NC0020737_Regional Office Historical File Pre 2018 (9)

FILE
00Y COOPE
Govcrnar
MICHAEL S. RECANI
5ererrary
LINDA CULPEPPER
Dfre"O .'
Certified Mail # 7018 0360 0002 2099 1567
Return Receipt Requested
Ricky C Duncan
City of Kings Mountain
PO Box 429
Kings Mtn, NC 28086
NORTH CAROLIN 1
en,vironmentat Qurartfty
January 13, 2020
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2020-1-M-0001
Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr. Duncan:
A review of the November 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Limit Reported
Location
Parameter
- Date Value Value
Type of Violation
001 Effluent
Nitrogen, Ammonia Total (as 11/30/2019 8.9 10.51
Monthly Average Exceeded
N) - Concentration (C0610)
Monitoring Violation(s):
Sample
Monitoring
Location
Parameter
Date Frequency
Type of Violation
001 Effluent
Nitrogen, Ammonia Total (as N) -
11/23/2019 5 X week
Frequency Violation
Concentration (C0610)
001 Effluent
Nitrogen, Ammonia Total (as, N) -
11/30/2019 5 X week
Frequency Violation
Concentration (C0610)
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A Notice of'Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to 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 G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already. been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.. 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.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
'be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc. -
If you have any questions, concerning this matter or to apply for an SOC, please contact Ori Tuvia of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
DocuSigned by:
H P for
F161F869A2D84A3...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
EC
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Certified Mail # 7016 1370 0000 2595 7306
Return Receipt Requested
November 3, 2017
Ricky C Duncan
City of Kings Mountain
PO Box 429
Kings Mtn, NC 28086
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-LV-0106
Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr. Duncan:
A review of the July 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the deficiency
indicated below:
Limit ExceedanceLimit Deficiency:
Sample Limit Reported
Location Parameter Date Value Value . Type of Deficiency
001 Effluent Arsenic, Total (as As) (01002) 7/31/2017 152.2 155 Monthly Average Exceeded
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you should need any assistance or would like to discuss this non-compliance situation, please contact Ori
Tuvia of the Mooresville Regional Office at 704-663-1699.
Sinc rely,
r
r
F,)-n-- W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

a,+
Water Resources
Environmental Quality
July 31, 2017
CERTIFIED MAIL:70151520 0002 6984 9317
RETURN RECEIPT REQUESTED:
Mr. Rick Duncan
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Monntain, North Carolina 28086
Dear Mr. Duncan:
ROY COOPER
Governor
MICHAEL S: REGAN
Secretary
S. JAY ZIMMERMAN
Director
Subject: Notice of Violation
Pretreatment Audit Inspection
City of Kings Mountain
NPDES Permit No. NCO0204-8 -
Cleveland County :Z01137 j
Tracking #: NOV-2.Q.17-PC-051.2✓/
Enclosed is a. copy of the Pretreatment Audit Inspection Report for the inspection of the City of
Kings Mountain approved Industrial Pretreatment Program on July 19, 2017,, by Mr. Wes Bell of this
Office. Please inform the City's Pretreatment Supervisor of our findings by forwarding a copy of the
enclosed report.
This report is-beiilg issued as a Notice of Violation .(NOV) due to the City's failures to properly
implement the Pretreatment Program, violations of North Carolina General Statute (G.S.).143-215.1, 15A
North Carolina Administrative Code (NCAC) 211.0900, and the. subject NPDES Permit. Specifically, the
City failed to initiate enforcement according to the Division approved Enforcement Response Plan (ERP)
to address a Significant Industrial User's (SILT) 2016 monitoring violations (mercury and thallium) and
failure to notify the City of the September 2016 permit limit violation within twenty-four (24) hours of
first knowledge. In addition, the Cityfailed maintain all required SIU documentation (TOMP). Pursuant
to 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 G.S. 143-215.1
In order to come back into compliance with the requirements of the. Pretreatment Program, the
City must issue appropriate enforcement actions and obtain the required documentation (TOMP) within .
fourteen (14) days of receipt of this inspection report. In addition, the City must obtain a copy of updated
slug/spill control plans and TOMPs from all applicable SIUs within thirty (30) days of receipt of this
inspection report.
State of North Carolina I Environmental Quality) Water Resources I Water Quality_ Regional Operations
Mooresville. Regional Office 1610.East Center Avenue, Suite 310 Mooresville, North Carolina 28115.
704-6631699 .

21. PRETREATMENT PROGRAM ELEMENTS REVIEW
Program Element:
NC0020737
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/2/15
® Yes ❑ No
4/21/16
® Yes ❑ No
9/1/20
Industrial Waste Survey (IWS)
12/18/14
® Yes ❑ No
12/1/15
® Yes ❑ No
12/1/19
Sewer Use Ordinance (SUO)
8/9/13
® Yes ❑ No
8/16/13
® Yes ❑ No
Enforcement Response Plan (ERP)
1/10/14
® Yes ❑ No
3/11/14
® Yes ❑ No
Long Term Monitoring Plan (LTMP) .
12/2/15
® Yes ❑ No
4/1/16
® Yes ❑ No
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas
23. If yes to #22, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 9/24/13
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a. copy of the ERP to your industries? ® Yes M. No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order. None
Resources
30.. Please Rate the Following: S=Satisfactory
M=Maroinnl TT=TTnsatisfactnry -
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
-Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Regional Workshops, Etc.)
®S ❑M ❑U
Computer Equipment (Hardware and
Software)
®S ❑M'❑U
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31. -Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
SIU Permit renewal fees and monthly pretreatment permit fees.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
❑ Yes ® No If yes, Explain. Currently no; however, a new power generation industry (NTE) will be connected to the
POTW by mid to late Summer of 2019 and discharging up to 0.5 MGD.
34. Has any one from the public ever requested to review pretreatment, program files? ❑ Yes'® No
If yes, Explain procedure. If no, How would the request be addressed? A written request would be reviewed and approved by
the Pretreatment Supervisor and Water Resources Director. Files would be reviewed at the WWTP with the Pretreatment
Staff in attendance.
35. Has any industry ever requested that certain information remain confidential from the public? ❑ Yes ® No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public. If no. how would the request be addressed? A written request would be reviewed and approved by the
Pretreatment Supervisor and Water Resources Director. Files would be kept secured in a locked file cabinet.
36. In addition to annual inspection, does the POTW periodically meet with industries_ to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? E Yes ❑ No ❑ NA
Permitting (Industrial Waste Survey-IWS): -
39a...How does the POTW become aware of new or changed Users? The POTW's Planning Department contacts the
Pretreatment Supervisor of any potential new Users.
39b. Once the POTW becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the'WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Short/Long IWS Forms submitted to the User and a site visit is'performed based on the information
provided. Flow volumes, categorical processes, discharge characteristics, and information provided in the ,
application are all evaluated during the SIU determinations.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) of landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable. NA
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required) No trucked waste (industrial and/or septage) is accepted.
43. How does the POTW allocate its loading to industries? Mark all that apply
❑ Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ❑. Yes ® No
If yes, What parameters are over allocated?
45. If yes to #44, What is being done to address the over allocations? (short-term IUPs, HWA to be revised, pollutant study, etc.)
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter? 9%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ❑ Yes ® No
If yes, Explain.
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48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern) Categorical Parameters, NPDES POCs,
industrial activities based on SIC Code.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
Monthly monitoring for twelve months (minimum) for a new SIU as baseline; monitoring may be reduced based on sample
results; semi-annual monitoring required at a minimum.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication?. ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Compliance Judgement Worksheet for SNC determinations; ERP
followed for violations (limit, reporting, permit conditions, etc.).
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs required to implement a slug/spill control plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
Emergency contacts kept up to date; proper chemical storage and secondary containment; presence of spill response
equipment; employee training.
56. How does the POTW decide where the sample point for an SITJ should be located?
The effluent of the pretreatment wastewater treatment system for regulated waste streams.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SAT: ® Yes ❑ No If yes, Explain. POTW — sampler O&M manual and employee
training; SIU — sampling practices reviewed during inspections.
58. Who performs sample analysis for the POTW for Metals — K&W Labs
Conventional Parameters — K&W Labs
Organics — K&W Labs
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
POTW and SIU both use contracted lab's COCs.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA):
60a. Is LTMP/STMP Monitoring Being Conducted at Appropriate'Locations and Frequencies? ® YES ❑ NO
60b. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES. ® NO
60c. Is LTMP/STMP Data Maintained in Table or Equivalent? ®.YES ❑ NO Is Table Adequate? ® YES ❑ NO
60d.
60e.
60f.
All LTMP/STMP effluent data on Discharge Monitoring Report (DMR)? ® YES ❑ NO
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
If yes, which ones? Eliminated: Added:
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, Who completes your HWA? Phone:
62. Do you have plans to revise your HWA in the near future? ❑ Yes ® No
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow ❑NPDES limits change
❑More LTMP data available []Resolve over allocation ❑5 year expiration []Other, explain.
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63.4n general, what is the most limiting criteria of your HWA?
®Inhibition ❑ Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ❑ No
Explain. NA - sufficient capacity at the WWTP.
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment? No
TNDUSTRTAT. TTCF.R PF.RMTT (UTP) FTLF, RFVTFW:
66. User Name
1. KMI
2. CFC
3. Steag
67. IUP Number
031 11
033
032
68. Does File Contain Current Permit?
® Yes ❑ No
FZ Yes ❑. No 11
® Yes ❑ No
69. Permit Expiration Date
6/20/20
2/17/19
7/18/21.
70. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
- 433 J1
433
433
7L L. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72. Does File Contain Inspection Completed Within Last Calendar Year?
® Yes ❑ No
®Yes El No.
®Yes ❑ No
73. a. Does File Contain Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes []No
a. ®Yes []No
b. If No, is One Needed? See Inspection Form from POTW)
b. ❑Yes- []No I
b. ❑Yes ❑No 11
b. ❑Yes ❑No
74. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/AIFRVTs❑NoON/A
❑Yes®No❑N/A
Organic Management Plan (TOMP)?
75. a. Does File Contain Original Permit Review Letter from Division?
®Yes []No
Fb
a. ®Yes []No
a. ®Yes []Nob.
All Issues Resolved?
❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
76. During Most Recent Semi -Annual Period, Did POTW Complete its
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
Sampling as Required by lUP, including Flow?
77. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ No 11
® Yes ❑ No
78. During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
❑Yes®No❑N/A
®Yes❑No❑N/A
Sampling as Required by lUP, including Flow?
79. During Most Recent Semi -Annual Period, Did SIU submit all reports on
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
time?
80a. For categorical 1Us with Combined Wastestream Formula (CWF), does
❑Yes❑No®N/A
1[77ON/Aj7sE1No0.N/A
file include rocess/dilution flows as Required by 1:UP?
80b. For categorical lUs with Production based limits, does file include
❑Yes❑No®N/A
11 ❑Yes❑NoON/A
❑Yes❑NoON/A
production rates and/or flows as Required by IUP?
81. During Most Recent Semi -Annual Period, Did POTW Identify All
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82. During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑No®N/A
❑Yes❑No®N/A
Re • ortin Non-Com liance from SIU Sampling?
83. a.,Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.®Yes❑No❑N/A
amYes®No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.®Yes[]No❑N/A
b.®Yes❑No❑N/A
b.❑Yes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
becomingaware of SI[J limit violations in the POTW's sampling of SIU?
84. During Most Recent Semi -Annual Period, Was SIU in SNC?
❑-Yes ® No
I ❑ Yes ®
No
I ❑
Yes ® No
$5. During Most Recent Semi -Annual Period, Was Enforcement Taken as
®Yes❑No❑N/A
j7YesMNo0N/A
11 ❑Yes®No❑N/A
Specified in POTW s ERP OVs; Penalties, timing, etc.)?
86. Does File Contain Penalty Assessment Notices?
I ❑Yes❑No®N/A
❑Yes❑NoNN/A.
❑Yes❑NoON/A
87. Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
11 ❑Yes❑No®N/A
❑Yes❑No®N/A
88. a. Does File Contain Any Current Enforcement Orders?
a.oYes❑No®N/A
a.❑Yes❑No®N/A
a.gYes❑No®N/A
b. Is SIU in Compliance with Order?
b.oYes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89. Did POTW Representative Have Difficulty in Obtaining Any Requested
❑ Yes ® No
❑ Yes ® No
® Yes ❑ No
Information For You?
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FILE REVIEW COMMENTS:
16/18. CFC was in SNC during the January — June 2016 period for TSS, chromium, and cyanide limit violations.
60b. The minimum detection levels for several metals (cadmium, chromium, copper, silver, lead, thallium, etc.) were higher than the
LTMP's minimum detection levels for the sampling events performed on the aeration basins and influent.
60d. The effluent mercury results using Methods 1631 (grab — low level) and 245.1 (composite - high level) were being reported under
the low level effluent mercury column (grab - ng/L) on the eDMR. The effluent mercury composite samples were being analyzed
(Method 245.1) during LTMP sampling events. Only the low level effluent mercury results can be reported in this column to determine
compliance with the NPDES Permit limit.
72. POTW performed SLU inspections on 7/11/16 (KMI), 7/13/16 (CFC), and 7/18/16 (Steag).
73. The POTW's contacts listed in the slug/spill control plans for CFC and Steag need to be updated.
74. The POTW's contacts listed in the TOMPs for KMI and CFC need to be updated. The TOMP for Steag could not be found during
the inspection.
78. CFC is required to collect monthly mercury and thallium samples; however, the SILT only collected quarterly mercury samples and
no thallium samples in 2016. The following laboratories have. been contracted by the SIUs to perform analyses: Pace Analytical
Services (KMI), Par Laboratories (CFC), and K&W Labs (Steag).
The contracted labs, used by both the POTW and SIUs failed to achieve the required IUP minimum detection levels for several metals
and chloride.
83. Steag failed to notify the POTW within 24 hrs. of first knowledge of the cadmium limit violation in July 2016.
85. The POTW issued NOVs to the SIUs for the following: chloride limit violation in September 2016 (KMI); zinc limit violation in
November 2016 (CFC); and cadmium limit violation in July 2016 (Steag).
The POTW did not initiate enforcement actions to Steag (failure to notify within 24-hrs.) and CFC (mercury and thallium monitoring
violations) according to the Division approved ERP.
89. Steag's TOMP could not be found during the inspection.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number MM/DD/YY Inspection type Inspector Facility Type
® N I C 10 10 12 10 1 107 119 17 UD --f I 2�
(DTIA) (TYPI) (INSP) (FACC)
1. Industry Inspected: KMI
2. Industry Address: 1755 S. Battleground Avenue, Kings Mountain, NC 28086
3. Type of Industry/Product: 433/Precision Grinding & Architectural design
4. Industry Contact: Todd Humpheries Title: Environmental. Liason/Safety Coordinator Phone: [phone]
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes ❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
B. Plant Tour
C. Pretreatment Tour
D. Sampling Review
E. Exit Interview
® Yes
❑ No
® Yes
❑ No
® Yes
❑ No
® Yes
❑ No
® Yes
❑ No
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Industrial Inspection Comments:
The industrial facility has three shifts; however, only the first shift generates the waste stream for the on -site wastewater pretreatment
system. There are currently eighty (80) employees and the facility operates five days per week. The on -site wastewater pretreatment
system includes the following: three holding tanks; pH adjustment; flocculation; settling; filtration (particulate filter); holding tank;
effluent pumping system; flow measurement; and filter press. The facility is also equipped with in -line pH and temperature effluent
monitoring systems. All hazardous and non -hazardous wastes (including dewatered wastewater solids) are transported/disposed at the
Chemtron facility in Avon, Ohio.
SUMMARY AND COMMENTS:
Requirements:
The POTW must initiate appropriate enforcement actions to Steag (failure to notify within 24-hrs. of first knowledge of the cadmium
limit violation) and CFC (mercury and thallium monitoring violations) according to the Division approved ERP. These enforcement
actions must be addressed within fourteen (14) days of receipt of the inspection report.
All minimum detection levels (LIMP and lUP) must be adhered to prior to the next sampling events by POTW and SIUs.
The POTW must obtain a TOMP for Steag within fourteen (14) days of receipt of the inspection report.
Updated slug/spill control plans (Steag and CFC) and TOMPs (KMI and CFC) must be received within thirty (30) days of receipt of the
inspection report. POTW staff must also ensure that the Steag TOMP is properly updated prior to submittal.
All eDMRs with the low level and high level effluent mercury results being reported under the same column (low level) must be revised,
processed, and signed prior to submittal (via mail) to the Division. The effluent mercury results using Method 245.1 (high level) should
be reported on the eDMR under the "Comments" Section.
NOD: ❑ Yes ® No
NOV: ® Yes ❑ No
QNCR: ❑ Yes ® No
POTW Rating:
Satisfactory ❑ Marg' al ® Unsatisfactory ❑
Audit COMPLETED BY:l/ i
DATE: July 31, 2017
Wes Bell, Mooresville Regional Office
NT(` MVP P—t-atlllPllt A-14 l:nrrl, PP{I —4- Tlll,, 75 1007 Po— I

h
THE CITY OF KINGS MOUNTAIN
Wes Bell
Division of Water Resources, NCDEQ
Mooresville Regional Office
Subject
Dear Mr. Bell,
P.O. BOX 429 • KINGS MOUNTAIN, NORTH CAROLINA 28086 . 704-734-0333
Rr-CEI1iE0/NCDENR//UgwR ust $, 2017
AUG 14 2017
WQROS
MOORESVILLE REGIONAL OFFICE
Pretreatment Audit Response
City of Kings Mountain
NPDES Permit No. NCO020737
The City of Kings Mountain's Pretreatment Department received the Pretreatment Audit
Inspection/NOV on Monday, August 7, 2017. This response is in regard to the July 19, 2017
inspection report.
Steag SCR -Tech Inc. failed to notify the City of a permit limit violation which occurred on July 6,
2016. Steag normally reports all non -compliances within 24 hours of becoming aware of the
violation via email. For some reason, Steag failed to do so with this violation and the City's
Pretreatment Department failed to catch the non -reporting. Steag was issued an NOV on
8/8/2017 failure to report the violation mentioned. The Pretreatment Department will review
all IDMR's, and results thoroughly from this point forward to ensure this doesn't happen again.
(NOV attached)
Carolina Finishing and Coatings (CFC) were issued a violation on 8/9/2017 for failure to monitor
for thallium and mercury as stated in IUP# 033. (NOV attached)
The following indicates dates in which Slug/Spill Plans and TOMPs were received by POTW:
Slug/Spill Plans: Steag (received on 8/8/2017)
CFC (received on 8/03/2017)
TOMP's: KMI (received on 8/8/2017)
CFC (received on 8/7/2017)
Steag (received on 7/24/2017)
All mentioned plans can be submitted upon request.
The Historical City

Thursday July 20th, 2017, an email was sent to K&W Laboratories informing them of the
detection limits needed when analyzing all Industrial data as well as LMTP detection levels for
the plant analysis. After confirmed receipt of the email; K&W then sent these limits to Pace,
who they use to as a contracted laboratory. Furthermore, all results obtained will be verified to
ensure these reporting limits are compliant.
Mercury results using Method 245.1(high level) has,been reported under the comments
section for January 2017, version 3.0 eDMR. After reviewing all the data, this was the only
revision needed to add additional mercury sampling. In the future, if mercury is analyzed using
Method 245.1, it will be entered into the comments section of the eDMR.
If further information is needed, please contact Richelle Meek:
Richelle Meek
City of Kings Mountain
Pilot Creek WWTP
[e-mail]
Office: [phone]
Sincerely,
L"
Ricky Duncan
Water Resources Director
City of Kings Mountain
[e-mail]
(Please see mentioned attachments)

THE CITY OF KINGS MOUNTAIN
P.O. BOX 429 • KINGS MOUNTAIN, NORTH CAROLINA 28086 • 704-734-0333
May 15, 2017
W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations NCDEQ
610 E. Center Avenue, Suite 301
Mooresville, North Carolina
Mr. Basinger,
RECEIVED/NCDENR/DWR
MAY 18 2017
WQROS
MOORESVILLE REGIONAL OFFICE
On May 15, 2017, my office received a Notice of Violation concerning the monthly average limit
exceeded for thallium at our Wastewater Treatment Facility. NOV-2017-LV-0319 states on 8/31/2016,
the City of Kings Mountain exceed our limit for thallium of 60.1 ug/L by reporting a limit of 72.5 ug/L.
I was hired as Director of the Water Resour
my primary concerns was the Special Ordei
Wastewater Treatment Facility was under.'
our system that discharged thallium into ou
once per month to determine the amounts o
reported to the State DEQ for a monthly av,
us enough information to accurately judge c
Steag. At that time I contacted our Wastew;
weekly. The increase in testing allowed the
was being discharged by each, as well as de
process.
;es Division in February of 2016. Upon taking office, one of
of Consent, EMC-SOC-WQ-216-001, that our Pilot Creek
✓e were aware that Steag Industries was the only industry in
collection system and it was required by the State to test
thallium leaving our Plant. This test was required to be
rage.l did not feel that monthly testing was sufficient to give
ur thallium levels in determining our course of action with
ter ORC, Richelle Meek, to increase sampling of thallium to
�ity, as well as Steag Industries, to better understand what
:ermine the corrective measures required by Steag in the
As a result of our increased monitoring, Steag Industries has significantly reduced thallium in their
effluent through process controls and changes. We have also met with Steag on a more frequent schedule
in order to comply with our SOC limits. I have attached a spreadsheet that shows a direct correlation
between our increase in sampling and significant reductions in thallium in our effluent. Steag has been
more responsive to the City due to the sampling information that we have provided them and I firmly
believe that the thallium issues will be resolved prior to expiration of our SOC. I was not aware that our
"in-house" testing was required to be reported to the State for obtaining our monthly average, I assumed
the monthly test that was in place was all that was required. Mr. Wes Bell, of NC DEQ, informed me that
had we taken these extra samples prior to our effluent sampling point, we would not have to report them.
My hope is that your office will consider this as an oversight on my part as well as take into consideration
the improvements that have been made to reduce the thallium levels in our discharge. It is our goal to
remain complaint with our discharge permit as well as the Special Order of Consent we are under. Please
consider our efforts in making your decision with regard to any penalties.
The Historical City

I appreciate the assistance that your office has provided to the City of Kings Mountain concerning this
issue. Mr. Wes Bell was extremely helpful to Richelle Meek and myself and we look forward to a
continued good relationship with your office.
Ricky Duncan
Water :ftj e
ctor
City of Kings Mountain
1013 N. Piedmont Avenue
Kings Mountain, N.C. 28086
RD/j s
enc.

THE CITY OF KINGS MOUNTAIN
a
April 12, 2017
CENTRAL FILES
NCDWQ
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
To whom it may concern,
P.O. BOX 429 . KINGS MOUNTAIN, NORTH CAROLINA 28086 . 704-734-0333
RECEIVED/NCDENR/DWR
APR 242017
RECEIVE® wQROs
MOORESVILLE REGIONAL
APR 1 $ 2017
CENTRAL FILES
DWR SECTION
Attached is all revisions requested during the 2017 inspection. These reports now
contain all thallium results obtained for Pilot Creek from the effluent discharge.
Once again, we apologize for this inconvenience. This was an honest mistake, and I
can assure you, it won't happen again.
All corrections have been on the reports attached. Violations are
indicated in red.
The attached October 2016 report will not be the final revision. After completing
the attached revision, I received a phone call from Ori Tuvia stating the PPA
performed in October 2016, needed to be added to this DMR. After modifications
with the state reporting site, I was able to add this parameter to the eDMR, and the
PPA has been added. This revision will be submitted, via hard copy, upon the
completion of processing on the website.
If further information is needed, please let me know.
Sincerely,
Richelle Meek
City of Kings Mountain
Pilot Creek WWTP ORC
The Historical City

Water'Resour es .
Certified Mail # 7015 1520 0002 6984 8716
Return Receipt Requested
February 14, 2017
Ricky C Duncan
City of Kings Mountain
PO Box 429
Kings Mtn, NC 28086
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2017-LV-0138
Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr. Duncan:
Et�?�`Pl?
�r�ut�r
MIC.IAE% S.'REGAN.
seaftry
S. JAY ZIMME.RMAN
Dktoi
A review of the October 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation
indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent Nitrogen, Ammonia Total (as 10/31/2016 2.6 2.93 Monthly Average Exceeded
N) - Concentration (C0610)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources 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 (SOC).
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you have any questions concerning this matter or to apply for an SOC, please contact Ori Tuvia of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina I Environmental Quality i Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

Pilot Creek Thallium Data
2015
Date:
Influent (wdL)
Effluent (µg/L)
8-Jan
<10
<10
15-Jan
31
<10
22-Janj
<10
<10
29-Jan
<10
<10
5-Feb
<10
<10
12-Feb
<10
<10
19-Feb
<10
710
26-Feb
<10
<10
5-Mar
<10
<10
12-Mar
<10
710
19-Mar
<10
<10
26-Mar
55
<10
2-Apr
<10
<10
9-Apr
17
<10
16-Apr.
13
<10
23-Apr
28
<10
30-Apr
<10
<10
8-May
<10
<10
14-May,
<10
<10
21-May
<10
<10
28-May
<10
<10
4-Jun
16.7
33.9
16-Jul
17
25
6-Aug
28
32
10-Sep
6.2
22
15-Oct
<10
17
5-Nov,
40.6
17.4
10-Deci
33.71
27
2016
Date:
Influent (µg/L)
Effluent (µg/L)
4-Jan
16.6
15.1
117b
43.7
21.4
10-Marl
35.6
23
14-Apr
24.4
5-May
24.2
32.8
12-May
108
35.05
19-May.
107
38.1
9-Jun
318
70.5
16-Jun
108
97
23-Jun
42
86
30-Jun
20
73
7-Jul
78
<10
14-Jul
21.4
64.4
21-Jul
31
51
28-Jul
40
49
4-Aug
46.2
60
11-Aug
57
87
18-Aug
44
77
25-Aug
43
66
1-Sep
26
59
8-Sep
18.3
41
15-Sep
78
51
22-Sep
24
39
29-Sep
67
52
6-Oct
70
44
13-Oct
21.7
21.9
20-Oct
26
36
3-Nov
63.5
32.1
22-Nov
30
<20
8-Dec
29
16.4
3-Dec
<20
20-Dec
LI
33
27-Dec
<20
2017
Date:
Influent (µg/L)
Effluent (ug/L)
5-Jan
25
18
10-Jan
<20
19-Jan
13.1
21.5
26-Jan
<20
16
2-Feb
<20
14
9-Feb
82.5
21.5
16-Feb
28
<10
23-Feb
<20
<20
2-Mar,
<20
19
16-Mar
<20
<10
23-Mar
42
47
30-Mar
<20
11
13-Apr
13.9
34.1

SHEALY ENVIRONMENTAL SERVICES, INC.
Report of Analysis
City of Kings Mountain WWTP
200 Potts Creek Rd.
Kings Mountain, NC 28086
Attention: Richelle Meek
Project Name: TCLP
Lot Number:UJ08079
Date Completed:10/23/2019
10/24/2019 2:34 PM
Approved and released by:
Project Manager: Grant Wilton
AAW
e
C PC D IT CD
C00 Eiai
The electronic signature above is the equivalent of a handwritten signature.
This report shall not be reproduced, except in its entirety, without the written approval of Shealy Environmental Services, Inc.
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.sfiealylab.com
Page 1 of 14

SHEALY ENVIRONMENTAL SERVICES, INC.
SC DHEC No: 32010001 NELAC No: E87653 NC DENR No: 329 NC Field Parameters No: 5639
Case Narrative
City of Kings Mountain WWTP
Lot Number: UJO8079
This Report of Analysis contains the analytical result(s) for the sample(s) listed on the Sample Summary
following this Case Narrative. The sample receiving date is documented in the header information
associated with each sample.
All results listed in this report relate only to the samples that are contained within this report.
Sample receipt, sample analysis, and data review have been performed in accordance with the most
current approved NELAC standards, the Shealy Environmental Services, Inc. ("Shealy") Quality
Assurance Management Plan (QAMP), standard operating procedures (SOPS), and Shealy policies. Any
exceptions to the NELAC standards, the QAMP, SOPs or policies are qualified on the results page or
discussed below.
Where applicable,, all soil sample analysis are reported on a dry weight basis unless flagged with a "W"-
qualifier
If you have any questions regarding this report please contact the Shealy Project Manager listed on the
cover page.
The pH analysis associated with the sample(s) in this report was/were performed after the method
recommended 15 minute holding time.
PCB Analysis - Method 8082A
The sample results associated with a P qualifier have a relative percent difference (RPD) between the two
dissimilar phase GC columns which exceeds 40%. Section 7.10.4 of SW-846 method 8000E states the
higher of the two results is reported. Per our standard operating procedure, the lower result is reported
when a result has a P qualifier because the disparity between the two results would yield a biased high or
false positive result. In the event that one column is a J qualified result and the other is an unqualified
detection greater than the PQL, the lower result is also reported.
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 2 of 14

Shealy Environmental Services, Inc.
CWA / WDES 106 Vantage Point Dave
Chain of Custody Record -WWt Golumbla, South Camflna 20172 Number
Telephone No, (803) 701-970ki Fax No. (a03) 791-9111
vAwo.shaalyls b.c*rn
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in check mm-5
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Number of Con,'ainers.
MAR -
prejIGC1 Nerne --I C) 4 -;1 -?4�:j
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(Confakzars for each sal 1pk may Date Time
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Note: All samples are retained for six weeks from racOlPt IMIOSS Other LAB USE OP - Y Re M- T." T(' I n P. feMp� clank
"'05� 01�110r LAB B USE �13'P I
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SHEALY ENVIRONMENTAL SERVICES, INC.
4'hc-�ly �t1'reu:ms:rllEt S�tic:cy 'nr,
I)ucumcrv?"ttnr.Eer,.,`;�1in4IM"I'3 i'hla: Loft
Sample Receipt (Checklist (SRQ Efficlive
Clifaw City of Kings Nfount®att Cuoier Inh ...rted lavttleta: nrtr.. IUr'�`,lb?19U.103079
�._.�' _ Ltt-
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EJ irca Nil NA .?. If cast ae ah; w+et' trc:;ent, Wert `.heir uttacl and tnEbrokcn?
A4 SUip ID: N.A Chlorine Strip ID: T �Eted
:l~ioiiutl tetttpetattare upon m-ce p `T7eritired (Carn^v€ed) tclrs�trsature upon. receipt 'l-tided Snap -Cup ID: 19-161 G
becthed: ®TotttpWralurc 131arilc E]t''.guin'4 90(tles 1R C.iun I1): 5 IR flint (orreution Factor: 0 'O
t'fethod Uf a nol, t: 21 lk-et 1c'-. [ Icc .Packs Dry l;;c NOile
® Yds E] No ® h A ''' If teJnperature Of any cpolur cmceddcd G-WC, was I'mject Maita?Tcr Notified,
yet
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t f1. Did ail coiltairle,-r label attFnrr fiun (1U, date, titne*,) aver with t1>~ COC?
Net
I I - w ere teats ,o be performed listed On the COG?
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I2. Di(I all samptcs arri ve inthe nrc�pt;r Cetitaincra for eee,h t l ant% r3^ in gacci onl titan
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El NO
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in wivoftha, Vo.A vialc7
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.
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ctrrz4*rtly trauscribed frtxtu :lie Coe intr- tFae-Cornet cnt ,eetictn iu i died �?
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ample Preservatiou (Must be out picted fbr army uEtplc(sj incc erectly prsscra tt or .vide stc3C%paee.!
Santgrlc[s WA were r t+ve d incnrreetly Fri; acn cd utd ri adjtastf zecurcliugly'
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Time of prMLre adon NA � lr";nun� than rite presen ative is, needed, plersc pate it the cummentx helow-
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`3iiiplest s j Nr1 acer. reeeivr t�'illr TItC: > t}.5 tttgiL (Tf 4l9 is eery) and were
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SR ba"de Iabc.ls applird by_ BNIG
bate: 1tl.'08;'19
Cantmerrts:
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 14 of 14

SHEALY ENVIRONMENTAL SERVICES, INC.
Sample Summary
City of Kings Mountain WWTP
Lot Number: UJO8079
Project Name: TCLP
Project Number:
Sample Number Sample ID Matrix Date Sampled Date Received
001 #2 basin Solid 10/01/2019 1345 10/08/2019
(1 sample).
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 3 of 14

SHEALY ENVIRONMENTAL SERVICES, INC.
Detection Summary
City
of Kings Mountain WWTP
Lot Number: UJ08079
Project Name: TCLP
Project Number:
Sample Sample ID
Matrix
Parameter
Method
Result Q
Units
Page
001
#2 basin
Solid
Ignitability (Pensky-Martens
1010A
>140
° F
5
001
#2 basin
Solid
Paint Filter Test
9095B
Pass
pass/fail
5
001
#2 basin
Solid
Aroclor 1254
8082A
680 P
ug/kg
9
001
#2 basin
Solid
Barium
601OD
0.40
mg/L
11
(4 detections)
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 4 of 14

Inorganic non-metals
Client: City of Kings Mountain WWTP Laboratory ID:UJ08079-001
Description: #2 basin Matrix: Solid
Date Sampled:10/01/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:10/0812019 Project Number:
Run Prep Method
Analytical Method
Dilution
Analysis Date Analyst Prep Date Batch
1
(Ignitability) 1010A
1
10/1.4/2019 1405
SLC 31922
1
(Paint Filter) 9095B
1
10/17/2019 0021
HET
1
(Reactive Cya) 7.3.3
1
10/22/2019 2125
KFE 10/16/2019 1034
1
(Reactive Sul) 7.3.4
-1
10/21/2019 1622
HET 10/16/2019 1034
1 -
(Soil pH meas) 9045D
1
10/17/2019 2125
HET 32442
CAS Analytical
Parameter
Number Method
Result Q
LOQ
Units
Run
Ignitability (Pensky-Martens Closed -Cup)
1010A
>140
140
° F
1
Paint Filter Test
9095B
Pass
pass/fail
1
Reactive Cyanide
7.3.3
ND
50
mg/kg
1
Reactive Sulfide
7.3.4
ND
50
mg/kg
1
Soil pH measured in water @ 18 ° C
9045D
4.7
su
1
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
ND = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40 %
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 5 of 14

TCLP Volatiles
Client: City of Kings Mountain WWTP Laboratory ID:UJ08079-001
Description: #2 basin Matrix: Solid
Date Sampled:10/01/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:10108/2019 Project. Number:
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch Leachate Date
1 1311/5030B 8260D 10 10/11/2019 1310 TML 31774 10/10/2019 0056
CAS Analytical
Parameter Number Method Result Q LOQ Units Run
Benzene
2-Butanone (MEK)
Carbon tetrachloride
Chlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethene
Tetrachloroethene
Trichloroethene
Vinyl chloride
Surrogate
Bromofluorobenzene
1,2-Dichloroethane-d4
Toluene-d8
71-43-2
8260D
ND
0.050
mg/L 1
78-93-3
8260D
ND
0.10
mg/L. 1
56-23-5
8260D
ND
0.050
mg/L 1
108-90-7
8260D
ND
0.050
mg/L 1
67-66-3
8260D
ND
0.050
mg/L 1
107-06-2
8260D
ND
0.050
mg/L 1
75-35-4
8260D
ND
0.050
mg/L 1
127-18-4
8260D
ND
0.050
mg/L 1
79-01-6
8260D
ND
0.050
mg/L 1
75-01-4
8260D
ND
0.010
mg/L 1
Run 1 Acceptance
Q % Recovery Limits
103 70-130
95 70-130
100 70-130
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
ND = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40 %
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 6 of 14

Chain of Custody
and
Miscellaneous Documents
Shealy Environmental Services, Inc. ,
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 12 of 14

TCLP Metals
Client: City of Kings Mountain WWTP Laboratory ID:UJO8079-001
Description: #2 basin Matrix: Solid
Date Sampled:10/01/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:10108/2019 Project Number:
Run Prep Method
1 1311/3010A
1 1311/7470A
Analytical Method Dilution Analysis Date Analyst
601OD 1 10/17/2019 0053 LLL
7470A 1 10/16/2019 2101 JMH
Prep Date Batch Leachate Date
10/11/2019 0938 31727 10/10/2019 0056
10/16/2019 1348 32178 10/10/2019 0056
CAS Analytical
Parameter
Number Method
Result Q
LOQ
Units
Run
Arsenic
7440-38-2 601OD
ND
0.15
mg/L
1
Barium
7440-39-3 601OD
0.40
0.25
mg/L
1
Cadmium
7440-43-9 601OD
ND
0.050
mg/L
1
Chromium
7440-47-3 601OD
ND
0.10
mg/L
1
Lead
7439-92-1 6010D
ND
0.10
mg/L
1
Mercury
7439-97-6 7470A
ND
0.0020
mg/L
1
Selenium
7782-49-2 601OD
ND
0.20
mg/L
1
Silver
7440-22-4 601OD
ND
0.10
mg/L
1
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
NO = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40 %
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 11 of 14

TCLP Pesticides
Client: City of Kings Mountain WWTP Laboratory ID:UJO8079-001
Description: #2 basin Matrix: Solid
Date Sampled: 10101/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:10108/2019 Project Number:
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch Leachate Date
1 131113520C 8081 B 1 10/17/2019 2032 DAL1 10/16/2019 1714 32251 10/10/2019 0056
CAS Analytical
Parameter
Number Method
Result
Q
LOQ
Units
Run
gamma-BHC (Lindane)
58-89-9 8081B
ND
H
0.00040
mg/L
1
Chlordane
57-74-9 8081B
ND
H
0.0040
mg/L
1
Endrin
72-20-8 8081 B
ND
H
0.00040
mg/L
1
Heptachlor
76-44-8 8081 B
ND
H
0.00040
mg/L
1
Heptachlor epoxide
1024-57-3 8081 B
ND
H
0.00040
mg/L
1
Methoxychlor
72-43-5 8081B
ND
H
0.0016
mg/L
1
Toxaphene
8001-35-2 8081B
ND
H
0.0080
mg/L
1
Run 1 Acceptance
Surrogate
Q % Recovery Limits
Decachlorobiphenyl
H 93 20-131
Tetrachloro-m-xylene
H 91 26-132
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
ND = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 10 of 14

