDES Permit requires that the facility be properly operated and maintained at all times. Although
RALFSD indicated that the company was making progress towards repairing/replacing the inoperable aerators,
the company (and operational firm) should incorporate an adequate preventive maintenance program to insure
the operational integrity of the aerators and associated components.
Although there were maintenance discrepancies observed, the facility appeared to be properly operated and the
surrounding grounds were well maintained. The operations firm has been able to maintain a compliant status
with effluent limitations for 2003 with the assistance of low influent flows and extended detention times.
Only one of the three final clarifiers was being utilized due to the low influent flows. The sludge
conditioning/treatment process has not been put into operation; however, the RALFSD indicated that the
operational status of the sludge treatment system would be evaluated within the near future. The process
control program includes pH, DO, settleability tests, MLSS, MLVSS, and microscopic examinations. The
facility continues to build up an appropriate biomass population; therefore, sludge wasting has not occurred.
The RALFSD was very knowledgeable of the treatment processes and equipment used at the facility.
Although the facility is staffed with appropriately certified operators, the back-up ORC has •✓-sited the
facility in 2003 in excess of twenty percent (based on a calender year). Please be advised that the ORC and
back-up ORC must comply with the responsibilities/requirements listed in 15A NCAC 8G .0204 and .0205(1)(a).
LABORATORY:
Research & Analytical Laboratories (Certification # 34) in Kernersville, N-C. has been contracted to provide
analytical support. The on -site field analyses are performed under the contracted laboratory's certification.
The laboratory field ecuipmer_t appeared to be properly calibrated and maintained. The facil-tv staff should
insure that the calibration times are documented (for field analyses) to verify that the meters are
calibrated prior to analysis.
EFFLUENT/RECEIVING STREAM:
The effluent appeared reddish brown with no floatable solids or foam_ The receiving stream was very turbid;
therefore, it was not possible to observe the impact the effluent was raving on the stream. The outfall
location/diffuser was accessible; however, the location was covered with thick vegetation_ The facility must
provide a safe and accessible location to the outfall/diffuser location.
SELF -MONITORING PROGRAM:
Self -monitoring reports were reviewed for the period July 2002 through June 2003, inclusive. Note: R&A
Laboratories, Inc. assumed operational and sampling duties in_ December 2002. Daily maximum TSR violations were
reported on October 29, November 21, and December 2, 2002. Daily maximum sulfide violation was reported on
December 2, 2002. Monthly average COD and TSR violations were both reported for October, November, and
December (TSR only) 2002. The violations have been previously addressed by the Division_ No effluent pH,
temperature, and flow and upstream and downstream temperature were performed for outfall 002 from November 2002
through June 2003 (40 total violations). No effluent pH, DO, temperature, and upstream and downstream DO,
temperature, and conductivity were reported on 11/21/02_ The 10-day interval between the collection of 2/m
samples was not adhered to for effluent chloride in April 2003. The facility failed to collect chronic toxicity
samples for December 2002 and January 2003. The Division has separately addressed the December 2002 violation.
The following monitoring violations were verified during the inspection as being collected and analyzed;
however, the values were inadvertently left off the DMRs. Effluent mercury was not reported for the weeks of
12/15 - 12/21/02 and 2/23 - 3/1/03. Only 2/wk monitoring was performed (3/wk required) for effluent 30D and
TSS during the weeks of 1/5 - 1/11/03 and 1/12 - 1/18/03_ Amended DMRs will be resubmitted_ In addition, the
same upstream and downstream sampling times were listed on 4/3/03 and 6/11/03. These times were
appropriately documented in the sampling log book; however, they were transcribed incorrectly on the DMRs. The
permittee and ORC/staff must insure that all DMRs are accurate and complete prior to submittal to the Division..
Effluent composite samples are currently being collected by the constant time/constant volume method. This
office has :o record of a variance request and/or approval to collect composite samples according to this

NPDES yr/mo/day Inspection Type
31 NC0004120 111 121 03/09/23 117 181J
(cont.) 2
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
method. Pursuant to NPDES permit requirements, composite samples are to be collected proportional to flow.
According to the 15A NCAC 2B .0503 (4)(d), if the flow varies by no more than 15%, a variance may be given
for samples collected by constant time/constant volume method, upon approval by DWQ. Any request to collect
samples by the constant time/ constant volume method should'be sent to the attention of Mr. Richard Bridgeman
of this office. The following °reformation should be included in the request:
1) a description of the flow measurement device used at 'the facility;
2) a representative sample of one (1) week's flow data, including copies of supporting strip chart recordings;
3) a description of the sampling method proposed for use at the facility (i.e., constant time/ constant
volume);
4) a description of any flow equalization used at the treatment facility.
All reviewed sample analyses appeared to be properly preserved and meet the required holding times. Effluent
sampling is performed in the appropriate location_
FLOW MEASUREMENT:
Effluent flow is measured continuously by a V-notch weir and ultrasonic flow meter with totalizer and chart
recording. The flow meter is calibrated 1/yr by Laboratory Instrument Services in Landrum, S-C. The flow
meter was last calibrated on 2/4/03.
SLUDGE DISPOSAL:
Currently no sludge has been treated and/or removed from the wastewater treatment facility following the
start-up in October 2002.

North Carolina
Michael F. Easley, Governor
MEMORANDUM
January 8, 2004
i
NGDENR
Department of Environment and Natural
To: Mike Templeton
DWQ / NPDES-Permits
Raleigh
From: Britt L. Setzer, Regional Engineer �-
Public Water Supply Section
Mooresville Regional.Off ice
Subject: Review of Draft NPDES Permit NC0004120
e-flex, Ilc — Cleveland County
Resources
William G. Ross Jr., Secretary
I have completed the review of the a -flex draft NPDES permit. As we discussed, the City
of Shelby drinking water supply intake is located downstream of this discharge point.
When the WWTP was being operated by Carolina Mills, there were several incidents of
extreme color in the First Broad River, which impacted the water supply system
associated with the City of Shelby. Intensive water treatment procedures had to be
incorporated to remove the color within the water treatment plant. The problem was
more profound during the low flow stream conditions associated with the almost 5 year
drought.
Based on this information, I concur with the issuance of the permit provided that the
facility is operated and maintained properly, the stated effluent standards are met prior to
discharge, the discharge does not contravene the designated water quality standards,
and any color associated with this discharge does not adversely impact the City of
Shelby water supply system as in the past. A conventional water treatment plant is not
designed to remove colors associated with dyes utilized in the textile industry. If color is
going to be an issue during low flow stream conditions, then a higher standard of
-removal should be incorporated into this permit.
If you have any questions, please call me at [phone], Ext. 278.
�..s Cc: Jessica Miles
.' Mark Hahn
G:\DEH\PW S\PERSONAL\BS\010803.mem.doc
919 North Main Street, Mooresville, North Carolina 28115
Phone: [phone] \ FAX: [phone] \ Internet: www.ennstate.nc.us
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Water Pollution Control System O ' C Designation Form
WPCSOCc
NCAC 15A:08G .021
General Information: t
Permittee Owner/Officer Name:
Mailing Address: P.O. Boa 2!
City: Town of Lawndale State: NC Z p: 28090 -
Telephone Number: 704 538-3146.
Signature. w Date:
.........................................................................
Facility Information:
Facility:
Permit Number: NC0004120
! SUBMIT A SEPARATE FORM FOR EACH
Mark (X) Type of Facility Class (1— 4)
Cleveland
OF SYSTEM!
Class
Wastewater Plant X 3 Sp y Irrigation N/A
Physical/Chemical Lan Application N/A
Collection System Su surface N/A
.........................................................................
Operator in Responsible Charge:
Print Name: Lee Sommers Douglass Social
Certificate Type and Grade:
,ertificate #: 986506
Work Telephone: [phone] Signature: '
Back -Up Operator in Responsible Charge:
Print Name: Jack Stanley Bettis Social Security # : All jjM
Certificate Type and Grade: WW II Certificote #: _ 10493
Work Telephone: [phone] Signature: _
Mail or Fax to: WPCSOCC
1618 Mail Service Center
Raleigh, N.C. 27699-1618
Fax: [phone]
APR 2 0 7047
Revised 10/2000
ublic,'W-r= 90tY

C'V�o IJ I
Mr. Jeff Enfield
e-flex, LLC
P. O. Box 68
Lawndale, NC 28090
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
AUG 1 4 2003
Subject: Remission Request of
Civil Penalty Assessment
NPDES Permit Number NC0004120
e-flex, LLC
Cleveland County
Case Number LV-2003-0181
MC . OF EWROSdMENT
AkM WMAL RESOURCES
rz=ES ILLF- -- "' ! OFFICE
AUG 9 g 2003
Dear Mr. Enfield: `V 't EE U' 6 '' N
I considered the information submitted in support of your request for remission in accordance
with G.S. 143-215.6A(f) and have decided to remit the entire civil penalty in the amount of
$1,335.45 and hereby close our case number LV-2003-0181.
Please be advised that a full reduction of the civil penalty assessment in no way precludes the
Division from taking future enforcement action against the subject facility should additional
violations occur.
If you have any questions about this letter, please do not hesitate to contact Bob Sledge at (919)
733-5083, extension 547.
Thank you for your cooperation in this matter.
Sincerely,
Alan W. Klimek, P.E.
cc: M©:ozesuille Regi.onaLO_ffice
Enforcement File
Central Files
T1„ :
''tU —R,>
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1 800 623-7748 [phone] Fax: [phone]

DWQ- - CIVIL ASSESSMENT REMISSION FACTORS CONSIDERATION
Case Number: _LV-2003-0181_Region _MRO
Assessed Entity:_e-flex, LLC.
County: Cleveland
() Whether one or more of the civil penalty assessment factors were wrongly applied to the
detriment of the petitioner;
Notes:
na
() Whether the violator promptly abated continuing environmental damage resulting from the
violation;
Notes
na
() Whether the violation was inadvertent or a result of an accident;
Notes:
Due to start up of the company in Sept. 2002, the violations occurring in November
apparently resulted because the wastewater treatment plant had not yet stabilized. 60 days
are usually allowed for a plant to achieve operational stability.
() Whether the violator had been assessed civil penalties for any previous violations;
Notes:
na
() Whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Notes:
na
Decision (Check one) /
Request Denied Full Remission it Partial remission Amount remitted
Date
Alan HIimek, P.E.

--- - Michael F. Easley, Governor
William G. Ross Jr., Secretary ._
_ Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
June 10, 2003
Mr. Jeff Enfield, Plant Manager
e-flex, LLC
101 West Main Street
Lawndale, NC 28090
Subject: Remission Request of
Civil Penalty Assessment
e-flex, LLC WWTP
NPDES Permit Number NC0004120
Cleveland County
Case Numbers LV-2003-0181 & LV-2003-234
Dear Mr. Enfield:
The Division of Water Quality is in receipt of your request for remission of the civil penalty
assessed in the matter of the cases noted above (submitted on your behalf by Research &
Analytical Laboratories, Inc.). Unfortunately, we did not find completed forms waiving your
right to an administrative hearing along with the letter when it arrived in this office. As this is a
necessary part of the remission request, we respectfully ask that you complete the attached
waiver forms and return them to the attention of Bob Sledge at the letterhead address. Once the
completed waiver forms are received, we can continue with the processing of your request. Your
requests will be placed on the agenda of the Director's next scheduled enforcement conference
and you will be notified of the result.
If you have any questions about this matter, please contact Bob Sledge at [phone],
extension 547.
Sincerely,
Shannon Langley, Supervisor
Point Source Compliance/Enforcement Unit
cc: Vloores_ville_._Regiorial Off ce:�w/att_ ach_ � e ts--
Central Files w/attachments
Enforcement File w/original & 3 attachments
R&A Labs; Mr. Dennis R. Herzig, P.E.
me DEPT. OF EPARRM MoEidy 1
AMC NATI Jr- ". r?I-SCNJRCES
0ORESY, ° ^! OFFICE
�n
JUN 1 6 2003
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
1 800 623-7748 [phone] Fax: [phone]

June 24, 2003
uhl�l�C�77ed1�111�1
TO: Rex Gleason
FROM: Richard Bridge man
6
SUBJECT: Request for Remission of Civil Penalty
Cases No. LV-2003-0181 and LV-2003-0234
e-flex, LLC
NPDES Permit No. NC0004120
Cleveland County
e-flex, LLC was assessed a civil penalty of $1335.45, including $85.45 in enforcement
costs, on 3/10/03 (LV-2003-0181), and a civil penalty of $1335.45, including $85.45 in
enforcement costs, on 4/23/03 (LV-2003-0234). LV-2003-0181 covers a COD monthly average
violation (not assessed), a TSS monthly average violation, and a TSS daily maximum violation,
occurring during 11/02. LV-2003-0234 covers a TSS monthly average violation, a TSS daily
main—u-in violation, and a Sulfide daily maximum violation (not assessed), occurring during
12/02.
The company indicates that, after being idle for several years, the WWTP was in a start-up
mode under the ownership of the new permittee, and that this accounts for the violations. The
WWTP was restarted during 9/02, but there were no discharges unti110/02 (22nd and 29t)
During 10/02, there was a COD monthly average violation, a TSS monthly average vio ation, and
a TSS daily maximum violation, but no assessment was made. During 11/02, there was only one
reported discharge, and during 12/02, there were 11 reported discharges. Even during 1/03, there
were only 13 reported discharges, but since then the discharges have become constant. Except
for TN and TP, minimum monitoring requirements range from weekly to 3/week. The company
reported compliance for 1/03 through 4/03.
There have been no previous civil penalty assessments against a -flex, LLC. Protection
from a civil penalty assessment during the start-up of a WWTP should be based on case specifics
and, by nature, is subjective. This discharge is to the First Broad River, a WS-IV CA water. The
IWC of the discharge is considered to be 2.4%. Although the mass loading on the stream during
the noncompliance was high, it is unlikely that there was much of a negative impact. `
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IDIVISION OF WATER QUALITY - CIVIL PENALTY ASSESSMENT
VIOLATOR:
COUNTY: CLL UCGRRI%j
CASE NUMBER:
ASSESSMENT FACTORS:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation(s);
[Tot Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
2) Tiie Duration and gravity of the violation(s);
Tot Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
3) The effect op ground or surface water quantity or quality or on air quality;
Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
4) The cost ofrectifying the damage;
[T Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
5) The amount of money savenoncompliance;
❑ Not Significant d oderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
6) Whether thf violations) was (were) committed willfully or intentionally;
® Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Envir onmegtal Management Commission has regulatory authority; and ;
ZNot Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
8) The cost to tWe State of the enforcement procedures.
of Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
Date A Rex Gleason, P. E.
Water Quality Regional Supervisor
REMISSION FACTORS:
() Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment of the
petitioner;
() Whether the violator promptly abated continuing environmental damage resulting from the violation(s);
(, Whether the violation(s) was (were) inadvertent or a result of an accident;
() Whether the violator had been assessed civil penalties for any previous violations;
and
() Whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Date Alan W. IOimek, P.E.
Director

VIOLATOR: Q—' Icxl L L G
COUNTY: CG E(iGLR i✓r�
CASE NUMBER:
ASSESSMENT FACTORS:
1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation(s);
2 Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
2) The Duratign and gravity of the violation(s);
Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
3) The effect op ground or surface water quantity or quality or on air quality;
of Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
4) The cost of lyttifying the damage;
GYNot Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
5) The amount of money saved noncompliance;
❑ Not Significant Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
6) Whether th5eviolation(s) was (were) committed willfully or intentionally;
M Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
7) The prior record of the violator in complying or failing to comply with programs over which the
Envinmegtal Management Commission has regulatory authority; and
Not Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
8) The cost to Oe State of the enforcement procedures.
tot Significant ❑ Moderately Significant ❑ Significant ❑ Very Significant ❑ Extremely Significant
2.3'2 oc�3�
Date D. Rex Gleason, P. E.
Water Quality Regional Supervisor
REMISSION FACTORS:
() Whether one or more of the civil penalty assessment factors were wrongly applied to the detriment of the
petitioner;
() Whether the violator promptly abated continuing environmental damage resulting from the violation(s);
(v/ Whether the violation(s) was (were) inadvertent or a result of an accident;
() Whether the violator had been assessed civil penalties for any previous violations;
and
() Whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Date
Alan W. Klimek, P.E.
Director

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
March 10, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 70012510 0004 8287 7828
Mr. Jeff Enfield, Plant Manager
e-flex, llc
101 West Main Street
Lawndale, NC 28090
SUBJECT
Dear Mr. Enfield:
Alan W. Klimek, P.E., Director
Division of Water Quality
Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143 -215. 1 (a)(6) and NPDES Permit No. NC0004120
e-flex, He WWTP
Case No. LV 03-181
Cleveland County
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$1335.45 ($1250.00 civil penalty + $85.45 enforcement costs) against e-flex, llc.
This assessment is based upon the following facts: A review has been conducted of the
discharge monitoring report (DMR) submitted by e-flex,- llc for the month of November 2002.
This review has shown the subject facility to be in violation of the discharge limitations found in
NPDES Permit No. NC0004120. The violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that e-flex, llc violated the
terms, conditions or requirements of NPDES Permit No. NC0004120 and North Carolina General
Statute (G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty
may be assessed in accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with
authority provided by the Secretary of the Department of Environment and Natural Resources and
the Director of the Division of Water Quality, I, D. Rex Gleason, Water Quality Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment against
e-flex, llc:
L� Customer Service Mooresville Regional Office, 919 North Main Street, Mooresvfite. NC 28115 PHONE [phone]
NdCDEN;R 1 800 623-7748 FAX [phone]

R
IN
/2sc:. "e
$ 85.45
For _/ of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Chemical Oxygen Demand (COD).
For i of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent limit
for Total Suspended Solids (TSS).
For. / of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0004120, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent limit
for Total Suspended Solids (TSS).
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
. Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-
282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality,
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority,
and
(8) The cost to the State of the enforcement procedures.

Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
2. Submit a written request for remission or mitigation including a detailed
justification for such request:
A request for remission or mitigation is limited to consideration of the
reasonableness of the amount of the penalty and is not the proper procedure for
contesting the accuracy of any of the statements contained in the assessment letter.
Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative
hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and
a detailed statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting
from the violations;
(c) the violations were inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violation;
(e) payment of the civil penalty will prevent payment for the rem ining
necessary remedial actions.
Please submit this information to the attention of
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Please note that all information presented in support of a request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review the information during a bimonthly enforcement conference and inform you
of his decision in the matter of the remission request. His response will provide
details regarding case status, directions for payment and provision for further
appeal of the penalty to the Environmental Management Commission's Committee
on Civil Penalty Remissions. Please be advised that the Committee cannot
consider information that was not part of the original remission request considered
by the Director and therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
K.
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an
administrative hearing. This request must be in the form of a written petition to
the Office of Administrative Hearings and must conform to Chapter 150B of the
North Carolina General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 276994 601
Failure to exercise one of the options above within thirty days, as evidenced by a date
stamp (not a postmark) indicating when we received your response, will result in this matter being
referred to the Attorney General's Office with a request to initiate a civil action to collect the
penalty.

Please be advised that any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty. If you have any questions about this civil
penalty assessment, please contact the Water Quality Section staff of the Mooresville Regional
Office at 704/663-1699.
(Date)
ATTACHMENTS
./:� � � , , Q"L'
D. Rex eason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office
Division of Water Quality
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

IAMB% 111 " 8_ Q
e-flex, llc
NPDES Permit No. NC0004120
Case Number LV 03-181
Limit Violations, .November 2002
Monthly Average Limit Violations
Parameter
Reported Value
Limit
Units
Chemical Oxygen Demand
3909
3828.0
lbs/day
Total Suspended Solids
3322 *
1046.6
lbs/day
Daily Maximum Limit Violations
Parameter
Reported Value
Limit
Units
Total Suspended Residue
3322 *
2091.4
lbs/day
* denotes assessment of civil penalty.

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF Cleveland
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN OF
CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING
AND STIPULATION OF FACTS
e-ilex, llc )
PERMIT NO. NC0004120 ) FILE NO. LV 03-181
Having been assessed civil penalties totaling for
violation(s) as set forth in the assessment document of the Division of Water Quality dated
the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document. The undersigned fiu-ther
understands that all evidence presented in support of remission of this civil penalty must be
submitted to the Director of the Division of Water Quality within 30 days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after 30 days
from the receipt of the notice of assessment.
day of
ADDRESS
TELEPHONE
ME
2003

e�
EFFLUENT
NPDES PERMIT NO. NC 0004120 DISCHARGE NO. 001 MONTH November YEAR 2002
FACILITY NAME E-Flex. LLC CLASS III COUNTY Cleveland
OPERATOR IN RESPONSIBLE CHARGE (ORC) Timothy Brooks GRADE II PHONE [phone]
CERTIFIED LABORATORIES (1) Test America (2)
CHECK BOX IF ORC HAS CHANGED PERSON(S) COLLECTING SAMPLES Ooerators
Mail ORIGINAL and ONE COPY to: r
ATTN: CENTRAL FILES
Cv
(SIGNA' U=&' 4O ATOR IN RESPONSIBI� CHARGE)
Y THIS SIGNATT.IRE, I CERTIFY THAT THIS REPORT IS
Z.-Ls-oZ
DATE
Copy DWQ Form MR-1 (01/00)

wz
Facility Status: (Please check one of the following) W
Q U f
All monitoring data and sampling frequencies meet permit requirements C
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
If the facility is noncompliant, please comment on corrective actions being taken in respect to equipment, operation, maintenance, etc.,
and a time table for improvements to be made.
Field data for pH temperature & Dissolved Oxygen for the Effluent. Upstream and Downstream are not included
on this DMR form. It appears that a former emplovee may have been removed the data upon their dismissal. Also, the
parameters -of COD & TSS were exceeded. This is due to the WWTP being just recently placed back on line. We are
currently woiking with Research & Analvtical Laboratories, Inc. (RAL) personnel to reseed the system. Due to the
cold temperatures causing slow acclimation of new organisms compliance may not be achieved immediatelv. .
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that a qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines anj imprisonment for knowing violations."
101 West Main Street
Permittee Address
00010 Temperature
00556 Oil & Greasd ;
00076 Turbidity
00600 Total Nitrogen
00080 Color (Pt -Co)
00610 Ammonia Nitrogen
00082 Color (ADMI)
00625 Total Kjeldhal
Nitrogen ,
00095 Conductivity
00630 Nitrates/Nitrites
00300 Dissolved Oxygerf
00310 BOD5
00665 Total Phosphorus
00340 COD
00720 Cyanide
00400 pH
00745 Total Sulfide
00530 Total Suspende
00927 Total Magnesium
Residue
00929 Total Sodium
00545 Settleable Matt(
00940 Total Chloride
Permittee
SiQnatur6/of
Phone Number
PARAMETER CODES
00951 Total Fluoride
01002 Total Arsenic
01027 Cadmium
01032 Hexavalent Chromium
01034 Chromium
01037
Total Cobalt
01042
Copper
01045
Iron
01051
Lead
01062
Molybdenum
01067 Nickel
01077 Silver
01092 Zinc
01105 Aluminum
G7
Date
Permit Exp. Date
50060 Total
Residual
Chlorine
01147 Total Seleniurr 71880 Formaldehyde
31616 Fecal Coliform 71900 Mercury
32730 Total Phenolic 81551 Xylene.
34235 Benzene
34481 Toluene
38260 MBAS
39516 PCBs
50050 Flow
Parameter Code assistance may obtained by calling the Point Source Compliance/Enforcement Unit at [phone], or by visiting
the Water Quality Section's web site at h2o.enr.state.nc.us/wes and linking to the Unit's information pages.
Use only units designated in the reporting facility's permit for reporting data.
* ORC must visit facility and document visitation of facility as required 15A NCAC 8G.0204.
** If signed by other than the Permittee, delegation of signatory authority must be on file with the state per 15A NCAC 213.0506 (b)
(2)(D). �� _