PCBs by GC
Client: City of Kings Mountain WWTP Laboratory ID:UJ08079-001
Description: #2 basin Matrix: Solid
Date Sampled:10/01/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:10/0812019 Project Number:
Run Prep Method
Cleanup Analytical Method Dilution Analysis Date Analyst
Prep Date
Batch
1 3546
366013/3665A 8082A 10 10/14/2019 2036 CHG
10/10/2019 1929
31687
CAS Analytical
Parameter
Number Method
Result Q
LOQ
Units
Run
Aroclor 1016
12674-11-2 8082A
ND
160
ug/kg
1
Aroclor 1221
11104-28-2 8082A
ND
160
ug/kg
1
Aroclor 1232
11141-16-5 8082A
ND
160
ug/kg
1
Aroclor 1242
53469-21-9 8082A
ND
160
ug/kg
1
Aroclor 1248
12672-29-6 8082A
ND
160
ug/kg
1
Aroclor 1254
11097-69-1 8082A
680 P p,ieg
n1k 160
y160
ug/kg
1
Aroclor 1260
11096-82-5 8082A
ND
7
ug/kg
1
Run 1 Acceptance
Surrogate
Q % Recovery Limits
Decachlorobiphenyl
Tetrach to ro-m-xylene
N 300 41-132
74 35-106
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitalion of compound exceeded the calibration range
NO = Not detected at or above the LOO N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40 %
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 9 of 14

TCLP Herbicides
Client: City of Kings Mountain WWTP Laboratory I D: UJO8079-001
Description: #2 basin Matrix: Solid
Date Sampled:10/0112019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:1010812019 Project Number:
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch Leachate Date
1 1311/8151A I8151A 1 10/14/2019 1520 DAL1 10/10/2019 1950 31660 10/10/2019 0056
CAS
Analytical
Parameter Number
Method Result Q LOQ
Units Run
2,4-D 94-75-7
8151A ND 0.020
mg/L 1
2,4,5-TP (Silvex) 93-72-1
8151A ND 0.0050
mg/L 1
Run 1 Acceptance
Surrogate Q % Recovery Limits
DCAA 80 50-112
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
NO = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40%
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 8 of 14

TCLP Semivolatiles
Client: City of Kings Mountain VYWTP Laboratory ID: UJ08079-001
Description: #2,basin Matrix: Solid
Date Sampled:10/01/2019 1345 Project Name: TCLP % Solids: 60.0 10/09/2019 0101
Date Received:1010812019 Project Number:
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch Leachate Date
1 1311/3520C 8270E 1 10/14/2019 1931 JCG 10/11/2019 1522 31771 10/10/2019 0056
CAS
Analytical
Parameter
Number
Method
Result Q
LOQ
Units
Run
1,4-Dichlorobenzene
106-46-7
8270E
ND
0.040
mg/L
1
2,4-Dinitrotoluene
121-14-2
8270E
ND
0.080
mg/L
1
Hexachlorobenzene
118-74-1
8270E
ND
0.040
mg/L
1
Hexachlorobutadiene
87-68-3
8270E
ND
0.040
mg/L
1
Hexachloroethane
67-72-1
8270E
ND
0.040
mg/L
1
2-Methylphenol
95-48-7
8270E
ND
0.040
mg/L
1
3+4-Methylphenol
106-44-5
8270E
ND
0.040
mg/L
1
Nitrobenzene
98-95-3
8270E
ND
0.040
mg/L
1
Pentachlorophenol
87-86-5
8270E
ND
0.20
mg/L
1
Pyridine
110-86-1
8270E
ND
0.040
mg/L
1
2,4,5-Trichlorophenol
95-95-4
8270E
ND
0.040
mg/L
1
2,4,6-Trichlorophenol
88-06-2
8270E
ND
0.040
mg/L
1
Run 1 Acceptance
Surrogate Q % Recovery Limits
2-Fluorobiphenyl
79
37-129
2-Fluorophenol
43
24-127
Nitrobenzene-d5
74
38-127
Phenol-d5
47
28-128
Terphenyl-d14
104
10-148
2,4,6-Tribromophenol
68.
41-144
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range
NO = Not detected at or above the LOQ N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 7 of 14

PKim7T.Moss
City of Kings Mountain
Pilot Creek WPCF
RT 6, 200 Potts Creek Road
Kings Mountain, NC 28086
AUGUST 08, 2005
ATTN: Ms. Debra Watts
Division of Water Quality
Groundwater Section
1632 Mail Service Center
Raleigh, NC 27699-1636
SUBJECT: City of. Kings Mountain Monitoring Wells
Dear Ms. Watts:
This letter is in response to our phone conversation August 05, 2005 concerning the monitoring wells
located at the Pilot Creek WPCF.
I would like to request that the Division of Water Quality Groundwater Section rescind our monitoring
wells listed under permit number NC0020737. The Well Identification Numbers are as follows: Q73V4,
Q73V5 and Q73V7. The request for installing and monitoring these wells were due to the ground bottom
aeration basin, which was renovated in the late 1990's, and put back into service.
In addition, I would like to request the Groundwater Section to rescind our Non -Discharge monitoring
wells listed under permit number WQ0005065. The Well Identification Numbers are as follows: Q73V1,
Q73V6, Q73V3 and Q73V8. The monitoring well ID # Q73V6 replaced monitoring well ID # Q73V2. The
monitoring well ID # Q73V8 was requested to be drilled in the old abandon city's trash landfill, adjacent to our
Monofill, by Mr. David Eudy of the Mooresville Regional Office.
The city was granted permission to rescind the Monofill permit # WQ0012760, and to my knowledge,
there has been no biosolids applied since around 1993, which at that time the Cleveland County Landfill was
receiving our biosoilds. Then we started land applying our biosolids which was contracted out to Dennis Key
with Southern Soil Builders for about 4 years, and due to the cost difference we decided by hauling the solids
our self to the Cleveland County Landfill we could at least save a little.
I realize that some of this information may be irrelevant but I wanted to make sure that all factors were
taken into consideration.

r7�ank You for your time and help. If I can supply you with any further information, please do not
hestaeo contact me at 704-739-7131 or 704-747-4799. My e-mail address is kimtmoss!a�,gusaol. com and our
fax number is 704-734-4528.
Respectfully Submitted,
Kim T. Moss
Wastewater Treatment Plant Supervisor

On -Site -Inspection Report
LABORATORY NAME:
NPDES PERMIT #:
ADDRESS:
CERTIFICATE #:
DATE OF INSPECTION:
TYPE OF INSPECTION:
AUDITOR(S):
LOCAL PERSON(S) CONTACTED:
I. INTRODUCTION:
"Pilot Creek" c/o City of King's Mountain
NC0020737
200 Potts Creek Road
King's Mountain, NC 28086
222
October 12, 2017
Municipal Maintenance
Beth Swanson and Jason Smith
`Jason Davis, Richelle Meek, Kathy Moses and Lee Bailey
This laboratory was inspected by representatives of the North Carolina Wastewater/Groundwater
Laboratory Certification (NC WW/GW LC) program to verify its compliance with the requirements
of 15A NCAC 2H .0800 for the analysis of environmental samples.
II. GENERAL COMMENTS:
The laboratory is neat and well -organized. The analysts were forthcoming and expressed interest
in the inspection process.
All required Proficiency Testing (PT) Samples have been analyzed and the laboratory has fulfilled
its PT requirements for the 2017 PT Calendar Year.
The laboratory submitted their Quality Assurance (QA) and/or Standard Operating Procedures
(SOP) document(s) in advance of the inspection. These documents were reviewed and editorial
and substantive revision requirements and recommendations were made by this program
outside of this formal report process. Although subsequent revisions were not requested to be
submitted, they must be completed by December 8, 2018.
The laboratory is reminded that any time changes are made to laboratory procedures, the
laboratory must update the QA/SOP document(s) and inform relevant staff. Any changes made
in response to the pre -audit review or to Findings, Recommendations or Comments listed in this
report must be incorporated to insure the method is being performed as stated, references to
methods are accurate, and the QA and/or SOP document(s) is in agreement with each
approved practice, test, analysis, measurement, monitoring procedure or regulatory
requirement being used in the laboratory. In some instances, the laboratory may need to create
an SOP to document how new functions or policies will be implemented.
The laboratory is also reminded that SOPs are intended to describe procedures exactly as they
are to be performed. Use of the word "should" is not appropriate when describing requirements
(e.g., Quality Control (QC) frequency, acceptance criteria, etc.). Evaluate all SOPs for the proper
use of the word "should".

Page 2
#222 "Pilot Creek" cb City of King's Mountain
Requirements that reference 15A NCAC 2H .0805 (a) (7) (A), stating "All analytical data pertinent
to each certified analysis must be filed in an orderly manner so as to be readily available for
inspection upon request", are intended to be a requirement to document information pertinent to
reconstructing final results and demonstrating method compliance. Use of this requirement is not
intended to imply that existing records are not adequately maintained unless the Finding speaks
directly to that.
Contracted analyses are performed by K & W Laboratories (Certification # 559).
Approved Procedure documents for the analysis of the facility's currently certified Field
Parameters were provided at the time of the inspection.
III. FINDINGS, REQUIREMENTS, COMMENTS AND RECOMMENDATIONS:
Documentation
A. Finding: Laboratory thermometers are not consistently labeled with their respective
correction factors.
Requirement: The thermometer/meter readings must be less than or equal to 10C from
the NIST certified or NIST traceable thermometer reading. The documentation must
include the serial number of the NIST certified thermometer or NIST traceable
thermometer that was used in the comparison. Also document any correction that applies
(even if zero) on both the thermometer/meter and on a separate sheet to be filed. Ref: NC
WW/GW LC Policy.
Comment: Temperature corrections of zero are not being documented on the
thermometers.
B. Finding: The weights used to check the balance are not documented to be Class S or
equivalent. This is considered pertinent data.
Requirement: The analytical balance must be checked with one class S, or equivalent,
standard weight each day used and at least three standard weights quarterly. The values
obtained must be recorded in a log and initialed by the analyst. 15A NCAC 2H .0805 (a)
(7) (K)•
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: Per NC WW/GW LC Policy, ASTM Class 1 weights (20 g to 25 kg) and ASTM
Class 2 weights (10 g to 1 mg) are equivalent to the NBS Class S weights specified in 15A
NCAC 2H .0805 (a) (7) (K).
C. Finding: There is no documentation of the weight verification. This is considered pertinent
data.
Requirement: ASTM Class 1 and 2 weights must be verified at least every 5 years. ASTM
Class 1 weights (20 g to 25 kg) and ASTM Class 2 weights (10 g to 1 mg) are equivalent
to the NBS Class S weights specified in 15A NCAC 2H .0805 (a) (7) (K). Ref: NC
WW/GW LC Policy.

Page 3
#222 "Pilot Creek" c/o City of King's Mountain
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: The laboratory stated that weights are verified by a balance technician
annually, but the documentation is not maintained.
D. Finding: The laboratory needs to increase the traceability documentation of purchased
materials and reagents, as well as documentation of standards and reagents prepared in
the laboratory.
Requirement: All chemicals, reagents, standards and consumables used by the
laboratory must have the following information documented: Date received, Date Opened
(in use), Vendor, Lot Number, and Expiration Date (where specified). A system (e.g.,
traceable identifiers) must be in place that links standard/reagent preparation information
to analytical batches in which the solutions are used. Documentation of solution
preparation must include the analyst's initials, date of preparation, the volume or weight of
standard(s) used, the solvent and final volume of the solution. This information as well as
the vendor and/or manufacturer, lot number, and expiration date must be retained for
primary standards, chemicals, reagents, and materials used for a period of five years.
Consumable materials such as pH buffers, lots of pre -made standards and/or media,
solids and bacteria filters, etc. are included in this requirement. Ref: NC WW/GW LC
Policy.
Comment: The laboratory was not maintaining a supply receipt log or including weights or
volumes of reagents in the preparation log. An example of a receipt log was given to the
laboratory during the inspection.
E. Finding: Units of measure are not consistently documented. This is considered pertinent
information.
Requirement: All laboratories must use printed laboratory bench worksheets that include
a space to enter the signature or initials of the analyst, date of analyses, sample
identification, volume of sample. analyzed, value from the measurement system, factor and
final value to be reported and each item must be recorded each time samples are
analyzed. Ref: 15A NCAC 2H .0805 (a) (7) (H).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A
NCAC 2H .0805 (a) (7) (A).
Requirement: The following must be documented in indelible ink whenever sample
analysis is performed: units of measure. Ref: NC WW/GW LC Approved Procedure for
the Analysis of Specific Conductance (Conductivity) and NC WW/GW LC Approved
Procedure for the Analysis of pH.
Comment: Units of measure were not documented in the following places:
• BOD benchsheet columns labeled as follows - Initial DO, 5th day DO, 02, Seed
Correction, Corrected 02 and Cl2.
• Conductivity benchsheet - conductivity obtained value column.
• pH calibration log - all pH values

Page 4
#222 "Pilot Creek" c/o City of King's Mountain
Proficiency Testing
F. Finding: The laboratory does not have a documented plan for PT procedures.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Requirement: Laboratories must have a documented plan (this is usually detailed in the
laboratory's Quality Assurance Manual or may be a separate Standard Operating
Procedure (SOP) of how they intend to cover the applicable program requirements for
Proficiency Testing per their scope of accreditation. This plan shall cover any commercially
available PT Samples - and any inter -laboratory organized studies, as applicable. The
laboratory must also be able to explain when PT Sample analysis is not possible for
certain methods and provide a description of what the laboratory is doing in lieu of
Proficiency Testing. This shall be detailed in the plan. The plan must also address the
laboratory's process for submission of PT results and related Corrective Action Reports
(CARs). Ref: Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
Requirement: SOPs must address situations where the instructions from the Accredited
PT Provider for the preparation, analysis or result calculations would constitute a deviation
from the laboratory's routine procedure. Examples of this may include how low-level
samples will be analyzed, including concentration of the sample or adjustment of the
normality of a titrant. These instructions shall be followed when the concentration of a PT
sample falls below the range of their routine analytical method. Instructions shall also be
included in the laboratory's SOP for how high-level samples will be analyzed, including
preparation of multiple dilutions of the sample. These instructions will be followed when the
concentration of a PT falls above the range of their routine analytical method. Ref:
Proficiency Testing Requirements, May 31, 2017, Revision 2.0.
G. Finding: The laboratory is not documenting PT Sample analyses in the same manner as
routine Compliance Samples.
Requirement: As specified in 15 NCAC 2H .0800, in order to meet the minimum
standards for Certification, laboratories must use acceptable analytical methods. The
acceptable methods are those defined or referenced in the current State and federal
regulations for the environmental matrix being tested. All samples, (including PT
Samples) that are, or that may, be used for Certification purposes, must be analyzed using
approved methods only. All PT Samples are to be analyzed and the results reported in a
manner consistent with the routine analysis and reporting requirements of Compliance
Samples. Laboratories must document any exceptions. All PT Sample analyses must be
recorded in the daily analysis records as for any Compliance Sample. This serves as the
permanent laboratory record. Ref: Proficiency Testing Requirements, May 31, 2017,
Revision 2.0.
Quality Control
Recommendation: The sample storage refrigerator temperature often reaches 6 °C. It is
recommended that the operating temperature be set to a lower temperature to avoid violations in
case of larger variations.

Page 5
#222 "Pilot Creek" c/o City of King's Mountain
H. Finding: Data that does not meet all QC requirements is not qualified on the electronic
Discharge Monitoring Report (eDMR).
Requirement: When quality control (QC) failures occur, the laboratory must attempt to
determine the source of the problem and must apply corrective action. If data qualifiers are
used to qualify samples not meeting QC requirements, the data may not be useable for
the intended purposes. A notation must be made on the electronic Discharge Monitoring
Report (eDMR) form, when any required sample quality control does not meet specified
criteria, and another sample cannot be obtained. Ref: NC WW/GW LC Policy.
Comment: Fecal Coliform duplicates not meeting the acceptance criterion are not
qualified. The laboratory established acceptance limit for Relative Percent Difference
(RPD) of duplicates is 10%, which is often not met and the results are not qualified.
Recommendation: It is recommended that the laboratory increase the RPD above 10 %
for duplicates with plate counts of >_ 20 cfu and establish a criterion of plus or minus a
certain number of colonies for plates with less than 20 colonies. In this case, a criterion for
duplicate plates that are not within the same acceptance range (e.g., 16 and 22 cfu) would
also need to be established.
Comment: Data is not qualified when the average of BOD dilution water blank values are
>0.20 mg/L.
Bacteria — Coliform Fecal — Standard Methods, 9222 D-1997 (MF) (Aqueous)
Finding: Consumable materials used for the Fecal Coliform MF method are not properly
tested.
Requirement: Before a new lot of consumable materials are used for the Fecal Coliform
MF method, those materials must be tested and compared to those currently in use to
ensure they are reliable. Consumable materials included in this requirement are:
membrane filters and/or pads (often packaged together) and media. It is recommended
that only one consumable be tested at a time. At a minimum, make single analyses on
five positive samples that will yield 20-60 colonies for both the current lot and the new lot.
There are two options for determining acceptance of results: .
Option 1: Follow the acceptance criteria described in Standard Methods 9020 B-2005 5. (fl
(2) (a) and (b).
Option 2: Compare the average colony count of each five -sample set and evaluate against
your routine sample duplicate acceptance criterion. Ref: NC WW/GW LC Policy. Please
obtain (i.e., purchase or borrow) a new lot of media and perform the consumable
testing on your current media and submit the results of this study with your
response to this report.
Comment: The laboratory conducts a comparison of the filter and pad packaged together,
but not the media. In addition, the comparison test is not performed per NC WW/GW LC
Policy. Dilutions of 1, 5, 100 and 100 mL are analyzed for the old and new lot. This does
not provide five dilutions of the same volume to compare and the resulting plate counts are
often not within 20-60 colonies.
J. Finding: The Fecal Coliform incubator temperature is not being monitored and recorded
twice daily.

Page 6
#222 "Pilot Creek" c/o City of King's Mountain
Requirement: When incubator is in use, monitor and record calibration -corrected
temperature twice daily. Ref: Standard Methods, 9020 B- 2005 (4) (n).
Comment: The incubator temperature is checked and recorded once per day.
K. Finding: The laboratory is not checking and documenting the pH of prepared media. This
is considered pertinent information.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Requirement: Rehydrate product in 1 L water containing 10 mL 1 % rosolic acid in 0.2 N
NaOH. Heat to near boiling, promptly remove from heat, and cool below 50 'C. If agar is
used, dispense 5- to 7-mL quantities to 50 x 12-mm petri plates and let solidify. Final pH
should be 7.4 ± 0.2. Ref: Standard Methods, 9222 D-1997. (1) (a).
L. Finding: Heat -indicating tape is not used with all materials each sterilizing cycle.
Requirement: Use heat -indicating tape to identify supplies and materials that have been
sterilized. Ref: Standard Methods 9020 B-2005. (4) (h).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
Comment: This is considered pertinent information and documentation must be
maintained.
M. Finding: The laboratory is not checking the autoclave operating temperature weekly with
a minimum/maximum thermometer.
Requirement: Record items sterilized temperature, pressure and time for each run.
Optimally use a recording thermometer. Check operating temperature weekly with a
minimum/maximum thermometer. Ref: Standard Methods, 9020 B-2005. Table 9020:1.
Requirement: Each laboratory requesting certification must contain or be equipped with
the glassware, chemicals, supplies and equipment required to perform all analytical
procedures included in their certification. Ref: 15A NCAC 02H .0805 (a) (6) (H).
Comment: The laboratory does not own a maximum registering thermometer.
N. Finding: The laboratory does not document all required information in the autoclave log.
Requirement: Record items sterilized and sterilization temperature along with total run-
time (exposure to heat), actual time period at sterilization temperature, set and actual

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#222 "Pilot Creek" c/o City of King's Mountain
pressure readings, and initials of responsible person for each cycle. Ref: Standard
Methods 9020 B- 2005. (4) (h).
Comment: The laboratory documents the items sterilized, time the autoclave was started
and set temperature and pressure of the autoclave. In addition to the items listed in the
requirement, autoclave logs must document that the heat -indicating tape was positive and
the temperature of the maximum reading thermometer when used.
O. Finding: The purchased Phosphate Buffer is not documented by the manufacturer or
verified by the laboratory to be pH 7.2 ± 0.5 S.U. This is considered pertinent information.
Requirement: Stock phosphate buffer solution — Adjust to pH 7.2 ± 0.5 with 1 N sodium
hydroxide (NaOH). Ref: Standard Methods, 9050 C-2005. (1) (a) (1).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: The laboratory may either check the pH of the Phosphate Buffer upon receipt
or obtain a copy of the Certificate of Analysis from the manufacturer.
P. Finding: Fecal bottle sterility is not documented by the manufacturer or verified by the
laboratory. This is considered pertinent information.
Requirement: Minimally test for sterility one sample bottle per batch sterilized in the
laboratory, or at a set percentage such as 1 to 4%. This is performed by adding sterile
dilution/rinse water to the bottle after sterilization and then subsequently analyzing it as a
sample. Document results. If sample bottles or bags are purchased pre -sterilized,
verification of sterilization is not required if the laboratory maintains copies of the
Certificate of Analysis from the vendor. Ref: NC WW/GW LC Policy.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: Pre -sterilized bottles are purchased but a Certificate of Analysis is not
obtained from the vendor and a sterility test is not performed.
Q. Finding: Culture positive plates are not analyzed with each batch of prepared media.
Requirement: A culture positive must be analyzed with each batch of prepared media and
once per week for purchased ready -to -use media. A sample volume that yields a
countable plate must be analyzed so that individual colonies may be verified to have
proper morphology (i.e. color, shape, size, surface appearance). Ref: NC WW/GW LC
Policy.
R. Finding: Plate comparison counts are not being performed.
Requirement: For routine performance evaluation, repeat counts on one or more positive
samples at least monthly, record results, and compare the counts with those of other
analysts testing the same samples. Replicate counts for.the same analyst should agree
within 5% (within analyst repeatability of counting) and those between analysts should
agree within 10% (between analysts reproducibility of counting). If they do not agree,

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#222 "Pilot Creek" c/o City of King's Mountain
initiate investigation and any necessary corrective action. Ref: Standard Methods, 9020 B-
2005. (9) (a).
Comment: The primary analyst will recount one plate monthly and compare the two
values and any auxiliary analysts will count the same plate twice comparing the two values
and compare the values with the main analyst. If any comparisons do not agree with the
established criteria, retraining may be necessary. All counts must be documented.
BOD — Standard Methods, 5210 B-2001 (Aqueous)
Recommendation: It is recommended that the column labeled "Sample W, which is used to
document seed volume, be renamed to "Seed Volume".
Comment: The column of mercury in the BOD incubator thermometer was separated. North
Carolina Administrative Code, 15A NCAC 02H .0805 (a) (6) (H) states: Each laboratory requesting
certification must contain or be equipped with the following: Glassware, chemicals, supplies, and
equipment required to perform all analytical procedures included in their certification. Acceptable
corrective action (i.e., the broken thermometer was replaced with a properly verified non -mercury
thermometer) was performed by the laboratory and approved by the auditor during the inspection.
No further response is necessary for this Finding.
S. Finding: The seed correction value is not consistently documented. This is considered
pertinent information.
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15A NCAC
2H .0805 (a) (7) (A).
Comment: The seed correction value is not documented for all seeded samples. Only
dilutions that are used to report a result have the seed correction applied to it, which
makes it appear the other dilutions are not seeded.
T. Finding: The laboratory does not use sodium sulfite to neutralize residual chlorine.
Require: If residual chlorine is present, dechlorinate sample. In some samples chlorine will
dissipate within 1 to 2 h of standing in the light. This dissipation often occurs during
sample transport and handling. For samples in which chlorine residual does not dissipate
in a reasonably short time. Destroy chlorine residual by adding Na2SO3 solution. Ref:
Standard Methods, 5210 B-2001. (4) (b) (2).
Comment: Chlorine neutralization is not needed very often but when needed, the
laboratory uses sodium thiosulfate instead of sodium sulfite. The procedure for
determining the amount of sodium sulfite that must be added to each sample is attached
at the end of this report.
U. Finding: The laboratory is not seeding all disinfected wastes and wastes having pH values
less than 6 or greater than 8 S.U.
Requirement: Some samples (for example, some untreated industrial wastes, disinfected
wastes, high -temperature wastes, wastes having pH values less than 6 or greater than 8,
or wastes stored more than 6 h after collection) do not contain a sufficient microbial
population. Seed such samples by adding a population of suitable microorganisms. Ref:
Standard Methods, 5210 B-2001. (4) (d).

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#222 "Pilot Creek" c/o City of King's Mountain
Requirement: Check pH; if it is not between 6.0 and 8.0, adjust sample temperature to 20
± 3 °C, then adjust pH to 7.0 to,7.2 using a solution of sulfuric acid or sodium hydroxide of
such strength that the quantity of reagent does not dilute the sample by more than 0.5%.
The pH of dilution water should not be affected by the lowest sample dilution. Always seed
samples that have been PH adjusted. Ref: Standard Methods, 5210 B-2001. (4) (b) (1).
Comment: The laboratory only seeds samples stored more than 6 hours after collection.
To keep the process simpler, it is acceptable to seed all samples, even if they do not fall
into one of the above categories.
V. Finding: Extra nutrient, mineral, and buffer solutions are not added to the BOD bottles
containing more than 67% (i.e., > 201 mL) sample.
Requirement: When a bottle contains more than 67% of the sample after dilution,
nutrients may be limited in the diluted sample and, subsequently, reduce biological activity.
In such samples, add the nutrient, mineral, and buffer solutions (3a through e) directly to
individual BOD bottles at a rate of 1 mUL (0.30 mU300-mL bottle) or use commercially -
prepared solutions designed to dose the appropriate bottle size. Ref: Standard Methods,
5210 B-2001. (5) (c) (2).
W. Finding: The Dissolved Oxygen (DO) meter is not properly checked for drift at the end of
the analytical series.
Requirement: If the membrane electrode method is used, take care to eliminate drift in
calibration between initial and final DO readings. Ref: Standard Methods, 5210 B-2001. (5)
(g)•
Requirement: Immediately after calibration, measure the DO of a BOD bottle of dilution
water. Stopper the bottle. Document the concentration on the benchsheet (day one initial
drift check). At the end of the sample set reanalyze the drift check bottle and document the
concentration (day one final drift check). The laboratory should verify the DO Meter
calibration throughout the sample set if needed. Repeat process on Day 5. If the meter
drifts more than 0.20 mg/L, recalibrate meter and reanalyze all samples since the last drift
check. Ref: NC WW/GW LC Policy.
Comment: The laboratory places the DO probe back in the air calibration bottle at the
end of analysis and compares the value to the meter reading obtained immediately after
calibration.
Recommendation:' It is recommended that drift be checked throughout the sample run for
larger sets since all bottles must be reanalyzed since calibration (or last acceptable drift
check) if the check is unacceptable.
X. . Finding: Multiple dilution water blanks are being analyzed, but not averaged.
Requirement: Multiple dilution water blanks in the same batch using the same dilution
water are to be treated as replicates and averaged. The average of the dilution water
blanks in a batch must not be >0.20 mg/L. Ref: "BOD Multiple Dilution Water Blanks",
Standard Methods Joint Editorial Board memorandum dated August 1, 2014.
Y. Finding: The laboratory reports <2 mg/L without qualification when no 300-mL dilution is
analyzed and no dilution depletes at least 2 mg/L.

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#222 "Pilot Creek" c/o City of King's Mountain
Requirement: The reporting limit for BOD5/CBOD5 is 2 mg/L. Only bottles giving a
minimum Dissolved Oxygen (DO) depletion of 2.0 mg/L and a residual DO of 1.0 mg/L
after 5 days of incubation are considered to produce valid data. It is not acceptable to
elevate the reporting limit and report as less than the value that would have been obtained
if the dilution had depleted the required 2.0 mg/L. It is required that the data be flagged as
a quality control failure if it does not deplete the 2.0 mg/L. The only exception to this is
when a 100% sample does not deplete 2.0 mg/L. In this case, report the value as <2.0
mg/L without qualification. Ref: NC WW/GW LC Policy.
Comment: Instead of reporting samples as <2 mg/L, the calculated result of the dilution
with the most sample is to be reported with qualification stating that the sample did not
deplete 2 mg/L.
Recommendation: It is recommended that the laboratory analyze a 100% (i.e., 300 mL)
sample dilution so that qualification of results is not necessary. The largest volume of
sample currently analyzed is usually 250 mL.
Z. Finding: Documentation does not demonstrate that the initial DO is measured within 30
minutes of sample preparation. This is considered pertinent data.
Requirement: After preparing dilution, measure initial DO within 30 min. Ref: Standard
Methods, 5210 B-2001. (5) (g).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
AA. Finding: BOD bottles are not filled to approximately two-thirds full with dilution water or
sample prior to adding seed.
Requirement: Fill each BOD bottle approximately two-thirds full with dilution water. Add
appropriate amounts of seed suspension (¶ d below) and nitrification inhibitor (¶ a below)
to the individual BOD bottles. Ref: Standard Methods, 5210 B-2001. (5) (c) (2).
Comment: Seed is being added to bottles containing only GGA or small amounts of
sample before adding a sufficient volume of dilution water.
BB. Finding: The laboratory does not decant the supernatant after seed preparation.
Requirement: Decant the supernatant to another clean container (after preparation),
carefully leaving the bran behind. For the remainder of the test, gently stir and pipette
aliquots to BOD bottles from the supernatant. Ref: PolySeed® Manufacturer's Instructions.
Comment: Bran often gets incorporated into the seeding material that is added to BOD
bottles.
CC. Finding: PolySeed® material is used greater than 6 hours after preparation.
Requirement: The PolySeed® solution will remain active for up to 6 hours. If your test
runs over 6 hours, it is necessary to prepare fresh solution. Ref: PolySeed@ FAQs. How
long is the prepared PolySeed® good for?
Ref: http://www.polyseed.com/fags/fags polyseed.php.

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#222 "Pilot Creek" c/o City of King's Mountain
Comment: The laboratory would use one batch of PolySeed® throughout the week until
the material was gone.
DD. Finding: Glucose and glutamic acid reagents are not dried at 103 °C for 1 hour before
use.
Requirement: Glucose-glutamic acid solution: Dry reagent -grade glucose and reagent -
grade glutamic acid at 103 °C for 1 h. Ref: Standard Methods, 5210 B-2001. (3) (h).
Nitrogen, Ammonia — Standard Methods, 4500 NH3 D-1997 (Aqueous)
Comment: At the time of the inspection, the laboratory was Decertified for this parameter due to
two consecutive unacceptable PT results. The laboratory completed all Recertification
requirements and was Recertified effective October 30, 2017.
Comment: The laboratory does not need to confirm the pH of samples with pH strips after NaOH
addition since it contains color indicator.
EE: Finding: The volume of 10N NaOH added to standards and samples is not documented.
This is considered pertinent information.
Requirement: Add a sufficient volume of 10N NaOH solution (1 mL usually is sufficient) to
raise pH above 11. If the presence of silver or mercury is possible, use NaOH/EDTA
solution in place of NaOH solution. If it is necessary to add more than 1 mL of either
NaOH or NaOH/EDTA solution, note volume used, because it is required for subsequent
calculations. Ref: Standard Methods, 4500 NH3 D-1997. (4) (b).
Requirement: Measurement of samples: Dilute if necessary to bring NH3-N concentration
to within calibration curve range. Place 100 mL sample in 150-mL beaker and follow
procedure in ¶ b above. Record volume of 10N NaOH added. Ref: Standard Methods,
4500 NH3 D-1997. (4) (e).
Requirement: All analytical data pertinent to each certified analysis must be filed in an
orderly manner so as to be readily available for inspection upon request. Ref: 15 NCAC
2H .0805 (a) (7) (A).
Comment: The laboratory's normal procedure is to add 2 mL of the color indicating NaOH
to each standard and sample.
Recommendation: It is recommended that a statement be added to the benchsheet
stating: 2 mL of NaOH added to standards and samples unless otherwise noted.
FF. Finding: The laboratory does not check and then document the pH of samples upon
receipt to verify preservation.
Requirement: A record of date collected, time collected, sample collector, and use of
proper preservatives must be maintained. Each sample must clearly indicate the State of
North Carolina collection site on all record transcriptions. Ref: 15 NCAC 2H .0805 (a) (7)
(M)
Requirement: Basic documentation requirements to verify that sample preservation and
hold time requirements are met include: Preservation status; temperature and chemical

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#222 "Pilot Creek" c/o City of King's Mountain
preservative(s) used (i.e., name of preservative, pH<2, pH>9, etc., where pH is not
adequately adjusted document the measured pH). Ref: NC WW/GW LC Policy.
GG. Finding: A calibration blank and calibration verification standard (mid -range) are not
analyzed.
Requirement: The calibration blank and calibration verification standard (mid -range) must
be analyzed initially (i.e., prior to sample analysis), after every tenth sample and at the end
of each sample group to check for carry over and calibration drift. If either fall outside
established quality control acceptance criteria, corrective action must be taken (e.g.,
repeating sample determinations since the last acceptable calibration verification,
repeating the initial calibration, etc.). Ref: NC WW/GW LC Policy.
HH. Finding: A method blank is not analyzed.
Requirement: Method blank (MB): Include at least one MB daily or with each batch of 20
or fewer samples, whichever is more frequent. Ref: Standard Methods, 4020 B-2011. (2)
(d).
Requirement: A reagent blank (method blank) consists of reagent water (see section
1080) and all reagents (including preservatives) that normally are in contact with a sample
during the entire analytical procedure. The reagent blank is used to determine whether,
and how much, reagents and the preparative analytical steps contribute to measurement
uncertainty. Ref: Standard Methods, 1020 B-2011. (5).
II. Finding: A laboratory -fortified blank (LFB) is not analyzed.
Requirement: Include at least one LFB daily or per each batch of 20 or fewer samples.
Ref: Standard Methods, 4020 B-2011. (2) (e).
Requirement: A laboratory -fortified blank [laboratory control standard (LCS)] is a reagent
water sample (with associated preservatives) to which a known concentration of the
analyte(s) of interest has been added. An LFB is used to evaluate laboratory performance
and analyte recovery in a blank matrix. Ref: Standard Methods, 1020 B-2011. (6).
Comment: The laboratory analyzed an LFB with the remedial PT in October, but was not
analyzing them with compliance samples prior to Decertification.
JJ. Finding: The laboratory is not evaluating the recoveries of the back -calculated standards.
Requirement: Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification.
Supporting records shall be maintained as evidence that these practices are being
effectively carried out. Ref: 15A NCAC 2H .0805 (a) (7).
Requirement: The back -calculated and true concentrations should agree within ± 10%,
unless different criteria are specified in an individual method. At the lower limit of the
operational range, acceptance criteria are usually wider. Such criteria must be defined in
the laboratory's QA plan. Ref: Standard Methods, 4020 B-2011. (2) (a).
Comment: The standards were back -calculated because it was automatically performed
by the spreadsheet the laboratory is using. They were not evaluating the -recoveries
against any acceptance criteria and the data showed that recoveries were not always

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#222 "Pilot Creek" c/o City of King's Mountain
within 10%, which it should be for concentrations above the lower limit of the operational
range.
Residue. Dissolved 180 C — Standard Methods, 2540 C-1997 (Aqueous)
Comment: The laboratory does not analyze Compliance Samples for this parameter. They
analyze mixed liquor for process control.
Residue, Suspended — Standard Methods, 2540 D-1997 (Aqueous)
Comment: It is recommended that QC acceptance criteria be printed on the benchsheet.
KK. Finding: The laboratory does not report results of all tests on the characteristics of the
effluent.
Requirement: The results of all tests on the characteristics of the effluent, including but
not limited to NPDES permit monitoring requirements, shall be reported on the monthly
report forms. Ref: 15A NCAC 26 .0506 (b) (3) (J).
Comment: The laboratory analyzes the composite effluent sample as stated in their
permit for reporting purposes. An effluent grab sample, collected at the permitted location,
is also analyzed but not reported.
Recommendation: It is recommended that a grab sample be collected immediately prior
to the last control device. The sample would then be considered process control and not
be required to be reported.
ILL. Finding: The laboratory is not analyzing a volume of sample to yield a minimum of 2.5
mg dried residue.
Requirement: Choose sample volume to yield between 2.5 and 200 mg dried residue. If
volume filtered fails to meet minimum yield, increase sample volume up to 1 L. Ref:
Standard Methods, 2540 D-1997 (3) (b).
Comment: Typically, 300 mL of sample is analyzed and the minimum of 2.5 mg is not
consistently obtained.
Comment: The range of measurement for Suspended Residue is determined by the
optimum solids loading on the filter, which can be controlled by adjusting the volume of
sample filtered. The method -defined reporting limit for Suspended Residue is 2.5 mg/L
when filtering 1 L of sample. This sample volume may not be necessary to demonstrate
compliance with regulatory limits; however, it is not acceptable to routinely report less -than
results using a reporting limit greater than 2.5 mg/L. A copy of this report will be shared
with the regional office.
MM. Finding: The laboratory is not basing the reporting limit on the minimum weight gain
required by the method.
Requirement: The minimum weight gain allowed by any approved method is 2.5 mg.
Choose sample volume to yield between 2.5 and 200 mg dried residue. This establishes a
minimum reporting value of 2.5 mg/L when 1000 mL of sample is analyzed. If complete
filtration takes more than 10 minutes increase filter diameter or decrease sample volume.
In instances where the weight gain is less than the required 2.5 ma, the value must be