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL Permit No. NC0004120
During the period beginning on the effective date of the permit and lasting until expansion above 0.78 MGD, the Pennittee is authorized to
discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the pennittee as specified below:
Effluent Characterlstic.
Flow
BOD, 5 Day, 20 °C
OGD
TSS
Sulfide
Phenols
Chromium
Dissolved Oxygen
Temperature
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorus
LbsLdAy Discharge Llmitatlonf
Units (specify
Mon. Ava, pally M" Mon, Ava. Daily Max.
0.78 MGD
242.7 483.6
3828.0 7656.0
1046.6 2091A
9.6 19.2
4.8 9.6
4.8 9.6
t8
_Measurement
SOMPIA
Frequency
Type
Continuous
Recorder
3/Week
Composite
Weekly
Composite
3/Week
Composite
Weekly
Grab
Weekly
Grab
Weekly
Composite
3/Week
Grab
3/Week
Grab
Semi-annually
Composite
Semi-annually
Composite
* Sample locations: E - Effluent, I = Influent, U - Upstream at NC Highway 182, D - Downstream at NCSR 1809
** Chronic Toxicity (Ceriodaphnia) P/F at 2.4%; March, June, September and December; See Part'Ilf, Condition E.
IorE
E
E
E
E
E
E
E,U,D
E,U,D
E
E
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit
Ver
Plnact PEffect
PExpir
Facility
Out Parameter UoM
Sample Frequency S Y E I U D MEffect
MExpir DMax DMin MAvg WAvg MGMean WGMean QAv(
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00010 -Temperature, V deg c
Grab 3 X week
0 1 0 0 1 1 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00010 -Temperature, V deg c
Grab 3 X week
0 1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 00095 - Specific Condu� umhos/ci Grab Weekly
0 1 0 0 1 1 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 00300 - DO, Oxygen, Di mg/I
Grab 3 X week
0 1 0 0 1 1 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00300 - DO, Oxygen, Di mg/l
Grab 3 X week
0 1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00310 - BOD, 5-Day (2C Ibs/day
Composi3 X week
0 1 1 0 0 0 09/01/93
483.6 242.7
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00340 - COD, Oxygen C Ibs/day
Composi Weekly
0 1 1 0 0 0 09/01/93
7.656 3,828
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 00400 - pH su
Grab Weekly
0 1 1 0 0 0 09/01/93
9 6
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00530 - Solids, Total Si Ibs/day
Composi' 3 X week
0 1 1 0 0 0 09/01/93
2,091.4 1,046.6
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00600 - Nitrogen, Total Ibs/day
Composl Semi-annuall�0
1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 00665 - Phosphorus, T( Ibs/day
Composi' Semi-annuall,O
1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 00745 - Sulfide, Total (z Ibs/day
Grab Weekly
0 1 1 0 0 0 09/01/93
19.2 9.6
id NC0004120
1.00
08/01/03
07/31/98
E-Flex- E- Flex
001 00940 - Chloride (as Cl: mg/I
Composl 2 X month
0 1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 01034 - Chromium, Tot Ibs/day
Composl Weekly
0 1 1 0 0 0 09/01/93
9.6 4.8
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 01042 - Copper, Total (; ug/I
Composl 2 X month
0 1 1 0 0 0 09/01/93
id NG0004120
1,00
08/01/93
07/31/98
E-Flex- E- Flex
001 01051 - Lead, Total (as ug/I
Composl 2 X month
0 1 1 0 0 0 09/01/93
id NC0004120
1.00
OB/01193
07/31/98
E-Flex- E- Flex
001 01092 - Zinc, Total (as ; ug/I
Composl 2 X month
0 1 1 0 0 0 09/01/93
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 32730 - Phenolics, Tota Ibs/day
Grab Weekly
0 1 1 0 0 0 09/01/93
9.6 4.8
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 39100 - Bis (2-Ethylhe)omg/I
Composi Weekly
0 1 1 0 0 0 09/01/93
1.3
id NC0004120
1.00
08101193
07/31/98
E-Flex - E- Flex
001 50050 - Flow, In conduli mgd
Recorder Continuous
0 1 1 0 0 0 09/01/93
0.78
id NC0004120
1.00
08/01/93
07/31/98
E-Flex - E- Flex
001 71900 - Mercury, Total I ug/I
Composi Weekly
0 1 1 0 0 0 09/O1/93
0.5
id NC0004120
1.00
08/01/93
07/31/98
E-Flex- E- Flex
001 TGP3B - P/F STATRE : pass/fail
Composi Quarterly
0 1 1 0 0 0 09/01/93

Fast Track Worksheet
Case Number LV ®181
Facility Name E- Flex
Permit Number INCO004120
Previous Case Statutory Maximun $10,000
in the Last No per violation
two years
Number of Assessments for previous 6 DMRs Total Assessment Factor =
0 1 0 20 03 0 40 05 6 1.00
1.00
Total
Number Number Penalty/ Assessment
Violations Assessed Parameter Violation Violation Factor Total Penalty
1
0
COD
Monthly/Quarterly
avg
$1000
1
$0.00
1
1
TSS
Monthly/Quarterly
av
$1000
Total Penalty
$1000.00
1
1
TSS
Weekly avg/daily
max
$250
$250.00
3
Grand
$1250.00
Percent of the Maximum Penalty 4.17
Authorized by G.S. 143-215.6A.
Comments
repared by Richard Bridgeman
Exit

OF W A r�R Michael F. Easley
Governor
r�g 7 (� William G. Ross, Jr., Secretary
>_ Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director,
Division of Water Quality
February 28, 2003
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Mike Wright
E-Flex, LLC (Cleveland Mills)
101 W Main St.
Lawndale, North Carolina 28090
Subject: NOTICE OF DEFICIENCY
Effluent Toxicity Testing
NPDES Permit No. NC0004120
E-Flex (Cleveland Mills) WWTP
Cleveland County
Dear Mr. Wright:
•�v:.. -� r;, {=PEE
WAR 0 6 200.E
This is to inform you that the Environmental Sciences Branch has not received your toxicity
self -monitoring report form for the month of December 2002. This is in violation of Title 15A of the
North Carolina Administrative Code, Chapter 2, Subchapter 213, Section .0506 (a)(1)(A) which states
that "monthly monitoring reports shall be filed no later than 30 days after the end of the reporting period
for which the report is made." '
Information contained on your December 2002 DMR indicates that there was an erratic
production schedule at the facility during December and you were unable to collect the chronic
toxicity sample. In the future, if you encounter problems with conducting a toxicity test during a
required toxicity testing month, then you should immediately contact this office and speak with a staff
representative. You should also follow-up the verbal notification with written documentation
indicating problem(s) with performing the test and you should provide a follow-up date for toxicity
testing.
You will be considered noncompliant with the reporting requirements contained in your
NPDES Permit for the month of December 2002 until you make acceptable demonstration to the
Environmental Sciences Branch that the report form was submitted to this office within the required
30 day reporting period. Late and,'or non -reporting of toxicity self -monitoring data subjects you to the
enforcement authority of the Division.
The reverse side of this Notice contains a summary of important toxicity monitoring and
reporting requirements. Please read this one page summary and if you have any questions concerning
this Notice please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at [phone].
cc:
PIA
�� CDEPiR
Customer Service
1-800 623-7748
Sincerely,
e Overton
Assistant Water Quality Section Chief
for Environmental Sciences
.=�xrCrleason1Ioorsville lZegtoulClffice
John Lesley- Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 [phone]

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity
testing and reporting information. Please take time to review this information. The items below do not address or include
all the toxicity testine and reporting requirements contained in your NPDES permit. If you should have any questions
about your toxicity testing requirement, please contact Mr. Kevin Bowden with the Aquatic Toxicology Unit at (919) 733-
2136 or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that
toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered (with the
appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the
reporting period (eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing
upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the
permit limit, then at least two multiple concentration toxicity tests (one per month) will be conducted over the following two
months. As many analyses as can be completed will be accepted. If your NPDES permit does not require use of multiple
concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct either single
concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives
effective July 1, 1999. Follow-up multiple concentration toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity
monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June, September, and
December, then toxicity testing must be conducted during these months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing this monthly test requirement, the permittee will
revert to the quarterly months specified in the permit. Please note that your permit may or may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-June 30,
then you must provide written notification to the Environmental Sciences Branch by June 30 that a discharge did not occur
during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the
Environmental Sciences Branch at [phone] and provide written documentation indicating why the test was
invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the
information block located at the top of the AT form indicating the facility name, permit number, pipe number, county and
the month/year of the subject report. You should also write "No Flow" on the AT form, sign the form and submit following
normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except for facilities
which have not received a facility classification. In these cases, a duly authorized facility representative must sign the AT
form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider submitting
your toxicity test results certified mail, return receipt requested to the Environmental Sciences Branch.

Cleveland Mills, Lawndale N.C., A Division of Spartan International
Gentlemen,
I am informing you that I am no longer ORC at Cleveland Mills.
Effective today December 10 2001 Cindy Morris will be ORC and will be
responsible for all duties and reports. I will remain at Cleveland Mills as
the Back-up Operator. Questions or concerns reguarding the change
should be directed to Mr. Ronnie Turner af the following number.
864-439-1829 or 864-415-4031
Sincerely,
Sam Waters , I
Cleveland Mills permit Number NC0004120
Samuel R. Waters Operators Number 25814
A1,0 r:`.k;t '.s:t. ?!-S ,tf

Michael F. Easley
Governor
A
>_ I VW\.J1 —I
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Timothy B. Brooks
Cleveland Mills Company
PO Box 68
Lawndale, North Carolina 28090
William G. Ross, Jr., Secretary
J Department of Environment and Natural Resources
l Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
November 30, 2001
SUBJECT: Effluent Toxicity Testing
NPDES Permit No. NC0004120
Cleveland Mills WWTP
Cleveland County
Dear Mr. Brooks:
DEC 0 3 2001
This is to inform you that the Division has not received your quarterly toxicity self -monitoring
report form for September 2001. While your September 2001 Discharge Monitoring Report
indicated, "Plant Down, No Flow," our office failed to receive a toxicity self -monitoring report form
labeled, "No Flow." Please be reminded that the reporting of toxicity testing data is a dual
requirement and that Aquatic Toxicity (AT) Report Forms are due no later than thirty days after the
end of the reporting period for which the report is made. AT report forms shall be submitted to the
following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please submit an AT test form to the above address during a month in which toxicity testing
is required by the permit, (ie, Mar, Jun, Sep and Dec) but testing is not conducted due to "NO FLOW"
from the facility. You should submit AT test forms to our office until such time that the NPDES Permit
is rescinded.
The reverse side of this Notice contains a summary of important toxicity monitoring and
reporting requirements. Please read this one page summary page and if you have any questions
concerning this Notice or any aspect of your toxicity testing requirement, please contact Mr. Kevin
Bowden with the Aquatic Toxicology Unit at (919) 73372136.
Sincerely,
Overton
Assistant Water Quality Section Chief
for Environmental Sciences
cc: Rex-Gleason=Mooresville-Region al -Off ice_ ,
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit Files
Central Files
NCDE®R,
Customer Service Environmental Sciences Branch 1621 Mail Service Center Raleigh, NC 27699-1621 (919)
733-2136 800 623-7748

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked
toxicity testing and reporting information. Please take time to review this information. The items below do not
address.or include all the toxicity testing and reporting requirements contained in your NPDES permit. If
you should have any questions about your toxicity testing requirement, please contact Mr. Kevin Bowden with
the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement
and that toxicity report forms are appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement. All toxicity test results must be entered
(with the appropriate parameter code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT' form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be filed with the Environmental Sciences Branch no later than 30 days after the
end of the reporting period (eg, January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration
toxicity testing upon failure of any single quarterly toxicity test. If the initial pass/fail test fails or if the chronic
value is lower than the permit limit, then at least two multiple concentration toxicity tests (one per month) will be
conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly
test, you may choose to conduct either single concentration toxicity testing or multiple concentration toxicity
testing per the Division's WET enforcement initiatives effective July 1, 1999. Follow-up multiple concentration
toxicity testing will influence the Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic
toxicity monitoring requirements (eg, if the testing months specified in your NPDES permit are March, June,
September, and December, then toxicity testing must be conducted during these months).
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January 1-
June 30, then you must provide written notification to the Environmental Sciences Branch by June 30 that a
discharge did not occur during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify
the Environmental Sciences Branch at [phone] and provide written documentation indicating why the test
was invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should
complete the information block located at the top of the AT form indicating the facility name, permit number, pipe
number, county and the month/year of the subject report. You should also write "No Flow" on the AT form, sign
the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Responsible Charge (ORC) except
for facilities which have not received a facility classification. In these cases, a duly authorized facility
representative must sign the AT form. The AT form must also be signed by the performing lab supervisor.
➢ To determine if your AT test forms were received on time by the Division of Water Quality, you may consider
submitting your toxicity test results certified mail, return receipt requested to the Environmental Sciences Branch.

eflex
July 22, 2002
Mr. Rex Gleason
Regional Supervisor
Water Quality Section
NC DENR
919 North Main Street
Mooresville, NC 28115
Re: NPDES Permit Number NC0004120
Dear Mr. Gleason:
:i a1 �Pe'1
JUL 2 4 2002
.Z�r� 17 C
In reference to the above mentioned permit, my company E-flex, LLC has recently purchased the
former Cleveland Mills property in Lawndale, NC. Change of ownership forms will be forwarded
to your office shortly.
Further, the Wastewater Treatment Plant will remain idle (no discharge) for at least the next 6
weeks, as there is currently no production at that site. Your office will be notified when and if
plant production resumes.
Currently, we have retained Mr. Tim Brooks as our wastewater ORC and Sam Waters serves as
his back-up ORC.
Regards, �.
�i��� Qc.
Isaac Assa, Manager
e-flex,11C
1 Industrial Way West • Building B, Suite J • Eatontown, NJ 07724 • Tel [phone] • Fax [phone] • www.e-flex.com

,yn ,-..,DIVISION
OF WATER QUALITY
Chemistry
Laboratory Reparl / Water Quality
lab Number :
3W77$
W SAMPLETYPE
Date Received:
10/16/98
COUNTY
CLEVELAND PRIORITY
Time Received:
9:30 AM
RIVER BASIN:
AMBIENT
QA
l S"1'REAM
EFFLUENT
Received By
11MW
�t�+ Li.flhlP t Yf�vr(IA [�M1t l�er! i iY
REPORT TO
MRO Regional Office 31 du i �U ur, ; ; E]
CHAIN OF CUSTODY
LAKE
INFLUENT
`GOMPbANCE
Other
EMERGENCY
ESTUARY
Data Released :
AR
COLLECTORS) :
LOVE
6
Date Reported :
12/11/98
Estimated BOD Range:
Station Location: CLEVELAND MILLS
Seed:
Chlorinated:
Remarks:
Station 0
Dale Begin (yy/mm/dd)
Dale End (yy/mm/dd)
Time Begin
Time End
1
Depth - DM, DB, DBNI
Valne Type -A,11, L
Composite-T, S,
Sample Type
CREEK
981015
150
0.1
BOD 310 mg/L
COD High 340 mg/L
COD Low 335 mg/L
Coliform: MF Fecal 31616 /loom]
Coliform: MF Total 31504 /100m!
Coliform: tube Fecal 31615 /loom]
Coliform: Fecal Strop 31673 /loom!
Residue: Total 500 mg/L
Volatile 505 me/L
Fired 510 mg/L
Residue: Suspended 530 mg/L
Volatile 535 mg/L
Fixed 540 mg/L
pH 403 units
Acidity to pH 4.5 436 mg/L
Acidity to pH 8.3 435 mg/L
Alkalinity to pH 8.3 415 mg/L
Alkalinity to pH 4.5 410 mg/L
TOC 680 mg/L
Turbiditv 76 NTU
Coliform Total Tube "/100 mis
COMMENTS:
Chloride 940 mg/L
Chi a: Tri 32217 ug/L
Chi a: Corr 32209 ug/L
Pheophytin a 32213 ug/L
Color: True 80 C.U.
Color: (pH) 83 pH= C.U.
Color: pH 7.6 82 C.U.
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total 900 mg/L
Specific Cond. 95 unrhos/cni2
MBAS 38260 mg/L
Phenols 32730 ug/L
Sulfate 945 mg/L
Sulfide 745 mg/L
Boron
Tannin R Lignin ug/L
lle:cavalent Chromium ug/L
NH3 as N 610 mg/L
TKN an N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 70507 mg/L
P: Dissolved as P 666 mg/L
K-Potassium mg/L
Cd- Cadmium 1027 ug/L
Cr-Chromium:Total 1034 ug/L
Cu- Copper 1042 ug/L
Ni-Nickel 1067 ug/L
Pb- Lead 1051 ug/L
Zn- Zinc 1092 ug/L
V-Vanadium ug/L
Ag-Silver 1077 ug/L
AI- Aluminum 1105 ug/L
Be -Beryllium 1012 ug/L
Ca- Calcium 916 mg/L
Co -Cobalt 1037 ug/L
Fe -Iron 1045 ug/L

DIVISION OF ENVIRONMENTAL MANAGEMENT For Lab Use ONLY
WATER QUALITY
FIELD -LAB FORM (DM1)
COUP,jrYr^• G I
%
a ✓�/ a G f
Ub
PRIORITY
SAMPLE TYPE
RIVER BASIN
/✓J
Fy qyl
❑AMBIENT
❑
❑
REPORT TO: ARO FRO
RO RO WaRO WIRO WSRO TS
QA
L.J STREAM
EFFLUENT
AT BM
❑COMPLIANCE
El
❑
❑
Otheerr
Other
CHAIN
LAKE
INFLUENT
OF CUSTODY
Shipped by: Bu Courier Staff, Other EMERGENCY I ❑ESTUARY
3 l._
Lab Number:
!?ate Received:
He by: From: Bus ouri -Hand Del
DATA ENTRY BY: CK:
DATE REPORTED: __--
COLLECTOR(.S): I r O Wes—
Estimated BOD Range: 0-5/5-25/25-65/40-130 or 100 plus STATION LOCATION: I e, ✓Qi/ q vt s' �% t /li -
Seed: Yes ❑ No ❑ Chlorinated: Yes ❑ No ❑ REMARKS:
Station / DagteQBegin (yy/mm/dd) Time Begln Date Endd Ime End Depth D DB DBBMM Value Type Composite Sample '1' pe
~ GIr�Q/ 1 0 I O i�� �S(�O �- I I ©i1 I A— H L T S Il _.—C_ GNX7f
1
BOD5 310 mg/1
2
COD High 340 mg/1
3
COD Low 335 mg/1
4
Collform: MF Fecal 31616 /100m1
5
Collform: MF Total 31504 /100ml
6
Collform: Tube Fecal 31615 /100ml
Collform: Collform: Fecal Strep 31673� /100ml
8
Residue: Total 500 mg/I
9
Volatile 505 mg/1
10
Fixed 510 mg/1
11
Residue: Suspended 530 mg/I
12
Volatile 535 mg/1
13
Fixed 540 mg/I
14
pH 403 units
15
Acidity to pH 4.5 436 rng/I
16
Acidity to pH 8.3 435 mg/1
17
Alkalinity to pH 8.3 415 mg/1
18
Alkalinity to pH 4.5 410 mg/1
19
TOC 680 mg/1
20
Turbidity 76 NTU
Chloride 940 mg/I
Chi a: Tri 32217 ug/I
Chi a: Corr 32209 ug/1
Pheophytin a 32213 ug/1
Color: True 80 Pt -Co
Color:(pH ) 83 ADMI
Color: pli 7.6 82 ADMI
Cyanide 720 mg/1
Fluoride 951 mg/I
Formaldehyde 71880 mg/1
Grease and Oils 556 mg/1
Hardness Tota1900 mg/1
Specific Cond. 95 uMhos/cm2
MBAS 38260 mg/1
Phenols 32730 ug/I
Sulfate 945 rng/1
Sulfide 745 mg/1
NH3 as N 610 — mgA
TKN as N 625 — rng/1
NO2 plus NO3 as N 630 — m9/1
P: Total as P 665 rng/I
1104 as P 70507 — mg/1
P: Dissolved as P 666 rng/I
Cd-Cadmium 1027 ug/I
Cr-Chromlum Total 1034 — ug/l
Cu-Copper 1042 119/1
NI -Nickel 1067 ug/1
Pb-Lead 1051 ug/1/1
Zn-Zinc 1092 ug/1
—
Ag-Silver 1077 ug/I
AI -Aluminum 1105 ug/1
Be -Beryllium 1012 ug/I
Ca-Calclurn 916 mg/1
Co -Cobalt 1037 ug/I
Fe -iron 1045 ' ug/I
LI-Lfthlum 1132 ug/I
Mg -Magnesium 927 mg/1
Mn-Manganese 1055 ug/I
Na-Sodlum 929 mg/1
Arsenic:Total 1002 ug/I
Se -Selenium 11.47 ug/1
Hg-Mercury 71900 ug/1
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Base/ Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'd)
Phytoplankton —
Sampling Point %
Conductance at 25 C
Water Temperature (C)
D.O. mg/1
pFi
Alkalinity
Acidity
Air Temperature (C)
pH 8.3 pH 4.5
pli 4.5 pH 8.3
2
94
10
300 •
400 •
82244 431
82243 182242
20
Salinity %
Preclpitlon QnJday)
Cloud Cover %
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
Wind Velocity M/H
can Stream Depth ft.
_
Stream Width ft.
0
0
2
I
480
45
32
36
1351
1350
35
64
4
DM1/Revlsed 10/86