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#222 "Pilot Creek" c/o City of King's Mountain
reported as less than the appropriate value based upon the volume used. Ref: NC
WW/GW LC Policy.
Residue, Dissolved 180 C — Standard Methods, 2540 C-1997 (Aqueous)
Residue, Suspended — Standard Methods, 2540 D-1997 (Aqueous)
NN. Finding: The samples are not weighed to constant weight, nor is an annual multiple
weighing study to verify the adequacy of the drying time, performed.
Requirement: Constant weights must be documented. The approved methods require the
following: "Repeat the cycle of drying, cooling, desiccating, and weighing until a constant
weight is obtained or until the weight change is less than 4% of the previous weight or 0.5
mg, whichever is less." In lieu of this, an annual study documenting the time required to
dry representative samples to a constant weight may be performed. Verify minimum daily
drying time is greater than or equal to the time used for the initial verification study drying
cycle. Drying cycles must be a minimum 1 hour for verification. Ref: NC WW/GW LC
Policy.
Chlorine, Total Residual — Standard Methods, 4500 Cl G-2000 (Aqueous)
00. Finding: The annual 5-standard calibration curve verification did not pass the individual
standard recovery criteria.
Requirement: The values obtained must not vary by more than 10% of the known value
for standard concentrations greater than or equal to 50 mg/L and must not vary by more
than 25% of the known value for standard concentrations less than 50 mg/L. The overall
correlation coefficient of the curve must be >_0.995. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Total Residual Chlorine. Please submit a passing curve
verification with the report reply.
Comment: Two different analysts prepared standard concentrations of 15, 50, 200, 500,
1000 and 2000 pg/L and verified the factory curve separately. One curve failed the 15 pg/L
(i.e., 22 pg/L), 200 pg/L (i.e., 150 pg/L) and 500 pg/L (i.e., 446 pg/L) standards. The other
curve failed the 50 pg/L (i.e., 33 mg/L) and 500 pg/L (i.e., 423 pg/L) standards.
Comment: Only one curve verification needs to be performed per year.
Recommendation: It is recommended that the laboratory verify the curve at the following
concentrations: 15, a concentration between 15 and 50, 50, 200 and 400 pg/L.
PP. Finding: The laboratory. is not analyzing a reagent blank with prepared standards.
Requirement: Reagent Blank: A reagent blank (sometimes also referred to as a method
blank) is only required when laboratory water is used to make quality control and/or
calibration standards. If you are using a sealed standard (e.g., gel) for your daily check
standard, a reagent blank would only be analyzed when preparing the annual 5-point
calibration curve or 5 annual calibration curve verification standards. Ref: NC WW/GW LC
Approved Procedure for the Analysis of Total Residual Chlorine.
Comment: A reagent blank is made from the same laboratory water source used to make
QC and/or calibration standards with DPD. The concentration of reagent blanks must not
exceed 50% of the reporting limit (i.e., the lowest calibration or calibration verification

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#222 "Pilot Creek" c/o City of King's Mountain
standard concentration), unless otherwise specified by the reference method, or corrective
action must be taken.
Conductivity —Standard Methods, 2510 B-1997 (Aqueous)
QQ. Finding: The laboratory does not calibrate the meter prior to analysis of samples each
day compliance monitoring is performed.
Requirement: Instruments are to be calibrated according to the manufacturer's calibration
procedure prior to analysis of samples each day compliance monitoring is performed. For
most meters, this is a one -point calibration. Ref: NC WW/GW LC Approved Procedure for
the Analysis of Specific Conductance (Conductivity).
Comment: The laboratory checks the conductivity meter with a 100 Nmho/cm standard
each day and did not know that the conductivity meter could be calibrated. The
instructions for calibrating the instrument can be found in Section 4.1 Cell Calibration, in
the YSI 3100 instrument manual.
Comment: An additional standard was also checked, but it was the 100 Nmho/cm
standard diluted 1:1 and the laboratory thought it was 50 Nmho/cm. It was explained that
conductivity standards cannot be diluted in that way. The analyst noted they will
purchase an additional standard.
RR. Finding: The Automatic Temperature Compensator (ATC) check is not being properly
performed.
Requirement: The ATC must be verified prior to initial use and annually (i.e., 12 months)
thereafter at two temperatures by analyzing a standard or sample at 25°C (i.e., the
temperature to which conductivity values are reported) and a temperature(s) that brackets
the temperature ranges of the environmental samples routinely analyzed. This may require
the analysis of a third temperature reading that is > 250C (see #3 below). The manner in
which the ATC is verified may depend upon the meter's capabilities and the
manufacturer's instructions. The following is one option.
1. Pour an adequate amount of conductivity standard or sample into a beaker or
other container and analyze at 25°C. Document the temperature and conductivity
value.
2. Lower the temperature of the standard or sample (e.g., by placing the container in
a refrigerator or ice chest) to less than the lowest anticipated sample temperature
and analyze. Document the temperature and conductivity value.
3. If samples greater than 250C are to be analyzed, perform the following additional
step: Raise the temperature above 250C to greater than the highest anticipated
sample temperature (e.g., by placing the container in a hot water bath) and
analyze. Document the temperature and conductivity value.
As the temperature increases or decreases, the value of the conductivity standard or
sample must be within ±10% of the true value of the standard or ±10% of the value of the
sample at 25°C. If not, corrective action must be taken. Ref: NC WW/GW LC Approved
Procedure for the Analysis of Specific Conductance (Conductivity).
Comment: The laboratory checks a 100 and 1000 Nmho/cm standard at one
temperature and the temperature is not documented: ,

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#222 "Pilot Creek" c/o City of King's Mountain
Dissolved Oxygen — Standard Methods, 4600 O G-2001 (Aqueous)
Comment: The laboratory was analyzing samples and reporting data for DO with a
Luminescence Dissolved Oxygen (LDO) meter without North Carolina
Wastewater/Groundwater Certification. North Carolina Administrative Code, 15A NCAC 2H
.0804 (a) states: Municipal and Industrial Laboratories are required to obtain certification for
parameters which will be reported to the State to comply with State surface water monitoring,
groundwater, and pretreatment Rules. The laboratory stopped using the meter the day of the
inspection and certification for DO by Hach 10360-2011, Rev. 1.2 (LDO) was granted effective
October 20, 2017. No further response is necessary for this Finding.
SS. Finding: Calibration documentation does not include all applicable information.
Requirement: Calibration documentation must include the following, where applicable
to the instrument used and the type of calibration performed: barometric pressure (in
mmHg). Ref: NC WW/GW LC Approved Procedure for the Analysis of Dissolved Oxygen.
Comment: A new meter (i.e., Thermo Orion RDO) had been purchased within the last
month and it uses the temperature and pressure for calibration. Only the temperature is
documented.
pH — Standard Methods, 4600 H+B-2000 (Aqueous)
Recommendation: It is recommended that the check standard acceptance criterion (i.e., ± 0.1
S.U.) be printed on the calibration log.
TT. Finding: Values were reported that exceed the method specified accuracy of 0.1 units.
Requirement: By careful use of a laboratory pH meter with good electrodes, a precision
of ±0.02 unit and an accuracy of ±0.05 unit can be achieved. However, ± 0.1 pH unit
represents the limit of accuracy under normal conditions, especially for measurement of
water and poorly buffered solutions. For this reason, report pH values to the nearest 0.1
PH unit. Ref: Standard Methods, 4500 H+ B-2000. (6).
Recommendation: It is recommended that the laboratory continue to record the result on
the benchsheet to the nearest 0.01 pH unit.
Residue, Settleable — Standard Methods, 2540 F-1997 (Aqueous)
Comment: The laboratory only analyzes process control samples for this parameter.
Comment: Due to the type of sample analyzed, the analyst does not stir at 45 minutes because
they say it will not settle. Since it is a timed test, it is acceptable for some particulates to hang in
suspension. The PT Sample is stirred at 45 minutes.
Comment: The sample volume analyzed is not documented on the benchsheet.
IV. PAPER TRAIL INVESTIGATION:
The paper trail consisted of comparing original records (e.g., laboratory benchsheets, logbooks,
etc.) and contract lab reports to eDMRs submitted to the North Carolina Division of Water

Page 17
#222 "Pilot Creek" c/o City of King's Mountain
lV
Resources. Data were reviewed for "Pilot Creek" c/o. City of King's Mountain (NPDES permit #
NC0020737) for January, April and August 2017. The following errors were noted:
Date
Parameter
Location
Value on
Benchsheet
Value on DMR
1/3/2017
pH
Downstream
6.38 SU
6.09 SU
1/11/2017
Nitrogen, Ammonia
Effluent
0.31 mg/L
<0.1 mg/L
8/30/2017
Residue, Suspended
Effluent
6.7 mg/L
7 mg/L
To avoid questions of legality, it is recommended that you contact the appropriate Regional Office
for guidance as to whether an amended eDMRs will be required. A copy of this report will be
made available to the Regional Office.
CONCLUSIONS:
Correcting the above -cited Findings and implementing the Recommendations will help this
laboratory to produce quality data and meet Certification requirements. The inspector would like to
thank the staff for their assistance during the inspection and data review process. Please
respond to all Findings and include supporting documentation, implementation dates and
steps taken to prevent recurrence for each corrective action.
Report prepared by: Beth Swanson
Report reviewed by: Jason Smith
Date: October 23, 2017
Date: October 30, 2017

Neutralizing Total Residual Chlorine in BOD Samples
It is acceptable to screen samples with DPD powder for the presence of Total Residual Chlorine
(use pillows appropriate for the volume, of sample tested). Generally total residual chlorine test
strips are not adequate; however, these may be used for samples where interference with DPD
precludes their use. If DPD yields no pink color, chlorine is absent. Document and proceed to set
sample. If pink color is observed, chlorine is present. In those cases, the titration procedure
outlined below must be used to determine the proper amount of Sodium Sulfite needed to
neutralize chlorine in the sample.
Chemicals:
Sodium Sulfite solution - Dissolve 0.1575 g Na2SO3 in 100 mL distilled water. Prepare
fresh daily.
2. 2% H2SO4 -Add 2 mL concentrated H2SO4 to 100 mL distilled water.
3. Potassium Iodide (KI) solution - Add 10 g KI to 100 mL distilled water. Initially this solution
will be clear, but in a few days it will turn greenish yellow. That's ok.
4. Starch - Commercially available or see SM 4500 O C (2) (d)-2001.
Procedure:
To 100 mL of sample, add approximately 1 mL of 2% H2SO4, 1 mL KI solution, and 1 mL starch.
If the solution remains clear, no chlorine is present. Document this on the bench sheet and
proceed to set up the sample for BOD analysis.
If the solution turns blue, chlorine is present. Add the Sodium Sulfite solution, drop by drop, while
stirring the sample, until the sample is clear again. Count the drops of Sodium Sulfite solution
needed to neutralize the 100-mL sample. Add the relative volume of Sodium Sulfite solution to the
volume of sample needed. For example, if it took 6 drops to neutralize the 100-mL sample volume
and you need 300 mL of sample to set the dilutions you want, add 18 drops of Sodium Sulfite
solution to 300 mL of sample. Document this on the bench sheet. Wait about 15 minutes and
recheck the sample to verify the chlorine has been neutralized. Proceed to set up the sample.
Note: If the blue color returns after a few seconds, do not add more Sodium Sulfite solution.
Recheck with DPD to verify that returning blue color is not caused by chlorine still in sample. If no
chlorine is still present, add amount of Sodium Sulfite solution equivalent to when blue color first
disappears. Adding an excessive amount of Sodium Sulfite solution creates an oxygen demand
and will result in a false high BOD value.

Tuvia, Ori A
<» rgorn:
Richelle Meek <richelle.meel:@Wiiyrjfkm.com>
Sent:
Tuesday, April 25, 2017 11:56 AM
To:
Tuvia, Ori A
Cc:
Bell, Wes
Subject:
Pilot Creek High Flow/ Sludge line bust
I hope you are having a good day.
Yesterday around 12:00pm we had a line to bust which contained sludge from our #2 digester. Approx. 50 gallons went
onto the ground and most of it drained into the drying bed. Soda ash was put on the sludge remaining on the ground
and the pipe was repaired within two hours tops.
Due to high amounts of rain received yesterday, we had 8.5mgd in our effluent discharge. This amount of rain caused
fecal coliform to be TMTC (to many to count); & effluent TSS was 131mg/L. These are above our permitted limits.
Is there anything else I need to do for these situations? I left a message with Mr. Bell this morning and tried calling you
about an hour ago to report these occurrences.
Please give me a call on my cell if you need anything further. (704-734-7851)
Sincerely,
Richelle Meek
City of Kings Mountain
WWTP Superintendent
Office #: [phone]
Fax: [phone]
"IMAGINE with all your mind. BELIEVE with all your heart. ACHIEVE with all your might!"
Statement of Confidentiality
The contents of this e-mail message and any attachments are confidential and are intended solely for addressee. The
information may also be legally privileged. This transmission is sent in trust, for the sole purpose of delivery to the
intended recipient. If you have received this transmission in error, any use, reproduction or dissemination of this
transmission is strictly prohibited. If you are not the intended recipient, please immediately notify the sender by reply e-
mail or phone and delete this message and its attachments, if any.

4
_i;A
F�LE
NC®ENRIYY*
North Carolina Department of Environment and Natural Resources ,
Pat McCrory John E. Skvarla, III
Governor Secretary
April 15, 2014
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Compliance Biomonitoring Inspection
City of Kings Mountain
NPDES Permit No. NC0020737
Cleveland County
Dear Mr. Wells:
Enclosed is a copy of the Compliance Biomonitoring Inspection Report for the inspection conducted at the
subject facility on April 8, 2014 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -
Responsible (ORC) of our findings by forwarding a copy of the enclosed report. The results of the effluent toxicity
samples collected on April 8 and April 10, 2014 will be forwarded to you under separate cover.
The report should be self-explanatory; however, should you have any questions concerning this report, please
do not hesitate to contact Mr. Bell at [phone] or at wes.bell(a,,ncdenr. ov.
Sincerely,
V Michael L. Parker, Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
Enclosure:
Inspection Report
cc: Cleveland County Health Department
1v,J/.1
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity t Affirmative Action Employer— 30% Recycled110% Post Consumer paper

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Comploginim Inspection Rpport
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 INI 2 15 I 31 NCO020737 111 121 14/04/08 117 181 B I 19I S I 20III
Remarks
211111 IIII III I II I I II II 1111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -- ---- --Reserved----- — -----
671 2.0 169 70141 711 D I 721 NJ 73I I 174 751 I I I I I I 180
w
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)
Pilot Creek WWTP
09:20 AM 14/04/08
10/08/01
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
02:50 PM 14/04/08
13/08/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kathy June Moses//704-739-7131 /
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Dennis Wells,PO Box 429 Kings Mountain NC 280860429/Water Resources Contacted
Director/704-734-4525/ 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 Irt/specc/tor(s) Agency/Office/Phone and Fax Numbers Date
Wes Bell g��? J�- `�� MRO WQ//704-663-1699 Ext.2192/
Signature of Management Q A Revi�$�Ver� p Agency/Office/Phone and Fax Numbers ate
Marcia Ilocco MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3 I N C0020737 111 12,
14/04/08 117 18 I B
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
The facility continues to operate under the Division approved waiver of the 24/7 staffing requirement
(WWTPs equal to or greater than 5 MGD) with certified operators. The faciilty is staffed with certified
operators eight hours per weekday (at a minimum) and four hours per day during weekends and holidays as
noted on the DMRs and on -site documentation.
Page # 2

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 04/08/2014 Inspection Type: Bioassay Compliance
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ n n n
Is the facility as described in the permit? ■ n _n n
# Are there any special conditions for the permit? n n ■ n
Is access to the plant site restricted to the general public? ■ n n n
Is the inspector granted access to all areas for inspection? ■ n n n
Comment: The subject permit expired on 8/31/2013; however, the Division received a
permit renewal application on 2/25/2013.
The permit adequately describes the facility; however, the sludge drying beds have
been taken out of service.
The last compliance evaluation inspection was performed on 8/23/2012.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
n
n
Are analytical results consistent with data reported on DMRs?
■
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?
■
Cl
n
n
Has the facility submitted its annual compliance report to users and DWQ?
■
n
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
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
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?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
■
❑
n
Page # 3

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 04/08/2014 Inspection Type: Bioassay Compliance
Record Keeping Yes No NA NE
Comment: The records reviewed during the inspection were organized and well
maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period
January 2013 through December 2013. Chronic Toxicity failures were reported in
January 2013, October 2013, and November 2013. The Division has previously
addressed these limit violations through the issuances of Notice of Violations (NOVs).
Only one effluent chloride was performed in May 2013. The Division has previously
addressed this monitoring violation through the issuance of a Notice of Deficiency
(NOD).
No upstream and downstream conductivity results were reported for the entire month of
May 2013; however, the inspection verified that instream conductivity sampling was
properly performed and an amended DMR will be resubmitted.
See "Summary" Section for additional comments regarding 24/7 staffing.
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?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
®
n
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
n
■
Comment: Influent and effluent (including field analyses) are performed under the
City's on -site laboratory (Certification #222). K&W Labs, Inc. (chloride, metals, cyanide,
total phosphorus, total nitrogen, and priority pollutants) and ETT Environmental, Inc.
(toxicity) have also been contracted to provide analytical support.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
n
n
n
Is sample collected above side streams? _
■
❑
n
❑
Is proper volume collected?
■
❑
n
n
Is the tubing clean?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Is sampling performed according to the permit?
■
n
n
n
Comment: The subject permit requires influent composite sampling (BOD and TSS).
The influent composite sampler was collecting 180 mis. per aliquot during the
inspection. See "Effluent Sampling" Section for additional comments regarding aliquot
verifications.
Effluent Sampling Yes No NA NE
Page # 4

Permit: NCO020737
Inspection Date: 04/08/2014
Effluent Sampling
Owner - Facility: Pilot Creek WWTP
Inspection Type: Bioassay Compliance
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: The subject permit requires composite and grab effluent sampling. The
ORC and staff must ensure to perform and document periodic aliquot verifications (100
mis. at a minimum) on. both composite samplers (influent and effluent) on a periodic
basis (tubing replacement, following sampler maintenance/repair, etc.). The effluent
composite sampler was collecting 150 mis. per aliquot during the inspection.
Yes No NA NE
■nnn
■ n n n
■nnn
■nnn
■nnn
■nnn
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n
Comment:
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Ve K1- KIA KIC
■nnn
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n
Judge, and other that are applicable?
Comment: The wastewater treatment plant appeared to be properly operated and well
maintained. The ORC and staff incorporate a comprehensive process control program
with all measurements being properly documented and maintained on -site.
The telemetry type alarm system (phone/text messaging system) was tested and
operational during the inspection. The alarm system is tested twice per month and
includes the following alarm conditions: high influent water level, screw pump failure,
low influent pH (below'6.0 s.u.) and high influent pH (above 10.0 s.u), blower failure,
RAS pump failure, chlorination/dechlorination system failures, and standby power
activiation.
Bar Screens Yes No NA NE
Type of bar screen
-- - - a.Manual n -
b.Mechanical ■
Are the bars adequately screening debris? ■ n ❑
Is the screen free of excessive debris? ■ n n n
Is disposal of screening in compliance? ■ ❑ ❑ n
Page # 5

Permit: NCO020737
Inspection Date: 04/08/2014
Is the unit in good condition?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Bioassay Compliance
Comment: Screenings are disposed at the County Landfill. The bar screenings
dumpster is covered; however, the ORC and staff must ensure that any dumpster
leakages are contained and properly disposed.
Both screw pumps (prior to screening) were operational.
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The flow meter is calibrated/verified once per year and was last
calibrated/verified on 4/12/2013 by Laboratory Instrumentation Service.
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment: Sodium hydroxide is added to the influent of the aeration basins to
maintain appropriate pH levels.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
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? _
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Comment: All three aeration basins were operational and in service.
Secondary Clarifier
■nnn
Yes No NA NE
■ n n n
■nnn
■nnn
■nnn
Yes No NA NE
Ext. Air
Diffused
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
Page # 6

Permit: NC0020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 04/08/2014 Inspection Type: Bioassay Compliance
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
Are weirs level?
■
n
❑
Is the site free of weir blockage?.
■
n
❑
n
Is the site free of evidence of short-circuiting?
■
n
n
n
Is scum removal adequate?
■
n
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
Cl
n
Is the overflow clear of excessive solids/pin floc?
■
n
n
n
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
■
n
n
n
Comment: The facility is equipped with four secondaries; however, only three were
operational and in service.
Pumps-RAS-WAS
Yes No
NA
NE
Are pumps in place?
■
n
n
n
Are pumps operational?
■
n
n
n
Are there adequate spare parts and supplies on site?
n
n
n
■
Comment:
Disinfection -Gas
Yes No
NA
NE
Are cylinders secured adequately?
■
n
n
n
Are cylinders protected from direct sunlight?
■
n
n
n
Is there adequate reserve supply of disinfectant? .
■
n
❑
n
Is the level of chlorine residual acceptable?
■
n
n
n
Is the contact chamber free of growth, or sludge buildup?
■
n
n
❑
Is there chlorine residual prior to de -chlorination?
■
n
n
n
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
■
n
n
n--- - -
If yes, then is there a Risk Management Plan on site?
■
❑
❑
n
If yes, then what is the EPA twelve digit ID Number? (1000- - )
1000-0005-8965
If yes, then when was the RMP last updated?
06/15/2009
Page # 7

Permit: NCO020737
Inspection Date: 04/08/2014
Owner - Facility: Pilot Creek WWTP
Inspection Type: Bioassay Compliance
Disinfection -Gas
Yes No
NA
NE
Comment: All three chlorine contact chambers were operational and in service. The
contact chambers are periodically monitored for any sludge accumulations and cleaned
on an as -needed basis.
De -chlorination
Yes No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
■ n
n
n
Is storage appropriate for cylinders?
■ n
n
n
# Is de -chlorination substance stored away from chlorine containers?
■ n
n
❑
Comment:
Are the tablets the proper size and type? ❑ ❑ ■ n
Are tablet de -chlorinators operational? ❑ 11 ■ ❑
Number of tubes in use? \
Comment: The chlorinated effluents from the three chlorine contact chambers are
combined prior to dechlorination.
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
■
n
n n
Is flow meter calibrated annually?
■
n
n n
Is the flow meter operational?
■
n
n n
(If units are separated) Does the chart recorder match the flow meter? n ❑ ■ n
Comment: The flow meter is calibrated/verified annually and was last
calibrated/verified on 4/12/2013 by Laboratory Instrumentation Service. Note: The
facility is equipped with three flow meters located at the effluent end of each chlorine
contact chamber. These flow meters are connected to a totalizer located in the office/lab
building.
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? ❑ n ■
Comment: The effluent appeared clear with no floatable solids or foam. The receiving
stream was high and turbid due to recent rainfall events; therefore, no visual evaluations
were performed. DWR staff split effluent chronic toxicity samples with the facility staff
on 4/8/2014 and 4/10/2014. The results will be forwarded under separate cover.
Page # 8

Permit: NC0020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 04/08/2014 Inspection Type: Bioassay Compliance
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
n
n
n
Is the mixing adequate?
■
❑
❑
n
Is the site free of excessive foaming in the tank?
■
n
n
n
# Is the odor acceptable?
■
n
n
n
# Is tankage available for properly waste sludge?
■
❑
❑
n
Comment: Both aerated sludge holding tanks were operational and in service.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
■
n
n
n
Is the chemical feed equipment operational?
■
n
n
n
Is storage adequate?
■
n
fl
n
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
n
n
n
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
n
n
n
Is the site free of excessive moisture in belt filter press sludge cake?
■
n
n
n
The facility has an approved sludge management plan?
■
n
n
n
Comment: The belt filter press was operational; however, the unit was not in service.
Dewatered bio-solids are transported to the County Landfill for final disposal. The
filtrate is returned to the head of the treatment plant.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
■
n
n
n
Is the generator tested by interrupting primary power source?
■
❑
n
n
Is the generator tested under load?
■
n
n
n
Was generator tested & operational during the inspection?
n
n
n
■
Do the generator(s) have adequate capacity to operate the entire wastewater site?
n
■
n
n
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■
0
n
n
Is the generator fuel level monitored?
■
n
n
n
Comment: The facility is equipped with_two standby generators. The main/stationary
generator is tested (automatically) under two
on a weekly basis and the second
generator is periodically tested under load . Both generators are serviced by a
contracted company (CPS) twice per year. The generators can power the screw
pumps, one blower per aeration basin, RAS and WAS pumps, chlorination and
dechlorination systems, and the lab building.
Page # 9

Frye,-:, — - -: -
Water Resources
ENVIRONMENTAL QUALITY
April 1, 2016
Mr. Rick Duncan, Director Water Resources
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
`r PAT. MCCRORY
? L._ I.
--.� Governor
DONAL� 7--v4'N DER VAART
Secretary'
S. JAY ZIMMERMAN
Director
Subject: Compliance Evaluation Inspection
City of Kings Mountain/Pilot Creek WWTP
NPDES Permit No. NCO. 020737
Cleveland County
Dear Mr. Duncan:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted
at the subject facility on March 30, 2016 by Mr. Wes Bell of this Office. Please inform the facility's
Operator -in -Responsible Charge (ORC) of our. findings by forwarding a copy of the enclosed report.
It is requested that a written response be submitted to this Office by April 22, 2016. This
response should provide an update on the results of the influent meter calibration (by the contracted
company) and the calibration/verification procedure for the total residual chlorine meter. In responding,
please address your comments to the attention of Mr. Bell.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at [phone], or via email at [e-mail].
Sincerely,
�r�vy W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report
cc: Cleveland County Health Department
MSC-1617 Central -Basement
ii ;
State of North Carolina I Environmental Quality. I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

41'
United States Environmental Protection Agency
Form Approved.
Washington, D.C. 20460
'EPA -
OMB No. 2040-0057
Water Compliance Inspection Report
Approvalexpires8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fad Type
1 IN 2 15 1 3 I N00020737 I11 12 16/03/30 17 18 I C 1 19 I c I 20 LJ
1_111111111111111111111
1, . II11111111111111111 f6
211
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CIA
672
.0 70 JJ 71 i 72 Lti 7374 75
80
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 Dermit Number)
09:45AM 16/03/30
15/06/01
Pilot Creek VVWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
02:OOPM 16/03/30
18/08/31
Kings Mountain NC 28086
Name(s) of Onsite Representative(s)Ttles(s)/Phone and Fax Number(s)
Other Facility Data
111
Kathy June Moses//704-739-7131 /
Name, Address of Responsible OfficialTtle/Phone and Fax Number
Contacted
Ricky Duncan,PO Box 429 Kings Mtn NC 28086/Director Water
Yes
Resourcesf704-734-452517047302152
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 Data
j
Wes Bell MRO W0//704-663-1699 Ext.2192/
Signature of Management Q A R viewer Agency/Office/Phone and Fax Numbers Date
Andrew Pitner A MRO GW//704-663-1699 Ext.215o, y i 4 ri
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
31 NCO020737 I11 12 16/03/30 j 17 18 I ,.]
(Cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Laboratory Section cont'd:
The pH meter was being standardized with three standards (4, 7, 10 buffers); however, a check
standard (7 buffer) verification had not been performed (verify meter is within +/- 0.1 SU).
The last annual curve verification (primary standards) on the total residual chlorine (TRC) meter was
performed on 3/3/14. The laboratory staff initiated daily verifications on three gel standards (secondary
standards) on 3/16/15. A gel standard mid -range check can only be performed if an annual verification
curve is performed on the TRC meter with primary standards._ If the. laboratory staff want to continue
three daily standard verifications, then the verifications must be performed with primary standards with
one of the standards being at or below the permit limit. The Division's Laboratory Certification Unit has
been contacted and will provide additional guidance to the laboratory staff.
Page# 2

r
• Permit: NCO020737 Owner - Facility: Pilot Creek VWVrP
�► p Type: Compliance Inspection Date: 03/30/2016 Inspection T e: Evaluation
Permit
Yes No NA NE
(if the present permit expires in 6' months or less). Has -the permittee submitted a new
❑
❑
❑
application?
Is the facility as described in the permit?
❑
❑
❑
# Are there any special conditions for the permit?
M
❑
❑
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
M
❑
❑
❑
Comment: The Citv imDlements an aDDroved Industrial Pretreatment Program.
The last compliance evaluation inspection (Bio-monitoring) was
performed at the facility
on
4/8/14.
The Division received a SOC application from the City on 12/29/15 due to the WVVTP's
inability to comply with the effluent thallium limits placed in the current permit (effective
6/1/15) The City has identified the source of the thallium and will oversee the industry's
corrective actions to reduce the thallium levels through the City's
Industrial Pretreatment
Program. The SOC is in the process of being approved.
Record Keepina
Yes No NA NE
Are records kept and maintained as required by the permit?
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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? ❑ ❑ ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ M ❑
on each shift?
Is the ORC visitation log available and current?
M
❑
❑
❑
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?
M
❑
❑
❑
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?
0
❑
❑
❑
Page# 3

Permit: NCO020737
Inspection Date: 03/30/2016
Record Keeping
Owner - Facility: Pilot Creek WwTP
Inspection Type: Compliance Evaluation.
Yes No NA NE
Comment: The records reviewed during the inspection were organized_and well maintained. Discharge
Monitoring Reports (DMRs) were reviewed for the period January 2015 through December
2015. Daily maximum and monthly average effluent thallium violations were reported from
June 2015 through December 2015. The above -noted violations have.been separately
addressed by the Division through the issuance of either a NOV/civil penalty or as part of the
upfront settlement for the SOC.
The facility continues to operate under the'Division approved waiver of the 24/7 staffing
requirement (WWTPs equal to or greater than 5 MGD). The facility is staffed with certified
operators eight (8) hours per weekday (at a minimum) and four (4) hours per day during
weekends and holidays.
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? M ❑. ❑ ❑
Comment: Influent and effluent analyses are performed under the City's certified laboratory #222. K&W
Labs (metals priority pollutants, total phosphorus,total nitrogen, oil & grease) and ETT, Inc.
(toxicity) have also been contracted to provide analytical support. See "Summary" Section
for additional comments.
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected above side streams?
❑
❑
❑
Is proper volume collected?
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Is sampling performed according to the permit? ❑ ❑ ❑
Comment: The subiect permit reouires influent composite BOD and TSS samples. The facility staff
perform and document periodic aliquot verifications. This Office recommends performing
monthly aliquot verifications.
Influent pH levels are continuously monitored by an in -line. monitoring system.
Effluent Sampling
Is composite sampling flow proportional?
Yes No NA NE
❑ ❑ ❑
1
• •
Page# 4

U
Permit: NCO020737 Owner -Facility: Pilot Creek VWffrP
y ~
Inspection Date: 03/30/2016 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes No NA NE
Is sample collected below all .treatment units?
❑
❑
❑ .
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or'equal to 6.0 degrees
M
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: The subiect Dermit requires composite and crab effluent samples. The facility staff perform
and document periodic aliquot verifications. This Office recommends performing monthly
aliquot verifications.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and M ❑ ❑ ❑
sampling location)?
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH,_DO, Sludge Judge, and other that are applicable?
Comment: The wastewater treatment facility appeared to be properly operated and well maintained.
The facility staff incorporate a comprehensive process control program with all
measurements being properly documented and maintained on -site.
The facility is equipped with a We type alarm system that is tested (and documented)
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment: Both screw pumps were operational and in-service.
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ■ ❑
Page# 5

Permit: NCO020737
Owner -Facility: Pilot Creek WWTP
Inspection Date: 03/30/2016
Inspection Type: Compliance Evaluation
•_ s
Pump Station - Influent
Yes No NA NE
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
S
❑
❑
❑
Is the screen free of excessive debris?
E
❑
❑
❑
Is disposal of screening in compliance?
N
❑
❑
❑
Is the unit in good condition?
N
❑
❑
❑
Comment: Screenings are disposed at the Cleveland County Landfill.
Flow Measurement -'Influent
Yes No NA NE
# Is flow meter used for reporting?
N
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
N
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment: The influent flow meter is calibrated annually, and was last calibrated on 4/22/15 by
Laboratory Instrumentation Service.
An instantaneous flow measurement was performed during the inspection. The flow rate
difference between the instantaneous measurement and the flow meter reading exceeded
tubing and have scheduled the contracted company that calibrates the flow meter to
recalibrate the meter within the week. Please be advised that the subject permit requires
that the flow measurement system be capable of measuring flows with a maximum
deviation of less than 10% from the true discharge rates'throughodt the range of expected
discharge volumes (Permit Condition - Part II, Section' D. (3) Flow Measurements).
Aeration Basins Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
N
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
0
❑
Are the diffusers operational?
N
❑
❑
❑
Is the foam the proper color for the treatment process?
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
❑
❑
❑
Is the DO level acceptable?
E
❑
❑
❑
Page#
6

Permit: NCO020737 Owner- Facility: Pilot Creek WWrP
Pe Inspection Date: 03/30/2016; Inspection T yp Com e: liance Evaluation p
Aeration Basins Yes No NA NE
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑ ❑
Comment: Three of four aeration basins were operational and in-service. Sodium hydroxide is added to
the aeration basin influent to maintain appropriate alkalinity/pH levels. .
Chemical Feed ,
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
Secondary Clarifier
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?
Is the sludge blanket level acceptable? (Approximately %a of the sidewall depth)
Comment: Three of four secondary clarifiers were operational and in-service.
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: ,
Disinfection -Gas
Are cylinders secured adequately?
Yes No NA NE
■ ❑ El El
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑.❑ ❑
Yes No NA NE
■
❑
❑
0
■
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
Yes No NA NE
❑
❑
❑
❑
❑
❑
❑
❑
❑
■
Yes No NA NE
❑ ❑ ❑
Page# 7

Permit: NCO020737 Owner -Facility: PilotCreekWWTP ,
Inspection Date: 03/30/2016 Inspection Type: Compliance Evaluation
'
Disinfection -Gas
Yes No NA NE
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
0
❑
❑
❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
0
❑
❑
❑
If yes, then is there a Risk Management Plan on site?
❑
❑
❑
If yes, then what is the EPA twelve digit ID Number? (1000- -_)
1000-0005-8965
If yes, then when was the RMP last updated?
06/06/2014
Comment: All three chlorine contact chambers and flow measurement 'systems (at the. end of each
chamber) were operational and in-service. Sodium hydroxide is also added to maintain
appropriate PH levels.
Sludge accumulation levels are monitored periodically and the contact chambers are
cleaned out on an as -needed basis. Sludge accumulations levels should be kept at less
than twelve (12) inches in the contact chambers.
De -chlorination Yes No NA NE
Type of system ? Gas
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑
Is storage appropriate for cylinders? ❑ ❑ ❑
# Is de -chlorination substance stored away from chlorine containers? ❑ ❑ ❑
Comment:
Are the tablets the proper size and type? ❑ ❑ N ❑
Are tablet de -chlorinators operational? ❑ ❑ E ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
0
❑
❑
Is flow meter calibrated annually?
E
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
Comment: The flow meters (end of each chlorine contact chamber) are calibrated annually and were.
last calibrated on 4/22/15 by Laboratory Instrumentation Service
e�
Page# 8

• Permit: NC0020737 Owner - Facility: Pilot Creek WWrP
Inspection Date: 03/30/2016 Inspection Type: Compliance Evaluation
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
❑
0
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
M
❑
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: Both aerobic digesters were operational and in-service.
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved. sludge management plan?
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
■.❑ ❑ ❑
■ ❑ ❑ ❑
Yes No NA NE
■
❑
❑
❑
❑
M
❑
❑
❑
❑
❑
■
-❑
❑
❑
■
❑
❑
❑
■
■
❑
❑
❑
Comment: The belt press was operational: however, the unit was not in-service at the time of the
inspection The mixer for the polymer system was in the process of being repaired.
Dewatered bio-solids are transported (by City staff) to the Cleveland County Landfill for
disposal.
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the, inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑
Page# 9

Permit: NC0020737
Inspection Date: 03/30/2016
Standby Power
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The facility is equipped with two backup -generators. The smaller generator powers the
blowers for aeration basin #3 and the larger generator powers the rest of the plant. The
larger generator is tested weekly under load and the smaller generator is tested monthly
under load. A contracted company (Carolina Power Solution) services the generators twice
Per year.
r
Page# 10

1 WRICRORY
GoVC17701'
DONALD R. VAN DER VAART
Secretary
Water Resources S. JAY ZIMMERMAN
ENVIRONMENTAL QUALITY - - Director
March 30, 2016
Mr. Rick Duncan
Water:Resource Director
City of.Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Pretreatment Compliance Inspection
City of Kings Mountain/Pilot Creek WWTP
NPDES Permit No. NC0020737
Cleveland County
Dear Mr. Duncan:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the
City of Kings Mountain approved Industrial Pretreatment Program on March 16, 2016iby Mr. Wes Bell
of this Office.
Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell
at. [phone], or via email at wes.bell@ncdenr�.
Enclosure:
Inspection Report
cc: Sarah Bass, PERCS Unit -
MSC-1617 Central -Basement
WB
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section .
Division of Water Resources, NCDEQ
State of North Carolina I Environmental Quality I. Water Resources I Water Quality Regional Operations -
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville,,North Carolina 28115
704 663 1699

NORTH CAROLINA DIVISION OF WATER RESOURCES
PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION [Complete Prior To PCI; Review Program Info Database Sheet(s)]
1. Control Authority (POTW) Name: City of Kings Mountain
2. Control Authority Representative(s): Richelle Meek
3. Title(s): Laboratory/Pretreatment Analyst
4. Last Inspection Date: 5/7/14 Inspection Type: ® PCI ❑ Audit.
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ®NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
PCS CODING
Trans.Code Main Program Permit Number MM/DD/YY Inspec.Type Inspector Fac. Type
N NCO020737 03/16/16 P S 1
(nTTA) (TYPT) (INSP) (FACC)
7. Current Number Of Significant Industrial Users (SI[Js)? '
7­1
SIDS
8. Current Number Of Categorical Industrial Users CIUs)?
7
CIUS
9. 'Number of SlUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SlUs Not Sampled By POTW in the Last Calendar Year?
0
11. Enter the Hi er Number of 9 or 10
0
NOIN
12. Number of SlUs With No ]UP, or With an Expired lUP
0
NOCM
13. Number of SlUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
1
pSNC
Semi -'Annual Periods Total Number of SlUs in SNC
14. Number of SlUs in SNC For Reporting During Either of the Last'2 Semi -Annual Periods
0
MSNC
15: Number of SlUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
1
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
0
Semi-annual Periods
POTW INTERVIEW .
IT Since the Last PCI, has the POTW had. any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
IV Since the Last PCI, has the POTW had any Problems Related to an Industrial.
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC foj
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi
Public Notice?(May refer to PAR if Excessive SlUs in SNC) Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SlUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES ❑ NO
See Comments Section'
❑ YES ® NO
Limits: KMI (Cr), January -June 2015
Reporting: NA
blished: NA
Buckeye and EMI; Yes
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? . ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? Z YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ❑ YES ® NO
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

28. PRETREATMENT PROGRAM ELEMENTS REVIEW — Please review POTW files, verify POTW has copy of Program Element in
their files, complete with supporting documents and co of PERCS Approval Letter, and dates consistent with Pro am Info:
Program Element Last Submittal Received Last Approval Date Next Due,
� file 1•f Applicable
Date In file.
Date In f
pp
Headworks Analysis A
12/2/15
® Yes ❑ No
In Review
❑ Yes ❑ No
9/1/20
Industrial Waste SurveyS
12/18/14
® Yes ❑ No
12/1/15
® Yes ❑ No
12/1/19
Sewer Use Ordinance (SUO)
8/9/13
® Yes ❑ No
8/16/13
® Yes ❑ No
Enforcement Response Plan RP
1/10/14
® Yes ❑ No
3/11/14
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
4/27/12
® Yes ❑ No
6/4/12
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR 1 FILE REVIEW AND 1 IU INSPECTION)
29. User Name IF
1. Carolina Finishing &Coating (CFC)
2. Kings Mountain Int.
3. Buckeye
30. IUP Number
033
031
015
31. Does File Contain Current Permit?
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
32. Permit Expiration Date
2/17/19
6/15/20
11/17/16
33. Categorical Standard Applied I.E. 40 CFR, Etc. Or N/A
433
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
®Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
® Yes ❑ No
® Yes ❑ No
®Yes ❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes []No
a. EYes ❑No
a. ®Yes []No
b. If No, is One Needed? See Inspection Form from POTW)
b. ❑Yes []No
b. []Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. EYes ❑No
a. EYes []No IF
a. EYes ❑No
b. All Issues Resolved?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
its Sampling as Required b IUP, includingflow?
40. Does File Contain POTW Sampling Chain-Of-Custod Forms?
® Yes ❑
No
® Yes ❑ No
® Yes ❑ No
41a. During the Most Recent Semi -Annual Period, Did the SILT Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A j[__0esE1No[1N�/A
Sampling as Required b IUP, includingflow?
41b. During the Most Recent Semi -Annual Period, Did SILT submit all reports
NYes❑No❑N/A
I
®Yes❑No❑N/A
®Yes❑No❑N/A
on time?
.
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
Dyes❑NoNN/A
❑YesONoNN/A
file include process/dilution flows as Required b IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
EYes❑No❑NA
NYes❑No❑N/A
NYes❑No❑N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
aaYes❑No❑N/A
a.®Yes❑NJN/Ab.
Yes❑No❑N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.®Yes❑No❑N/A
b.®Yes❑NYes❑No®N/A
c. Did POTW resample within 30 days of knowledge of SIU limitc.❑Yes❑No®N/A
c.❑YespNYes❑No®N/A
violations from the POTW sam le event?45.
Durin the Most Recent Semi -Annual Period, Was the SIU in SNC?
❑Yes ®No
, ❑ Yes
Yes ® No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
NYes❑No❑N/A
NYes❑No❑N/A
NYes❑No❑N/A
as Specified in the POTW s ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penal Assessment Notices?
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
48. Does The File Contain Proof Of Penal Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
❑Yes❑No®N/A
j[b0Yes[3No0N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑Yes ® No
❑ Yes ® No
Requested Information For You?
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 2

F
ILE REVIEW COMMENTS:
. The POTW submitted an SOC application to the Division on 12/29/15 due to the WWTP's inability to meet the effluent thallium
imits placed in the reissued NPDES Permit (effective date 6/1/15). A draft SOC has been submitted to the POTW for review and
comments.
17. The POTW's WWTP exceeded the daily maximum and monthly average effluent arsenic limits in December 2014 and the daily
maximum and monthly average effluent thallium limits from June 2015 through January 2016.
20. KMI's consent order was issued on 10/21/15 and expires 7/1/16. Buckeye's consent order was issued on 4/4/15 and expired on
9/9/15; however, the POTW allowed a continuation of the order via email correspondence. An official consent order document should
be developed (and enforced) by the POTW.
23. The detection level for thallium (10 ug/L) was above the LTMP's level (2 ug/L). The POTW has submitted a revised HWA and
updated LTMP to the PERCS Unit for review and approval.
35. SIU inspections were performed on 11/6/15.(CFC), 7/29/15 (KMI), and 8/18/15 (Buckeye).
39. The POTW's on -site certified laboratory performs analyses for conventional and field parameters. K&W Labs has been contracted
to perform the analyses for metals.
41a. Buckeye and CFC both contract PAR Labs to perform analyses. KMI contracts Pace Analytical Services to perform analyses.
46. CFC was issued NOVs for limit violations of chromium and nickel (August and September 2015) and Zinc (December 2015). KMI
was issued a NOV for a chloride limit violation in November 2015. Buckeye was issued NOVs for limit violations that occurred in July
2015 (arsenic), August 2015 (nickel and total phosphorus), and October 2015 (nickel, chromium, zinc, total phosphorus).
SUMMARY AND COMMENTS:
Comments:
The records reviewed were organized and well maintained. The POTW's pretreatment staff have made commendable improvements to
the implementation of the Industrial Pretreatment Program during the last few years.
Requirements:
The POTW staff must ensure that all listed detections levels (cadmium, copper, ammonia) in the WPs are adhered to by the SIUs and
the POTW's contracted lab.
If the POTW intends to extend the requirements of the expired consent order with Buckeye, then an official consent order should be
developed, signed, and implemented by April 15, 2015.
NOD: ❑ YES ®NO
NOV: ❑ YES ®NO
QNCR: ❑ YES ® NO
POTW Rating:
Satisfactory ® Marginal ❑ Un isfactory ❑
PCI COMPLETED BY: DATE: March 30, 2016
Wes Bell, Mooresville Regional Office
NC DWR Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 3

Permit No. _NC0020737
Outfall _001
Annie �WlWonitoiiag and Pollutant scan
be d �,>.. • �.<
DEC 0 5 20"b
Month _October
Year _2016
Facility Name :Pilot Creek WWTP CENTRAL RAL FILE �, SE+" , TiQ�+� ORC : Richelle Meek
Date of sampling :October 13, 2016 D\(VR Phone : [phone]
Analytical Laboratory : K & W Labs. Pace and Pilot Creek WWTP Laboratory
RECEf1!ED/f J'CIDENR/DWR
01IF:_11 2 2016
INORO R
Parameter
Sample"" '
Type.
Analytical'
Method
Quantitation
Level
'Sample''-_tTaitsVf;
Result .
I I
Measurement
E rNwhber OFFF
samples
Ammonia (as N)
Composite
4500NH3C
0.1
6.15
MG/L
1
Dissolved oxygen
Grab
SM5210B
1.0
8.40
MG/L
2
Nitrate/Nitrite
Composite
450ONO3F
0.1
15.00
MG/L
1
Total Kjeldahl nitrogen
Composite
4500NH3D
1.0
N/D
MG/L
1
Total Phosphorus
Composite
SM450OP-F
0.1
4.90
MG/L
1
Total dissolved solids
Composite
SM2540C
100.0
1596.00
MG/L
1
Hardness
Composite
SM2340C
1.0
120.00
MG/L
1
Chlorine (total residual, TRC)
Grab
SM4500CIG
15.0
19.00
UG/L
1
Oil and grease
Grab
EPA1664B
5.6
N/D
MG/L
1
Metals (total recoverable), cyanide
and total"phenols``
Antimony
Composite
EPA 200.7
50.0*
N/D
UG/L
1
Arsenic
Composite
EPA 200.7
100.00*
51.00
UG/L
1
Beryllium
Composite
EPA 200.7
10.0*
N/D
UG/L
1
Cadmium
Composite
EPA 200.7
10.0*
N/D
UG/L
1
Chromium
Composite
EPA 200.7
50.0*
N/D
UG/L
1
Copper
Composite
EPA 200.7
50.0*
N/D
UG/L
1
Lead
Composite
EPA 200.7
50.0*
N/D
UG/L
1
Mercury
Composite
EPA 245.1
0.2
N/D
UG/L
1
Nickel
Composite
EPA 200.7
50.0*
42.00
UG/L
1
Selenium
Composite
EPA 200.7
100.0*
61.00
UG/L
1
Silver
Composite
EPA 200.7
50.0*
N/D
UG/L
1
Thallium
Composite
EPA 200.7
100.0*
N/D
UG/L
1
Zinc
Composite 1
EPA 200.7
100.0*
1 0.31 1
UG/L
1
Cyanide
Grab
4500-CN-E
8.0
1 N/D I
UG/L
1 1
Total phenolic compounds
Grab
EPA 420.4
0.01
0.02
MG/L
1
Volatile organic compounds
j
Acrolein
Grab
624
5.0
N/D
UG/L
1
Acrylonitrile
Grab
624
50.0
N/D
UG/L
1
Benzene
Grab
624
2.0
N/D
UG/L
1
Bromoform
Grab
624
2.0
2.60
UG/L
1
Carbon tetrachloride
Grab
624
2.0
N/D
UG/L
1
Chlorobenzene
Grab
624
2.0
N/D
UG/L
1
Chlorodibromomethane
Grab
624
2.0
8.10
UG/L
1
Chloroethane
Grab
624
2.0
N/D
UG/L
1
2-chloroethylvinyl ether
Grab
624
5.0
N/D
UG/L
1
Chloroform
Grab
624
2.0
3.90
UG/L
1
Dichlorobromomethane
Grab
624
2.0
7.70
UG/L
1
1, 1 -dichloroethane
Grab
624
2.0
N/D
UG/L
1
1,2-dichloroethane
Grab
624
2.0
N/D
UG/L
1
Trans-1,2-dichloroethylene
Grab
624
2.0
N/D
UG/L
1
-Parameter = -=
Samp a
Type =
Ana ytica ::
- Method"
Quantitation
= -Level
= =
­.Unitsof
.0
Measurement--
Number o
=samples•
Volatile organic compounds'(Cont.)
1, 1 -dichloroethylene
Grab
624
2.0
N/D
UG/L
1
1,2-dichloropropane
Grab
624
2.0
N/D
UG/L
1
1,3-dichloropropylene
Grab
624
2.0
N/D
UG/L
1
CE
Form - DMR- PPA-1 Page 1

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Annual Monitoring and Pollutant Scan
Permit No. _NC0020737
Outfall _001
Month _October
Year _2016
Dimethyl phthalate
Grab
625
5.0
N/D
UG/L
1
2,4-dinitrotoluene
Grab
625
5.0
N/D
UG/L
1
2,6-dinitrotoluene
Grab
625
5.0
N/D
UG/L
1
1,2-diphenylhydrazine
Grab
625
5.0
N/D
UG/L
1
Fluoranthene
Grab
625
5.0
N/D
UG/L
1
Fluorene
Grab
625
5.0
N/D
UG/L
1
Hexachlorobenzene
Grab
625
5.0
N/D
UG/L
1
Hexachlorobutadiene
Grab
625
5.0
N/D
UG/L
1
Hexachlorocyclo-pentadiene
Grab
625
10.0
N/D
UG/L
1
Hexachloroethane
Grab
625
5.0
N/D
UG/L
1
Indeno(1,2,3-cd)pyrene
Grab
625
5.0
N/D
UG/L
1
Isophorone
Grab
625
10.0
N/D
UG/L
1
Naphthalene
Grab
625
5.0
N/D
UG/L
1
Nitrobenzene
Grab
625
5.0
N/D
UG/L
1
N-nitrosodi-n-propylamine
Grab
625
5.0
N/D
UG/L
1
N-nitrosodimethylamine
Grab
625
5.0
N/D
UG/L
1
N-nitrosodiphenylamme
Grab
625
10.0
N/D
UG/L
1
Phenanthrene
Grab
625
5.0
N/D
UG/L
1
Pyrene
Grab
625
5.0
N/D
UG/L
1
1,2,4,-trichlorobenzene
Grab
624
5.0
N/D
UG/L
1
I certify under penalty of law that this document and all attachments were prepared under my direction
and supervision in accordance with a system to design to assure that qualified perdonnel properly
gather and evaluat the information submitted. Based on my inquiry of the person or persons that
manage the system, or those persons directly responsibel 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.
QIrWPILF iUT'FL I
eAut orized Representative name
ature
II-I�-I�n
Date
* All Parameters ran under Preparation Method: EPA 200.7 indicated with * has a dilution factor of 10x.
Form - DMR- PPA-1 Page 3

Water Resources
ENVIRONMENTAL QUALITY
C I��CI CA
Edgar Murphrey
City of Kings Mountain
101 W Gold St
Kings Mountain, NC 28086
June 24, 2016
Subject: NPDES Electronic Reporting Requirements
Pilot Creek WWTP
NPDES Permit Number: NCO020737
Dear NPDES Permittee:
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretmy
S. JAY ZIMMERMAN
Director
RECEIVEDINCDENRIDWR
3 0. HIG
k"IQFROS
MOORES`,rILLE REL;iCiIA OFFICE
The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge
Elimination System (NPDES) Electronic Reporting Rule. The rule requires NPDES regulated facilities to
report information electronically, instead of filing written paper reports. The rule does not change what
information is required from facilities. It only changes the method by which information is provided (i.e.,
electronic rather than paper -based).
EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and their
key milestones, are:
• Phase 1—Starting on December 21, 2016, regulated entities that are required to submit Discharge
Monitoring Reports (DMRs) will begin submitting these reports electronically. If you are currently
reporting your DMR data electronically using eDMR, then you simply need to continue reporting
in the same way as you are now. The key change is that, starting on December 21, 2016,
electronic reporting of DMRs will be required, instead of voluntary.
• Phase 2 —Starting on December 21, 2020, regulated entities that are required to submit certain
other NPDES reports will begin submitting these reports electronically. Reports covered in the
second phase include Notices of Intent to discharge in compliance with an NPDES general permit,
Sewer Overflow/Bypass Event Reports, and a number of other NPDES program reports.
Incorporating Electronic Reporting Requirements into NPDES Permits
The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic
reporting requirements into NPDES permits beginning December 21, 2015. Under the new rule, the
electronic reporting process supersedes the paper reporting process. According to our files, your NPDES
permit became effective after November 2013, and should contain the requirement to electronically
report your Discharge Monitoring Reports using NC DWR's eDMR system.
In addition to requiring permittees to report information electronically, the rule also requires permittees
to identify the initial recipient for the NPDES electronic reporting data [see 40 CFR 122.41(I)(9)]. Initial
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6300

recipient of electronic NPDES information from NPDES-regulated facilities (initial recipient) means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES Data [see 40 CFR 127.2(b)]. Permittees are required to electronically
submit the required NPDES information to the appropriate initial recipient, as determined by EPA. By July
18, 2016, EPA must identify and publish on its web site and in the Federal Register a listing of initial
recipients by state and by NPDES data group. Once available, you can use EPA's web site to find out or
determine the initial recipient of your electronic submission.
NC DWR has submitted a request to EPA to be the initial recipient for the following NPDES data groups:
1. Discharge Monitoring Reports;
2. General Permit Reports [Notices of Intent to discharge (NOls); Notices of Termination (NOTs)];
3. Pretreatment Program Reports; and
4. Sewer Overflow/Bypass Event Reports
EPA's web site will also link to the appropriate electronic reporting tool for each type of electronic
submission for each state. Instructions on how to access and use the appropriate electronic reporting
tool will be available as well.
For more information on EPA's NPDES Electronic Reporting Rule, visit
http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes-
electronic-reporting-rule. For more information on electronic reporting to NC DWR, visit
http://deg.nc.gov/about/divisions/water-resources/edmr/npdes-electronic-reporting or contact Vanessa
Manuel at 919-807-6392 or via email at [e-mail].
Sincerely,
Jeffrey O. pav-pa4r
forS. Jay Zimmerman, P.G.
Cc: NPDES File
Central Files
N1ao"" re vi'ilARegi I Office / IUUa e.rxQual�tlnProgra

W2
1
t
June 2, 1
Wastewater Branch
Water Quality Permitting Section
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
THE CITY ®i' KINGS MOUNTAIN
P.O. BOX 429 - KINGS MOUNTAIN, NORTH CAROLINA 28086 • 704-734-0333
I
Subject: Delegation of Signature Authority
Pilot Creek Wastewater Treatment Facility
NPDES Number NCO020737
To Whom It May Concern:
R50EIVED/NCDENR/DWR
JUN a 2016
\�-Iulnos
MOORESVILLE RIEGIi)NAL OFFICE
By notice of this letter, I hereby delegate signatory authority to each of the following individuals for all
permit applications, discharge monitory reports, and other information relating to the operations at Pilot
Creek Wastewater Treatment Plant as required by all applicable federal, state, and local environmental
agencies specifically with the requirements for signatory authority as specified in 15A NCAC 2B.0506.
Kim Moss
Wastewater Plant Supervisor/ORC
City of Kings Mountain
P O Box 429
200 Potts Creek Road
Kings Mountain, NC 28086
[e-mail]
704-739-1731 (office)
704-472-7472 (mobile)
Richelle Meek
Laboratory/Pre-Treatment Analyst
City of Kings Mountain
P O Box 429
200 Potts Creek Road
Kings Mountain, NC 28086
[e-mail]
704-739-1731 (office)
704-734-7851 (mobile)
If you have any questions regarding this letter, please feel free to contact me at 704-734-4525.
Sincerely,
Ricky C. Duncan
Water Resources Director
City of Kings Mountain
P O Box 429
Kings Mountain, NC 28086
704-734-4525 (office)
704-477-2928 (mobile)
✓Cc: NCDWR Mooresville Regional Office, Water Quality Permitting Section
The Historical City

t
June 2, 2016
Wastewater Branch
Water Quality Permitting Section
Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
THE CITY OF KINGS MOUNTAIN
P.O. BOX 429 • KINGS MOUNTAIN, NORTH CAROLINA 28086 0 704-734-0333
Subject: Delegation of Signature Authority
Pilot Creek Wastewater Treatment Facility
NPDES Number NCO020737
To Whom It May Concern:
RECEIVED/NCDENR/DWR
JUN 8 2016
WQROS
MOORESVILLE REGIONAL OFFICE
By notice of this letter, I hereby delegate signatory authority to each of the following individuals
for all permit applications, discharge monitory reports, and other information relating to the
operations at Pilot Creek Wastewater Treatment Plant as required by all applicable federal, state,
and local environmental agencies specifically with the requirements for signatory authority as
specified in 15A NCAC 2B.0506.
Ricky C. Duncan
Water Resources Director
If you have any questions regarding this letter, please feel free to contact me at 704-734-0333.
Sincerely,
G. Scott Neisler
Mayor, City of Kings Mountain
ACc: NCDWR Mooresville Regional Office, Water Quality Permitting Section
The Historical City

+.
PAT MCCRORY
Governor
r�
DONALD R. VAN DER VAART
Secretary
WaterResources
ENVIRONMENTAL QUALITY S. JAY ZIMMERMAN
Director
December 11, 2015
CERTIFIED MAIL #70151520 0002 83761220
RETURN RECEIPT REQUESTED
Mr. Dennis R. Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number NOV-2015-LV-0784
Pilot Creek WWTP
NPDES Permit NCO020737
Cleveland County
Dear Mr. Wells:
A review of the October 2015 self -monitoring report for the subject facility revealed violations of the
following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
10/15/2015
Thallium
17-ug/I
1.43 ug/I (Daily Average)
10/31/2015
Thallium
17 ug/I
1.43 ug/I (Monthly Average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.)143-215.1 and NPDES Permit No.
NC0020737. Pursuant to G.S.143-215.6A, a civil penalty of not more that twenty-five thousand
dollars ($25,000.00) maybe assessed against any person who violates or fails to act in.
accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.143-
215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
October 2015 Discharge Monitoring Report (DMR). You will then be notified of,' any civil penalties
that may be assessed regarding these violations. If no response is received in this Office within
the 10-day period, a civil penalty assessment may be prepared.
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office) 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

Mr. Dennis R. Wells
City of Kings Mt. WWTP
NOV-2015-LV-0784
December 11, 2015
Page 2
Remedial actions, if not already implemented, should be taken to correct any noted problems. The
Division of Water Resources 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 (SOC). If you have questions concerning this matter or to apply for a
SOC, please do not hesitate to contact Roberto Scheller or myself at [phone].
Sincerely,
W. Cory Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,-NCDEQ
cc: Wastewater Branch
MSC 1617 — Central Files Basement
RLS

North Carolina Department of Environmental Quality
Pat McCrory
Governor
November 25, 2015
CERTIFIED MAIL #7015 1520 0002 8376 1121
RETURN RECEIPT REQUESTED
Mr. Dennis R. Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086
Donald van der Vaart
Secretary
.��� tom! �-�� E
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number NOV-2015-LV-0765
Pilot Creek WWTP
NPDES Permit NCO020737
Cleveland County
Dear Mr. Wells:
A review of the September 2015 self -monitoring report for the subject facility revealed violations of
the following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
9/10/2015
Thallium
22 ug/1
1.43 ug/l (Daily Average)
9/30/2015
Thallium
22 ug/1
1.43 ug/l (Monthly Average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to G.S. 143-215.6A, a civil penalty of not more that 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 G.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
August 2015 Discharge Monitoring Report (DMR). You will then be notified of any civil penalties
that may -be assessed regarding these violations. If no response is received in this Office within the 10-
day period, a civil penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any noted problems. The
Division of Water Resources 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
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone:[phone] Internet: www.ncdenr.gov
An Equal Opportunity 1 Affirmative Action Employer — Made in part by recycled paper

Mr. Dennis R. Wells
City of Kings Mt.
NOV-2015-LV-0765
Page 2
you anticipate remedial construction activities, then you may wish to consider applying for a Special
Order by Consent (SOC). If you have questions concerning this matter or to apply for a SOC, please
do not hesitate to contact Roberto Scheller or myself at [phone].
Sincerely,
.;z ichael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: Wastewater Branch
MSC 1617 — Central Files Basement
RLS

North Carolina Department of Environmental Quality
Pat McCrory Donald van der Vaart
Governor Secretary
November 25, 2015
CERTIFIED MAIL #7015 1520 0002 8376 1114
RETURN RECEIPT REQUESTED
Mr. Dennis R. Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number NOV-2015-LV-0764
Pilot Creek WWTP
NPDES Permit NCO020737
Cleveland County
Dear Mr. Wells:
A review of the August 2015 self -monitoring report for the subject facility revealed violations of the
following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
8/6/2015
Thallium
32 ug/1
1.43 ug/l (Daily Average)
8/31/2015
Thallium
32 ug/1
1.43 ug/1(Monthly Average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to G.S. 143-215.6A, a civil penalty of not more that 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 G.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
August 2015 Discharge Monitoring Report (DMR). You will then be notified of any civil penalties
that may be assessed regarding these violations. If no response is received in this Office within the 10-
day period, a civil penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any noted problems. The
Division of Water Resources 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
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] \ Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer — Made in part by recycled paper

Mr. Dennis R. Wells -
City of Kings Mt.
NOV-2015-LV-0764
Page 2
you anticipate remedial construction activities, then you may wish to consider applying for a Special
Order by Consent (SOC). If you have questions concerning this matter or to apply for a SOC, please
do not hesitate to contact Roberto Scheller or myself at [phone].
Sincerely,
r
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: Wastewater Branch
MSC 1617 — Central Files Basement
RLS

North Carolina Department of Environmental Quality
Pat McCrory
Governor
October 13, 2015
Mr. Dennis Wells, Dir.
City of Kings Mountain
101 W Gold St.
King Mountain, NC 28086
Donald R. van der Vart
hqtCEIVED/ Secretary
NCDENR/DWR
OCT 2 1 2015
MOORESVILLE OROS
EGIONAL OFFICE
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Pilot Creek WWTP
Permit Number: NCO020737
Case Number: LV-2015-0190
Cleveland County
Dear Mr. Wells:
This letter is to acknowledge receipt of check number 9340 in the amount of $1, 646.97 received from you on October 13,
2015. This payment satisfies in full the above 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 contact Wren Thedford at 919-807-6304.
Sincerely,
Wren Thedford
cc: Central Files
W7ooresvi11e3Raionalsr
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 91 M07-6492
Internet: wvvw.ncwater.org
An Equal Opportunity 1 Affirmative Action Employer

A -41 7A4tA F
�I_ rl�r �'T
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
September 14, 2015
CERTIFIED MAIL 7015 0640 0002 9299 3489
RETURN RECEIPT REQUESTED
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
101 W Gold St.
Kings Mountain, NC 28086
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. NCOO20737
Pilot Creek WWTP
Cleveland County
Case No. LV-2015-0190
Dear Mr. Wells:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$1646.97 ($1500 civil penalty + $146.97 enforcement costs) against the City of Kings Mountain.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for December 2014. This review has shown the subject facility to be in
violation of the discharge limitations found in NPDES Permit No. NCOO2O737. The violations are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that the City of Kings Mountain
violated the terms, conditions, or requirements of NPDES Permit No. NCOO2O737 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 Resources, I, Michael L. Parker, Regional Supervisor for the Mooresville
Region, hereby make the following civil penalty assessment against the City of Kings Mountain:
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: http://portal,ncdenr.org/webhvq
— C......i t AM—i:.... Anf;nn r.nni..,,...... 1001 D.—A.A7MOL D—f --,

$ 0.00 For 2 of the two (2) violations of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0020737, by discharging waste into the
waters of the State in violation of the permit daily maximum
effluent limit for Arsenic.
$ 1500.00 For 1 of the one (1) violation of G.S. 143 -215. 1 (a)(6) and
NPDES Permit No. No. NC0020737, by discharging waste into
the waters of the State in violation of the permit monthly average
effluent limit for Arsenic.
$ 1500.00
$ 146.97
$ 1646.97
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 riot 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:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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 Resources 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. 14313-282.1(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 Resources 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 Resources also requests that you complete and submit the enclosed
"Justification for Remission Request." Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
11
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 petition may be filed by facsimile (fax) or electronic mail by an
attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing
fee is required by NCGS § 15013-23.2) is received in the Office of Administrative Hearings within
seven (7) business days following the faxed or electronic transmission. You should contact the
Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process. The mailing address and telephone and fax numbers for the Office of Administrative
Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mr. Sam M. Hayes, General Counsel
DENR
1601 Mail Service Center
Raleigh, NC 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 notice, 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 you have any questions about this civil penalty assessment please
contact staff in the Mooresville Regional Office at [phone].
te)
ATTACHMENTS
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Mooresville Regional Office Compliance File w/ attachments
Raleigh Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT A
CASE NO. LV-2015-0190
Outfall
Date
Parameter
Reported Value
Permit Limit
001
12/18/2014
Arsenic
355 ug/l
340 ug/l (Daily Maximum)
001
12/23/2014
Arsenic
360 ug/l
340 ug/1(Daily Maximum)
001
12/31/2014
Arsenic
249.6 ug/1*
184 ug/l (Monthly Average)
* Denotes civil penalty assessment
The City of Kings Mountain response to NOV-2015-LV-0127 received on March 27,
2015 was reviewed by DWR staff. Mitigating factors were not found to result in a
reduced civil penalty amount.

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 PENALTY AGAINST ) ADMINISTRATIVE HEARING AND
CITY OF KINGS MOUNTAIN ) STIPULATION OF FACTS
PERMIT NUMBER NC0020737 )
FILE NO. LV-2015-0190
Having been assessed civil penalties totaling $1646.97 for violation(s) as set forth in the
assessment document of the Division of Water Resources dated March 16, 2015, 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 Resources 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 , 2015
BY
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWR Case Number: LV-2015-0190
Assessed Party: City of Kings Mountain
County: Cleveland
Permit Number: NC0020737
Amount Assessed: $1646.97
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of 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-282.1(b) were
wrongfully 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: (use additional pages as necessary)

Violator:
Facility:
County:
NORTH CAROLINA DIVISION OF WATER RESOURCES
ASSESSMENT FACTORS
Cijy of Kings Mountain
Pilot Creek WWTP
Cleveland
Case Number: LV-2015-0190
Permit Number: NC0020737
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;
No harm has been documented;
2) The duration and gravity of the violation;
The Arsenic daily maximum effluent limit violations exceeded the permit limit by 4.4%, and 5.9%.
The Arsenic monthly average permit limit was exceeded by 35.7%, during the month of December
2014.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on the receiving stream is unknown.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount.of money saved by noncompliance;
The amount of money saved by noncompliance is unknown.
6) Whether the violation was committed willfully or intentionally;
The Division of Water Resources has no evidence that 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;
There have been 19 previous CPAs for the Pilot Creek WWTP with the last CPA issued on November
15, 2012 for zinc violations that occurred in July 2012.

8) The cost to the State of the enforcement procedures.
The cost to the Division of Water Resources is $146.97.
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR

.A* North Carolina Department of Environmental Qval
't -
Pat McCrory Donald vanae."rt
Governor Secretary
'9/29/2015
CERTIFIED MAIL #7015 0640 0002 9299 3731
RETURN RECEIPT REQUESTED
Mr. Dennis R. Wells, Water Resources Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number NOV-2015-LV-0618
Pilot Creek WWTP
NPDES Permit NCO020737
Cleveland County
Dear Mr. Wells:
A review of the July 2015 self -monitoring report for the subject facility revealed violations of the
following parameter at Outfail 001:
Date
Parameter
Reported Value
Permit Limit
7/16/2015
Thallium
25 ug/l
1.43 ug/l (Daily Maximum)
7/31/2015
Thallium
25 ug/l
1.43 ug/l (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to 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 G.S. 143-215.1.
If you wish to provide additional information.regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
July 2015 Discharge Monitoring Report. You will then be notified of any civil penalties that may be
assessed regarding these violations. If no response is received in this Office within the 10-d4y
period, a civil penalty assessment may be prepared.
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] \ Internet: www.ncdenr.gov
An Equal Opportunity \Affirmative Action Employer -Made In part by recycted paper

01.
NOV-2015-LV-0618 Page 2
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources 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.
If you have questions concerning this matter, please do not hesitate to contact Ori Tuvia or myself at
[phone].
Sincerely,
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: Wastewater Branch
MSC 1617 — Central Files Basement
OT

City of Kings Mountain Pilot Creek WWTP
200 Potts Creek Road
Kings Mountain, NC 28086
September 3, 2015
Michael L. Parker
Water Quality Regional Operations Section
610 East Center Ave. Suite 301
Mooresville, NC 28115
RECEIVED/NCDENRIDW I?
SEP 8 2015
WQROS
MOORESVILLE REGIONAL OFFICE
LU^2v�S�- OZ3�
Z S' 0
1,5,0
I�J v
�
Dear Mr. Parker: 0 6, c/ '� -
J N 6 a q�
In reference to the NOV/NRE dated August 28, 2015 for the Pilot Creek WWTP, June 2015 self -
monitoring report, the City of Kings Mountain would like to request a permit modification for the
parameter, "Thallium". As noted in our request submitted during the draft permit, we requested that
the limit be removed and replaced with monitoring of this parameter. After no response, we received
our final permit effective June 01, 2015. The Thallium limit remained the same, (1.43 ug/I daily
maximum and 1.43 ug/I monthly average).
However, we have been tracking Thallium throughout the collection system. Once we had become
aware of this parameter, we begin to collect samples from our eight (8) permitted SIU's, Local Permit
holders, wastewater treatment plant's Influent, Aeration Basin, and Effluent discharge. According to
these results, there is only one (1) SIU found to have Thallium in its discharge. The Thallium valves
discharged from this SIU ranged from 240-1,240 ug/I.
Therefore, with monitoring only of this parameter (Thallium), we can work with this industry to
determine what additional process is needed. Also we will need to revise the city's LTMP and HWA so
that removals rates can be calculated and Thallium limits can be set.

Pat McCrory
Governor
4�yy �LE
1
NC®ENR
North Carolina Department of Environment and Natural Resources
8/26/2015
CERTIFIED MAIL #7015 0640 0002 9295 6194
RETURN RECEIPT REQUESTED
Mr. Dennis R. Wells, Water Resources Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086
Donald van der Vaart
. Secretary
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking Number NOV-2015-LV-0552
Pilot Creek WWTP
NPDES Permit NCO020737
Cleveland County
Dear Mr. Wells:
A review of the June 2015 self -monitoring report for the subject facility revealed violations of the
following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
6/4/2015
Thallium
33.9 ug/I
1.43 ug/I (Daily Maximum)
6/30/2015
Thallium
33.9 ug/I
1.43 ug/I (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is, being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to 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 G.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
June 2015 Discharge Monitoring Report. You will then be notified of any civil penalties that may be
assessed regarding these violations. If no response is received in this Office within the I 0-day
period, a civil penalty assessment may be prepared.
Mooresville Regional Office
Location: 610 East Center Ave„ Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: http://porLal.ncdenr.org/web/wq

NOV-2015-LV-0552 Page 2
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources 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.
If you have questions concerning this matter, please do not hesitate to contact Ori Tuvia or myself at
[phone].
Sincerely,
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617 — Central Files Basement
OT

Pat McCrory
Governor
FILE
NCDENR
North Carolina Department of Environment and Natural Resources
March 16, 2015
CERTIFIED (MAIL #7011 0110 0000 9960 7815
RETURN RECEIPT REQUESTED .
Mr. Dennis R. Wells
Water Resources Director
City of Kings Mountain
P.O. Box 429'
Kings Mountain, North Carolina 28086
Donald van, der Vaart
Secretary
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2015-LV-0127
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Wells:
A review of the December 2014 self -monitoring report for the subject facility revealed violations of the
following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
12/18/14
Total arsenic
355.0 µg/L
340.0 µg/L (Daily maximum)
12/23/14
Total arsenic
360.0 µg/L
340.0 µg/L (Daily maximum)
12/31/14
Total arsenic
250.0 µg/L
184.0 µg/L (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to 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 G.S. 143-215.1.
If you wish to provide.additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
- - - --December-2014-Discharge -Monitoring--Report. - You will -then be notified -of any -civil -penalties -that— -
Mooresville Regional Office -
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] t Fax: [phone] Customer Service:1-877-623-6748
Internet http://portal.nodenr.org/web/wq

NOV-2015-LV-0127, Page 2
may be assessed regarding these violations. If no response is received in this Office within the
10-day period, a civil penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources 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. -
If you have questions concerning this matter, please do not hesitate to contact Ms. Marcia Allocco or
myself at [phone].
Sincerely,
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617 — Central Files Basement

NC®ENR
North Carolina Department of Environment and
Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
April 16, 2015
Ms. Kim Moss
WWTP ORC/Pretreatment Coordinator
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: PAR Review
City of Kings Mountain/Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear .Ms. Moss:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the reporting
period of January through December 2014. Based on the review, the POTW completed the PAR in accordance
with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for North Carolina
Pretreatment Programs. The next PAR will be due March 1, 2016.
If you have any questions concerning your PAR, please do not hesitate to contact me at [phone] and/or
Sarah Bass at [phone] or at wes.bellanedenr.gov and sarah.bassancdenr.gov.
Sincerely,
Wes Bell
Environmental Specialist
Water Quality Regional Operations Section
cc: Sarah Bass, PERCS Unit
Mooresville Regional Office
Location: 610 East Center Ave„ Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: www.nGwaterquality.org
An Equal Opportunity l Affirmative Action Employer — 30% Recycledil0% Post Consumer paper

Sifford, Barbara
From: Parker, Michael
Sent: Friday, March 06, 2015 1:56 PM
To: Sifford, Barbara; Bell, Wes
Subject: FW: NC0020737 24/7 Waiver Request
Additional info. Still need both of your comments.
Michael Parker— Regional Supervisor
[e-mail]
North Carolina Dept. of Environment & Natural Resources Division of Water Resources Water Quality Regional
Operations Section
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Direct Line: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
-----Original Message -----
From: Belnick, Tom
Sent: Friday, March 06, 2015 11:03 AM
To: Parker, Michael
Cc: Sledge, Bob
Subject: RE: NC0020737 24/7 Waiver Request
Mike- Looks like we dropped the ball in 2010. Jackie did 2010-renewal and indicated that the waiver would be handled
separately, and I see MRO recommending waiver denial at that time, but there was no follow-up letter in our files. I've
copied Sledge, just in case he recalls any of this as former MRO ROC.
So, what to do with this round. They are requesting 24/7 waiver continuation. MRO staff report (Samar, 3/22/2013) did
not mention any operational/compliance issues. NPDES generally relies on Region recommendation for 24/7 waiver
request. As mentioned, we did not receive any supporting material for request with their application package. Can MRO
review situation again and provide recommendation. Thanks.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit NCDWR/Water Quality Programs
919-807-6390
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties
-----Original Message -----
From: Parker, Michael
Sent: Friday, March 06, 2015 9:30 AM
To: Belnick, Tom
Subject: RE: NC0020737 24/7 Waiver Request

Tom,
Can you get someone to send us a copy of the "official" waiver denial that was issued back in 2009? The cover letter
attached to the 2009 permit indicates that a decision will be made on their waiver request and forwarded to them under
separate cover, but we do not have a copy of the final decision in our files.
Thanks
Mike
Michael Parker — Regional Supervisor
[e-mail]
North Carolina Dept. of Environment & Natural Resources Division of Water Resources Water Quality Regional
Operations Section
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Direct Line: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
-----Original Message -----
From: Belnick, Tom
Sent: Thursday, March 05, 2015 4:40 PM
To: Parker, Michael
Subject: FW: NC0020737 24/7 Waiver Request
Mr Parker- can you provide input on City of Kings Mountain/Pilot Creek WWTP request (attached) for waiver of 24/7
staffing per 2H.0124. The attachment was from the Cover Letter for permit renewal, but City included no information
pertaining to request. Permit file indicates that Division denied same request during 2009 renewal. NPDES will keep this
action separate from the permit renewal, which we are hoping to finalize next week. Thanks.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit NCDWR/Water Quality Programs
919-807-6390
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties
-----Original Message -----
From: Tom Belnick [mailto:tom.be[[e-mail]]
Sent: Thursday, March 05, 2015 4:24 PM
To: Belnick, Tom
Subject: Message from "RNP0026733F34F1"
This E-mail was sent from "RNP0026733F34F1" (Aficio MP C4502).
Scan Date: 03.05.2015 16:24:09 (-0500)
Queries to: [e-mail]

V
Bell, Wes
From: Hollenkamp, Carol
Sent: Friday, May 09, 2014 4:06 PM
To: Bell, Wes
Cc: Ventaloro, Christopher; Moore, Cindy
Subject: RE: Toxicity Test Reports
Hi Wes,
For King's Mtn, we are recommending that another split test be performed when you have time. This could be in June
or at one of their next quarterly sampling events. I know you are swamped with work after our last round of RIFs and
staff changes, so whenever you consider this to be practical.
Our test failed and ETT's test passed, but they actually had the same control mean reproduction —ours was 17.9, ETTs
was 17.8. So far, I have not found any reason to invalidate ETTs test or our own, and I have found no discrepancies in
the chain of custodies, water chemistries, etc. ETT's test had a somewhat low test reproduction mean and somewhat
low control performance, but the test meets all test acceptability criteria, is valid, and so they will receive a pass for
compliance. Because this facility has had so many failing tests over the past few years, and their test results are so
variable, we recommend another split test.
If you have any questions, just let me, Chris, or Cindy know.
Thanks,
Carol Hollenkamp
Aquatic Toxicology Branch/Water Sciences Section
North Carolina Division of Water Resources/DENR
1621 Mail Service Center, Raleigh, NC 27699-1621
Phone: [phone]
Fax: [phone]
Website: http://Portal.ncdenr.org/web/wq/ess/atu
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Hollenkamp, Carol
Sent: Friday, May 09, 2014 3:54 PM
To: Parker, Michael
Cc: Bell, Wes; Ventaloro, Christopher; Moore, Cindy
Subject: Toxicity Test Reports
Attached are the toxicity test reports for Gastonia Long Creek WWTP and King's Mountain Pilot Creek WWTP. If you
have any questions, please let me know.
Thanks,