5ti� 1��1°0 AST.
U4;� 2001 DIVISION OF WATER QUALITY
Chemistry
Laboratory Report / Water Quality
Lab Number
8W7752
COUNTY
"`t� 'i M ETRETT � MN%4l
W❑ SAMPLE TYPE
Date Received :
10/16/99
RIVERBASIN:'°ffli`E:'u-s
CLEVELAND Srl a PRIORITY
tr� ''t sr I AMBIENT
'�,;6d� ❑
❑ Q A
X❑ STREAM
❑ EFFLUENT
Time Received:
Received
9:30 AM
By
HMW
REPORT TO
MRO Regional Office ❑ COMPLIANCE
❑ CHAIN OF CUSTODY
❑ LAKE
❑ INFLUENT
Other
❑ EMERGENCY
❑ ESTUARY
Data Released
AR
COLLECTOR(S)
LOVE
7
Date Reported:
12/11/98
Estimated BOD Range:
Station Location: CLEVELAND MILLS
Seed:
Chlorinnted:
Remarks:
Station k
Date Begin (yyhnm/dd)
Dnle End (yy/mm/dd)
Time Begin
Time End
Depth - DM, DB, DBI11
Value Type -A, II, L
Composite-T, S,
Sample Type
RIVER
981015
1510
0.1
BOD 310 mg/L
COD High 340 mg/L
COD Low 335 mg/L
Coliform: AIF Fecal 31616 /loom[
Coliform: NIF Total 31504 /loom)
Coliform: tube Fecal 31615 /loom[
Coliform: Fecal Strep 31673 /loom[
Residue: Total 500 mg/L
Volatile 505 mg/L
Fixed 510 mg/L
Residue: Suspended 530 mg/L
Volatile 535 mg/L
Fixed 540 mg/L
pH 403 units
Acidity to pH 4.5 436 mg/L
Acidity to pH 8.3 435 mg/L
Alkalinity to pH 8.3 415 mg/L
Alkalinity to pH 4.5 410 mg/L
TOC 680 mg/L
Turbidity 76 NTU
Coliform Total Tube "/100 mis
COMMENTS:
Chloride 940 mg/L
Chl a: Tri 32217 ug/L
Chl a: Corr 32209 ug/L
Pheophytin a 32213 ug/L
Color: True 80 C.U.
Color: (pH ) 83 pH= C.U.
Color: pH 7.6 82 C.U.
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total 900 mg/L
Specific Cond. 95 mnhos/cm2
MBAS 38260 mg/L
Phenols 32730 ug/L
Sulfate 945 mg/L
Sulfide 745 mg/L
Boron
Tannin & Lignin ug/L
Hexavalent Chromium ug/L
NI 13 as N 610 mg/L
TKN an N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 70507 mg/L
P: Dissolved as P 666 mg/L
K-Potassium mg/L
Cd- Cadmium 1027 ug/L
Cr-Chromium:Total 1034 ug/L
Cut- Copper1042 ug/L
Ni-Nickel 1067 ug/L
Pb- Lead 1051 ug/L
Zn- Zinc 1092 ug/L
IV -Vanadium ug/L
Ag- Silver 1077 ug/L
AI -Aluminum 1105 ug/L
Be- Beryllium 1012 ug/L
Ca- Calcium 916 mg/L
Co- Cobalt 1037 ug/L
Fe- Iron 1045 ug/L

DIVISION OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
r-
/f
C '!JNV' <' '�- ✓ ` Cr h PRIORITY SAMPLE TYPE
RIVER BASIN ✓ o A
REPORT TO: ARO FR MRO ORO WaRO WIRO WSRO TS ❑AMBIENT ❑ QA IT -STREAM ❑ EFFLUENT
AT BM ❑ COMPLIANCE ❑ CHAIN 1 ❑ LAKE ❑ INFLUENT
Other OF CUSTODY
Shipped by: Bus ourie tatf, Other ❑EMERGENCY ❑ESTUARY
R 5 • `J � l.� t,t.e�"
Fnr lah II.. f1N1.V
Lab Number:
Date Received: 7ime: 0930
Rec'd by:
i
- From: Bus ourier Hand Del
DATA ENTRY BY: CK:
DATE REPORTED:
Estimated BOD Range: 0-5/5-25/25-65/40-130 or 100 plus STATION LOCATION: C l ,e- V—
Seed: Yes ❑ No ❑ Chlorinated: Yes ❑ No ❑ REMARKS:
Station1 -Tate Begin ( /mm/dd) Time Begin Date End
1 BOD5 310 mg/1
2
COD High 340 mg/1
3
COD Low 335 mg/I
4
Coliform: MF Fecal 31616 /loom,
5
Coliform: MF Total 31504 /100ml
6
Coliform: Tube Fecal 31615 `/100ml
7
Collform: Fecal Strep 31673- /100ml
8
Residue: Total 500----- --- --' mg/1
9
Volatile 505 /1 mg
10
Fixed 510 m9/1
11
Residue: Suspended 530 mg/I
12
Volatile 535 mg/I
13
Fixed 540 mg/1
14
pH 403 units
15
Acidity to pit 4.5 436 mg/1
16
Acidity to pit 8.3 435 mg/I
-17
Alkalinity to pH 8.3 415 mg/I
18
Alkalinity to pH 4.5 410 mg/1
19
TOC 6B0 mg/1
20
Turbidity 76 NTU
Time End Depth I_F DB DBM Value Type
O f I A H L
Chloride 940 mg/1
Chi a: TO 32217 ug/1
Chi a: Corr 32209 ug/1
Pheophytin a 32213 ug/I
Color: True 80 Pt -Co
Color:(pH ) 83 ADM]
Color: pit 7.6 82 ADMI
Cyanide 720 - mg/l
Fluoride 951 mg/l
Formaldehyde 71880 mg/1
Grease and Oils 556 mg/I
Hardness Total900 mg/l
Specific Cond. 95 uMhos/em2
MBAS 38260 mg/l
Phenols 32730 ug/l
Sulfate 945 mg/1
Sulfide 745 Ing/I
NH3 as N 610 mg/1
TKN as N 625 mg/1
NO2 plus NO3 as N 630
P: Total as P 665 t119/1
I104 as P 70507 mg/1
11: Dissolved as P 666 tng/1
Cd-Cadmltna 1027-- --ug/l
Cr-Chromlum-Total 1034 — ugA
Cu-Copper 1042 1-9/1
NI -Nickel 1067 ug/i
Pb-Lead 1051 ug/I
Zn-Zinc 1092 ug/1
Ag-Silver 1077 ug/l
AI -Aluminum 1105 ug/1
Be -Beryllium 1012 ug/1
Ca -Calcium 916 mg/I
Co -Cobalt 1037 ug/I
Fe -Iron 1045 ug/i
Composite
T S 11
Sample "
C' G GNXX
- __j
Li-Lithlum 1132 ug/l
Pig -Magnesium 927 mg/I
Mn-Manganese 1055 ug/I
Na-Sodium 929 mg/1
Arsenic -Total 1002 ug/I
Se -Selenium 1147 ug/l
1lg-Mercury 71900 - ug/l
Organochlor,ne Pesticides
Organophosphorus Pesticides
Acid Herbicides -
Base/ Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'd)
Phytoplankton
Sampling Point %
Conductance at 25 C
Water Temperature (C)
D.O. mg/,
pH
Alkalinity
Acidity
Air Temperature (C)
fL
pH 8.3 pit 4.5
pit 4.5 pH 8.3
2
94
10
300 1.
400 •
82244 1 431
82243 182242
20 _
Salinity %
Preclpition On/day)
Cloud Cover %
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
Wind Velocity M/H
4ean Stream Depth it.
Stream Width ft.
I
480
45
32
36
1351
1350
35
64
4
DM1/Revtsed 10/R6

1 \ Tv
\ Vie% f ll DIVISION OF WATER QUALITY
Chemistry Laboratory Report / Witter Quality
COUNTY CLEVELAND � r is f i,ij�PRIORITY
RIVER BASIN: AMBIENT QA
REPORTTO MRO Regional Office COMPLIANCE CHAIN OF CUSTODY
Other EMERGENCY
COLLECTOR(S) LOVE
W❑ SAMPLE TYPE
XO STREAM EFFLUENT
❑ LAKE XD INFLUENT
ESTUARY ❑
T
Lab Number :
8W7208
Date Received:
9/24/98
Time Received:
9:10 AM
Received By
HMW
Data Released
AR
Date Reported :
11/20/98
Estimated BOD Range: Station Location: CLEVELAND MILLS
Seed: Chlorinated: Remarks:
Station 9 Date Begin (yy/mm/dd) Date End (yy/mm/dd) Time Begin Time End I Depth - DM, DB, DBDI Value Type - A, II, L Composite-T, S, Sample Type
CREEK 980923 - - 1535 0.1
BOD 310 mglL
COD High 340 mg/L
COD Low 335 mg/L
Coliform: MF Fecal 31616 /100.1
Coliform: MF Total 31504 /100ml
Coliform: tube Fecal 31615 /looml
Coliform: Fecal Strep 31673 /loom]
Residue: Total 500 mg/L
Volatile 505 mL/L
Fixed 510 mg/L
Residue: Suspended 530 mg/L
Volatile 535 mg/L
Fixed 540 meil-
pH 403 units
Acidity to pH 4.5 436 mg/L -
Acidity to pH 8.3 435 mg/L
Alkalinity to pH 8.3 415 mg/L
Alkalinity to pH 4.5 410 mg/L
TOC 680 mg/L
Turbidity 76 NTU
Coliform Total Tube "/100 mIs
COMMENTS:
Chloride 940 mg/L
Chl a: Tri 32217 ug/L
Chl a: Corr 32209 ug/L
Pheophytin a 32213 ug/L
Color: True 80 C.U.
Color: (pH ) 83 pH= C.U.
Color: pH 7.6 82 C.U.
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total900 mg/L
Specific Cond. 95 unrhos/cm2
MBAS 38260 mg/L
Phenols 32730 ug/L
Sulfate 945 mg/L
Sulfide 745 mg/L
Boron
l'annin R Lignin ug/L
Hexayalent Chromium ug/L
NF13 as N 610 mg/L
TKN an N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 70507 mg/L
P: Dissolved as P 666 mg/L
K-Potassium mg/L
Cd- Cadmium 1027 ug/L
Cr-Chromium:Total 1034 ug/L
Cu- Copper1042 ug/L
Ni-Nickel 1067 ug/L
Pb- Lead 1051 ug/L
Zn- Zinc 1092 ug/L
V-Vanadium ug/L
Ag- Silver 1077 ug/L
AI- Aluminum 1105 ug/L
Be- Beryllium 1012 ug/L
Ca- Calcium 916 mg/L
Co -Cobalt 1037 ug/L
Fe- It 1045 ug/L

DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY FIELD -LAB FORM (DM1).:
%
COUNTY` vl
PRIORITY
SAMPLE TYPE
RIVER BASIN V' o
❑AMBIENT
❑ QA
STREAM
❑ EFFLUENT
REPORT TO: ARO FR MRO RO WaRO WIRO WSRO TS
AT BM
❑COMPLIANCE
❑ CHAIN
❑ LAKE
INFLUENT
Other
❑EMERGENCY
OF CUSTODY
Shipped by: Bus Staff, Other
ourier
ESTUARY
For Lab Use ONLYj
Lab Number: :LY29nd �j
Dale Received: _ Time: DVIAO
Rec'd by: � From: Bus ouri Hand Del
DATA ENTRY BY: . CK:
UA7=E REPORTED: --
COLLECTOR(.S): �3 , L O ✓Q/
STATION LOCATION: C_ I 4p— V 191I ot (
Estimated BOD Range: 0-5/5-25/25-65/40-130 or 100 plus --
Seed: Yes ❑ No ❑ Chlorinated: Yes ❑ No ❑ REMARKS:
Station Date Begin (yy/ram/dd) Time Begin Date End Tyne End Depth t h)B DBM Value 7'ylrc Composite Sanrl�ir; 'Type
G �� 9 g O cl �3 ) 535 A H L T— S— 13 C G GNXX
1
BOD5 310 mg/1
2
COD High 340 mg/I
3
COD Low 335 mg/I
4
Coliform: MF Fecal 31616 r /100In
5
Coliform: Ml- Total 31504 /100ml
G
Coliform: Tube Fecal 31615 /100ml
7
Coliform: Fecal Strep 31673� /100ml
8
Residue: Total 500 mg/1
9
Volatile 505 mg/1
10
Fixed 510 mg/1
11
Residue: Suspended 530 mg/1
2
—Volatile 535 mg/1
13
Fixed 540 mg/1
14
pH 403 units
15
Acidity to pH 4.5 436 mg/1
16
Acidity to pH 8.3 435 mg/I
�17
Alkalinity to pH 8.3 415 mg/I
18
Alkalinity to pH 4.5 410 mg/I
19
TOC 680 mg/I
20
Turbidity 76 NTU
Chloride 940 mg/I
Chi a: Tri 32217 ug/I
Chi a: Corr 32209 ug/I
Pheophytin a 32213 ug/I
Color: True 80 ' Pt -Co
Color -.(pH ) 83 ADMI-
Color: pit 7.6 82 ADMI
Cyanide 720 _ mg/1
Fluoride 951 -- mg/1
Formaldehyde 71880 mg/1
Grease and Oils 556 mg/1
Hardness Total900 mg/I
Specific Cond. 95 uMhos/cm2
MBAS 38260 mg/I
Phenols 32730 119/1
Sulfate 945 rngA
Sulfide 745 mg/I
N113 as N 610 1119/1
TKN as N 625
NO2 plus NO3 as N 630 mg/I
P. Total as P 665 rng/I
+mg/I
1104 as P 70507
Ymg/1
P: Dissolved as P 666
Cd-Cadrnium 1027 ug/1
cr{:hrointumaotal1034 ugA
Cu-Copper 1042 ug/I
NI-Nichel 1067 ug/I
Pb-Lead 1051 _ ug/I/I
Z11-7111c 1092 ug/I
A_11l er 1077 ug/I
AI -Aluminum 1105 ug/1
Be -Beryllium 1012---ug/I
Ca -Calcium 916 mg/I
Co -Cobalt 1037 19/1
Fc•Iron 1045 ug/1
LI-Lithlum 1132 ug/I
Mg-Magneslum 927 mg/1
Mn-Manganese 1055 ug/I
Na-Sodium 929 mg/I
Arsenlc:Total 1002 ug/I
Se -Selenium 11.47 ug/I
g-Mercury 71900 ug/1
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Base/ Neutral Extractable Organics _
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'(1)
Phytoplanklon
Sampling Point %
Conductance at 25 C
Water Temperature (C)
D.O. mgA
pH
Alkalinity
Acidity
Air Temperature (C)
::
pH 8.3 pit 4.5
pit 4.5 pH 8.3
2
94
10
300 •
400 •
82244 431
82243 182242
20
Salinity %
Precipition On/day)
Cloud Cover %
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
Wind Velocity M/H
can Stream Depth ft.
Stream Width ft.
O
�
I
480
45
32
36
1351
1350
35
64
4
riuo..t�.t tnia�

a
1�
�..r� DIVISION OF \VA"I'GR QUALITY
g Chemistry Laboratory Report / Water Quality
COUNTY CLEVELAND _ PRIORITY
_ RIVER BASIN: ' A$ 7.5 201E ANIBIENT E] QA
REPORT TO MRO Regional Office PP;�y0:r��kkllryqCEOMPLIANCE � CIiAIN OF CUSTODY
6"C Lu111�k[!e�k ��}Y�k� i.3F86:i417�;d ��.
Olhcrg{y1,35tnFi�vMERGENCY
COLLECTOR(S) : LOVE fE�°ttffetiii''■■ii�S_IIFFJJ.aa P?
W❑ SAMPLE TYPE
STREAM EFFLUENT
El LAKE E INFLUENT
❑ ESTUARY
6
Lab Number
8W7207
Date Received :
9/24/98
Time Received :
9:10 AM
Received By
HNIW
Data Released
AR
Date Reported :
11/20/98
Es(inrnled DOD Range: Station Location: CLEVELAND MILLS
Seed: Chlorinated: Remarks:
--J
Station H Date Begin (yy/mm/dd) Dale End (yy/nrnr/dd) Time Begin Time End Depth - DM, DD, DBAI F
Type- A,11, L Composite-T, S, Sample Type
RIVER 980923 1530 0.1
IIOD 310
('OI) I ligh 340
COD Low 335 mg/I,
Coliform: MF Fecal 31616 /loom]
Coliform: MF Total 31504 /loom]
Coliform: tube Fecal 31615 /IOOnd
Coliform: Fecal Strep 31673 /loom]
Residue: Total 500 mg/L
Volatile 505 mg/L
Fixed 510 nrg/L
Residue: Suspended 530 mg/L
Volatile 535 mg/L
Fixed 540 ma/L
pH 403 units
Acidity to pH 4.5 436 mgiL
Acidity to pH 8.3 435 mg/L
Alkalinity to pH 8.3 415 mgiL
Alkalinity to pH 4.5 410 mg/L
TOC 680 mg/L
Turbidity 76 NI'U
Coliform Total Tube "/100 mis
COMMENTS:
Chloride 9.10 mg/I,
Chl a.'Iri 32217 ug/l,
Chl a. Corr 32209 ug/l,
Pheophytin a 32213 ug/L
Color: True 80 C.U.
Color: (pl1) 83 pl l= C.L.I.
Color: pli 7.6 82 C.U.
Cyanide 720 mg/L
Fluoride 951 mg/L
Formaldehyde 71880 mg/L
Grease and Oils 556 mg/L
Hardness Total900 nrg/L
Specific Cond. 95 unnhos/cm2
MBAS 38260 mg/L
Phenols 32730 ug/L
Sulfate 945 mg/L
Sulfide 745 mg/L
Boron
Tannin & Lignin ug/L
I lexnvalcm Chromium ug/L
NI13 ns N 610 nrg/L
TKN an N 625 mg/L
NO2 plus NO3 as N 630 mg/L
P: Total as P 665 mg/L
PO4 as P 70507 mg/L
P: Dissolved as P 666 mg/L
K-Potassium mg/L
Cd- Cadmium 1027 ug/L
Cr-Chromium:Total 1034 ug/L
Cu- Copper 1042 ug/L
Ni-Nickel 1067 ug/L
Pb- Lead 1051 ug/L
Zn- Zinc 1092 ug/L
V-Vanadium ug/L
Ag- Silver 1077 ug/L
Al- Aluminum 1105 ug/L
Be- Beryllium 1012 ug/L
Ca- Calcium 916 mg/L
Co -Cobalt 1037 ug/L
Fc- Iron 1045 ug/L
Li -Lithium 1132 ug/L
Mg- Magnesium 927 mgFL
Mn-Manganese 1055 ug/L
Na- Sodium 929 mg/L
Arsenic:Total 1002 ug/L
Se- Selenium 1 147 ug/L
X
Hg- Mercury 7190 <0.2 ug/L
Ba Barium ug/L
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Base/Neutral&Acid Extractable Organics
TPH Diesel Range
Purgeable Organics (VOA bottle req'd)
TPH Gasoline Range
TPII/BTEX Gasoline Range
Phytoplankton

c.,. 1 .1, IT.. ntJt v
DIVISION.OF ENVIRONMENTAL MANAGEMENT WATER QUALITY FIELD -LAB FORM (DM1)
i l
COUNTY G�J�� p/ r /^� PRIORITY SAMPLE TYPE b
RIVER BASIN £7,0 C1 ❑AMBIENT 0 p6 STREAM EFFLUENT
❑ ❑
REPORT TO: ARO FRO RO!RRO WaRO W1R0 WSRO TS
AT BM ❑COMPLIANCE ❑ CHAIN ❑ LAKE INFLUENT
Other OF CUSTODY
Shipped by: Bu Cnurler1 Staff, Other
❑EMERGENCY ❑ESTUARY
COLLECTOR(S): � / L� )
Estimated BOD Range: 0 5/5 25/25 65/40-130 or 100 plus STATION LOCATION: G�e-��/ol rto� i Is
Seed: Yes ❑ No ❑ Chlorinated: Yes ❑ No ❑ REMARKS: _
Station # Date Begin (yy/mm/dd) Time Begin Date End
V,_ 1, 9 8 v C J5 )0
1
BOD5 310 rng/I
COD High 340 mg/I
2
3
COD Low 335 mg/I
Coliform: MF Fecal 31616 /100ml
4
5
Coliiorm: MF Total 31504 J /100m1
6
Coliform: Tube Fecal 31615 /100ml
_
Coliform: Fecal Strep 31673 /100ml
7
8
Residue: Total 500 -- mg/1
9
Volatile 505 mg/1
10
Fixed 510 mg/I
11
Residue: Suspended 530 m9/1
^ 12
---Volatile 535 --_--_ rOg/1
—
13
Fixed 540 mg/I
14
pH 403 units
15
Acidity to pii 4.5 436 mg/I
16
Acidity to pli 8.3 435 mg/1
17
Alkalinity to pH 8.3 415 rug/I
18
Alkalinity to pH 4.5 410 mg/I
19
TOC 680 mg/I
Turbidity 76 NTU
201
Lab Number:/ 1J
Date Recelved: D Tinte: V D
Rec'd by: , .From: Bus ourier and Del
DATA ENTRY BY: (:IC:v
DATE REPORTED: _--
Time EndjDepth0ZLfbB DBM Value Tylre
U I - A -_H 1,
Chloride 940 mg/1
Chi a: Tri 32217 ug/I
Chi a: Corr 32209 ug/I
Pheophytin a 32213 ug/I
Color: True 80 Pt -Co
Color:(pH ) 83 ADMI-
Color: pli 7.6 82 ADMI
Cyanide 720 mg/1
Fluoride 951 mg/I
Formaldehyde 71880 tng/I+
Grease and Oils 556 mg/I
Ilardness Total 900 mg/I --
Specific Cond. 95 uMhos/cm2
MBAS 38260 mg/1
Phenols 32730 ug/1
Sulfate 945 mg/l
Sulfide 745 mg/I
N113 as N 610 mg/I
_ �mg/I
TKN as N 625
NO2 plus NO3 as N 630 tng/1
P: Total as P 665 Iug/I
—mg/I/I__
1104 as 1' 70507 —
—mg/l
P: Dissolved as 1' 666
Cd•Cadutlum 1027 ug/1
Cr-Chrontlum-Total1034 ugA
Cu-hopper 1042 ug/I
NI -Nickel 1067 ug/I
Pb-Leud 1051'— — u9%1
�ug/1
Zn-Zinc 1092
iug/l
Ag-Sliver 1077�
Al -Aluminum 1105 ug/I
Be -Beryllium 1012 ug/l
Ca -Calcium 916 mg/I
Co -Cobalt 1037 ug/I
Fe -iron 1045 ug/l
Composite Sample T e
T S 11 _ C= G GNXX A
Li-Lilhlum 1132 ug/l
Mg -Magnesium 927 mg/l
Mn-Manganese 1055 ug/l
Na-Sodlum 929 mg/l
Arsenic:Total 1002 ug/i
Se-Selenlum 11.47 ug/1
Hg-Mercury 71900 ug/l
Organochlorine Pesticides
Organophosphorus Pesticides
Acid Herbicides
Base/ Neutral Extractable Organics
Acid Extractable Organics
Purgeable Organics (VOA bottle reg'd)
Phytoplankton
Sampling Point %
Conductance at 25 C
Water Temperature (C)
D.O. mgA
pH
`Alkalinity
pH 8.3 pH 4.5
Acidity
pH 4.5 pH 8.3
Air Temperature (C)
2
94
10
300 1.
400 •
82244 431—
82243_ 182242
20
Salinity %
Precipitlon an/day)
Cloud Cover %
Wind Direction (Deg)
Stream Flow Severity
Turbidity Severity
Wind Velocity M/H
can Stream Depth it.
Stream Width ft.
480
45
32
36
1351
1350 I
35
64
4
nm1 In—i—A in/nf,