Carol Hollenkamp
Aquatic Toxicology Branch/Water Sciences Section
North Carolina Division of Water Resources/DENR
1621 Mail Service Center, Raleigh, NC 27699-1621
Phone: [phone]
Fax: [phone]
Website: http://portal.ncdenr.org/web/wq/ess/atu
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
z

Pat McCrory
Governor
North C8roliha Department,of Environment -an.d Natural Resources
April 29, 2014
CERTIFIEDMAIL
—
RETURNRECEIPT REQUESTED:
70,112 2210 0002 3534 8536.
Mr.DemiisWblls
Director
City of Kings , , Mo , Mountain
P.O. 13ox'429
Kin -NC 28086-0429
gs,, imt4h�,
SUBJECT:
LATION: NGNOV-'2014-TXmO013
Non CE I 'OF VIOLATION:
'
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NO0020737
Pilot Creek WWTP
'Cleveland County
Dear Mr..Wells:
John E. Skvarla III
Secretary
Thi&Js1tpjnfprrn yowthat.a review of your toxicity -,self-moiiit6dngtepoh;fd forihtmonthoffebruarylbi4 indicates aviQlation,df the toxicity,
limitation specified . in your :NP-DESPermit
You �should �tak& whatever remedial actions- are necessary to eliminate the conditi . ons.causing the, effluent toxidityvic!14don(s). Yo
ur 'm efforts ay
i , nchide.condu6ting a Toxicity Reduction Evaluation (TRE), a sit , e= I spec I i I fic, sWdy designed to,tidentify the causative agents of . effluent toxicity, isolate
the sources oftb)461y, evaluate the effectiveness oftoxi6i"ty(!on'tr61;bptidn§,.aiid c6hfirmydductions'in effluent toxicity, Pase, aware that le 'be it North,
e'
C I arojina General'Stit - utes provide fdr asse§sment'of civi , I , Venilties'fdryiolations of NPDES perffi,it'liMitatioiO and requirements.
The reverse:side of, this Notice contains iniportarit infOrmAtiOn concerning your Whole I E I ffluent'Tox'idiiy Monitoring and R60ortingRequiferrichts.,
dA�uatic toxicity {AT) T�sfforms, 'We
noncom note,appropriat mailing addre�ses for submitting, ��ur Discharge monitoring Repor4s PyRs) an - -
,9 1 1 would resolve effluent tonicity
encourage you td:reView this information; if X wo be, heipH. to this situation or possible solutions to
m6neomp - liancei�l please contact'Mr. John.Gidrgino with this offipp-at(519) 743- 8441.
Sincerely,
Cindy Moore,,Supervisor Aquatic Toxicology Branch
Water Sciences Sectibii
Division of Water Resources, NCDENR
Wes -Beft -Mooresville Regional. Office-.,
Aquatk Toxicology Unit
Central File's
1621 Mail Service C6hter,.Rale0j North:.Carolina V6,99-167,11
I Locafiom4461'R664 Creekkoad, Raleigh, North Carolina 27607,
Phone: [phone] l!`Ak 919743Z17
Intemet porta1,ncdenr,org/webMq1home
An Equal Opportunity) Mrmake'Action tmpjoyer

13
WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
The following; items are provided in an effort to assist you with identifying -critical and
information. Please take time to review this information. The items below do not a&
requirements contained in vour NPDESpermit. If you should Have any questions.a
.Iohn Giorgrno with the Aquatic Toxicology Branch at [phone] or another Branch. representative at the same number,
Y The permittee:is responsible, for ensuring that tox;icity.testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
lie 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 Reportwhich is submitted to:
North Carolina Division of Water Resources
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 Resources
Water Sciences Section
1621 Mail Service .Center
RaleighNoith`Carolina 27699-1621
Toxicity test results shall be filed with the Water'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).
9 Toxicity test,condifion language contained in.yourNPDES `permit.may require use ofmultiple concentration toxicity testing,upon fa . lur e<of any
single quarterly toxicitytest. 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-enforcementresponse.
Toxicity testing months are specified by the'NPDES Permit, except for NPDES Permits which contain episodic toxicitymonhor rig,
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.7anuary 1-June :30, then you. must provide
written. notification to:the Water Scierces. Section by7une 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, ydti shouldimmediately notify the, Water Sciences Section
at [phone] and provide written documentation indicating why the Pest was invalidated and the date when follow-up. testingwill occur.
p 1f your facility is required to conduct toxicity testing during:a month in which no discharge occurs, you -should complete the information block;
located. atthe top of the AT form ;indicatingthe facility -name, permit number, pipe number, eountyand. the month/year of the subject report..
You should also write °`No;FIow" 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 inResponsible Charge (ORC) except for facilities which have not
received a facility _classification.. In these cases, a duly authorized facility representative mist sign the AT form. The AT form must also be
signed by perfoririinglab supervisor.
➢ To determine if your AT test forms were received on time,by the Division of Water Resources, you may consider submitting your toxicity, test.
results certified, mail, return•receipt requested to the Water Sciences Section..
1621 Mail Service Center, Raleigh, North; Carolina 276Q9' 1621
Location' 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone]'001 FAX: [phone]
Internet: po ial.ncdenr,orglweb..Mq/home
An Equo 0ppoTW0y S AKnnative Action Employer

Ql 1, LITY
4
Oq APR
17 2014
GEAR
North Carolina Department -of Environment and Natural Resources"
71i",L G F 10'
PatMcCrory
Gbverh&
April 4, 2014
:CERTIFIED.,MAIL,
RETURNRECEIPT REQUESTED.- 70122210 00023534 8444
Mr. Dennis Wells
Director
:City.,6f Kings.Mount'ain
P.O. Box 419
Kings Mountain, NC 19686-o429.
'SUBJECT:.
NOTICE OF VIOLATION: NC-NOV-20,14-.PC-0057
Whole-EffluentToxicity (WET) Testing
NPDES Permit No. NC 00.20737
'
Pilot Creek WWTP'
Cleveland. County
Dear Mr; Wells:
Jcihh E. Skvatla 111,
Secretary
This is to inform you that.a review of yourtoxicity self -monitoring "report form for the 'month' of.January 2014 indicates a violation of the toxicity limitation specified in your NPDES Permit
Youslibuld t&dwhatbver remedial actions are necessary to eliminate the, conditions'caus ing the effluent toxicity vioutidii(s). Your efforts may
include conducting A Toxicity Reductioi.i Evaluation (TlZE),, a site -specific stud designed,to identif� the, causative agents of effluent
y toxicity; iso'late
the sources of toxicity, evaluate the effectiveness of toxicity control options; and confirm reductions in effluent toxicity. Please be awa
re that Norft
Carolina General Statutes.:providefib,r assessment of civil penalties for violations -of NPDES. permit limitations and requirements.
The reverse side of this Notice. contains -Important information concerning -your Whole Effluent Tbxicity'Mcinitofing and Reporting , Requirements..
port
Please. note 'appropriate mailing addresses for submitting. your Discharge Monitoring Reports (L)MRs) and Aquatic Toxicity (AT) Test_,ForMs' s . We
ge you to review this information; if it would helpful to •'discuss this situation, or, possible golutionsAb resolve effluent toxicity * '
encourage coura be ..
noncompliance, please contact Mr. John Giorgirio with this office. at (919) 743 - 8441.
4 M
Cindy'Moore, Supervisor Aquatic Toxicology Branch
Division of Walter'Resourcesi NCDENR.
cc: Wes Bell ;. Mooresville Regional Office
Aquatic Toxic6l6gy Unit -
Central Files
Water Sciences Section
.1621 Mail-Servim'Unter, Raleigh, Nodh Carolina 27699-1621
Location: 4401, Reed y Creek Road, Raleigh, North Carolina 27607.
Phone [phone]FAX: [phone]
lntemdt:'Por6l.ncdenr.oigtvieb/wqlhOM6
n-
AEqual OppbauniV \ Affirmative.. , Adon Employer

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 reuortilig
requirements contained in your NPDES Hermit. If you should have any questions about your toxicity testing requirement, please contact h4r.
John Giorgino with, the Aquatic Toxicology Branch at [phone] or another Branch 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 Resources
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
'Toxicity test data (original "AT' form) must besubmitted to the following address:
North Carolina Division of Water. Resources
Water Sciences Section
1621"Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity. test results shall be fried with the Water Sciences Section no later than 30 days after the end of the reporting tieri'od (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.d"oes 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 of 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 bythe 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 inust
be` conducted' during these months).
'if youi 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 e Water Sciences Section by June 30 that a discharge did not occur during the first six months of the year.
the
If you receive notificatim from your contract laboratory that a test was invalidated, you should immediately notify the Water 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,fotm, sign the1b.rm and submit following normal procedures.
9 The;Aquatie 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 sigh 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 Resources, you may consider submittingyoui'toxicity test
results certified mail. return receipt requested'to the Water, Sciences.Section„
Water. Sciences Section
1621 Mail ServlW Center,•RaleO, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, Noah Carolina 27607
Phone: [phone] FAX: 919:743-8517
Internet portal,ncdencorglweb1wg1h0me
An Equal Opportunity 1 Affirmative Action Employer

KWA
NCDEHR-
North Carolina Department - of trvirprmet and Natural Resources
Division
n of ' Water
teT Resources,
Water Programs
Pat McCrory Thomas A. Reeder
John E. Rvarla'111
Governor Director Secretary
January 36,1-2014
CERTIFIED MAIL
RETURN RECEIPT
T REQUESTgp,:I. 70 LX 212-110-0002 3534 8215
Mr.. Dennis Wells'
Director
City ofKings Mountain
, 6k 429.
Kings: MounWn;. NG28086-0429
SUBJECT:
NOtICE-OF-VIOL - ATION:,NC-NOV-2014-TX-00 1,1
Whole Ef&ent Toxicity (WFI) Testing
NPDES PerinifNo.°NC00267-37
P , il6t.Creek-WWTP
'Cl6eland County
1),ear Mr.. Wells;
Thisis to inform you that-areviewof your'toxicity seit-monitoring;reportform for the month"of November 2013 indicates aviolation of the toxicity
limitatioln specified iny.obrNPDES Perinix
You should takeviiatever remedial actions are necessary to eliminate the conditions causing the effluent tonicity 'violation(s). Y ­5 rts-
our e o , may
include d6nducting,'a'Toxidity Redubti6fi-Evaluation(TRE), a:site�- fecific.stud designedto,identif afiv '-
-'sp - - - y ythe,caus e:pgeriisofefflui!iittoxiciiy,fsolate,
the sources of toxicity, evaluate; the effectiveness of toxicity control o0doh-s and confirm`lredadtidds W -dfflddnt
"- ' - " I -- - tolkicit.y. 1' Please, beawarethat North
C&Ioliha.General Statutes proVi-de for.assessment of civil penalties forviolationsofWPL)ES.permit.limitatibris andirejuirements.
The reverse side of this Notice. contains important information ,concerning your. Whole Effluent Toxicity Monitoring. and. Reporting Rquitein ' q - nts:
Please note appropriate mailing oddress�e.,s',for'§ubmitting.your Discharge Monitoring.Reports (DURs) and Aquatic Toxic (AT)TestFor,
Ic Toxicity *s.
We
encourage you to review :his information; 'if it would• be helpful to discuss this situation- or possible 'solutions to resolve i6fflucni toxicity
noncompliance, pleas6 Contact Mr. JbhA Giorginom4b this office at-.(919)14I'- 8441..
Sincerely,
Cindy Moore
Supervisor, AquaticTOX ic logy Branch
cc: Wes Bell - MooreviHe,Regignal-Office,
Aquatic Toxicologyunit
Central'Files,
Environmental Sciences Section,
1621 Mail Service center; Raleigh, Noah Carolina 27699-1621
Locall6n:401 Reedy .Creek R6ad',.Raleigh; Ndrth.Carolina:27607
Phone: 91WQ-8400 1 F'A&919=74M517 VCustomdr 86rvices I-nR77-623V48,
,Internet http:llborteil.tiederit.ot4lwebWctless/hotbe
D fte.
North'Camaina,
An Equal -,Oppftunily \ MrmIaUvIe.AcIibn.Em.Ploy-er

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 t me-to,rev►ew this information. The items below do not'address o"r include aff the toxicity testing and reporting
requirements contained in your NPDES nerinit. ifyou Aould have any questions about your toxicity testing 'requirement, please contact. Mr.
John.Giorgino with.the Aquatic'ToxicologyUnit at (919) 743 '8 ,! I or aho.ther:Unit representative at the same number.
The permittee is responsible for ensuring that toxicity testing is conducted according 10 the permit requirement and that;toxicity'report.forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual reouirement. 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 Resources
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 Resources
Environmental Sciences Section
162,1_Mail Service Center
Raleigh,-,North.Carolina '27699.-1621
➢ Toxicity test results shall be filed with the Enviroiimental'Sciences Section no later than30 days after the end of the reporting Period
(eg, `)angry test result is due by the end of February).
Toxicity test condition language. contained in your NPDES.permii 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 in will be conducted 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 testingupon 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 ace specified by the NPDES Permit; except for NODES Permits: which contain episodic toxicity monitoring
requirements,(eg, ifthe testing, months specified in your NPDES„peTrnjfare March, June, September,, and December, then toxicity testing must
be conducted during these m6iitfis).
If your.NPDES.Permit:specifies;episodic,monitoring and your facility does not have a discharge- from January l-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 contractlaboratory that 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.
D If yourfacility; s;required to conduct toxicity testing during a montfi.in which no discharge_occurs; you should, complete thelnformation;block
located at the top of the AT form'indicating the facility.name, perrnitnumber, pipe number, county and the motiWyear of the subject report..
You should also write "No Flow".on the AT form, sign the farm and submit -following normal procedures.,
➢ The Aquatic Toxicity Test forms shall. be signed by thefacility'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 mii t also be
signed by the performing lab. supervisor.
➢ To -determine if your AT test forms were received on time by the Division of Water'Resources, you may consider'submittijag) our toxicity test
results certified mail, return receipt' requested to the Environmental Sciences Section:
Environmental Sciences Section
1621 Mail Service Center, Raleigh North Carolina 27699-1621 �TOne
Location 4401 Reedy Creek Road, Raleigh, North Carolina 276d7 1�1 of thCc`1Tolln&
Phone [phone] FAX [phone] Customer Service; ;1-87T623-6748
'Internet http:Hbortal.ncdenr.orct/web/waless/home atura"y
,k6.Equar'6ppoitunityl Aifirmalive'Acfion Emploor

PPPFF
Ad 'LT4
NR
North Carolina Department of Environment.and Natural Resources
Division. of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
January 14,1014
CERTIFIED MAIL
RETURN RECEIPT REQUESTED: 7012 2210 0002 3534 8109
Mr. Dennis Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NG28086-0429
SUBJECT:
NOTICE OF VIOLATION: NC;NOV-2014-TX-0003
Whole Efttuent'Toxicity (WET) Testing
NPDES Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr;.Wells:
John E. Skvarla III
Secretary
This -is to inform you that a review of your toxicity self -monitoring report form for the month of October 2013 indicates a violation of the toxicity
limitation specified in your NPDES Permit
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity vio16tion(s). Your efforts may
include conducting'a Toxicity Reduction Evaluation (TRE), a site=specific study.designed to identify the causative agents of effluent toxicity, isolate:
the sources of toxicity, evaluate the effectiveness of toxicity control options, and confirm reductions in effluent toxicity. Please be aware.that North
Carolina General Statutes provide for assessment of civil penalties for violations of NPD>✓S permit limitations and requirements;
The ,reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting Requirements.
Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DURs) and Agudtic Tonicity (AT) Test Forms. We
encourage you to review this information; 'if it "would be helpful `to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
Sincerely,
CindyMoore
Supervisor, Aquatic Toxicology Branch
cc: Wes Bell — Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental,Sciences Section
1621`Mail,SerAce Cenier Raleigh; North.Carolina27699-1621
Location: 4401 Reedy Creek Road, Raleigh; North Carolina 27607
Phone: [phone]A FAX: [phone] Customer Service:1-877-623.6748
Internet: htty://portal.hcdenr.orcttweb/wg/esslhome'
NonrthCarolina
VVahirdAff ,
An Equat Opportunity \ Affirmative Action Employer

WHOLEJEFFLITNTTQXICITY MONITORING pNP REPORTING -INFORMATION'
➢` The permittee is>respons 6le'for ensuru►gahat,toxicity testing is condacted, accotd11 nig V the'permit requirement and 'that toxicity report forms, are
appropriately filed.. „
The repotting ofwhole effluent; toxicity testing data, s a daal re uirement: tAli toxicity test-resulg=st.be entered?(with tlae-appropriate;'
parameter code) on,pour monthly Discharge 1Vlonituring Report which is submitted to=
Notth Carolina Division of VJater.Resources
Central Files;
1617`1VLai1'3ervice .Center
Kuteigh,:NC .E276994 6,17
IN ADDITION
Toxicity test'data (original""AT"�3form� �mugt tie submitted to the�foll'o*.ving�itiresst
North caroling Division of Water Resources
'Enyironnl' tal Sciences'_Section
1621 Mail Service.Genter
Raleigh, North Carolina; Z7699-16Z1
p If ypur N>'DES,Pe
written:notificatiot
year.
Iiyowreceive'noti.
Section;at.(M) 7l
occur:
iepisodic monitoring and your facility does not iiave:a;discharge from Janu,a y'1-June.3(
fies,
nvironmental Sciences' section by June O'that a discharge did not occur 6png the firstsix
tal `Soiences.
festmg will
ck
Environmental Sciences Seefion
1621 Mail SO�ice Center, Raleigh North Carohna'27699m1621 Onyx
Location 4401 ReedyCreek`Road %fth NorihCaroUna27607 Noit.hCarolitial
Phone 91�143,=84001FAX,919 74,305171 i 77-&23 6748
Internet rtal nedenr ora/weti/uvqless/home'
An Equal Dpp6durnty Y_affirmatve'A6on Employer

NCDENR F i L
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director, Secretary
August 27, 2013
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, North Carolina 28086
Subject: Notice of Deficiency — Monitoring Limitation
Tracking #: NOD-2013-MV-0057
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Wells:
A review of the May 2013 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001:
Date Parameter Reported Value Monitoring Requirement
5/31/13 Chloride 1x/month 2x/month
Remedial actions, if not already implemented, should be taken to correct the causes(s) of the noted
violation. Unresolved violations may lead to the issuance of a Notice of Violation and/or assessments
of civil penalties by the Division of Water Resources.
If the violations are due to a transcription error (data left off the DMR) please submit an amended
DMR (two copies) to this Office along with a cover letter asking for rescission of the Notice of
Deficiency. Please address your correspondence to Ms. Marcia Allocco at the letterhead address.
Thank you for your attention to this matter. If you have questions concerning this matter or to apply
for a SOC, please do not hesitate to contact Ms. Allocco at [phone].
Sincerely,
Michael L. Parker
Water Quality Programs
Regional Supervisor
cc: Point Source Branch
MA
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: hftp:Hportal.ncdenr.org/web/wq
An Equal Opportunity \ Affirmative Action Employer- 30% Recycled110% Post Consumer paper
NorthCarohna
Naturally

NCDENR
North Carolina Department of Environment and
Division of Water Quality
Pat McCrory Charles Wakild,-P. E.
Governor Director
January 7, 2013
CERTIFIED MAIL: 7007 1490 0004 5533 721.6
RETURN RECEIPT REQUESTED
Mr. Dennis_ Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086-0429
SUBJECT: NOTICE OF VIOLATION: NOV-2013-TX-0002
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO020737
Pilot Creek W WTP
Cleveland County
Dear Mr. Wells:
Natural Resources
John Skvarla
Secretary
O4V4�f' 1 CE4VEC
C)A. O,F: V1/r1TE'R QUALITY
S"Vp REC-T40
jq
11400RE�VYLLG EECPONAL OFFICE
This is to inform you that a review of your toxicity self -monitoring report form for the month of October 2012 indicates a violation of
the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your
efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -specific study designed to identify the causative agents
of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and confirm reductions in
effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil penalties for violations of
NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic
Toxicity (AT) Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible
solutions to resolve effluent toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
S*cerely,,.
Cindy Moore
Supervisor, Aquatic Toxicology Unit
cc: Mike Parker- Mooresville Regional Office
Wes_fl_ell3Moo L1le,Rogional ceANWW
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Selvice:1-877-623-6748
Internet http://h2o.enr.state.nG.us/esb/
One .:
Nolth Carolina
Natmrallff .
An Equal Opportunity 1 Affirmative Action Employer

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.
John Giorgino 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).
➢ 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 notificationto 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.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthCarolina
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet hftp:llh2o.enr.state.nc.uslesbl 'NatuA711
An Equal Opportunity 1 Affirmative Action Employer

Beverly Eaves Perdue
Governor
F7'
� L E
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P.E.
Director
October 25, 2012
CERTIFIED MAIL #7010 0780 0000 5519 1864
RETURN RECEIPT REQUESTED
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
PO Box 429
Kings Mountain, North Carolina 28086
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2012-LV-0547
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Wells:
Dee Freeman
Secretary
A review of the July 2012 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
7/13/12
Zinc
1 660 µg/L
581 µg/L (Daily maximum)
7/19/12
Zinc
643 µg/L
581 µg/L (Daily maximum)
7/31/12
Zinc
665.5 µg/L
497.2 µg/L (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0020737. Pursuant to 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 G.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
July 2012 Discharge Monitoring Report. You will then be notified of any civil penalties that may be
assessed regarding these violations. If no response is received in this Office within the 10-day
period, a civil penalty assessment may be prepared.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] l Fax: [phone] Customer Service: 1-877-623-6748
Internet: http://portal.ncdenr.org/webtwq
One
NorthCarohna
Nahmullff
An Equal Opportunity 1 Affirmative Action Employer — 30% Recycled/10% Post Consumer paper

Mr. D Wells, City of Kings Mountain
NOV-2012-LV-0547, Page 2
October 25, 2012
Remedial actions, if not already implemented, should be taken to correct any problems. 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. Marcia Allocco of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco at (704)
235-2204.
Sincerely,
Michael Parker
Acting Regional Supervisor
Surface Water Protection
cc: Point Source Branch

RXA
FiL
NCDETR
- — -- - fit? .+h G; [lra r+.,- - 1r'' f �r = r, --
:.: .:arolina . ,pa ,.- fi-:R rr r;r� z
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor . Director Secretary
August 28, 2012
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Compliance Evaluation Inspection
Pilot Creek WWTP
NPDES Permit No. NC0020737
Cleveland County
Dear Mr. Wells:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject
facility on August 23, 2012 by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible
(ORC) 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 Mr. Bell at [phone], or at [e-mail].
Sincerely,
for Robert Krebs
Surface Water Protection Regional Supervisor
Enclosure:
Inspection Report
cc: Cleveland County Health Department
W.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
Nne
orthCarolina
An Equal Opportunity 1 Affirmative Action Employer— 30% Recycled/10% Post Consumer paper

m7l
United States Environmental Protection Agency Form Approved.
EPA Washington, D.C. 20460 OMB No. 2040-0057
Approval expires 8-31-98
Water Cnrj.P1J.'qn(;P. -'.OP<Sttin..
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 INI 2 15 I 31 NCO020737 111 121 12/08/23 117 181 C I 19I S I 20III
Remarks
21II1111IIIIII IIIIIIII IIIIIIII IIII IIIIIIIIIIIIIII6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
67 I 1.5 169 70141 711 N I 721 NJ 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)
09:35 AM 12/08/23
10/08/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
04:00 PM 12/08/23
13/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kathy June Moses//704-739-7131 /
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis Wells,PO Box 429 Kings Mountain NC 280860429//704-734-4525/
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 Find in /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
Wesley N Bell f yr /7 , _,.(� MRO WQ//704-663-1699 Ext.2192/
Signature of Management Q A Reviewer 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

NPDES yr/mo/day Inspection Type
3I NCO020737 111 12, 12/08/23 117 18I d
ill
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

IF
Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 08/23/2012 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the per mittee submitted a new application? n n is n
Is the facility as described in the permit? ■ n ❑ n
# Are there any special conditions for the permit? ■ n n n
Is access to the plant site restricted to the general public? ■ n n n
Is the inspector granted access to all areas for inspection? ■ n n n
Comment: The subject permit expires on 8/31/2013. The permit adequately describes
the facility; however, the sludge drying beds have been taken out of service.
The last compliance evaluation inspection was performed on 1/19/2011.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
0
❑
Are analytical results consistent with data reported on DMRs?
■
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
n
Has the facility submitted its annual compliance report to users and DWQ?
n
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
Q
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
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?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
■
fl
❑
n
Page # 3

Permit: NCO020737
Inspection Date: 08/23/2012
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
11
Record Keeping Yes No NA tJE --- -- . - _ ..
Comment: The records reviewed during the inspection were organized and well
maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period May
2011 through April 2012. Chronic toxicity failures were reported in July 2011, January
2012, and April 2012. The Division has separately addressed these violations through
the issuances of NOVs.
The ORC and staff must ensure "B" ( Backup ORC) is documented on future DMRs for
the days when the Backup ORC serves as the ORC and the summer effluent limits are
correctly listed on the bottom of the applicable DMRs.
The facility continues to operate under the Division approved waiver of the 24/7 staffing
requirement (WWTPs equal to or greater than 5 MGD) with certified operators. The
facility is staffed with certified operators eight hours per weekday (at a minimum) and
four hours per day during weekends and holidays as noted on the DMRs.
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?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
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: Influent and effluent analyses (including field) are performed under the
City's Pilot Creek WWTP Laboratory (Certification #222). K&W Laboratories
(Certification #559) and ETT Environmental, Inc. (toxicity) have also been contracted to
provide analytical support.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
n
n
n
Is sample collected above side streams?
■
n
n
n
Is proper volume collected?
■
In
n
n
Is the tubing clean?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Is sampling performed according to the permit?
■
n
❑
❑
Comment: The subject permit requires BOD and TSS influent composite samples.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ■ n n n
Is sample collected below all treatment units? ®n n n
Page # 4

Permit: NCO020737
Inspection Date: 08/23/2012
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA
NE
Is proper volume collected?
o
n
n
n
Is the tubing clean?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
n
Comment: The subject permit requires both composite and grab effluent samples.
Upstream / Downstream Sampling
Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n
Comment:
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 fl Q
Judge, and other that are applicable?
Comment: The facility appeared to be properly operated and well maintained. The
operations staff incorporate a comprehensive process control program with all
measurements being properly documented and maintained on -site.
The facility is equipped with a telemetry type alarm system that notifies the operations
staff (via phone/text systems) of the following conditions: high influent water level, screw
pump failure, high/low influent pH, blower failure, and standby generator activiation.
The alarm system was tested and operational during the inspection.
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment: The influent pump station is equipped with two screw pumps (both
operational).
Rnr Rcraunc
Type of bar screen
a.Manual
Yes No NA NE
■ n n n
■nnn
■0010
■nnn
nn■n
nn■n
nn■n
Yes No NA NE
n
Page # 5

Permit: NCO020737
Inspection Date: 08/23/2012
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
L
- - .. _-Yes No NA - NE- _
Comment: The City had recently installed a mechanical bar screen. The facility staff
should provide a cover for the screenings dumpster to prevent the potential discharge of
stormwater that may accumulate inside the dumpster.
Screenings are disposed at the County Landfill.
IN
Chemical Feed
Yes
No
NA
NE
Is containment adequate?
■
n
n
n
Is storage adequate?
■
fl
n
Are backup pumps available?
■
n
❑
n
Is the site free of excessive leaking?
■
n
n
n
Comment: A new chemical storage building housing a 6,200 gallon bulk caustic
storage.tank (with feed pumps) has been constructed per ATC dated 3/7/2012.
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
n
n
n
Are surface aerators and mixers operational?
❑
❑
■
Are the diffusers operational?
■
n
n
n
Is the foam the proper color for the treatment process?
■
n
n
n
Does the foam cover less than 25% of the basin's surface?
■
n
n
n
Is the DO level acceptable?
■
n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
n
Comment: The facility uses a floating fine bubble aeration system for all three aeration
basins per ATC dated 1/17/2008. Caustic is added to the aeration basins to maintain
appropriate pH/alkalinity levels.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? ■ n n n
Page # 6

Permit: NCO020737 Owner -Facility: PilotCreekWWTP
ction Date: 08/23/2012 Inspection Type: Compliance Evaluation
Secondary Clarifier
Yes
No
NA
NE
Is the site free of excessive buildup of solids in center well of circular clarifier?
®
n
n
n
Are weirs level?
■
❑
❑
❑
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 sludge blanket levels in all three secondaries were measured at less
than 0.5 feet.
Pumps-RAS-WAS
Yes No
NA
NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?.
If yes, then what is the EPA twelve digit ID Number? (1000- -
If yes, then when was the RMP last updated?
Comment:
De -chlorination
Yes No NA NE
■ n n n
■nnn
■ n n n
■ n n n
■ n n n
■ n n n
■nnn
■nnn
1000 0005 8965
06/16/2009
Yes No NA NE
Page # 7

Permit: NCO020737
Inspection Date: 08/23/2012
De -chlorination -
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Gas
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: The flow meters located at each chlorine contact chamber (3-total) are
calibrated annually and were last calibrated on 4/19/2012 by Laboratory Instrumentation
Service.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: The facility is equipped with two aerated sludge holding tanks. Sodium
bicarbonate is added on an as -needed basis to maintain appropriate pH levels.
n n ■ n
nn■0
Yes No NA NE
Yes No NA NE
■nnn
■ n n n
nn■0
Yes No NA NE
■nnn
■nnn
■ n n n
■nnn
■nnn
Page 9 8

Permit: NC0020737
Inspection Date: 08/23/2012
Solids Handling' Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes
No
NA
NE '
®
n
n
n
®❑nn
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment: Dewatered solids are transported to the County Landfill for final disposal.
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Comment: The facility is equipped with two backup generators that are tested under
load on a weekly basis. A contract company (currently Carolina Power Solution)
services the generators twice per year. The generators can power the screw pumps,
one blower per aeration basin, RAS and WAS pumps, chlorination and dechlorination
systems, and the lab building.
■ n n n
■nnn
■nnn
■nnn
■nnn
Yes No NA NE
■nnn
■ n n n
■nnn
■nnn
■nnn
■ n n n
.nnn
Page # 9

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
June 29, 2012
CERTIFIED MAIL: 7007 1490 0004 5533 6332
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086-0429
SUBJECT: NOTICE OF VIOLATION: NOV-2012-TX-0048
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr. Wells:
Dee Freeman
Secretary
RECEIVED
DIVISION OF WATER QUALITY'
JUL 13 2012
SWP SECTION
iMOORESVILLE REGIONAL OFFICE
This is to inform you that a review of your toxicity self -monitoring report form for the month of April 2012 indicates a violation of
the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your
efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -specific study designed to identify the causative agents
of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and confirm reductions in
effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil penalties for violations of
NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic
Toxicity (AT) Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible
solutions to resolve effluent toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
S' c rely,
Cindy Moo e
Supervisor, Aquatic Toxicology Unit
cc: pb,Krebs: Moor_esv :ll egio 4 fft,
John Lesley- Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: http:i/h2o.enr.state.nc.us/esb/
No thCarolina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

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.
John Giorgino 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).
➢ 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.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
NorthCarofina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: hfp://h2o.enr.state.nc.us/esb/
aturall%/
,
✓ U
An Equal Opportunity 1 Affirmative Action Employer

.-47WA FIL-�4/
NC®ENR E
North Carolina Department of Environment and Natural ]resources
Division of water Quality
Beverly Eaves Perdue Charles Wakild, P. E Dee Freeman
Governor Director Secretary
May 2, 2012
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086
Subject: Response to NOV/NRE-2012-PC-0140
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Wells:
Mooresville Regional Office staff reviewed the City of Kings Mountain response to Notice of Violation
and Notice of Recommendation for Enforcement number NOV-2012-PC-0140. Based upon the review, and
consultation with Ms. Sarah Morrison, PERCS Unit, it appears that the City of Kings Mountain has taken
appropriate steps that would justify no further actions being taken against the City at this time. Be advised that
should noncompliance continue, enforcement action, including the assessment of civil penalties, could be taken
by the Division of Water Quality in accordance with G.S. 143-215.6A(a)(2).
Thank you for your continued cooperation with the Division of Water Quality. Should you have any
questions regarding the decision by this office in regards to this matter please contact Mr. John Lesley of this
office or me at 704-663-1699.
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
Cc: Bob Sledge, Point Source Compliance
Sarah Morrison, PERCS Unit
JL
Mooresville Regional Office
Location: 610 East Center Ave.. Suite 301 Mooresville. NC 28115
Phone: [phone] t: Fax: [phone] Customer Service: 1-877-623-6748
Internet: hftp://portal.nodenr:ofg/web/wg
North¢nu Caroli
�/��ILLUU14l/
An Equal Opportunity i Affirmative .Action Employer— 501; Recycled/]0% Post Consumer paper

RCDEN
North Carolina Department of'Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
March 28, 2012
CERTIFIED MAIL: 7007 0220 0001 4482 1633
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086-0429
SUBJECT: NOTICE OF VIOLATION: NOV-2012-TX-0019
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear Mr. Wells:
Resources
Dee Freeman
Secretary
PECEIVED
DIV'ISiON OF WATER QUALITY
APR - 2 2012
SVVP `:"C'IION
€e100P,E31VLLE F,IrGIONAL O FIcE
This is to inform you that a review of your toxicity self -monitoring report form for the month of January 201.2 indicates a violation of
the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your
efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -specific study designed to identify the causative agents
of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control options, and confirm reductions in
effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil penalties for violations of
NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity"'Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic
Toxicity (AT) Test Forms. We encourage you to review this information; if it would be helpful to discuss this situation or possible
solutions to resolve effluent toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
mcerJ e, y,
�
Cmdy oI yk I V11
ore
Supervisor, Aquatic Toxicology Unit
cc: tRctb-IY .-e 5`S2-FAIooresville Regional Office
John Lesley —Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section i
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:llh2o.enr.state.nc.us/esb/
Nne
ofthCarohna
Naturally
An Equal Opportunity 1 Affirmative Action Employer

WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlogked 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.
John Giorgino 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 multipleconcentration 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 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.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
North Carolina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: hftp:lih2o.enr.state.nc.us/esbl
'j
An Equal Opportunity 1 Affirmative Action Employer

PV
City of Kings Mountain
P.O. Box 429
Kings Mountain, N. C 28086
April 27, 2012
Mrs. Sarah Morrison
PERCS Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Response to NOV dated April 23, 2012
Tracking Number: NOV-2012-PC-0140
Dear Mrs. Morrison:
RECEI ED
DIVISION OF WAT-ER QUALITY
APR 3 0 CE'E?
IOQ�VVo�,!. ac�l ,SAL OFFICE
This letter is in response to the NOV resulting from the Pretreatment Audit Inspection
Report dated April 23, 2012. A meeting was held with Dennis Wells, Director, Kim
Moss ORC WWTP and Brian Ramsey, Pretreatment Coordinator to discuss these issues
of non-compliance and a plan of action was immediately put into place.
I (Brian) called Mrs. Morrison to apologize for the condition of the program and ask for
assistance to bring the program back to the standard that the City of Kings Mountain and
NCDENR expects. Mrs. Morrison expressed a willingness to assist me in reaching this
goal.
To address the 5 issues outlined in the NOV:
1. The PAR has been completed and received by the Mrs. Morrison and Mr. Lesley.
2. An electronic submission was forwarded to Mrs. Morrison on Thursday
April 26, 2012 containing the additional information requested to complete the
Headworks Analysis.
3. All SIU customers to this POTW have been contacted and TTO certifications
have been requested from those SIUs where certifications were not located.
Written notification will follow of specific due dates for each SIU customer to
have TTO certifications mailed to POTW.
4. A revision to the LTMP has been electronically sent to Mrs. Morrison containing
the additional information requested.
5. A modification has been made to the SIU permit regarding Arsenic, which should
help reduce the over allocation. That modification has NOT been sent to the State
for approval but will be forwarded by May 4 h, 2012.

PV
Please be assured that all resources are being utilized to ensure that the City of Kings
Mountain's Pretreatment Department is returned to the level of compliance that is
expected.
If you have any questions or need more information please call me at [phone].
Cc: Dennis Wells
John Lesley
Sincerely,
Brian Ramsey
Pretreatment Coordinator

k,
k*� FiLE/ .
N C- DENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E Dee Freeman
Governor Director Secretary
April 23, 2012
CERTIFIED MAIL # 7010 2780 0003 14619621
RETURN RECEIPT REQUESTED , .
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
PO Box 429
Kings Mountain, North Carolina 28086
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2012-PC-0140
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Wells:
Enclosed is a copy of the Pretreatment Audit Inspection Report for the inspection of the City of Kings
Mountain approved Industrial Pretreatment Program on April 16, 2011 by Mr. John Lesley and Ms.
Donna Hood of this office.
This Report is being issued as a Notice of Violation (NOV) because of violations of the subject permit
and North Carolina General Statute (G.S.) 143-215.1, G.S.143-215.3(a)(14), and 15A NCAC 2H .0900
for failure to properly implement the Pretreatment Program. Pursuant to 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 G.S. 143-215.1. The following is a list of violations noted during the Audit.
1. Failure to submit the Pretreatment Annual Report by the extended due date of March 14, 2012.
2. Failure to submit the Headworks Analysis (HWA) by the extended due date of January 31, 2011.
3. Failure to document TTO Certifications as required by the Industrial User Permits.
4. Failure to submit revisions to the Long Term Monitoring Plan by December 30, 2010.
5. Over Allocation of arsenic in the current allocation table.
If you wish to provide additional information regarding the noted violations, request technical assistance, or
discuss overall compliance please respond in writing within 10 days of receipt of this Notice. A review of
your response will be considered. You will then be notified of any civil penalties that may be assessed
regarding these violations. If no response is received in this Office within the 10-day period, a civil
penalty assessment may be prepared.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: http://portal.ncdenr.org/web/wq
One
NOTthCa.1'Olina.
Natmallil
An Equal Opportunity 1 Affirmative Action Employer— 30% Recycled/10% Post Consumer paper

Dennis Wells,'City of Kings Mountain
NOV-2012-PC-0140, Page 2
April 20, 2012
If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or Ms. Hood at (704)
663-1699.
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
JL

��� OF vvn �Fq
— — NORTH CAROLINA DIVISION OF WATER QUALITY 0 4�
NCDENR PRETREATMENT AUDIT REPORT ? _�
Background Information:
1. Control Authority (POTW) Name: City of Kings Mountain
2. Control Authority Representative(s): Brian Ramsey
3. Title(s): Pretreatment Program Coordinator
4. Address of POTW:
Street/Post Office Box PO Box 429
City/State/Zip Code Kings Mountain, NC 28086
Phone Number 704-739-7131 Fax Number 704-734-4528 E-Mail brianrna,cityofkm.com
5. Audit Date 04/16/2012
6. Last Inspection Date: 01/19/2011 Inspection Type: ® PCI ❑ Audit
7. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s) ? ❑ Yes ® No
If No, Explain. Headworks Analysis submittal was due by no later than 1/31/11. The last submittal was 12/31/10,
The Pretreatment Annual Report due by no later than 311113 was extended to 3/14/12 was not submitted until
4/16/12 (received in PERCS Unit 4/17/12). The Long Term Monitoring Plan (LTMP) was due 8/1/10. An extension
of the LTMP due date was granted to 11/15/10, more information was requested and the due dated extended to
12/30/10. The LTMP was modified (added arsenic); however, the PERCS Unit has no record of the final submittal
of the LTMP.
8. In the last year has the POTW experienced any NPDES or Sludge Permit compliance problems? ® Yes ❑ No
If Yes, Explain. Toxicity test failure, 7/2011
9. Is POTW under an Order That Includes Pretreatment Conditions? ❑ Yes ® No
Order Type and Number: Are Milestone Dates Being Met? ❑ Yes ❑ No ® NA
Parameters Covered Under Order
PCS (WENDB)Coding:
Trans.Code Main Program Permit Number MM/DD/YY
LLLI INIC10 IO I2 IO I7 I3 I7 I 04I16I12I
(DTIA)
10..Current Number of.Significant Industrial Users(SIUS)?.....................................................................
11. Current Number of Categorical Industrial Users CIUS
...................................................:......................................... .
12. Number of SIUs Not Inspected by. POTW in Last Calendar Year?
......................................................................................................................................
13. Number of SIUs Not Sampled by POTW in Last Calendar Year?
.........................................................................................................................................
14. Enter Higher Number of 12 or 13
......................................................................................................................................................................................................................................................................
15. Number of SIUs with No IUP, or with an Expired.IUP
............................................................................
16. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of Last 2
Semi -Annual Periods (Total Number of SIUs in SNC
................................................._.............................................................................................................................................................................................
17. Number of SIUs in SNC for Reporting During Either of Last 2 Semi -Annual Periods
.........................................................................................
18. Number of SIUs in SNC for Limits Violations During Either of Last 2 Semi -Annual Periods
19. Number of SIUs in SNC for Both Reporting and Limits Violations During Either of Last 2
Semi -Annual Periods
............................................................................................................................................................................................................................................................................
20. Number of SIUs in SNC for Self -Monitoring Reauirements that were Not Inspected or Samr
Inspec.Type
Inspector
Fac. Type
II
LSJ
LIA
(TYPI)
(INSP)
(FACC)
6
SIUS
6
CIUS
0
..........................
0
..........................
0
NOIN
0
NOCM
0
PSNC
0 MSNC:
0 SNPS
0
[I'MIN l
NC TIWO PratrPntmPnt Amiit Fnrm RPviePA• Tnly 'M% ?nm paoP 1

21 PRFTRF..ATMFNT PRfDC_R AM FT.F.MF.NTC RF.ViFW
Program Element
Last Submittal
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/31/10
® Yes ❑ No
2/22/08
® Yes ❑ No
*1131111
Past due
Industrial Waste Survey (IWS)
9/2/10
® Yes ❑ No
11/22/10
® Yes ❑ No
12/1/14
Sewer Use Ordinance (SUO)
6/21/07
® Yes ❑ No
11/6/07
® Yes ❑ No
12/31/12
Enforcement Response Plan (ERP)
8/24/94
® Yes ❑ No
8/25/94
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
*12/31/10
® Yes ❑ No
9/20/05
® Yes ❑ No
*12/30/10
Past due
*See Comments on # 7 above.
Legal Authority (Sewer Use Ordinance-SUO)
22. Do you have any towns and/or areas from which you receive wastewater which are not in your annexed jurisdiction?
❑ Yes ® No If yes, Please list these towns and/or areas.
23. If yes to 922, Do you have current Interjurisdictional Agreements (IJAs) or other Contracts? ❑ Yes ❑ No ® NA
A copy, if not already submitted, should be sent to Division.
24. If yes to #22, Have you had any trouble working with these towns or districts? ❑ Yes ❑ No ® NA
If yes, Explain.
25. Date of Last SUO Adoption by Local Council 03/27/01
26. Have you had any problems interpreting or enforcing any part of the SUO? ❑ Yes ® No
If yes, Explain.
Enforcement (Enforcement Response Plan-ERP)
27. Did you send a copy of the ERP to your industries? ® Yes ❑ No
If no, POTW must send copy within 30 days.
28. Have you had any problems interpreting or enforcing any part of the ERP (i.e. any adjudication, improper enforcement, etc?
❑ Yes ® No If yes, Explain.
29. List Industries under a Schedule or Order and Type of Schedule or Order
None
Resources
30. Please Rate the Following: S=Satisfactory M=Marginal U=Unsatisfactory
Rating
Explanation, if Unsatisfactory
Personnel Available for Maintaining
One full time staff
POTW's Pretreatment Program
®S ❑M ❑U
Access to POTW Vehicles for
Sampling, Inspections, and
®S ❑M ❑U
Emergencies
Access to Operable Sampling
Equipment
®S ❑M ❑U
Availability of Funds if Needed for
Additional Sampling and/or Analysis
®S ❑M ❑U
Reference Materials
®S ❑M ❑U
Staff Training (i.e. Annual and
Has not attended annual or regional workshops in at least 3
Regional Workshops, Etc.)
❑S ®M ❑U
years.
Computer Equipment (Hardware and
Software)
®S ❑M ❑U
NC T)WO PrPtrPntmant Awlit Pnr 12PvigP& hilu 75 ?nn7 PnaP 7

Does the POTW have an adequate data management system to run the pretreatment program? ® Yes ❑ No
Explain Yes or No. Excel Spreadsheet
32. How does the POTW recover the cost of the Pretreatment Program from their industries? Explain.
Bill each SIU Pretreatment fees based on the Pretreatment Program budget divided by the number of SIUs.
Public Perception/ Participation:
33. Are there any local issues affecting the pretreatment program (e.g.. odor, plant closing, new or proposed plants)?
® Yes ❑ No If yes, Explain. Chemtal Foote Mineral may be added as an SIU.
34. Has any one from the public ever requested to review pretreatment program files? ❑ Yes ® No
If yes, Explain procedure. If no, How would the request be addressed? No written procedure in place, but would require
appointment for file review.
35. Has any industry ever requested that certain information remain confidential from the public? ® Yes ❑ No If yes, Explain
procedure for determining whether information qualified for confidential status, as well as procedure for keeping files confidential
from public.' If no. how would the request be addressed?. Locked file in secure location.
36. In addition to annual inspection, does the POTW periodically meet with industries to discuss pretreatment? ® Yes ❑ No
37. Is the public notified about changes in the SUO or Local Limits? ® Yes ❑ No
38. Were all industries in SNC published in the last notice? ❑ Yes ❑ No ® NA
Permitting (Industrial Waste Survey-IWS):
39a... How does the POTW become aware of new or changed Users? Director's office notifies Pretreatment Coordinator
39b. Once the POTW-becomes aware of new or changed Users, how does the POTW determine which industries have the
reasonable potential to adversely impact the WWTP and therefore require a new permit or a permit revision? (Who is an
SIU?) Historical data from industry, regulatory requirements, categorical determination.
40. Does the POTW receive waste from any groundwater remediation projects (petroleum, CERCLA) or landfill leachate?
❑Yes ®No If Yes, How many are there?
Please list each site and how it is permitted, if applicable.
41. Does the POTW accept waste by (mark if applicable) ❑ Truck ❑Dedicated Pipe ® NA
42. If the POTW accepts trucked waste, what controls are placed on this waste? (example. designated point, samples drawn,
manifests required)
43. How does the POTW allocate its loading to industries? Mark all that apply
® Uniform Limits ® Historical Industry Need ❑ By Surcharge ® Categorical Limits ❑ Other
Explain Other:
44. Review POTW's copies of current allocation tables for each WWTP. Are there any over allocations? ® Yes ❑ No
If yes, What parameters are over allocated? Arsenic is over -allocated, the HWA has not been approved because
requested information has not been submitted.
45. If yes to #43, What is being done to address the over allocations? (short-term IUDs, HWA to be revised, pollutant study, etc.)
HWA due date was extended to 1/31/11, has not been submitted for approval as of this audit.
46. Does the POTW keep pollutant loading in reserve for future growth / safety? ® Yes ❑ No
If yes, what percentage of each parameter 25%
47. Has the POTW experienced any difficulty in allocation? (for example: adjudication by an industry) ® Yes ❑ No
If yes, Explain. Previous allocation has over -allocation of TSS and arsenic, revised allocation table based on unapproved
HWA is over -allocated for aresenic.
W T)Wn PratrPntmPnt Am it Fnrm PpAl pd- hilv 75 ?nm pnar 4

48. How does the POTW decide on which pollutants to limit in the permits? Monitor for? (for example: were only those pollutants
listed on the application limited; categorical parameters; NPDES Pollutants of Concern)
Flow constituents, categorical parameters, NPDES pollutants of concern.
49. How does the POTW decide what the monitoring frequency should be for the various pollutants in industry permits ? Explain.
All SIUs are given monthly monitoring frequencies.
Permit Compliance:
50. Does the POTW currently have or during the past year had any permits under adjudication? ❑ Yes ® No
If yes, which industries? What was (will be) the outcome of the adjudication?
51. Demonstrate how the POTW judges compliance. This should include compliance judgment on all violations of limits, reporting
requirements, and permit conditions, as well as for SNC. Limits; calculates CJPs; Reporting, due by 20th of next month, past
the due date receives a NOV, consecutive late reports is SNC; permit condition violations, NOV maybe SNC depending on
impact to WWTP.
52. Does the POTW use the Division's model inspection form or equivalent? ® Yes ❑ No
If no, does the POTW form include all DWQ data? ❑ Yes ❑ No
53. Were all SIUs evaluated for the need of a slug/spill control plan during their most recent inspections? ® Yes ❑ No
If no, Explain.
54. What criteria are used to determine if a slug/spill control plan is needed?
All SIUs must have a plan.
55. What criteria does the POTW use to determine if a submitted slug/spill control plan is adequate?
MSDS documentation, contact information, and schematics of facility showing discharge points and storage areas.
56. How does the POTW decide where the sample point for an SILT should be located?
Process wastewater segregated from all other discharges.
57. Has the POTW established a procedure to ensure that representative samples will be taken by the POTW or SIU each time?
(example: correct location; proper programming of sampler; clean equipment; swirling the sample bucket uniformly)
POTW: ® Yes ❑ No SIU: ❑ Yes ® No If yes, Explain.
58. Who performs sample analysis for the POTW for Metals K & W Labs
Conventional Parameters K & W Labs
Organics K & W Labs
59. Explain the Chain of Custody Procedure used for both in house and commercial lab samples.
Chain of custody forms must accompany all sample reports.
Long/Short Term Monitoring Plan (L/STMP) and Headworks Analysis (HWA):
60a.
60b.
60c.
60d.
60e.
60f.
Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ❑ YES ® NO
Is LTMP/STMP Data Maintained in Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
All LTMP/STMP effluent data on Discharge Monitoring Report.(DMR)? ® YES ❑ NO DWQ Inspector, verify yourself!
If NO to any above, list violations
Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ® YES ❑ NO
If yes, which ones? Eliminated: Added: Selenium due to implementation of WO Standard.
61. Do you complete your own headworks analysis (HWA) ? ® Yes ❑ No
If no, Who completes your HWA? Phone �) --
62. Do you have plans to revise your HWA in the near future? ® Yes ❑ No
If yes, What is the reason for the revision? (mark all that apply) ❑Increased average flow
❑More LTMP data available ®Resolve over allocation 05 year expiration
Explain. The HWA was not submitted as required by 1/31/11.
❑NPDES limits change
❑Other
C
NC DWO Pratraatmant Anrlit Fnr Ravicad- Tnly ?5 ?M7 Dana A

F
In general, what is the most limiting criteria of your HWA? ❑Inhibition ® Pass Through ❑Sludge Quality
64. Do you see any way to increase your loading in the future (Example: obtaining more land for sludge disposal)? ❑ Yes ® No
Explain.
Summary:
65. Do you plan any significant changes to the pretreatment program or changes to the WWTP that may affect pretreatment?
No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW:
66.
User Name
1. Kings Mountain International
2. Evonik Industries
3. Carolina Finishing and Coating
67.
IUP Number
31
32
33
68.
Does File Contain Current Permit?
® Yes ❑ Nol
®
Yes ❑ No7F
® Yes ❑ No
69.
Permit Expiration Date
7/31/15
3/1/13
12/31/13
70.
Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
413.71
433
433
71.
Does File Contain Permit Application Completed Within One Year Prior
® Yes ❑ No
® Yes ❑ No
® Yes ❑ No
to Permit Issue Date?
72.
Does File Contain Inspection Completed Within Last Calendar Year?
I ®Yes ❑ Rol
® Yes ❑ No
1 0 Yes ❑ No
73.
a. Does File Contain Slug/Spill Control Plan?
a. ®Yes ❑No
a. NYes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. pYes ❑No
b. []Yes ❑No
b. ❑Yes ❑No
74.
For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
❑Yes®No❑N/A
❑YesgNo❑ 71
Organic Management Plan (TOMP)?
75.
a. Does File Contain Original Permit Review Letter from Division?
a. ❑Yes NNo
a. ❑Yes NNo
a. ❑Yes NNo
b. All Issues Resolved?
I b.❑Yes®No❑N/A
b.❑Yes®No❑N/A
b.❑Yes®No❑N/A
76.
During Most Recent Semi -Annual Period, Did POTW Complete its
FgVe-S ❑ No
®Yes ❑ No
® Yes ❑ No
Samplifig as Required by IUP, including Flow?
77.
Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes ❑ No
® Yes ❑ -N-7ol
® Yes ❑ No
78.
During Most Recent Semi -Annual Period, Did SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by IUP, including Flow?
79.
During Most Recent Semi -Annual Period, Did SIU submit all reports on
N
®Yes❑No❑/A
®Yes❑No❑N/A
®Yes❑No❑N/A
time?
1
80a.
For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoO
❑Yes❑No ON/A
file includeprocess/dilution flows as Required by IUP?
I[_5Ws0NoZN/A
80b.
For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoON/A
❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
il
81.
During Most Recent Semi -Annual Period, Did POTW Identify All
❑No❑N/A
r
®Yes❑No❑N/A
®Yes❑No❑N/A
Limits Non -Compliance from Both POTW and SIU Sampling?
82.
During Most Recent Semi -Annual Period, Did POTW Identify All
❑Yes❑No®N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
Rg ortin Non-Com liance from SIU Sampling?
83.
a. Was POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW within 30 Days?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
c. If applicable, did POTW resample and obtain results within 30 days of
becomingaware of SIU limit violations in the POTW's sam lin of SIU?
c.❑Yes❑No®N/A
c.❑Yes❑No®N/A
c.❑Yes®No❑NIA
84.
During Most Recent Semi -Annual Period, Was SIU in SNC?
❑
Yes ® No
❑ Yes ®
No
I
❑ Yes ® No
85.
During Most Recent Semi -Annual Period, Was Enforcement Taken as
❑Yes❑NoNN/A
®Yes❑No❑N/A
❑Yes❑No®N/A
Specified in POTW's ERP (NOVs, Penalties, timing, etc.)?
86.
Does File Contain Penalty Assessment Notices?
E1Yes[1No0N_/_A_1j
®Yes❑No❑N/A
❑Yes❑No®N/A
87.
Does File Contain Proof Of Penalty Collection?
❑Yes❑NoON/A
®Yes❑No❑N/A
❑Yes❑No®N/A
88.
a. Does File Contain Any Current Enforcement Orders?
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
a.❑Yes❑No®N/A
b. Is SIU in Compliance with Order?
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
b.❑Yes❑No®N/A
89.
Did POTW Representative Have Difficulty in Obtaining Any Requested
® Yes ❑ No
® Yes El No
® Yes ❑ No
Information For You?
NIC T)WO PrPtrPntmP nt AnAit Pn P-AePA- T111V 75 )nm 13.RP S

FILE REVIEW COMMENTS:
74. The file did not contain any SIU Certification Statements for TTO. A TOMP was available for Kings Mountain International. Evonik had
a comprehensive spill and slug plan that included some information regarding storage of TTO materials, but there was no TOMP. There
was no TOMP for Carolina Finishing and Coating. Be advised that all CFR 413 and 433 CIU must either submit a signed
certification statement and provide a TOMP or perform the TTO analyses as required by the WP. Evonik and Carolina
Finishing and Coating TOMPs and certification statements were not available during the Audit. Kings Mountain International
had a current TOMP but no certification statements were on file for either six month period in 2011.
75. Draft modifications for Evonik Industries, Carolina Finishing and Coating, and Kings Mountain International were submitted for approval
on 11/15/10 (Buckeye Adonizing, Mayflower Vehicle, and Eaton were also submitted). Modifications were based on the HWA
submission and approval (the submittal required by 1/31/11 has not been received). The draft IUDs were reviewed; however, the permits
were not approved because copies of si ned permits were not sent.
81, 83, 84. The issued permits have arsenic limits of 0.001 mg/1. Violations of the limit have been reported but the POTW did not "intend"
for the limit to be included, only monitoring. It is required that the permits with the arsenic limits that were to be for monitoring only be
revised to remove the limit and replaced with a "Monitor Only" requirement. These permits have not been approved by PERCS (see
above). Kings Mountain International would be in SNC for arsenic if the limit were to be enforced.
INDUSTRY INSPECTION PCS CODING:
Trans.Code Main Program Permit Number
MM/DD/YY
Inspection type
Inspector
Facility Type
FN N I C 10 0 12 10 17 3 7
04 116 12
UO
2❑
(DTIA)
(TYPI)
(INSP)
(FACC)
1. Industry Inspected: Kings Mountain International
2. Industry Address: 1755 S. Battleground Hwy. Kings Mountain, NC 28086
3. Type of Industry/Product: Chrome molds for building materials
(siding, floor covering) and mirrored
panels.
4. Industry Contact: Mr. Mark Jarvis Title: Plant Manager
Phone: [phone] Fax:
5. Does the POTW Use the Division Model Inspection Form or Equivalent? ® Yes
❑ No
6. Did the POTW Contact Conduct the Following Parts of the Industrial Inspection Thoroughly?
Comments:
A. Initial Interview
® Yes
❑ No
B. Plant Tour
® Yes
❑ No Viewed all wet processes
C. Pretreatment Tour
® Yes
❑ No Physical Chemical WWTP
D. Sampling Review
® Yes
❑ No
E. Exit Interview
® Yes
❑ No
Industrial Inspection Comments:
3-5,000 gallon tanks store wastewater from the platting area and wash down processes. One of the tanks has more
concentrated waste so it feeds less than the other two. The wastewater is settled by chemical additon and solids are removed by
a clarifier and a plate press. Sludge is removed as hazardous waste. Ferric chloride is recycled and used in water treatment
facilities.
W nwn PrPtraatmrnt Amiit Fnr Rrvicarl• Tidy 7S 7nn7 Paoa 6

F_
SUMMARY AND COMMENTS:
Audit Comments: The POTW records were difficult to find and some documents were not available. Submission of program
elements are routinely late and incomplete. The IUPs have not been approved because of failure to submit signed cover pages and the
requested information for headworks apporval (see the attahced e-mail from Sarah Morrison, PERCS Unit, dated 11/22/10).
Requirements: Pretreatment Program Elements must be submitted in a timely manner with all pertinent information included. Failure
to do so is a violation of the POTW's NPDES Permit and 15A NCAC 2H .0900 regulations. Failure to submit program elements in
a timely manner may result in the issuance of civil penalties.
Recommendations: Reorganize files to have all material related to each SIU in a separate book/file (permit, application,
correspondence, monitoring data, chain of custody form, NOVs etc). Enter LTMP data into the spreadsheet in a timely manner (2011
data had not been entered into the spreadsheet). Develop a tracking system to ensure that all Program Element submittals are carried
out in a timely manner, including requests for more information.
NOD: ❑ Yes
NOV: ® Yes
QNCR: ® Yes
POTW Rating:
® No
❑ No
❑ No
Satisfactory ❑
Audit COMPLETED
Audit COMPLETED
Marginal ❑ Unsatisfactory
John Lesley, Mooresville Regional Office
Donna Hood, Mooresville Regional Office
DATE: April 17, 2012
DATE: April 17, 2012
W T)W() PratrPatmant Anrlit Pnrm RPvicPrl• fnly 75 7007 PaaP 7

Lesley, John
From: Morrison, Sarah
Sent: Monday, November 22, 2010 3:29 PM
To: Brian Ramsey
Cc: Lesley, John
Subject: Kings Mountain HWA, LTMP and IWS submission
Attachments: kingsmtn.iws.004.pdf
Brian,
In regard to the HWA submission, please review the following guidance on our website: "What Items to Submit with
your POTW's HWAT' The following information was not included with the submission. Please provide this information
to PERCS (an email submission is fine —spreadsheets for all data, removal rates, mass balance, scanned documents of
any design criteria stamped engineers calculations, etc.) by December 30, 2010 or notify if additional time is needed.
• Organized Data Summaries-
LTMP, SIU, Uncontrollable, and DMR
Data from all sampling sites in your approved L/STMP
• Removal Rate Calculations
• Mass Balance Spreadsheet
• Documentation of Design Influent values
• Explanation of Choices, Assumptions, etc.
http://Portal.ncdenr.org/web/wq/swp/ps/­pret/headworks
Also, I wanted to confirm that the draft IUP modifications were sent out and are pending approval of the HWA as signed
cover pages were not submitted. The Division will be unable to complete our review of the IUPs until the HWA is
approved.
Regarding the LTMP,
• Detection Levels: The Arsenic detection level was listed as .0005 mg/L. The DWQ State Lab approved detection
level is .01 mg/L. I wanted to confirm that this value was not a typo, as the Division will judge compliance based
on the approved Sampling Plan.
• Pollutants: Silver is an SIU limited parameter, and must be included in the LTMP at the Influent, Effluent, Basins,
Uncontrollable locations and at least once/permit cycle at the SIUs (preferably 1/year). We apologize for this
previous oversight.
• Aeration Basins: The following are required to be sampled in the aeration basins: NH3 and % solids. TSS is
currently sampled in the aeration basin and is not required.
• Sludge: The LTMP states that sludge to disposal samples will be grab. Which parameters are sampled in the
POTW's sludge to disposal? It is strongly recommended that the POTW sample their sludge to disposal
periodically for the 40 CFR 503 metals. This will allow the POTW to document compliance with the 503
ceiling standards should the POTW ever lose their landfill disposal option, or otherwise wish to land
apply or compost their sludge in the future.

0 WWTP Hydraulic Detention Time: It was noted that the LTMP indicates the detention times will be considered,
and it is assumed that the POTW takes influent and effluent samples staggered by this time period. PERCS has
serious concerns with the ability to collect paired data accurately. Please review the Removal Rate
Determination Guidance on the HWA page of our web -site for details. The Division does not .require or
recommend detention time paired data be collected, and the POTW may modify the LTMP at any time to
remove this condition.
0 SIU sampling: It is strongly recommended that each SIU be sampled (by POTW or SIU) for all LTMP POCs at least
once per year or once per HWA cycle at the LTMP specified detection levels. This data would be very helpful in
your uncontrollable mass balance determination.
Please comment on the above, or make any required changes as noted by December 30, 2010. Please notify if
additional time is needed.
Attached is the PERCS response to the submission of additional information regarding the Industrial Waste Survey,
received by the Division on November 15, 2010.
Thanks,
Sarah Morrison
Environmental Engineer
N.C. Dept. of Environment and Natural Resources
Pretreatment, Emergency Response & Collection Systems Unit (PERCS)
1617 Mail Seiirice Center, Raleigh, NC 27699-1617
[phone]; fax [phone]
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Before printing this email, please consider your budget and the environment.
If you must print, please print only what you need and save ink with the free Eco-Font.
2

' RECEIVED
DIVISIONOF WATER QUALITY
NCDER MAR j 1. ?7_
North Carolina Department of Environment and Natural Re ources ,
Division of Water Quality s��'�u'gte '°'. i _�n R'== °Oq' AL OFFICE
Beverly Eaves Perdue Charles Wakild, P.E. Dee Freeman
Governor Director Secretary
March 7, 2012
Mr. Dennis Wells
City of Kings Mountain
101 W. Gold Street
Kings Mountain, North Carolina 28086
SUBJECT: Authorization to Construct
A to C No. 020737A02
City of Kings Mountain
Pilot Creek WWTP
Dear Mr. Wells:
A letter of request for an Authorization to Construct was received January 23, 2012, by
the Division of Water Quality (Division), and final plans and specifications for the subject
project have been reviewed and found to be satisfactory. Authorization is hereby granted for the
construction of modifications to the existing 6.0 MGD Wastewater Treatment Plant, with
discharge of treated wastewater into Buffalo Creek in the Broad River Basin.
This authorization results in no increase in design or permitted capacity and is awarded
for the construction of the following specific modifications:
Construction of a new chemical storage building; installation of a 6,200 gallon
bulk caustic storage tank, five (5) IBC tanks, and five (5) electronic metering
pumps, in conformity with the project plans, specifications, and other supporting
data subsequently filed and approved by the Department of Environment and
Natural Resources.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of
NPDES Permit No. NCO020737 issued July 6, 2010, and shall be subject to revocation unless the
wastewater treatment facilities are constructed in accordance with the conditions and limitations
specified in Permit No. NC0020737.
The sludge generated from these treatment facilities must be disposed of in accordance
with G.S. 143-215.1 and in a manner approved by the Division.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.rimaterauality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Natmallb

Mr. Dennis Wells
March 7, 2012
Page 2
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as may
be required by the Division, such as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Mooresville Regional Office, telephone number [phone], shall be notified at
least forty-eight (48) hours in advance of operation of the installed facilities so that an on site
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted facility
has been installed in accordance with the NPDES Permit, this Authorization to Construct and the
approved plans and specifications. Mail the Certification to: Infrastructure Finance Section,
DWQ/DENR, 1633 Mail Service Center, Raleigh, NC 27699-1633.
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to or greater than the classification assigned to the wastewater treatment
facilities by the Certification Commission.
The Permittee must also employ a certified back-up operator of the appropriate type and
grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each
Class I facility at least weekly and each Class II, III and IV facility at least daily, excluding
weekends and holidays, must properly manage the facility, must document daily operation and
maintenance of the facility, and must comply with all other conditions of T15A:8G.0202.
A copy of the approved plans and specifications shall be maintained on file by the
Permittee for the life of the facility.
During the construction of the proposed additions/modifications, the permittee shall
continue to properly maintain and operate the existing wastewater treatment facilities at all times,
and in such a manner, as necessary to comply with the effluent limits specified in the NPDES
Permit.
You are reminded that it is mandatory for the project to be constructed in accordance
with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North
Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's
responsibilities shall be in complying with these Acts.

Mr. Dennis Wells
March 7, 2012
Page 3
Prior to entering into any contract(s) for construction, the recipient must have obtained all
applicable permits from the State.
Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division in accordance with North
Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does -not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Seth Robertson, P.E. at telephone
number [phone].
Sincerely,
Charles Wakild, P.E.
MM: sr
cc: Joel E. Wood, P.E. - Joel E. Wood & Associates, Clover, SC
Cleveland County Health Department
Technical Assistance and Certification
Point Source Branch, NPDES Program
Michelle McKay, E.I.
ATC File

C
City of Kings Mountain
A To C No. 020737A02
Issued March 7, 2012
Engineer's Certification
I, , as a duly registered Professional Engineer in
the State of North Carolina, having been authorized to observe (periodically/weekly/full time)
the construction of the modifications and improvements to the Pilot Creek WWTP, located off
U.S. Highway 74 Bypass in Cleveland County for the City of Kings Mountain, hereby state that,
to the best of my abilities, due care and diligence was used in the observation of the following
construction:
Construction of a new chemical storage building; installation of a 6,200 gallon
bulk caustic storage tank, five (5) IBC tanks, and five (5) electronic metering
pumps, in conformity with the project plans, specifications, and other supporting
data subsequently filed and approved by the Department of Environment and
Natural Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Signature
Date
Registration No.
Mail this Certification to: Attn: Michelle McKay, E.I.
Infrastructure Finance Section
DENR/DWQ
1633 Mail Service Center
Raleigh, NC 27699-1633

FILL:
IACDENR
North Carolina De artment of Environment and Natural Resources
P
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
CC'
W
October 6, 2011
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
P. O. Box 429
Kings Mountain, North Carolina 28086
Subject: Rescission of Notice of Violation
Tracking #: NOV-2011-LV-0454
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Wells:
Dee Freeman
Secretary
On October 3, 2011, this Office received an amended June 2011 Discharging Monitoring
Report (DMR) from the Pilot Creek WWTP Operator in Responsible Charge in response to the above
referenced Notice of Violation (NOV). The NOV was issued for exceedance of the pH daily maximum
permit limit at Outfall 001 on June 2, 2011.
The cover letter to the amended DMR noted that the pH value for June 2, 2011, had been entered
incorrectly on the originally submitted DMR. Based on the amended DMR this Office is rescinding the
above referenced Notice of Violation. If you have any further questions concerning this matter,
please do not hesitate to contact Marcia Allocco at [phone].
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
Point Source Branch
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One 1
Phone: [phone] \ Fax:, [phone] \ Customer Service: 1-877-623-6748 NOf"t�l�,c`1T0�1lla
Internet: hftp://portal,ncdenr.org/web/wq UftAg alZ y
n_..,..�,... -I nrr.,,,.,�l,,.. nF;— Cmnlnver_ loq-. Rcrvrler11101V� Post consumer pacer a66 bbSS�66 j1

IFI
f
HCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
CERTIFIED MAIL: 7002 31.50 0003 7052 4214
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director
City of Icings Mountain
P.O. Box 429
Kings Mountain, NC 28086-0429
QN
Division of Water Quality
Coleen H. Sullins
Director
September 23, 2011.
SUBJECT: NOTICE OF VIOLATION: NOV-2011-TX-0042
Whole Effluent Toxicity (WET) Testing
NPDES Permit No. NCO020737
Pilot Creek WWTP
Cleveland County
Dear W. Wells:
Dee Freeman
Secretary
RECEIVED
DIVISION OF WATER QUALITY
SEP v 0 20111
''��, ? SECTION
MOORCS'v:LLE REGIONAL OFFICE
This is to inform you that a review of your toxicity self -monitoring report form for the month of July 2011 indicates a violation of the
toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent toxicity violation(s). Your
efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -specific study designed to identify the causative agents
of effluent toxicity, isolate the sources of toxicity, evaluate the effectiveness of toxicity control .options, and confirm reductions in
effluent toxicity. Please be aware that North Carolina General Statutes provide for assessment of civil penalties for violations of
NPDES permit limitations and requirements.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity Monitoring and Reporting
Requirements. Please note appropriate mailing addresses for submitting your Discharge Monitoring Reports (DMRs) and Aquatic
Toxicity (AT) Test Forms. We encourage you to review this information; if it would be helpful to discuss- this situation or possible
solutions to resolve effluent toxicity noncompliance, please contact Mr. John Giorgino with this office at (919) 743- 8441.
' , cerely,
Cindy Moore
Supervisor, Aquatic Toxicology Unit
cc: uRFob-*Crebs oosysvil'Ie=Regional ®ff ce
John Lesley- Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: hftp:llh2o.enr.state.nc.us/esb/
One
NorthCarolrlia
N%turallrY
An Equal Opportunity 1 Affirmative Action Employer

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.
John Giorgino 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 NI'DES 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 nothave a discharge from January 1-.Tune 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.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
One
Location: 4401 Reedy Creek Road. Raleigh. North Carolina 27607
North C
Phone: [phone] FAX: [phone] CUStofner Service: 1-877-623-6748
Internet: hftp://h2o.enrstate. nc.uslesbl
pars. pohna
6%
An Equal Opportunity% Affirmative Action Employer

Beverly Eaves Perdue
Governor
cc:
'A
F i L E-
HCDE R X
North Carolina Department of Environment and Natural Resources
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
P. O. Box 429
Kings Mountain, North Carolina 28086
Dear Mr. Wells:
Division of Water Quality
Coleen H. Sullins
Director
September 23, 2011
Subject: Notice of Violation — Effluent Limitations
Tracking #: NOV-2011-LV-0454
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dee Freeman
Secretary
A review of the June 2011 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001:
Date Parameter Reported Value Permit Limit
6611 pH 10.7 SU 9.0 SU (Daily maximum)
Remedial actions, if not already implemented, should be taken to correct any problems. 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. Marcia Allocco of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at
[phone].
Sincerely,
-Robert B. Krebs
Surface Water Protection
Regional Supervisor
Point Source Branch
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http://portal.ncdenr,org/weblwq
One
N&thCarolina
Nat maul
An Equal Opportunity', Affirmative Action Employer — 30% Recycled/10% Post Consumer paper

Kk'Ar- FILE
HC®ENR
North Carolina Department of .Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 25, 2011
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, NC 28086
Subject: PAR Review
City of Kings Mountain
NPDES Permit No. NC0020737
Cleveland County, NC
Dear Mr. Wells:
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR) for the
reporting period of January through December 2010. Based on the review, the POTW completed the PAR in
accordance with 15A NCAC 2H .0908(b) requirements and guidelines set forth in Comprehensive Guidance for
North Carolina Pretreatment Programs. The next PAR will be due March 1, 2012.
If you have any questions concerning your PAR, please do not hesitate to contact me at [phone]
or by email [e-mail].
Sincerely,
JoJ1n Lesley
Mooresville Regional Office Contact
Cc: Sarah Morrison, PERCS Unit
Mooresville Regional Office One
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 NorthCarolina
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748 AV11, 71411
Internet: hfp:/Iportal.ncdenr.orQ/web/wq
An Equal Opportunity \ Affirmative Action Employer— 50% Recycled/10% Post Consumer paper

p"
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
PO Box 429 .
Kings Mountain, North Carolina 28086
Dear Mr. Wells:
Division of Water Quality
Coleen H. Sullins
Director
March 18, 2011
Subject: Notice of Violation — Effluent Limitations
Tracking 9: NOV-2011-LV-0104
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dee Freeman
Secretary
A review of the December 2010 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
12/21/10
pH
5.47 SU
6.0 SU (Daily minimum)
12/22/10
pH
5.79 SU
6.0 SU (Daily minimum)
12/23/10
pH
5.95 SU
6.0 SU (Daily minimum)
Remedial actions, if not already implemented, should be taken to correct any problems. 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. Marcia Allocco of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at
[phone].
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
MA
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 NorthCarolina
Internet: http://portal.ncdenr.orgiweblwq /IV�gl/e�qf�/
An Equal Opportunity \ AYrmative Action Employer— 30% Recycled!10% Post Consumer paper �/ b6 d l Gd < J

{
FILE
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
January 21, 2011
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Pretreatment Compliance
Inspection
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Wells:
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of
Kings Mountain approved Industrial Pretreatment Program on January 19, 2011 by Mr. John Lesley of this
Office.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley at [phone].
Sincerely,
�'✓
.� {n/
� ..'. O'bert B. Krebs
Regional Supervisor
Surface Water Protection Section
Enclosure
cc: Central Files
Sarah Morrison, PERCS Unit
Mooresville Re-ional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer service: 1-877-623-6748
Internet: http://porlal.ncdenr.org/web/wg
. — _ _ _:._ % . «_.__.:.._ A -I:-- r.....i...,e.. _ cno/ P.,. 1 ,I/I r)01 Pncl Cnnsmnr_r naner
One
NorthCarolina

'A r 4 .R j .
t ?.
�:�iORTH CAROLINA DIVISION OF WATER QUALITY
RCDENR PRETREATMENT COMPLIANCE INSPECTION (PCI) REPORT
BACKGROUND INFORMATION (Complete Prior To PCI• Review Program Info Database Sheet(s)I
1. Control Authority (POTW) Name: City of Kings Mountain
2. Control Authority Representative(s): Brian Ramsey
3. Title(s): Pretreatment Program Coordinator
�OF vd AT ,9
�r
4. Last Inspection Date: 2/9/2010 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
PCS CODING
Trans.Code Main Program Permit Number MIVUDD/YY Inspec.Type Inspector Fac. Type
N NCO020737 01/19/11 P
(DTIA) (TYPI)
S
(INSP)
1
(FACC)
7. Current Number Of Significant Industrial Users (SIUs)?
6
6
SIUS
CIUS
8. Current Number Of Categorical Industrial Users (CIUs)?
Year?
0
9. Number of SIUS Not Inspected By POTW in the Last Calendar
0
10. Number of SIUS Not Sampled By POTW in the Last Calendar Year?
0
NOIN
11. Enter the Higher Number of 9 or 10
0
NOCM
12. Number of SIUs With No IUP, or With an Expired IUP
0
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
PSNC
Semi -Annual Periods (Total Number of SIUs in SNC)
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
0
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
SNPS
0
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC foi
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC foi
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES ❑ NO
pH - December 2010.
® YES ❑ NO
pH - pass through, has been linked
to Buckeye Anodizing.
Limits: Buckeye Anodizing (see 18)
Reporting: None
blished: None
Evonik
❑ YES ® NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ®YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? ® YES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? ® YES ❑ NO Is Table Adequate? ® YES ❑ NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? [I YES ®NO
If yes, which ones? Eliminated: Added:
NC DWO Pretreatment Compliance Inspection (PCI) Form Updated 7/25/07 Page 1