r 1 h
Cleveland Mlbs
QUALITY KNITS • ESTABLISHED 1873
February 8, 1999
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor
DEHNR
Mooresville Regional Office
919 North Main St.
Mooresville, NC 28115
Re: Cleveland Mills NPDES Permit No. NC0004120
Split Sampling/Mercury Violations
Dear Mr. Gleason:
N.C. DFPT. OF
BNV IR.f',` z NT, HEALTH ,
& NATI)ITRAL, F€rSOURCFS
FEB 1 0 1999
IM WT 6)4-':L'xaul K'gAwUAflil
BMW RE
This letter is to inform you of the test results of the split sampling for mercury that was done by the Division
of Water Quality Laboratory, Piedmont Labs, Inc., and Burlington Research, Inc.
On 9-23-98 Barry Love and myself collected a sample from the First Broad River and London Creek. The
sample was split among the above mentioned labs. As you know, the Division of Water Quality Lab
returned a result of <0.2 ug/l for both streams as did Burlington Research. Piedmont Labs returned a result
of 0.6 ug/1 for the river and 2.6 ug/1 for the creek. On 10-15-98 the split sampling was performed again with
the Division of Water Quality Lab and Piedmont Labs doing the testing. The Division of Water Quality
Lab returned a result of <0.2 ug/l for both streams and Piedmont Labs returned a result for the river of <0.2
ug/l and 0.2 ug/l for the creek. I have enclosed the data sheets from Piedmont Labs and Burlington
Research.
From 6-15-98 to 10-31-98 nine effluent samples were split between Piedmont Labs and Burlington
Research. During that period we reported three violations for mercury based on results from Piedmont
Labs. If we had used the results from Burlington Research we would not have had any violations. The
results from Piedmont -Labs and Burlington Research matched four times and all of those were below
detectable limits. We have switched all of our testing to Burlington Research for 1999.
If you have any questions, please contact me.
Sincerely,
Timothy B. Bro s
Environmental & Utilities Manager/ORC
101 WEST MAIN STREET • POST OFFICE BOX 68 • LAWNDALE, NORTH CAROLINA 28090-0068
PHONE [phone] • PHONE [phone] . FAX [phone]

r�
Piedmont Laboratory, Inc.
70� N. Morgan Street
h •r �" iPOpB6x.2548
she by, North Carolina 28150
* � u a � ^Clv � v�d lvlllliS
t01We8t.Main Street
Box 68
,y Lawndale, North Carolina 28090
At%ri: Tim Brooks
z8a:nple.ID it Cleveland Mill Project (Mercury)
Collected. 09/23/98-10/14/98
yP
y Time couecttd
Recelvtd Date : 09125198-10114/99
x Time Received
,Sample Matrix Water
ry
Analytical Report
October 26,1998
Report Quan Dil
CM CREEK 10121
<.0002
mg/I
.0002
.0002
CM PRO WAT 10/14
<.0002
mg/I
.0002
.0002
CM CREEK 9/25/98
<.0002
mg/I
.0002
.0002
CM PRO WAT 10112
<.0002
mg/I
.0002
.0002
CM EFF NR 10/12
C0002
m9/1
..0002
0002
CM CREEK 9%28i9B
<.0002
mgii
.0002
.0002
CM RIVER 9/25/98
<.0002
mg/I
.0002
.0002
CM PRO WAT 9/28/98
<.0002
mg/I
.0002
.0002
CM PRO WAT 9/25198
<.0002
mg/I
.0002
.0002
CM RIVER 10/14/98
<.0002
mg/I
.0002
.0002
PO # 6068006779
TA8
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
i .0
i Oi20i98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
1.0
10/20/98
FBL
EPA245.1
Respectfully Submitted
^n
Annette McMurray
Piedmont Laboratorie
I I r
SC 999041

Piedmont Laboratory, Inc.
702 N. Morgan Street
PO Box 2548
Shelby, North Carolina 28150
Cleveland Mills
101West Main Street
PO Box 68
Lawndale, North Carolina 28090
Atten: Tim Brooks
Sample ID m Mercury Special project
Date Collected : 10/15/98 10/21/98
Time Collected:
Received Date: 10/15/98 10/15/98
Time Received:
Sample Matrix: Water
Analysis: All Sample were analyzed for Mercury
Sample ID
CLV 10/19/98 CREEK
CLV 10/16/98 RIVER
CLV 10/21/98 PRO WATER
CLV 10/16/98 PRO WATER
CLV 10/21/98 CREEK
CLV 10/16/98 CREEK
CLV 10/19/98 PRO WATER
Result Units
.0011 mg/1
<.0002 mg/1
.0010 mg/1
.0002 mg/1
.0007 mg/1
<.0002 mg/1
.0002 ma/I
Analytical Report
November 8,1998
Quan
Limit
.0002
.0002
.0002
.0002
.0002
.0002
Test
Date
10/28/98
10/28/98
10/28/98
10/28/98
10/28/98
10/28/98
Analyst
FBL
FBL
FBL
FBL
FBL
FBL
FBL
Method
EPA 245.1
EPA 245.1
EPA 245.1
EPA 245.1
EPA 245.1
EPA 245.1
EPA 245.1
CLV 101598 NR <.0002 mg/1 .0002 10/28/98 FBL EPA 245.1
CLV 101998 NR <.0002 mg/1 .0002 10/28/98 FBL EPA 245.1
Respectfully Submitted
JV l
Annette McMurray
Piedmont Laboratories, nc
NC#307
SC #99041

. OCT 26 '98 03:56PM BURLINGTON RESEARCH
P.10/13
Aquatic bioassay Testing • Aquatic Toxicity Reduction Evaluations
chemical Product Environmental Assessments • NPDES Testing
[E311 Reporting & Data Handling Services
BURLINGTON 1302 Belmont Street • Burlington, NC 27215-6935 - Phone [phone] • Fax [phone]
RESEARCH
ANALYTICAL REPORT
CUSTOMER: Cleveland Mills Company
REPORT TO: Mr. Tim Brooks
SAMPLE DESQ SPECIAL STUDY
SAMPLE TYPE: WASTEWATER, GRAB
COLLECTED: 091-231 QO Od SITE:.R7N K
WORK ORDER #:
8J322-009
RECEIVED:
10/13/98
REPORTED:
10/26/98
PO NUMBER: Verbal: Tim Brooks
PARAMETER
DATE/TIME/ANALYST
MOL
RESULT
1NA^rrnrty Tnt91 by 17TAC
StArtAd 10/15/98 12:50
0.0002
Core 1 ..rmg2
EPA 245.1 r Analyzed 10/16/98 by SIH at BRI - Burlington
MQL = Minimum Quantitation Limit
Water Environmental Services - Eden
Division of Burlington Research. Inc.
370 W. Meadow Road Eden, NC 27288
Phone [phone] Fax [phone]
Page 9 Water Environmental Services - Kinston
Division of Burlington Research, Inc.
100 E. Gordon Street - Kinston, NC 28501
Phone [phone] * Fax [phone]
BM a19a

OCT 26 '98 03:56PM BURLINGTON RESEARCH
P.11/13
Aquatic Bioassay Testing @ Aquatic Toxicity Reduction Evaluations
Chemical Product Environmental Assessments + NPDES Testing
[oil Reporting & Data Handling Services
BURLINGTON 1302 Belmont Street • Burlington, NC 27215-6935 - Phone [phone] - Fax [phone]
RESEARCH
ANALYTICAL REPORT
CUSTOMER: Cleveland Mills Company WORK ORDER #: 8J322r010
REPORT TO: Mr. Tim Brooks RECEIVED: 10/13/98
REPORTED: 10/26/98
SAMPLE DESC: SPECIAL STUDY
SAMPLE TYPE: WASTEWATER, GRAB PO NUMBER: Verbal: Tim Brooks
COLLECTED: 49!/3l9800 SITE; ;"reek
PARAMETER DATE/TIME/ANALYST MQL RESULT
Mercury, Total by HAS Started 10/15/98 12:50 0.0002 10-0002 1g/,
BPA 245.1 Analyzed 10/16/98 by SJH at BRI - Burlington
MQL = Minimum Quantitation Limit
Water Environmental Services - Eden Page 10 Water Environmental Services - Kinston
Division of 6ufngton Research, Inc. Division of Burlington Research, Inc.
370 W. Meadow Road Eden, NC 27288 100 E. Gordon Street • Kinston, NC 28501
Phone [phone] Fax [phone] Phone [phone] • Fax [phone]
eR 13M

..j
Cleveland Milk
QUALITY KNITS • ESTABLISHED 1873
.�M
January 28, 1999
Mr. D. Rex Gleason, P.E.
Water Quality Regional Supervisor
DEHNR
Mooresville Regional Office
919 North Main St.
Mooresville, NC 28115
Re: Cleveland Mills NPDES Permit No. NC0004120
Dear Mr. Gleason:
This letter is to inform you of an unintentional discharge of return activated sludge down
a storm drain at our wastewater treatment plant. At approximately 1:45 PM on January
27, 1999 a drain on our sludge thickener stopped up which caused the thickener to
overflow. The containment area for the thickener also overflowed resulting in the
discharge down the storm drain. Based on the size and length of the storm drain and the
fact that very little sludge made it immediately to the end of storm drain it was estimated
that 300 gallons of RAS was lost. The storm drain terminates in the First Broad River.
At 2:33 PM on January 27, 1999 I contacted Mr. Roberto Scheller at the Mooresville
Regional Office and notified him of the unintentional discharge.
Operational changes will help to insure that this situation does not occur again.
If you have any questions, please contact me.
Sincerely,
Timothy B. Broo s
Environmental & Utilities Manager/ORC
101 WEST MAIN STREET • POST OFFICE BOX 68 • LAWN DALE, NORTH CAROL INA 28090-0068
PHONE [phone] . PHONE [phone] • FAX [phone]

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 18, 1993
MEMORANDUM TO: Brenda J. Smith
FROM: D. Rex GleasonV
PREPARED BY: M. Joseph Crabb, Jr.my--­'
SUBJECT: Tax Certification
Wastewater Treatment Facilities
Cleveland Mills Company, Inc.
Cleveland County, North Carolina
This Office has conducted an on -site investigation confirming
the construction and operation of wastewater treatment facilities
at Cleveland Mills Company, Inc., Cleveland County, North Carolina.
The facilities are operating -under a valid Permit No. NC0004120.
Therefore, the attached Tax Certification has been prepared for
your signature.
If you have any questions or require additional information,
please contact either Joe or me.
Attachment
MJC