F28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element in
1:1.,.. ,.,.,1 + . 41, o, ..nr ;nn rinrnmantc nnri rr)nj r fPFRC'Q, Annrnval Vetter- and dates consistent with Program Info:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
12/31/10
©
Yes ❑
No
2/22/08
Yes
❑
No
1/31/11
Industrial Waste Survey (IWS)
9/2/10
®
Yes ❑
No
11/22/10
®Yes
❑
No
12/1/14
Sewer Use Ordinance (SUO)
6/21/07
®
Yes ❑
No
11/06/07
Z
Yes
❑
No
Enforcement Response Plan (ER P)
8/24/94
®
Yes ❑
No
8i25/94
®
Yes ❑ No
Long Term Monitoring Plan (LTiVIP)
12/3.1/10
®
Yes ❑
No
9/20/05
Yes ❑ No
1/31/11
T'\jnyr4IIAt UII PRRI%/iiT'(TTIP)FTI.F. RFVTFW f , TTIP FILE REVIEWS OR l FILE REVIEW AND 1 IU INSPECTION)
29. User Name ir-1.
Buckeye Anodizing IF
2. Mayflower
3. Eaton Corporation
30. IUP Number
0015
0026
008
31. Does File Contain Current Permit?
® Yes ❑ NoI
® Yes ❑ K701
® Yes ❑ No
32. Permit Expiration Date
11/17/11
l 1/17/1111
I1/17/11
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
®Yes ❑ No
® Yes ❑ No
®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
36. a. Does the File Contain a Slug/Spill Control Plan?
I ® Yes ❑ No
a. ®Yes ❑No
11
® Yes ❑ No
a. ®Yes EIN107
® Yes ❑ No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes ❑No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
EYes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes ❑No
a. ®Yes ❑No
Yes ❑No
FboY-q
b. All Issues Resolved?
b.®Yes❑No❑N/A
b.®Yes❑No❑N/A
❑No❑N/.A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
® Yes ❑ No
_®yes ❑ No
® Yes ❑ No
its Sampling as Required by IUP, including flow?
Chain Forms?
® Yes ❑ No
® Yes ❑ No 11
® Yes ❑ No
40. Does File Contain POTW Sampling -Of -Custody
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
EYes❑No❑N/A
EYes❑No❑N/A
❑Yes❑No®N/A
Sampling as Required by IUP, including flow?
41b. During the Most Recent Semi -Annual Period; Did SIU submit all reports
EYes❑No❑N/A
EYes❑No❑N/A
❑Yes❑NoEN/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
file include rocess/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoEN/A
❑Yes❑NoEN/A
❑Yes❑NoEN/A
production rates and/or flows as Required b IUP?
43a. During the Most Recent Semi -Annual Period, Did the POT`J✓ Identi y
®Yes❑No❑NA
E1YesE1No❑N/A
❑YesE1No®N/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi-Atuural Period, Did the POTW Identify
EYes❑No❑N/A
EYes❑No❑N/A
❑Yes❑No®N/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
a.❑Yes❑No®N/A
Monitoruig Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days?
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
c.❑Yes❑NoEN/A
violations from the POTW sample event?
45. During the Most Recent Semi-Aruival Period, Was the SIU in SNC?
® Yes ❑ No
11 ❑ Yes ® No
❑ Yes ® No
46. During the Most Recent Semi-Aruival Period, Was Enforcement Taken
EYes❑No❑N/A
EYes❑No❑N/A
s❑No®N/A
r
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
EYes❑No❑N/A
❑Yes❑NoEN/A
❑Yes❑No®N/A
❑Yes❑No®NIA
❑Yes❑NoEN/A
❑Yes❑No®N/A
48. Does The File Contain Proof Of Penalty Collection?
49. a. Does the File Contain Any Current Enforcement Orders?
b. Is SIU in Compliance with Order?
.❑Yes❑NoEN/A
[b�.FoY,sDNoSN/A
a.❑Yes❑NoEN/A
b.❑Yes❑NoEN/A
a.❑Yes❑NoEN/A
b.❑Yes❑No®N/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
❑ Yes ® No
❑ Yes ® No
Requested Information For You?
mnT% r.____. I T—Ai In 1 7M'5/A7 Pn"P')

FILE REVIEW COMMENTS:
1. (Questions 19, 46, 48) The POTW discovered a low pH wastewater being discharged from Buckeye Anodizing on 12/20/10.
The low pH slug to the WWTP resulted in NPDES Permit limit violations of the daily minimum pH. The POTW also found total
phosphorous, nickel, and zinc limit violations at the Buckeye facility for which a Notice of Violation was issued on 10/22/10.
Buckeye Anodizing is being assessed a civil penalty ($5,000.00 plus costs) by the POTW for the pH slug.
2. Permit Applications: Buckeye, 11/16/06; Mayflower, 3/30/06; Eaton Corp. 4/3/06.
3. Inspections: Buckeye, I1/2/10; Mayflower, 11/3/10; Eaton Corp. 11/4/10.
4. Question 37: All SIUs are required to submit updated Spill and Slug Control Plans and TOMP in 2011 (Eaton Corp. has
already submitted an up to date SSCP and TOMP).
5. Questions 39 and 41b: Eaton Corp. has a non -discharge recycle facility and did not generate a wastewater discharge in 2010.
6. Question 46 (See Comment 1 relative to Buckeye). Mayflower was issued a Notice of Violation for a zinc limit violation on
4/16/10.
7. Questions 47, 48: Buckeye civil penalty assessment is ongoing at this time. The POTW Utility Dept. notifies the Pretreatment
Coordinator by copying him on the billing statement and receipt of payment.
SUMMARY AND COMMENTS:
Comments:
The POTW has shown significant progress in the management and organization of the Pretreatment Program. All issues relative to the
2009 Pretreatment Compliance Inspection (NOV-2010-PC-0141) have been addressed.
The Sewer Use Ordinance has not been adopted, but is under review by City Attorney.
Evonik Energy Services was placed under a SOC for limits violations and SNC status in 2009 in addition to being assessed a civil penalty
of $2,667.42. The SIU has been compliant with the order.
Requirements:
Include a copy of the Evonik Energy Services SOC in the 2010 PAR due on March 1, 2011.
See the Pretreatment Program Elements for due dates of HWA, LTMP, and IWS submittals.
Recommendations:
NOD: ❑ YES ® NO
NOV: [:]YES ® NO
QNCR: ❑ YES ®NO
POTW RatinjZ:
Satisfactory ® Marginal ❑ Unsatisfactory- ❑
PCI COMPLETED BY:
John Lesley, Mooresville Regional Office
DATE: January 21, 2011
NT!' Tl\l/n D—f-oar,, f r',,.,,n1ignr.e Twmection MCII Form Updated 7/25/07 Page 3

E1,)A1
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
January 21, 2011
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Compliance Evaluation Inspection
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Wells:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on January 19, 2011 by Mr. John Lesley 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 Mr. Lesley at [phone].
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Central Files
JL
Cleveland County Health Department
Mooresville Regional Office One
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 NortbCaroliina
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: http://pogal.ncdenr.org/web/wq
An P—ni nnnnrtnnifv \ AFF,—ti— Amino A.„nlnvPr_ ir)o/ P--l"I1 no/ P—t rnncumPr nanvr

u
United States Environmental Protection Agency
Form Approved.
EP/� A 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 1 N1 2 1 51 31 N00020737 Ill 121 11/01/19 117 181 1
I I CI 191 si 20L1
Remarks
21111111111111111111111111111111111111111111111_1j6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CIA ------------------------ —Reserved ----------------------
671 3.0 169 70131 71 I N I 721 N I 73 LU 74 751 1 1 1 1 I I 180
1—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)
11:30 AM 11/01/19
10/08/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
02:00 PM 11/01/19
13/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis Wells,PO Box 429 Kings Mountain NC 280860429//704-734-4525/
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 Fj 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
John E Lesley MRO WQ//704-663-1699 Ext.2198/
%-zr-j�
S' nature of Management Q A evj er Agency/Office/Phone and Fax Numbers Da e
T
Marcia Allocco MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NCO020737 I11 12I 11/01/19 I17 181
CI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Monthly self -monitoring reports were reviewed for the period January 2010 through October 2010. No
violations were reported during the period.
Page # 2

Permit: NCO020737
Inspection Date: 01119/2011
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Operations u Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ®❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge 0 ❑ ❑ ❑
Judge, and other that are applicable?
Comment:
--_ 1 Vic K1— NA NC
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
®
❑
Is the facility as described in the permit?
®
❑
❑
❑
# 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?
®❑
❑
❑
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
®❑
❑
❑
Is all required information readily available, complete and current?
®❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
®❑
❑
❑
Are analytical results consistent with data reported on DMRs?
®❑
❑
❑
Is the chain -of -custody complete?
®❑
❑
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?
a®
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
11110
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑
❑
®
❑
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?
❑
❑
❑
Page # 3

Permit: NCO020737 Owner - Facility: Pilot Creek WVVTP
Inspection Date: 01/19/2011 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No NA NE
Facility has copy of previous year's Annual Report on file for review?
®
n n n
Comment: The facility continues to operate under a waiver of the 24/7 operation rule
according to the NPDES Permit cover letter date July 6, 2010.
Flow Measurement - Effluent
Yes
No NA NE
# Is flow meter used for reporting?
®
n n n
Is flow meter calibrated annually?
®
n n n
■
n n n
Is the flow meter operational?
(if units are separated) Does the chart recorder match the flow meter?
■
n n n
Comment:. The flow meter was calibrated on March 3, 2010 by Laboratory Instrument
Service.
Pump Station - Influent
Yes
No NA NE
Is the pump wet well free of bypass lines or structures?
®
n n n
Is the wet well free of excessive grease?
®
n n n
Are all pumps present?
®
❑ ❑ Cl
Are all pumps operable?
®
n n n
®
n n n
Are float controls operable?
Is SCADA telemetry available and operational?
w
n n n
Is audible and visual alarm available and operational?
n
n n
Comment: In -line pH monitoring of the influent is to be installed at the influent screw
pumps. The in -line monitoring will be tracked on the SCADA system.
Bar Screens
Yes
No NA NE
T ype of bar screen
a.Manual
b.Mechanical
n
Are the bars adequately screening debris?
n n n
Is the screen free of excessive debris?
®
❑ ❑ n
Is disposal of screening in compliance?
®❑
❑
Is the unit in good condition?
®
n n n
Comment: The manual bar screen is very labor intensive and could be a safety
concern (the operator has to lean over the open channel and the screen to rake the
screen). In the event of severe weather or a sudden dislodging of debris in the
collection system after the staff has left the facility, the screen could become blocked for
several hours.
Page # 4

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 01/19/2011 Inspection Type: Compliance Evaluation
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext.
Air
Type of aeration system
Diffused
Is the basin free of dead spots?
n
n
n
Are surface aerators and mixers operational?
n
n
n
Are the diffusers operational?
®n
n
n
Is the foam the proper color for the treatment process?
®
n
n
❑
Does the foam cover less than 25% of the basin's surface?
®
n
n
n
Is the DO level acceptable?
®n
n
n
Is the DO level acceptable?(1.0 to 3.0 mg/1)
®
n
n
n
Comment: The area around the perimeter of the basins does not appear to be mixed
and solids are accumulating.
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
Are weirs level?
®
n
n
n
Is the site free of weir blockage?
®
n
❑
n
Is the site free of evidence of short-circuiting?
■
n
❑
n
Is scum removal adequate?
®
n
❑
n
Is the site free of excessive floating sludge?
®
❑
n
n
Is the drive unit operational?
®
n
n
n
Is the return rate acceptable (low turbulence)?
®IJ
n
n
Is the overflow clear of excessive solids/pin floc?
®
n
❑
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
®
n
n
n
Comment: Clarifier #3 is down for repair. Because the clarifier feeds a separate
chlorine contact chamber one of the three available chlorine contact chambers is also
out of service.
Disinfection -Gas
Yes
No
NA
NE
Are cylinders secured adequately?
®
Cl
n
n
Are cylinders protected from direct sunlight?
®
n
n
n
Is there adequate reserve supply of disinfectant?
n
n
n
Is the level of chlorine residual acceptable?
®
n
n
n
Page # 5

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 01/19/2011 Inspection Type: Compliance Evaluation
Disinfection -Gas
Yes
No
NA
NE
Is the contact chamber free of growth, or sludge buildup?
®
n
n
Cl
Is there chlorine residual prior to de -chlorination?
■
n
n
n
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
■
n
n
n
If yes, then is there a Risk Management Plan on site?
■
n
n
n
If yes, then what is the EPA twelve digit ID Number? (1000- - )
1000-0005-8965
If yes, then when was the RMP last updated?
06/19/2009
Comment: The Risk Management Plan was available for inspection and up to date.
Yes
No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
■
0
n
n
Is storage appropriate for cylinders?
®n
n
❑
# Is de -chlorination substance stored away from chlorine containers?
■
n
n
n
Comment:
Are the tablets the proper size and type?
n
n
®
n
Are tablet de -chlorinators operational?
n
n
Number of tubes in use?
Comment:
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
®
n
In
n
Is the generator tested by interrupting primary power source?
■
n
n
n
Is the generator tested under load?
®
n
n
n
Was generator tested & operational during the inspection?
n
n
n
Do the generator(s) have adequate capacity to operate the entire wastewater site?
®
n
n
n
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
®
n
n
n
Is the generator fuel level monitored?
®
n
n
n
Comment: The generator can operate the screw pump station, one blower on each
aeration basin, WAS and RAS pumps, chlorine and sulfur dioxide systems, and the
Lab/Operator's office.
Royster Fuel Company supplies fuel for the generators.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
®
n
❑
n
Page # 6

Permit: NCO020737
Inspection Date: 01/19/2011
Pumps-RAS-WAS
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Owner - Facility: Pilot Creek VVWTP
Inspection Type: Compliance Evaluation
Laboratory
Are field parameters performed by certified personnel or laboratory?
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 less than or equal to 6.0 degrees Celsius)?
®nnn
®nnn
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: The on -site lab (Certification #222) is certified through 12/31/11. K&W
Labs (starting in 12/2010) and ETT Environmental Solutions provide contract laboratory
services.
Influent Sampling res No NA N
# Is composite sampling flow proportional? ■ n ❑ ❑
Is sample collected above side streams? ■ n n n
Is proper volume collected? ■ n n n
Is the tubing clean?
®
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
®
n
n
n
Is sampling performed according to the permit?
®
❑
n
n
Comment:.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
n
Is sample collected below all treatment units?
®
n
n
n
Is proper volume collected?
®
n
n
n
Is the tubing clean?
®
n
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
®n
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? IN n n n
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? 0 n n n
Page ## 7

Permit: NCO020737
Inspection Date: 01/19/2011
Upstream / Downstream Sampling
Comment:
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment:
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment: The facility has set up a 5,500 gallon tank (only about 30 inches of liquid
NaOH in tank) to determine the feasiblity of using a bulk feed system.. An Authorization
to Construct has been recently submitted for the chemical addition of NaOH to the
aeration basins. No containment for the NaOH feed system is currently installed. No
evidence of spills or leaks were observed.
Yes No NA NE
nnn
®nnn
®nnn
®nnn
®nnn
Yes No NA NE
®nnn
®nnn
®nnn
®nnn
®nnn
IMnnn
®nnn
Page # 8

RECI=IVED
DIVISION O- Iftb-. t E3 e QUALITY
FEB 2 8 2012
hPOORESVILLE REGIONAL OFFICE
SYS�rEJW PPRFORMAWCP
-AX-W -Al RPPORr.'r"
�® R
CITY OF .7C1'NGS MOU.N'.�.�LIN
Pl.LOfrCREEX 1NPCF
JULY 01, 2010 - JUNE 30, 2011
D
[SEP 01 2011 1

The Pilot Creek wastewater treatment facility
is owned and operated by the City of Xings
.Mountain. The facility was established in 1963.
The responsible parties including contact
phone numbers are as follows:
g-O-WNNAyOR.
'Air. Rick Murphrey 704.734.4604
CITY JW-AX-AgjNER
Mrs. Marilyn SeClers 704.734.4606
CITY COUWClr
Mr. Mike ButCer 704.734.0333
Mr. Huston Corn 704.734.0333
Mr. Rodney Gordon 704.734.0333
Mr. Xeith .Miller 704.734.0333
Mr. Tommy Hawkins 704.734.0333
Mr. Dean Spears 704.734.0333
Mr. Howard Shipp 704.734.0333

WA'TER RRSOURSP DIRECTOR
Mr. Dennis 'Wells
704.734.4525
SU PPR.TNTPND ENT/ORC
Ms. Xim T. Moss
704.739.7131
PRPTRPATW PNTCOORDIWATE R
.AIr. Brian Ramsey 704.739.7131
FACIICITY OPERATORS
Mrs. Brenda Xay Barker (Back-up Operator)
.Mrs. Brenda Xay Barker (laboratory `tech.)
Ms. Xathy June Moses (Chief Operator)
Ar. Joshua Slycord (Operator IT)
Mr. Rickey lee Bailey (Operator 1)
Mr. Brian X. Ramsey (PT/'1NWTPO 1)
704.739.7131
704.739.7131
704.739.7131
704.739.7131
704.739.7131
704.739.7131

The State of North Carolina regulates the treated
wastewater which is discharged into the Buffalo Creek.
The (jNPDES) Permit Number for this facility is
NC0020737 This facility is Cocated off of highway 74,
west of Xings Mountain.
PROCESS DESCR£PTION
When wastewater is dischargedfrom a home,
industry, etc., flow travels through miles of underground
Cines by gravity or by pumps. This process is called a
Collection System, which is describedmore in detail in the
Collections AnnuaCReport.
Once the wastewater enters this facility it contains
organic and inorganic materiaCwhich consist of thirty
percent (3o°0) IndustriaClWastewater.
The wastewater is C�fted approximately thirty two
(32) foot by two (2) SpiraCScrew Pumps. Wastewater then
travels through a ManuaCBar Screen, where debris is
collectedanddremovedfor disposaC it then travels
through a ParshadFlume with a twenty four (24) inch
throat which includes a staff gauge, and a flow meter all
for measuring the incoming flow. A 24 hour circular
chart yHmeter is also installed at the Influent. As the
wastewater travels through the throat of the Parshad
Flume a flow proportionaCrefrigerateddtwenty four (24)
hour composite sample is coClectedfor analysis.

The wastewater then enters a SpCitter Box
(Diversion Box) that splits theflow into three (3)
Aeration Basins based on their design flow. Caustic Soda
is added at the diversion box to adjust the incoming yH
and aCkaCinity to the aeration basins. Once the fresh
wastewater enters the aeration basin the organic
material is consumed by the microorganism. The
aeration basins are equ ppedwith floating diffusers
which supplies oxygen andmixing for the microorganism
to survive. The detention time in these basins are
approximately four (4) to seven (7) days. This process is
called activatedsludge.
The activatedsludge then enters the center weCCof a
circuCar clarifier, which is where the microorganism
settCe at the bottom to digest the organic material that
they consumed in the aeration basin. The detention time
in these clarifiers are approximately two (2) to four (4)
hours. As the activatedsludge settles in the cCarifier's, a
portion of it is either returned to the head of the aeration
basin (Pals) or wasted (WAS) to the aerobic holding tank
for disposaCby pumps.
As the treatedwastewater Leaves the clarifier's, it
then enters a Chlorine Contact Basin where Chlorine Gas
is injected to kill the disease causing bacteria before
leaving the facility. These contact chambers are
equippeddwith baffles (walls) to provide enough contact
time. The flow exit's these chambers over a rectangular
weir or a V Notch weir, which has a staff gauge and a
flow meter that sends a signaCto a totalizer.

As
the three (3) effluent flows combine into a
manhole, Sur Dioxide Gas is injected to remove the
residuaCchlorine. llhe flaw continues to traveCto the
plants effluent flow proportionaCCtwenty four (24) hour
refrigerated composite sampler where a sample is
coClectedfor laboratory analysis.
91his facility is also equippedwith a waste pump
station that has two (2) grinder pumps that conveys the
floatabCe soCids from the clarifiers back to the head of the
Influent.
Also included is a wash water pump station that
pumps treatedwastewater to the BeCt Filterpress which
is used to operate our 2.2 meter xCamp Press. This
XCamp Press is used to dewater the waste activated
sludge. This press produces a dry sludge cake of
approximately 15 to 18°0. A dry polymer is used in the
polymer system that mixes with the waste sludge to form
a floc so the water can drain through the pores in the
belts.
The disposaCprocess also includes two (2) aerobic
holding tanks which are gravity feed to the disposal
sludge pump station. These pumps convey the waste
sludge to the belt fiCterpress for operation.
Once the dry cake leaves the beCtpress, it travels up
a conveyor belt, through a hopper, into a tandem truck
and is hauled to the CCeveCand County .LandfiCCfor finaC
disposal

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-VIOL.AllOWS/DEFICIE rCIES
,FOR
_TUIy01,2010-JUNE30,2011
During this period there was a Daily violation
issuedforyHresuCts during December 2010. Notice of
'VioCations has been issued to industries exceeding Limits.
W09-I ICA'1OW
9'his AnnuaCR.eport is availabCe upon request. If
there are any questions concerning this report, please feeC
free to contact the Superintendent/ORC.

CERVj71C AVOW S�rA9-EJtE-WT
I certify that this report is accurate to the best of my
knowledge.
SUPS NTEJ V D2 /ORC

AGILA-
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 5, 2010
Mr. Dennis Wells
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Sample Analysis Results
City of Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Wells:
Enclosed is a copy of the sample analysis results relative to the inspection conducted at
the subject facility on February 9 and 12, 2010 by John Lesley and Marcia Allocco of this office.
An effluent composite sample was collected on February 8-9, 2010 and grab samples were taken
on February 9, 2010 by facility and Division of Water Quality staff to determine compliance
with permit conditions. A review of the analytical results found the following:
1. Evidence of toxicity was found in the sample. BOD results were characterized by a
significant increase in the BOD value as the sample concentration decreased. The
reported value was calculated from the highest dilution (5%) representing the maximum
loading potential. The BOD test result is considered an estimated value.
2. Matrix interference was found in the cyanide sample. The reported value is the Practical
Quantitation Limit (PQL) for the analysis.
3. The composite sample contained excess reducing agents. According to facility staff
caustic was being fed into the effluent discharge for pH adjustment during the February
8-9, 2010 composite period. Be advised that caustic should not be added directly to the
discharge.
4. The toxicity test result of the split effluent samples sent to the Division's Aquatic
Toxicology Unit were invalid because the second sample was not delivered by -the State
Courier due to inclement weather. The test conducted by ETT Environmental, the City's
contract lab, was invalid because of quality control problems.
Mailing Address Phone [phone] Location NorthCarolina
610 East Center Avenue, Suite 301 Fax [phone] East Center Avenue, Suite 301 ,Naturally
Mooresville, NC 28115 Mooresville, North Carolina
Internet: www.ncwaterquality.or2 Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Mr. Lesley or me at [phone].
Sincerely,
-Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Point Source Branch
Cleveland County Health Department

ANALYTICAL RESULTS SHEET
Name of Facility: Kings Mountain Pilot Creek WWTP
Grab: ❑ Composite:
Sample Date(s): February 9, 2010
NPDES Permit No.: NCO020737
Sample Location: Outfall 001 — WWTP Effluent
County: Cleveland
Biological Oxygen Demand, 5-day (BOD5)
18.0 mg/L (G4) i *
Chromium (Cr)
< 10.0 µg/L
Total Suspended Solids (TSS)
23 mg/L
Iron (Fe)
8.2 mg/L
Ammonia -nitrogen (NH37N)
0.03 mg/L
Lead (Pb)
< 10.0 µg/L
Total Kjeldahl Nitrogen (TKN)
1.8 mg/L
Lithium (Li)
<25.0 µg/L
Nitrate/Nitrite-nitrogen (NO2 and NO3)
11.0 mg/L
Magnesium (Mg)
4.0 mg/L
Total Phosphorus (P)
2.1 mg/L
Manganese (Mn)
59 µg/L
Aluminum (AI)
< 5.0 µg/L
Mercury (Hg)
< 0.2 µg/L
Antimony (Sb)
< 10.0 µg/L
Nickel (Ni)
36 µg/L
Arsenic (As)
18 µg/L
Potassium (K)
8.7 mg/L
Barium (Ba)
12 µg/L
Selenium (Se)
< 5.0 µg/L
Beryllium (Be)
< 5.0 µg/L
Silver (Ag)
< 5.0 µg/L
Calcium (Ca)
20 mg/L
Sodium (Na)
76 mg/L
Cadmium (Cd)
< 1.0 µg/L
Tin (Sn)
< 10.0 µg/L
Cobalt (Co)
< 50.0 µg/L
Vanadium (V)
32 µg/L
Copper (Cu)
9.7 µg/L
Zinc (Zn)
81 µg/L
t - Data was qualified. Sample contained excess reducing agents and BOD was calculated at the highest dilution (5%).
x - See DWQ Analytical Laboratory Sample Anomaly Report and Data Remark Codes for more information

ANALYTICAL RESULTS SHEET (font' d.)
Name of Facility: Kings Mountain Pilot Creek WWTP
Grab: ® Composite:
Sample Date(s): February 9, 2010
NPDES Permit No.:
NCO020737
Sample Location: Outfall 001 — WWTP Effluent
County: Cleveland
Fecal coliform (CFU/100 mL)
2 (Q1)*
Cyanide
(PQL 0.02 mg/L)
0.1 mg/L (U, P, J3)*
denotes a violation of the permit limit
11

AA
G A sin le quality control failure occurred during biochemical oxygen demand (BOD) analysis. The
sample results should be used with caution.
G1. The dissolved oxygen (DO) depletion of the dilution water blank exceeded 0.2 mg/L.
G2. , The bacterial seed controls did not meet the requirement of a DO depletion of at least 2.0
mg/L and/or a DO residual of at least 1.0 mg/L.
G3. No sample dilution met the requirement of a DO depletion of at least 2.0 mg/L and/or a
DO residual of at least 1.0 mg/L.
G4. Evidence of toxicity was present. This is generally characterized by a significant increase
in the BOD value as the sample concentration decreases. The reported value is calculated
from the highest dilution representing the maximum loading potential and should be
considered an estimated value.
G5. The glucose/glutamic acid standard exceeded the range of 198± 30.5 mg/L.
G6. The calculated seed correction exceeded the range of 0.6 to 1.0 mg/L.
G7. Less than 1 mg/L, DO remained for all dilutions set. The reported value is an estimated
greater than value and is calculated for the dilution using the least *amount of sample.
G8. Oxygen usage is less than 2 mg/L for all dilutions set. The reported value is an estimated
less than value and is calculated for the dilution using the most amount of sample.
G9. The DO depletion of the dilution water blank produced a negative value.
J Estimated value; value may not be accurate. This code is to be used in the following instances:
J1. Surrogate recovery limits have been exceeded;
J2. The reported value failed to meet the established quality control criteria for either
precision or accuracy;
J3. The sample matrix interfered with the ability to make any accurate detennination;
J4. The data is questionable because of improper laboratory or field protocols (e.g. composite
sample was collected instead of grab, plastic instead of glass container)
J5. Temperature limits exceeded (samples frozen or >6° C) during transport or not verifiable
(e.g., no temperature blank provided);, non -reportable for NPDES compliance monitoring.
J6. The laboratory analysis was from an unpreserved or improperly chemically preserved
sample. The data may not be accurate.
P. This qualifier is used to identify analyte concentration exceeding the upper calibration
range of the analytical instrument/method. The reported value should be considered
estimated.
J8. Temperature limits exceeds (samples frozen or >6°C during storage. The data may not be
accurate.
A The reported value is determined by a one -point estimation rather than against a
regression equation. - The estimated concentration is less than the laboratory practical
quantitation limit and greater than the laboratory method detection limit.
J10.. Unidentified peak; estimated value.
Jl 1. The -reported value is determined by a one -point estimation rather than against a
regression equation. The estimated concentration is less than the laboratory practical
quantitation limit and greater than the laboratory method detection limit. This code is
used when an AdDL has not been established for the analyte in question.
J12. The calibration verification did not meet the calibration acceptance criterion for field
parameters.
Note: A "J" value shall not be used if another code applies (ex. N, V, M).

:Remark
1.2
M
Sample and duplicate results are "out of control." The sample is non -homogenous (e.g. VOA
soil). The reported value is the lower value of duplicate analyses of a sample.
N
Presumptive evidence of presence of material; estimated value. This code is to be used if.
Nl. The component has been tentatively identified based on mass spectral library search;
N2. There is an indication that the analyte is present, but quality control requirements for
confirmation were not met (i.e., presence of analyte was not confirmed by alternate
procedures).
N3. This code shall be used if the level is too low to permit accurate quantification, but the
estimated concentration is less than 't ' he laboratory practical quantitation limit and greater
than the laboratory method detection limit. This code is*not routinely usedforMost
analyses.
N4. This code shall be used if the level is too low to permit accurate quantification, but the
estimated concentration is less than the laboratory practical quantitation limit and greater
than the instrument noise level. This code is used when an MDL has not been
established for the analyte in question.
N5. The component has been tentatively identified based on a retention time standard.
P
Elevated practical quantitation limit (PQL)* due to matrix interference and/or sample dilution.
Q
Holding time exceeded. These codes shall be used if the value is derived from a sample that was
received, prepared and/or analyzed after the approved holding time -restrictions for sample
preparation and analysis. The value does not meet NPDES requirements.
Q1. Holding time exceeded prior to receipt by lab
Q2. Holding time exceeded following receipt by lab
S
Not enough sample provided to prepare and/or analyze a method -required matrix spike (MS)
and/or duplicate (MSD).
U
-
Indicates tharthe analyte was analyzed for but not detected above the reported practical
quantitation limit (PQL)*. The number value reported with the "U" qualifier is equal to the
laboratory's PQL*.
V
Indicates the analyte was detected in both the sample and the associated method blank.
Note: The value in the blank shall not be subtracted from the associated samples.
X
Sample not analyzed for this constituent. This code is to be used if.
X1. Sample not screened for this compound.
X2. Sampled, but analysis lost or not performed -field error
X3. Sampled, but analysis lost or not performed -lab error
Y
Elevated PQL* due to insufficient sample size
Z
The presence or absence of the analyte cannot be verified. The sample analysis/results are not
reported due to:
Z1. Inability to analyze the sample.
Z2. Questions concerning data reliability.
*PQL The Practical Quantitation Limit (PQL) is defined as the lowest level achievable among laboratories within specified limits
during routine laboratory operation. The Practical Quantitation Limit (PQL) is "about three to five times the method detection limit
(MDL) and represents a practical and routinely achievable detection level with a relatively good certainty that any reported value is
reliable." (APHA, AWWA, WEF. 1992. Standard Methods for the Examination of Water and Wastewater, 18 h ed.)
11

Report to: _MRO/SWP
Lab Number: AB54667
ition Location: Kings Mtn.
WWTP
Sample Type:
Date collected: 2/9/10
Affected Parameter(s):
Effluent
I 181
NC DENR/DWQ Laboratory
Sample Anomaly Report (SAR)
Sample ID:
County: Cleveland
Priority: Compl. COC
Date received: 2/10/10
Analytical Area (check one):
❑ W CH []METALS
❑NUT ®MICRO
The following anomalies occurred (check all that apply):
[]Samples
❑Improper container used
❑VOA vials with headspace
❑Sulfide samples with headspace
❑Samples not received, but listed on fieldsheet
❑Samples received, but not listed on fieldsheet
❑Mislabeled as to tests, preservatives, etc.
❑Holding time expired
❑Prior to receipt in lab
❑After receipt in lab
❑Insufficient quantity for analysis
❑Sample exhibits gross non -homogeneity
❑Sample not chemically preserved properly
❑pH out of range (record pH):
❑Improper chemical
❑Residual chlorine present in sample
❑Color interference
❑Heavy emulsion formed during extraction
❑Sample bottle broken in lab - no reportable results
❑Other (specify):Evidence of Toxicity present.
NCO020737
Region: .
Collector:
Date analyzed:
Broad River Basin
M. Allocco
2/10/10
❑VOA ❑SVOA
❑PEST
❑Quality Control
❑Instrument failure — no reportable results
❑Analyst error — no reportable results
❑Surrogates .
❑None added
[]Recovery outside acceptance limits
❑Spike recovery
❑None added
[:]Recovery'outside acceptance limits
❑Failed to meet criteria for precision
❑Internal standards
❑Blank contamination
❑QC data reported outside of controls (e.g., QCS, LCS)
❑Incorrect procedure used
❑SOP intentionally modified with QA and Branch Head
approval
❑Invalid instrument calibration
❑Elevated detection limits due to:
❑Insufficient sample volume
Comments: Toxicity is generally characterized by a significant increase in the BOD value as the sample concentration decreases. The
reported value is calculated from the highest dilution representing the maximum loading potential and should be considered an
estimated value. % Sample.................BOD mg/L
50 ...........................6.78
25 ...........................9.64
10 ..........................12.6
10 (d up) ..................12.1
5......................... 18.0.... reported with a qualifier "G4"
The sample also contains excessive REDUCING AGENTS as indicated by the Oxidation Reduction test
Corrective Action:
❑Samples were rejected by DWQ Lab. Authorized by: Date:
❑Accepted and analyzed after notifying the collector or contact person and determining that another sample could not be secured.
❑Sample(s) on hold until:
®Sample reported with qualification. Data qualification code used:G4 .
❑Other (explain):
Notification Required? ❑ Yes ❑ No �
Person Contacted: Date: ,i / ',
.rn completed by.:
Lead Chemist vie initial):
❑BIOCHEM�
❑METALS
❑PEST
❑VOA
Date: 2/16/2010
❑SVOA
Branch.Head Review (initial): Z'j NL) t)
� / / f .,�„PA fntn riafahaca by (initiall- (CMd 1 .1�17 ��

Data Remark Codes for Use with Coalition Data (current as of Mav 21, 2009)
Data
Remark
Code Definition
Code
Value reported is the mean (average) of two or more determinations. This code is to be used if the
results of two or more discrete and separate samples are averaged. These samples shall have been
A
processed and analyzed independently (e.g. field duplicates, different dilutions of the same
sample). This code is not required for BOD or coliform reporting since averaging multiple
dilutions for these parameters is fundamental to those methods.
Results are based upon colony counts outside the acceptable range and should be used with
caution. This code applies to microbiological tests and specifically to membrane filter (MF)
B
colony counts. It is to be used if less than 100% sample was analyzed and the colony count is
generated from a plate in which the number of coliform colonies exceeds the ideal ranges
indicated by the method. These ideal ranges are defined in the method as:
Fecal coliform bacteria: 20-60 colonies Total coliform bacteria: 20-80 colonies
B l . Countable membranes with less than 20 colonies. Reported value is estimated or is a total
of the counts on all filters reported per 100 mL.
B2. Counts from all filters were zero. The value reported is based on the number of colonies
per 100 mL that would have been reported if there had been one colony on the filter
representing the largest filtration volume (reported as a less than "<" value).
B3. Countable membranes with more than 60 or 80 colonies. The value reported is calculated
using the count from the smallest volume filtered and reported as a greater than ">" value.
B4. Filters have counts of both >60 or 80 and <20. Reported value is a total of the counts from
all countable filters reported per 100 mL.
B5. Too many colonies were present; too numerous to count (TNTC). TNTC is generally
defined as > 150 colonies. The numeric value represents the maximum number of counts
typically accepted on a filter membrane (601or fecal and 80 for total), multiplied by 100
and then divided by the smallest filtration volume analyzed. This number is reported as a
greater than value.
136. Estimated Value. Blank contamination evident.
137. Many non-coliform colonies or interfering non-coliform growths are present. In this
competitive situation, the reported coliform value may under -represent actual coliform
density.
C
Total residual chlorine was present in sample upon receipt in the laboratory; value is estimated.
Generally applies to cyanide, phenol, NH3, TKN, coliform, and organics)
11

AA
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Dennis Wells
Water Resources Director
Division of Water Quality
Coleen H. Sullins
Director
February 17, 2010
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Compliance Evaluation Inspection
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Wells:
Dee .Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on February 12, 2010 by Mr. John Lesley of this Office. Please inform the facility's Operator -
in -Responsible Charge of our findings by forwarding a copy of the enclosed report.
Effluent samples were collected on February 9 and 12, 2010 for use in a chronic Ceriodaphnia dubia
pass/fail toxicity test. Unfortunately, the State Courier did not pick up the second set of toxicity samples on
February 12, 2010 due to inclement weather and the test could not be completed. Samples were also collected
on February 9, 2010 for NPDES Permit parameter analysis. The analytical results will be forwarded under
separate cover when available.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC. 28115
Phone: [phone] \ Fwx: [phone] \ Customer Service: 1-877-623-6748
Internet: hfp:llportal.nodenr.orglweblwg
One
NorthCatolina
An Equal Opportunity \ Affirmative Action Employer — 50116 Recycled/l0% Post Consumer paper

The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley or me at [phone].
Sincerely, ,
/ Robert B. Krebs
Regional Supervisor
Surface Water Protection
Enclosure
cc: Central Files
Cleveland County Health Department
JL

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 I SI 31 N00020737 Ill 121 10/02/12 117 181 CI 191 gI 20I / I
Remarks
21IIIIIIIIIIIIIIIIIII1IIIIIIIIIIIIIIIIIIIIII1I1I16
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ------------Reserved------
67 I 3.0 169 70 13 I 711 DI 721 N I 73 I I 174 751 I I I I III 80
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)
10:00 AM 10/02/12
04/05/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
02:00 PM 10/02/12
09/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis Wells,PO Box 429 Kings Mountain NC 280860429//704-734-4525/ 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 Find in /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
John E Lesley MRO WQ//704-663-1699 Ext.2198/
_
Signature of Management Q A Reviewer 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

NPDES yr/mo/day Inspection Type (cont.) i
3I NCO020737 I11 121 10/02/12 117 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
SUMMARY AND COMMENTS
NPDES Limits Violations
Cadmium limit violations were reported in November 2008 and June and October 2009.
Toxicity test failures were reported in January, February, April, and May 2009.
pH was reported at below the minimum (<6.0 su) for six days in October 2009.
Enforcement actions have been taken for the above violations.
Arsenic values reported at >184 ug/I on two occassions in August 2009 and on 7 occassions in October
2009. According to NPDES modeling for the reasonable potential analysis arsenic concentrations at >184
ug/I would be predicted to have chronic impacts on the receiving stream at the design flow of the facility.
The City is investigating the industrial users to determine the source of the arsenic.
Page # 2