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office `
James 8. Hunt, Jr., Governor Jonathan B. Hones, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 18, 1993
Mr. Jim Hedrick
Tax Assessor
Cleveland County
Shelby, North Carolina 28151
Subject: Tax Certification
Wastewater Treatment
Facilities
Cleveland Mills Co. Inc.
Cleveland County, NC
Dear Hedrick:
Transmitted herewith is Tax Certification No. TCS-436 covering
wastewater treatment facilities at Cleveland Mills Company, Inc.
located at 101 West Main Street, Lawndale, North Carolina, as
described in plans on file with the Division of Environmental
Management, and operated under Permit Number NC0004120.
By letter dated May 7, 1993 (copy attached), Mr. Timothy B.
Brooks, Cleveland Mills Environmental Technician, requested tax
certification for the following items: an analytical balance,
composite sampler, electronic flow indicator, communications
network computer (CNC), personal computer and printer which is
linked to the CNC. An inspection of this equipment indicated that
the flow indicator, pc/printer, and the communications network
computer are used exclusively for waste disposal or to abate,
reduce or prevent the pollution of water in accordance with North
Carolina General Statute 105-275.(8)(a).
-
P.O. Box 950, 919 North Main Sum Mooresville, N.C. 28115-0950 • Telephone 704-M3.1699 • FAX [phone]
An Equal Opportunity AHinrnative Action Emplom

. a
1 Page Two {
Cleveland County Tax Assessor
The Company may use this Certification to obtain tax benefits
in keeping with the appropriate Statutes.
Sincerely,
0 4�A jh
enda J. Smit , J. G.
Regional Supervisor
Attachment
MJC

I
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH
TAX CERTIFICATION
(Franchise/privilege; Amortization; Property)
In accordance with the provisions of the General Statutes of North
Carolina (G. S. 105-122(d), 105-130.10, 105-147(13), 105-275(8)),
this is to certify that:
Cleveland Mills Company, Inc
Cleveland County
HAS BEEN ISSUED
Permit No. NC0004120 for the operation of a 0.78 MGD wastewater
treatment facility consisting of an influent catch basin with rough
screening, flow equalization basin, variable speed lift station,
flow metering device, aeration basin, mixer/flocculator flow
splitter box, three (3) secondary clarifiers, gas chlorination
unit, chlorine contact tank, continuous recording effluent flow
measuring device, discharge diffuser, a sludge plate and frame
dewatering system, all necessary pumps, valves, and appurtenances.
The Environmental Management Commission and the Department of
Environment, Health, and Natural Resources have found that the
treatment facilities:
a. Have been constructed or installed;
b. Comply with the requirements of the Commission;
C. Are being effectively operated in accordance with the
terms and conditions of the Permit, Certification of
Approval, or other document or approval issued by the
Commission; and
d. Have as their primary rather than incidental purpose the
reduction of water pollution resulting from the discharge
of wastewater.
J

Issued at Raleigh, North Carolina this the 18th day of May, 1993 by
the Directive of the North Carolina Environmental Management
Commission and the North Carolina Department of Environment, Health
and Natural Resources.
ends J. Smith, P.G.
Regional Supervisor
Mooresville Regional office
TCS-436
T

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office.
James B. Hunt, Jr., Governor
Mr. Timothy B. Brooks
Cleveland Mills Company,
101 West Main Street
Lawndale, North Carolina
Dear Mr. Brooks:
Jonathan B. Bowes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 18, 1993
Inc.
W101111
Subject: Tax Certification
Wastewater Treatment
Facility
Cleveland Mills Company, Inc.
NPDES Permit No. NC 0004120
Cleveland County, NC
Attached are two (2) copies of Tax Certification No. TCS-436
covering the operation of wastewater treatment facilities at the
subject facility.
In your letter dated May 7, 1993, you requested tax
certification for the following items: an analytical balance,
composite sampler, electronic flow indicator, communications
network computer (CNC), personal computer and printer which is
linked to the CNC. An inspection of this equipment indicated that
the flow indicator, pc/printer, and the communications network
computer are used exclusively for waste disposal or to abate,
reduce or prevent the pollution of water in accordance'with North
Carolina General Statute 105-275.(8)(a).
The Company may use this Certification to obtain tax benefits
in keeping with the appropriate Statutes.
Attachment
MJC
Sincerely,
Brenda J. Smit P. G.
Regional Supervisor
P.O. Banc 950, 919 North Main Sum Mooresville, N.C. 28115-0950 • Telephone [phone] * FAX 704-663-"
An Equal Opportunity Affirmative Action Emp6m

e .0
N
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH
TAX CERTIFICATION
(Franchise/privilege; Amortization; Property)
In accordance with the provisions of the General Statutes of North
Carolina (G. S. 105-122(d), 105-130.10; 105-147(13), 105-275(8)),
this is to.certify that:
Cleveland Mills Company, Inc
Cleveland County
HAS BEEN ISSUED
Permit No. NC0004120 for the operation of a 0.78 MGD wastewater
treatment facility consisting of an influent catch basin with rough
screening, flow equalization basin, variable speed lift station,
flow metering device, aeration basin, mixer/flocculator flow
splitter box, three (3) secondary clarifiers, gas chlorination
unit, chlorine contact tank, continuous recording effluent flow
measuring device, discharge diffuser, a sludge plate and frame
dewatering system, all necessary pumps, valves, and appurtenances.
The Environmental Management Commission and the Department of
Environment, Health, and Natural Resources have found that the
treatment facilities:
a. Have been constructed or installed;
b. Comply with the requirements of the Commission;
C. Are being effectively operated in accordance with the
terms and conditions of the Permit, Certification of
Approval, or other document or approval issued by the
Commission; and
d. Have as their primary rather than incidental purpose the
reduction of water pollution resulting from the discharge
of wastewater.

4 �
Issued at Raleigh, North Carolina this the 18th day of May, 1993 by
the Directive of the North ' Carolina Environmental Management
Commission and the North Carolina Department of Environment, Health
and Natural Resources. -
/I
tY-e-nda J. Smith, P.G.
Regional Supervisor
Mooresville Regional Office
TCS-436

ClevelandWk
QUALITY KNITS • ESTABLISHED 1873
ALaDzp:O _
JR
�o
SAY 1 01993
AIVIS27 if.
May 7, 1993
D. Rex Gleason, P. E.
Division of Environmental,Management
919 North Main Street
Post Office Box 950
Mooresville, NBC 28115-0950
RE: Additional Information for Tax Certification
Dear Mr. Gleason:
Carolina Financial Group, Inc. made several errors on the
Schedule of Waste Treatment Equipment that was sent to your
office. Please remove the following equipment from
consideration because they are not part of the waste
treatment system: three(3) Dye Machines and Equipment,
Uster Slub Catcher, Wire Uster Controls, Card -Waste,
Discharge Regulator"Waste.
The analytical balance is used in the Waste Water Lab for
solids determination as required by our NPDES permit. The
Isco sampler is for composite sampling of the effluent. The
electronic flow indicator is an ultrasonic unit that measures
and records the effluent flow for the Waste Water Treatment
Plant.
The personal computer and printer are used for the storage,
manipulation, and output for all of the Waste Water Treatment
Plant's data. The monthly DMR and UPSTREAM%DOWNSTREAM REPORT
are generated and printed using this system. The- personal
computer and the computer/waste treatment are linked together
and are used to control, schedule, and monitor all pumps and
areators at the Waste Water Treatment Plant. The personal
computer and the computer/waste treatment are linked to a
communications network which allows the pumps, areators and
effluent flow to be monitored at night and on weekends so that
if there is a problem I will be notified.
If you have any questions or need additional information, please
contact me.
Sincerely, �.
Timothy B, gooks
Environmental Technician
LAWNDALE, NORTH CAROLINA 28090 • PHONE [phone] TELEX [phone]

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office
James a. Hunt, Jr., Governor Jonathan D. Eaves, secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 5, 1993
Mr. Timothy B. Brooks
Cleveland Mills Company
101 West Main Street
Lawndale, North Carolina 28090
Subject: Tax Certification
Cleveland Mills Company, Inc.
NPDES Permit No. NC 0004120
Cleveland County, NC
Dear Mr. Brooks:
Please find enclosed a copy of the Tax Certification request
for your company from Carolina Financial Group, Inc.
As you are aware, Tax Certifications are required by County
Tax Offices to exempt pollution abatement equipment from annual
taxes. In order to process this request, please provide this
Office with a detailed description of the water pollution
abatement equipment (see attached list of equipment).
If you have any questions concerning this matter,, please do
not hesitate to contact Mr. Crabb or me.
Enclosure
Into
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
P.Q Sm 950, 919 North Main SoeR Mooresville, NIC. 28115a50 • Teiephom 7N.663- M • FAX 704m3"
An Equji Qppmnfry Affirmative Action Employer

>�. C. Dyp . of NATURAI-
RFsoURCES AND
pop,[MUNITY Il€FI.f. EbP a9`'Ti
arol1na
roup, inc.
April 20, 1993
Ms. Brenda J. Smith, Regional Supervisor
State of N.C. Environmental, Health &
Natural Resources
Mooresville Regional Office
P.O. Box 950, 919 N: Main St.
Mooresville, NC 28115-0950
APR 2 2 1993
p1VISICN aF EK6I�Jz %!',E�i
gB01. SE'1,0LE. Mai � L 02a
141 Old Rock School
PO Drawer 488
Valdese, NC 28690
Tel: [phone]
Fax: [phone]
COMPANY:: Cleveland Mills Company, Inc.
WATER PERMIT #: NC0004120
LOCATION: 101 West Main St., Lawndale, NC 28090
PROPERTY DESCRIPTION: Water Pollution Equipment
Dear Ms. Smith:
In accordance with the North Carolina Machinery Act, Section 105-275(8)(a),
we are requesting on behalf of the above —mentioned client, for property to be certified
as personal property used for air cleaning or waste disposal or to abate, reduce
or prevent pollution of air or water.
We are requesting that you consider waste water treatment equipment that is used
to treat water before it is released as anti water pollution equipment. The total cost
of the waste equipment is $338,247.
If you have any questions with regard to this matter, please do not hesitate to
contact me. We sincerely appreciate your assistance in this matter.
Very truly yours,
CAROLINA FINANCIAL GROUP
By: _
Ramona T. Woods, PA
Associate
Enclosure
Tax Consultants

CLEVELAND MILLS COMPANY, INC.
SCHEDULE OF WASTE TREATMENT EQUIPMENT (WATER POLLUTION)
1993 PROPERTY TAX RETURN
YEAR
DESCRIPTION
COST
ACa
DEPT
OF EQUIPMENT
AMOUNT
1992
_
(CIP)
3 DYE MACHINES&EQUIP- WASTE TREATMENT NIS
304,774
1990
WT
PC & PRINTER - WASTE TREATMENT
3,511
1990
DYE & FIN
ANALYTICAL BALANCE -WASTE TREATMENT
2,620
1990
DYE & FIN
ISCO FLOW PROPORTIONAL SAMPLER
4.557
1990
DYE & FIN
COMPUTER/WASTE TREATMENT
8,983
1987
DYE & FIN
ELECT FLOW INDICATOR -WASTE TREATMENT.
2,409
1987
YARN
LISTER SLUB CATCHER -WASTE TREATMENT
6,743
1987
YARN
WIRE USTER CONTROLS -WASTE TREATMENT
515
1974
YARN
CARD -WASTE W/HOLLINGSWORTH MOD
2,961
1968
DYE & FIN
DISCHARGE REGULATOR WASTE
1,174
TOTAL
338,247