Permit: NCO020737
Inspection Date: 02/12/2010
Owner - Facility: Pilot Creek WWrP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ fl ❑ ❑
Judge, and other that are applicable?
Comment: The previous inspection noted scrap metal and construction debris stored
on site. The scrap metal and other debris have been removed and the facility grounds
appeared to be well maintained.
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
0
n
n
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
n
■
❑
n
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment: A draft permit has been issued. The facility continues to operate under the
constraints of the expired permit.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
❑
n
Is all required information readily available, complete and current?
■
n
❑
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
❑
n
Are analytical results consistent with data reported on DMRs?
■
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
n
Has the facility submitted its annual compliance report to users and DWQ?
■
❑
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?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Page # 3

Permit: NCO020737 Owner - Facility: Pilot Creek VVVVTP
Inspection Date: 02/12/2010 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
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?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
■
Cl
n
n
Comment: The facility currently has a waiver of the 24/7 operations requirement.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
❑
n
Is flow meter calibrated annually?
■
❑
❑
n
Is the flow meter operational?
■
n
n
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑
❑
❑
Comment: The flow meters were calibrated by Laboratory Instrument Service on
10/19/09.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
❑
❑
❑
Is the mixing adequate?
■
❑
❑
❑
Is the site free of excessive foaming in the tank?
■
❑
❑
71
# Is the odor acceptable?
■
n
n
n
# Is tankage available for properly waste sludge?
■
n
❑
n
Comment:
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
[J
n
❑
Is the wet well free of excessive grease?
■
n
n
n
Are all pumps present?
■
❑
❑
Are all pumps operable?
■
❑
❑
n
Are float controls operable?
■
n
❑
❑
Is SCADA telemetry available and operational?
■
n
n
n
Is audible and visual alarm available and operational?
n
n
■
Comment: New screw pumps have been installed since the last inspection.
,.
Yas
Nn
NA
NF
Type of bar screen
a.Manual ■
Page 9 4

Permit: NCO020737
Inspection Date: 02/12/2010
Bar Screens
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Comment:
Secondary Clarifier
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?
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
n
■nnn
■nnn
■nnn
■nnn
Ext. Air
Diffused
■nnn
■❑n❑
■ ❑ ❑ ❑
■nnn
■nnn
n■nn
■nnn
■nnn
■nnn
❑ ■ ❑ ❑
■nnn
Page # 5

Permit: NC0020737
Inspection Date: 02/12/2010
Owner - Facility: Pilot Creek VW/TP
Inspection Type: Compliance Evaluation
Secondary Clarifier
Comment: The number one clarifier has been repaired and is ready to placed back
into service (no scum removal available).
The rake on the number three clarifier has been repaired and is in operation.
The number four clarifier (scum removal inoperable) has been scheduled for repair.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is. the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment: The RMP was available for inspection and was up to date.
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
■ n ❑ ❑
■nnn
■nnn
■nnn
■nnn
■nnn
■❑❑❑
■ n n n
1000-0005-8965
Gas
nnn■
■nnn
■nnn
❑ ❑ ■ ❑
nn■n
Page # 6

Permit: NCO020737 Owner - Facility: Pilot Creek WVVfP
Inspection Date: 02/12/2010 Inspection Type: Compliance Evaluation
Standby Power
Yes
No
NA
NE
Do the generator(s) have adequate capacity to operate the entire wastewater site?
n
■
n
n
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■
n
n
n
Is the generator fuel level monitored?
■
n
n
n
Comment: The generator can operate one screw pump, one blower, and the chlorine
disinfection/dechIorination system.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place? •
■
n
n
n
Are pumps operational?
■
n
n
n
Are there adequate spare parts and supplies on site?
■
n
n
n
Comment:
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?
■
n
n
n
# Is the facility using a contract lab? i
■
n
❑
n
# Is temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
proper
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: The facility uses Par Labs and ETT Environmental Solutions for contract
laboratory services.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
n
n
n
Is sample collected above side streams?
■
n
❑
n
Is proper volume collected?
■
n
n
n
Is the tubing clean? i
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Is sampling performed according to the.permit?
■
n
n
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
n
n
n
Is sample collected below all treatment units?
■
n
00
Is proper volume collected?
■
o
n
n
Page # 7

Permit: NCO020737
Inspection Date: 02/12/2010
Owner - Facility: Pilot Creek VWVTP
Inspection Type: Compliance Evaluation
Effluent Sampling
Is the tubing clean? ■ n n n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ ❑ n n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n n
Comment:
Upstream / Downstream Sampling .. Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n
Comment:
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment: The solids handling facility was not in operation on the day of this
inspection.
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment: Caustic is being utilized for alkali.nity addition and pH adjustment on a
temporary basis. Be advised that should the chemical addition become a permanent
part of the treatment process, a containment area must be constructed for the caustic
addition and storage. An Authorization to Construct would be necessary prior to the
construction of a permanent caustic addition system.
Page # 8
Ll

NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. Dennis Wells
Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Mr. Wells:
Division of Water Quality
Coleen H. Sullins
Director
February 11, 2010
Subject: Notice of Violation
Tracking Number: NOV-2010-PC-0141
Failure to implement Pretreatment Program
NCGS 143-215.3(14)
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County, NC
Dee Freeman
Secretary.
Enclosed is a copy of the Pretreatment Compliance Inspection Report for the inspection of the City of
Kings Mountain approved Industrial Pretreatment Program on February 9, 2010 by Mr. John Lesley of this
Office.
This Report is being issued as a Notice of Violation (NOV) because of violations of the subject permit
and North Carolina General Statute (G.S.) 143-215.1, G.S.143-215.3(a)(14), and 15A NCAC 2H .0900 for
failure to submit the Industrial Waste Survey as required by the Division of Water Quality PERCS Unit (see the
PCI Summary and Comments Section of the report). Pursuant to 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 G.S. 143-215.1.
Should this Office make an enforcement recommendation relative to the violations, you will be advised in
writing.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: hfp://Portal.ncdenr.org/web/wq
An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/]0% Post Consumer paper
one
NorthCmolina
Natlmally

A written response is requested that addresses the deficiencies addressed in the subject Pretreatment
Compliance Inspection Report, specifically the preparation of the Industrial Waste Survey and activities the
City of Kings Mountain is taking to locate any sources of wastewater that could cause noncompliance with the
NPDES Permit, beneficial use of sludge, or stream standard violations, and to ensure that pass through of
pollutants do not continue at the WWTP. Please submit your response to the attention of Mr. Lesley of this
office and to Ms. Sarah Morrison of the PERCS Unit in the Central Office.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley or me at [phone].
Sincerely,
Robert B. Krebs
Division of Water Quality
Surface Water Protection Section
Regional Supervisor
Enclosure
cc: Central Files
Sarah Morrison, PERCS Unit
JL

�� FWATF
NORTH CAROLINA DIVISION OF WATER QUALITY \oao R°9
WDE R PRETREATMENT COMPLIANCE INSPECTION PCI REPORT
BACKGROUND INFORMATION Womnlete Prior To PCI: Review ProLyram Info Database Sheet(s)1
1. Control Authority (POTW) Name: Kings Mountain
2. Control Authority Representative(s): Brian Ramsey
3. Title(s): Pretreatment Program Coordinator
4. Last Inspection Date: 03/09/09 Inspection Type: ® PCI ❑ Audit
5. Has Program Completed All Requirements from the Previous Inspection and Program Info Sheet(s)? ® YES ❑ NO
6. Is POTW under an Order That Includes Pretreatment Conditions? ❑ YES ® NO
Order Type, Number, Parameters: Are Milestone Dates Being Met? ❑ YES ❑ NO ® NA
PCS CODING
Trans.Code Main Program Permit Number MNUDD/YY Inspec.Type Inspector Fac. Type
N NCO020737 02/09/10 P. S 1
(DTIA) (TYPI) (INSP) (FACC)
7. Current Number Of Significant Industrial Users (SIUs)?
6
SIDS
8. Current Number Of Categorical Industrial Users (CIUs)?
6
CIUS
9. Number of SIUs Not Inspected By POTW in the Last Calendar Year?
0
10. Number of SIUs Not Sampled By POTW in the Last Calendar Year?
0
11. Enter the Higher Number of 9 or 10
0
NOIN
12. Number of SIUs With No IUP, or With an Expired IUP.
0
NOCM
13. Number of SIUs in SNC for Either Reporting or Limits Violations During Either of the Last 2
Semi -Annual Periods (Total Number of SIUs in SNC)
1 0
PSNC
14. Number of SIUs in SNC For Reporting During Either of the Last 2 Semi -Annual Periods
0
MSNC
15. Number of SIUs In SNC For Limits Violations During Either of the Last 2 Semi -Annual Periods
0
SNPS
16. Number of SIUs In SNC For Both Reporting and Limits Violations During Either of the Last 2
Semi-annual Periods
0
POTW INTERVIEW
17. Since the Last PCI, has the POTW had any NPDES Limits Violations?
If Yes, What are the Parameters and How are these Problems Being Addressed?
18. Since the Last PCI, has the POTW had any Problems Related to an Industrial
Discharge (Interference, Pass -Through, Blockage, Citizens' Complaints, Increased
Sludge Production, Etc.)?
If Yes, How are these Problems Being Addressed?
19. Which Industries have been in SNC for Limits or Reporting during SNC for
either of the Last 2 Semi -Annual Periods? Not Been Published for SNC for
Public Notice?(May refer to PAR if Excessive SIUs in SNC) Not Pu
20. Which Industries are on Compliance Schedules or Orders? For all SIUs on an
Order, Has a Signed Copy of the Order been sent to the Division?
21. Are.Any Permits Or Civil Penalties Currently Under Adjudication? If Yes, Which
Ones?
® YES ❑ NO
See comments
EYES [:]NO
Cadmium pass through
Arsenic pass through
Toxicity
Limits:
Reporting:
dished: NA
None
❑ YES ®NO
LTMP/STMP FILE REVIEW:
22. Is LTMP/STMP Monitoring Being Conducted at Appropriate Locations and Frequencies? ® YES ❑ NO
23. Are Correct Detection Levels being used for all LTMP/STMP Monitoring? EYES ❑ NO
24. Is LTMP/STMP Data Maintained in a Table or Equivalent? EYES []NO Is Table Adequate? ®YES [:]NO
25. All LTMP/STMP effluent data reported on Discharge Monitoring Report? ® YES ❑ NO
26. If NO to 23 - 26, list violations:
27. Should any Pollutants of Concern be Eliminated from or Added to LTMP/STMP? ® YES ❑ NO
If yes, which ones? Eliminated: Added: Arsenic and Selenium
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7.125/07 Page I

28. PRETREATMENT PROGRAM ELEMENTS REVIEW— Please review POTW files, verify POTW has copy of Program Element i
their files com lete with supporting documents and copy of PERCS Approval Letter, and dates consistent with Program Info:
Program Element
Last Submittal Received
Date In file?
Last Approval
Date In file
Date Next Due,
If Applicable
Headworks Analysis (HWA)
11/15/06
® Yes ❑ No
2/22/08
® Yes ❑ No
9/1/10
Industrial Waste Survey (IWS)
12/13/04
® Yes ❑ No
12/30/04
® Yes ❑ No
12/1/09
see comments
Sewer Use Ordinance SUO)
6/21/07
® Yes ❑ No
11/9/07
® Yes ❑ No
Enforcement Response Plan (ERP)
8/24/94
® Yes ❑ No
8/25/94
® Yes ❑ No
Long Term Monitoring Plan (LTMP)
9/6/05
® Yes ❑ No
9/20/05
® Yes ❑ No
INDUSTRIAL USER PERMIT (IUP) FILE REVIEW (3 IUP FILE REVIEWS OR I FILE REVIEW AND 1 IU INSPECTION)
11
29. User Name .
1. Evonik Energy Services
2. K.M. International
3. Carolina Finishing & Coatings
Z.
30. IUP Number
032
031
033.
31. Does File Contain Current Permit?
® Yes
ElNo
11
® Yes [INo
®Yes ❑ No
32. Permit Expiration Date
3/1/12
7/1/10
12/31/13
33. Categorical Standard Applied (I.E. 40 CFR, Etc.) Or N/A
433
433
433
34. Does File Contain Permit Application Completed Within One Year Prior
®Yes ❑ No
® Yes ❑ No
®Yes ❑ No
to Permit Issue Date?
35. Does File Contain an Inspection Completed Within Last Calendar Year?
NY
❑ No
® Yes
❑
No
® Yes
❑ No
36. a. Does the File Contain a Slug/Spill Control Plan?
a. ®Yes ❑No
a. ®Yes ❑No
a. ®Yes ❑No
b. If No, is One Needed? (See Inspection Form from POTW)
b. ❑Yes []No
b. ❑Yes ❑No
b. ❑Yes ❑No
37. For 40 CFR 413 and 433 TTO Certification, Does File Contain a Toxic
®Yes❑No❑N/A
®Yes❑No❑N/A
❑YesNNo❑N/A
Organic Management Plan (TOMP)?
38. a. Does File Contain Original Permit Review Letter from the Division?
a. ®Yes []No
. ®Yes ❑No
Fb
a. ®Yes ❑No
b. All Issues Resolved?
b.®Yes❑No❑N/A
.®Yes❑No❑N/A
b.®Yes❑No❑N/A
39. During the Most Recent Semi -Annual Period, Did the POTW Complete
®Yes ❑ No
® Yes ❑ No
®Yes ❑ No
its Sampling as Required by IUP, including flow?
40. Does File Contain POTW Sampling Chain -Of -Custody Forms?
® Yes El No
®Yes El
No
®Yes
❑
No
41a. During the Most Recent Semi -Annual Period, Did the SIU Complete its
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
Sampling as Required by I-T, including flow?
41b. During the Most Recent Semi -Annual Period, Did SIU submit all reports
®Yes❑No❑N/A
®Yes❑No❑N/A
®Yes❑No❑N/A
on time?
42a. For categorical IUs with Combined Wastestream Formula (CWF), does
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
file include process/dilution flows as Required by IUP?
42b. For categorical IUs with Production based limits, does file include
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
production rates and/or flows as Required by IUP?
43a. During the Most Recent Semi -Annual Period, Did the POTW Identify
®Yes❑No❑NA
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Limits Non -Compliance from Both POTW and SIU Sampling?
43b. During the Most Recent Semi -Annual Period, Did the POTW Identify
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
All Reporting Non -Compliance from SIU Sampling?
44. a. Was the POTW Notified by SIU (Within 24 Hours) of All Self-
a.®Yes❑No❑N/A
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
Monitoring Violations?
b. Did Industry Resample and submit results to POTW Within 30 Days9
b.NYes❑No❑N/A
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
c. Did POTW resample within 30 days of knowledge of SIU limit
c.®Yes❑No❑N/A
c.❑Yes❑NoNN/A
c.❑Yes❑NoNN/A
violations from the POTW sample event?
45. During the Most Recent Semi -Annual Period, Was the SILT in SNC?
❑ Yes ® No
❑Yes
® No
❑ Yes ® No
46. During the Most Recent Semi -Annual Period, Was Enforcement Taken
NYes❑No❑N/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
as Specified in the POTW's ERP (NOVs, Penalties, timing, etc.)?
47. Does the File Contain Penalty Assessment Notices?
❑Yes❑NoNN/A
11 ❑Yes❑NoNN/AI
❑Yes❑NoNN/A
48. Does The File Contain Proof Of Penalty Collection?
❑Yes❑NoNN/A
❑Yes❑NoNN/A
❑Yes❑NoNN/A
49. a. Does the File Contain Any Current Enforcement Orders?
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
a.❑Yes❑NoNN/A
b. Is SIU in Compliance with Order?
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
b.❑Yes❑NoNN/A
50. Did the POTW Representative Have Difficulty in Obtaining Any of This
❑ Yes ® No
Yes ® No
IF
❑Yes ® No
Requested Information For You?
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated 7/25 /07 Page 2

FILE REVIEW COMMENTS:
34. IUP Applications: Evonik Energy Services - 9/28/06; Kings Mountain International - 3130106; Carolina Finishing & Coating
11/21/08.
35. Inspections: Evonik Energy Services-11/19/09; Kings Mountain International-11/17/09; Carolina Finishing & Coating-11/1/09.
37. Carolina Finishing and Coatings performed TTO Analyses in the first and second six-month periods of 2009. A TOMP is currently
being prepared. Kings Mountain International last Slug/Spill Control Plan and TOMP are out of date. The SILT should submit a new
Slug/Spill Control Plan and TOMP with updated information.
41a. Evonik Energy Services 10/20/09 sample chain of custody form indicated that the temperature of the sample was recorded as
11degrees C when it was received in the lab (it also indicated the sample was received on ice). The POTW should contact the SIU and
the contract lab to determine if the chain of custody form is correct and if so qualify the data or reject data that is temperature critical
(BOD, ammonia, etc.). Any sample data that is rejected should be addressed as a reporting violation and resampled.
45. Evonik Energy Services is suspected of causing pass through of arsenic and cadmium at the Kings Mountain WWTP (See
Summary Comments Section). Samples taken at the designated sampling point found cadmium violations (not enough for SNC) but no
arsenic in violation of the IUP limits; however, samples collected from the collection system downstream of the facility found high
concentrations of arsenic. There are no other known discharges to the collection system at the sampling point below the SILT. There is
an underground tank used by previous SIUs that contain wastewater that could potentially be discharging to the collection system.
Litigation is currently underway to determine responsibility for the wastewater and ownership of the tank and other potential sources
of wastewater. The POTW is evaluating the evidence to determine if Evonik Energy Services is responsible for arsenic pass through at
the WWTP. Should Evonik Energy Services be responsible for the arsenic pass through, the SIU will be placed in SNC.
SUMMARY AND COMMENTS:
NPDES Limits Violations
Reporting Month
Parameter
Reported Value
Permit Limit
11/2008
Cadmium
7.0 ug/1 weekly average
6.1 ug/1 weekly average
01/2009
Toxicity
Fail @ 33%
Pass @ 33%
02/2009
Toxicity
Chronic Value 9.95%
Pass @ 33%
04/2009
Toxicity
Fail @ 33%
Pass @ 33%
05/2009
Toxicity
Chronic Value 11.49%
Pass @ 33%
06/2009
Cadmium
6.5 ug/l weekly average
6.1 ug/l weekly average
10/2009
pH
<6.0 su on six days
pH 6.0 su — 9.0 su
10/2009
Cadmium
9.5 ug/l weekly average
10.5ug/l weekly average
8.0 ug/1 weekly average
8.0 ug/1 weekly average
6.1 ug/1 weekly average
NC TW() Pretreatment (mmnliance Tncnectinn (PC Tl Firm T'nrlateari 7r'�;07 Pace 3

Arsenic > 184ug/l in the discharge would be predicted to have chronic water quality impacts according to modeling in the NPDES
Permit reasonable potential analysis dated 4/15/09. Data used in the Reasonable Potential Analysis was taken prior to September 2008.
The following concentrations were reported for arsenic (LTMP data) from September 2008 through October 2009:
September 2008
188 ug/l
614 ug/l
358 ug/
October 2008
221 ug/l
420 ug/1
December 2008
236 ug/l
August 2009
198 ug/l
188 ug/l
October 2009
269 ug/l
262 ug/l
282 ug/l
232 ug/l
221 ug/l
229 ug/l
187 ug/l
Comments
There is no documentation that the City of Kings Mountain has adopted the Sewer Use Ordinance (approved 11/9/07).
Requirements:
The IWS was not performed as required by the. Division's PERCS Unit. It is required that the IWS be submitted no later than April 3 0, 2011.
Recommendations:
It recommended that dye testing be conducted on the abandoned wastewater tank near the Evonik Energy Systems facility to determine if a
discharge is occurring and if so, testing the discharge to determine the constitutents.
NOD: ❑ YES ® NO
NOV: ® YES ❑ NO
QNCR: ® YES ❑ NO
POTW Rating:
Satisfactory ❑ Marginal ® Unsatisfactory_ ❑
PCI COMPLETED BY:
John Lesley, Mooresville Reg io al Office
DATE: February 10, 2010
NC DWQ Pretreatment Compliance Inspection (PCI) Form Updated. 7,25/07 Page 4

0
Beverly Eaves Perdu
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
e Coleen H. Sullins Dee Freeman
Director Secretary
February 3, 2010
MARILYN SELLERS
CITY OF KINGS MOUNTAIN
PO BOX 429 -
KINGS MOUNTAIN NC 280860429
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment FEB — 8 2010
Pilot Creek WWTP
Permit Number: NCO020737
Case Number: LV-2010-0012
Cleveland County
Dear Mrs. Sellers:
This letter is to acknowledge receipt of check number 67744 in the amount of $2,183.71 received from you
dated January 21, 2010. This payment satisfies in full the above 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 919-807-6398.
cc: Central Files
Q.=.YY�i le�I�Qxo>lQ:ce3a a ,isD
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] \ FAX: [phone] \ Customer Service:1-877-623-6748 NorthCarol.ina
Internet: www.ncwaterquality.org �6ii90����d ,
An Equal Opportunity \ Affirmative Action Employer i

�l
HCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
January 11, 2010
CERTIFIED MAIL 7008 1140 0002 2716 7253
RETURN RECEIPT REQUESTED
Ms. Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
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. NCO020737
Pilot Creek WWTP
Cleveland County
Case No. LV-2010-0012
Dear Ms. Sellers:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$2,183.71 ($2,100.00 civil penalty + $83.71 enforcement costs) against the City of Kings Mountain.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for October 2009. This review has shown the subject facility to be in
violation of the discharge limitations found in NPDES.Permit No. NC0020737. The violations are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that the City of Kings Mountain
violated the terms, conditions, or requirements of NPDES Permit No. NCO020737 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, Robert B. Krebs, Surface Water Protection Regional Supervisor
for the Mooresville Region, hereby make the following civil penalty assessment against the City of
Kings Mountain:
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 �TOne 1
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748 1�d oI thCar6* 1ina
Internet: www.ncwaterquality.org

$ 100.00 For 6 of the six (6) violation(s) of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0020737, by discharging waste into the
waters of the State in violation of the permit daily maximum
effluent limit for pH.
$ 2,000.00 For 4 of the four (4) violation(s) of G.S. 143-215.1(a)(6)
and NPDES Permit No. NC0020737, by discharging waste into
the waters of the State in violation of the permit weekly average
effluent limit for cadmium.
$ 2,100.00
$ 2,183.71
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
[0141
2. Submit a written request for remission including a detailed justification for such request:
il

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:
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 petition may be filed by facsimile (fax) or electronic mail by an
attached file (with restrictions) - provided the signed original, one (1) copy and a filing fee (if a filing
fee is required by NCGS §150B-23.2) is received in the Office of Administrative Hearings within
seven (7) business days following the faxed or electronic transmission. You should contact the
Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process. The mailing address and telephone and fax numbers for the Office of Administrative
Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mary Penny Thompson, General Counsel
DENR
1601 Mail Service Center
Raleigh, NC 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 notice, 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 [phone].
(Date) Robert Robert B. Krebs
Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Division of Water Quality

ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
rb/ma

ATTACHMENT A
CASE NO. LV-2010-0012
Outfall
Parameter
Reported Value
Permit Limit
001
pH
5.01 SU*
6.0 SU (Daily minimum)
001
pH
5.65 SU*
6.0 SU (Daily minimum)
001
pH
5.03 SU*
6.0 SU (Daily minimum)
001
pH
5.43 SU*
6.0 SU (Daily minimum)
001
pH
5.31 SU*
6.0 SU (Daily minimum)
001
pH
5.31 SU*
6.0 SU (Daily minimum)
001
Cadmium
9.5 µg/L*
6.1 µg/L (Weekly average)
001
Cadmium
10.5 µg/L*
6.1 µg/L (Weekly average)
001
Cadmium
8.0 µg/L*
6.1 µg/L (Weekly average)
001
Cadmium
8.0 µg/L*
6.1 µg/L (Weekly average)
X Denotes civil penalty assessment

COUNTY OF CLEVELAND
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
CITY OF KINGS MOUNTAIN
PERMIT NO. NCO020737
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV-2010-0012
Having been assessed civil penalties totaling $2,183.71 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated January 11, 2010, 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 3 0 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 , 2010
BY
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REOUEST
DWQ Case Number: LV-2010-0012
Assessed Party: City if Kings Mountain
County: Cleveland
Permit Number: NC0020737
Amount Assessed: $2,183.71
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission 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-282.1(b) were
wrongfully 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: (use additional pages as necessary)

Violator:
Facility:
NORTH CAROLINA DIVISION OF WATER QUALITY
City of Kings Mountain
Pilot Creek WWTP
County: Cleveland
Case Number: LV-2010-0012
Permit Number: NC0020737
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;
The cadmium average concentrations of 9.5 µg/L, 10.5 µg/L, 8.0 µg/, and 8.0 µg/L for the weeks
ending October 10th, 17th, 24th, and 31 st exceeded the permit limit of 6.1 µg/L. The pH
concentrations of 5.01 SU, 5.65 SU, 5.03 SU, 5.43 SU, 5.31 SU, and 5.31 SU on October 23rd
through October 30th did not meet the daily minimum permit limit of 6.0 SU.
2) The duration and gravity. of the violation;
The cadmium weekly average permit limit was exceeded by 31.1 % to 72.1 % for the weeks ending
October 10th, 17th, 24th, and 31 st. The pH concentration is measured on an inverse logarithmic
scale and unlike linear scales, which have a constant relationship between the item being measured
and the value reported, each individual pH unit is a factor of 10 different than the next higher or lower
unit. For October 23rd through October 30th the pH concentration was 35-fold (5.65 SU) to 100-fold
(5.01 SU) lower than the minimum pH (6.0 SU) allowed by the permit.
3) The'effect on ground or surface water quantity or quality or on air quality;
The effect on the receiving stream is unknown as in -stream monitoring of cadmium is not required by
the permit. Cadmium is a toxic substance to aquatic organisms and the water quality standard for
Class C freshwater is 2.0 µg/L. The Kings Mountain Pilot Creek WWTP discharges into Buffalo
Creek, which is classified as C waters in the Broad River basin.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved by noncompliance is unknown.
6) Whether the violation was committed willfully or intentionally;
The Division of Water Quality has no evidence that the violations were committed willfully or
intentionally. The facility has added a chemical -feed system to adjust pH and is addressing source of
cadmium through their pre-treatment program.

III
01
The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
There have been 16 other CPAs against the City of Kings Mountain for their Pilot Creek WWTP
during the life of the permit with two CPAs having been issued in the past twelve months as detailed
below.
Case Number
Description
TX-2009-0016
$2,064.84 toxicity violation for second Quarter of 2009. Penalty has been paid in full.
LV-2009-0040
$583.64 Limit violation for cadmium. Penalty has been paid in full.
The cost to the State of the enforcement procedures.
The cost to the Mooresville Regional Office was $83.71.
11 zI- io
Date
--� Cam---�
Robert B. Krebs
Surface Water Protection
Regional Supervisor
Division of Water Quality

MONITORING REPORT(MR) VIOLATIONS for: ReportDate: 01/07/10 Page:" 7 of 26
PERMIT: NCO020737
FACILITY: City of Kings Mountain - Pilot Creek WWTP.
COUNTY: Cleveland REGION: Mooresville
Limit Violation
MONITORING OUTFALL/
REPORT PPI LOCATION
PARAMETER
VIOLATION.
DATE
FREQUENCY
UNIT OF
MEASURE
LIMIT
CALCULATED c,,4(
VALUE / VIOLATION TYPE
VIOLATION ACTION
10 -2009
001
Effluent
Cadmium, Total (as Cd)
10/10/09
Weekly
ug/I
6.1
9.5 Weekly Average Exceeded
None *Y0
10-2009
001
Effluent
Cadmium, Total*(as Cd)
10/17/09
Weekly
ug/1
6.1�
10.5 A Weekly Average Exceeded
None
10 -2009
001
Effluent
Cadmium, Total (as Cd)
10/24/09
Weekly
ug/1
6.1
8Weekly Average Exceeded
None,
10 -2009
001
Effluent
Cadmium, Total (as Cd)
10/31/09
Weekly
ug/I
6.1
8 '�'� Weekly Average Exceeded
None
Minimum Not Reached
None
10 -2009
001
Effluent
pH
10/23/09
5 X week
su
6
5.01V(CQ-4 Daily
10 -2009
001
Effluent
pH
10/26/09
5 X week
su
6
5.65/'b;�L Daily Minimum Not Reached
None
10 -2009
001
Effluent
pH
10/27/09
5 X week
su
6\/
5.03`-/j& % Daily Minimum Not Reached
None
- boF'
10 -2009
001
Effluent
pH
10/28/09
5 X week
su
6
5.43 Daily Minimum Not Reached
None
10 -2009
001
Effluent
pH
10/29/09
5 X week
su
6
5.31�a,� Daily Minimum Not Reached
None
10 -2009
001
Effluent
pH
10/30/09
5 X week
su
6
5.31'-•Ici7' Daily Minimum Not Reached
Non

_% 4
6QR L L. LION,
November 13, 2009
City of Kings Mountain
Pilot Creek WWTP
200 Potts Creek Road
Kings Mountain, NC 28086
ATTN: Mr. Wes Bell
North Carolina Department of Environmental & Natural Resources
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Re: Report of By -Pass for City of Kings Mountain Pilot Creek WWTP
Dear Mr. Bell;
This letter is to confirm our phone conversation on November 13, 2009 at 0850,
concerning the spill that occurred at the Pilot Creek WWTP.
The spill took place at 0815 and lasted until 1030 on November 12, 2009.
The Effluent line from the aeration basin begin to clog, due to excessive rags, trash and
other debris which overflowed the basin manhole.
The City's High Pressure Jet Vac equipment was dispatched to the facility to free
the line and install risers on the low manhole. Once this was completed, the overflow begin
to cease.
We then begin cleaning the area around the manhole by applying lime and straw
to the affected areas. Once this was completed, a visual inspection downstream of the site
was made. Everything appeared to be normal.
A schedule has been made to take the basin out of service so that the trash can be
Removed from the line and in the center well of the clarifier. During this time we will be
replacing the risers with concrete bricks for a more permanent solutions.

I have completed the form WWTP-BYPASS/UPSET form which is attached.
If you should have any further questions concerning this matter please feel free to contact
Me at 704-739-7131.
Respectfully Submitted,

�0F \NATF9Q Form WWTP-BYPASS/UPSET
�O G Treatment Plant (WWTP) Bypass/Upset Reporting Form 5-Day Report
6
O �
This form shall be submitted to the appropriate DWQ Regional Office within five days of the first knowledge of
the unanticipated bypass or upset.
C 1\
Permittee: � �t ► 4's MNou'L 1 At 0 Permit Number:
Facility Name: �l� �� W W County: 0.Lo4 E LA u D
Incident Started: Date: Time: Og 15
Incident Ended: Date: l l l2 2co Time: l 03 O
Weather Conditions during Bypass/Upset event: 6�A11•l — �-�ti�A�l is MCS
Level of Treatment:
_None _Primary Treatment ✓ Secondary Treatment Chlorination/Disinfection Only
Estimated Volume of Spill/Bypass: 3000 icy 500O GRk (must be given even if it is a rough estimate)
Describe how the volume was determined: U % 5 Lky L C 1 MVa 11 G
Did the Spill/Bypass reach the Surface Waters? ZYes No
If yes, please list the following:
Volume Reaching Surface Waters: ADO GAS-- Surface Water Name:
Did the Spill/Bypass result in a Fish Kill? Yes \/No
Was WWTP compliant with permit requirements? Yes
Were samples taken during event? Yes _�Z No
Source of the Upset/Spill/Bypass (Location or Treatment Unit):
EFWIF_N l AEP-1kalb ­?5kSkQ-114 MA'J1WG-

Form WWTP-BYPASS/UPSET
Page 2
Cause or reason for the Upset/Spill/Bypass:
CUB UME. —QUc 1-6 Nth!-1 6ws
Describe the repairs made or actions taken:
C-Ep'RE �► f,(i� I A t.11� 1 t l §—u4I k e-0 2 k S;Epis m M A04I L.
Action taken to contain, lessen the impact, clean up, and remediate the site (if applicable) due to the bypass:
c IE)AZ U u e 141-Lti � u s� a I�
MA No1� 2k�>EszS . PPjLk ED ZS 4 D sD -Z 07 L� ME LOTOA
Action taken or proposed to be taken to prevent occurrences:
Clatz(�tF-72- aU.i o� SEtzUi�,r, '�� eL�A�c Ct�%rz W Wu�YLLSp�c�
C�uQRi it LoCACS ,
Were adequate equipment and resources available to fix the problem? [94es ❑ No
Additional comments about the event:

Form WWTP-BYPASS/UPSET
Page 3
24-Hour Report Made To: Division of Water Quality V Emergency Management
Contact Name: VAS �J'�1��- Date: �Abq . !3,21W9 Time: 0$56
Other Agencies Notified (Health Dept, etc):
Person Reporting Event: C, M % mu'� Phone Number:
Did DWQ request an additional written report? ZYes No
If Yes, what additional information is needed:
qA _'l3; -rl 131
-GASc C C bgE,iZ �--eA � 2- V3 0 �\ � fA \TA � M�6.L l
As a representative for the responsible party, I certify that the information contained in this
report is true and accurate to the best of my knowledge.
Person Submitting Claim: dC inn '� gS
Signat e
Title:
Date: I�b����E� � 3, �OD9
Telephone Number: q b `t ` `-zq I
Any additional information to be submitted should be sent to the appropriate Division Regional
Office within five days of first knowledge of the Bypass with reference to the incident number
(the incident number is only generated when electronic entry of this form is completed, if used).

Dee Freeman
Secretary
September 30, 2009
MARILYN SELLERS
CITY OF KINGS MOUNTAIN
PO BOX 429
KINGS MOUNTAIN NC 280860429
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Pilot Creek WWTP
Permit Number: NCO020737
Case Number: TX-2009-0016
Cleveland County
Dear Ms. Sellers:
This letter is to acknowledge receipt of check number 66472 in the amount of $2,064.84 received from you
dated September 24, 2009. This payment satisfies in full the above 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 John D Giorgino at 919-807-6398.
cc: Central Files
D�14Io®reunlle RegionalOffice Supervisor..
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 �TOne
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748 1 v 64- hCarofina
Internet: www.ncwaterquali)f.org Naturally„
An Equal Opportunity \ Affirmative Action Employer

I 3
1�
NCD
E
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 25, 2009 s~
CERTIFIED MAIL: 7006 2760 0001 9282 0167
RETURN RECEIPT REQUESTED A U G 3 1 2009
Mr. Dennis Wells
Director
City of Kings Mountain r,_
P.O. Box 429
Kings Mountain, North Carolina 28086-0429
SUBJECT: Assessment of Civil Penalty for Violations of NC General Statute 143-215.1(a)(6) and NPDES
Permit No. NCO020737
Kings Mountain -Pilot Creek WWTP
Cleveland County
TX 2009-0016
Dear Mr. Wells:
This letter transmits a Civil Penalty assessment against Kings Mountain -Pilot Creek WWTP in the amount of
$ �O(9 q, & q ($ 2,p ©y. p Z) civil penalty + $ - Y7 enforcement costs).
This assessment is based upon the following facts. A review of the facility's toxicity self -monitoring data from June has
been conducted. The review has shown Kings Mountain -Pilot Creek WWTP to be in violation of the 33% chronic
toxicity effluent discharge limitation found in NPDES Permit No. NC0020737. The facility's toxicity self -monitoring
reports for April through June 2009 revealed the following effluent toxicity permit limit violations.
April 15, 2009 Fail (chronic P/F))
May 21, 2009 11.49 % (7 day chronic value) Non -Compliant
June 19, 2009 46.67 % (7 day chronic value) Compliant
The chronic average for the quarter (29.08%) is less than the 33% chronic limit for the facility. Based upon the above
fact(s), I conclude as a matter of law that Kings Mountain -Pilot Creek WWTP violated the terms, conditions or
requirements of NPDES Permit No. NCO061182 and N.C.G.S 143-215.1(a)(6) in the manner and extent shown above. A
civil penalty in accordance with the maximum established by N.C.G.S. 143-215.6A(a)(2), may be assessed against a
person who violates the terms, conditions or requirements of a permit required by N.C.G.S. 143-215.1(a).
Environmental Sciences Section .
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:lih2o.enr.state.nc.us/esb/
AahlrallY
Nne
oftbCarohna
An Equal Opportunity Affirmative Action Employer

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, 1, Cindy
Moore, Supervisor, Aquatic Toxicology Unit, hereby make the following civil penalty assessment against Kings
Mountain -Pilot Creek WWTP
For _ ( of / violation(s) of G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0020737, by discharging waste into the waters of the State in
violation of the facility's permit effluent limit for chronic toxicity for April
15, 2009.
For ( of �_ violation(s) of G.S. 143-215.1(a)(6) and NPDES
Permit No. NC0020737, by discharging waste into the waters of the State in
violation of the facility's permit effluent limit for chronic toxicity for May
21, 2009.
$ 6 V � � Enforcement costs.
$ D62 `i 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 violation;
(2) The duration and gravity of the violation;
(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 violation was 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 receipt of this notice, you must do one of the following:
Submit payment of the penalty:
Payment should be made directly to the Department of Environment and Natural Resources (do not include
waiver form). Payment of the penalty will not foreclose enforcement action for any continuing or new
violation(s).
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:llh2o.enr.state.nc.us/esbl
No rthCarolina
atlfl'allY
An Equal Opportunity 1 Affirmative Action Employer

V_
`Please submit payment to the attention of.
Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Submit a written request for remission or mitigation 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 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. 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
and agreement 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) one or more of the civil penalty assessment factors in G.S. 14313-282.1(b) were wrongfully
applied to the detriment of the petitioner;
(2) the violator promptly abated continuing environmental damage resulting from the violation;
(3) the violation was inadvertent or a result of an accident;
(4) the violator had been assessed civil penalties for any previous violations;
(5) payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division 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 the case status, directions for
payment, and provision for further appeal of the penalty to the Env ironm ental.Managem ent Comm issilon'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 stateinent•in support of your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for Remission of Civil Penalties
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:
Environmental Sciences Section
Division of Water Quality
1621 Mail Service Center
Raleigh, NC 27699-1621
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 North Carohna
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 f f/�q /%
Internet: http://h2o.enr.state.nc.us/esb/ XrqGli(ral J
An Equal Opportunity 1 Affirmative Action Employer

W
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, NC 27699-6714
Telephone [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Ms. Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, NC 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.
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 me at 919 743-8442 or Mr. John
Giorgino at 919-743-8441.
Pt k
Date Cindy Moor
Supervisor, Aquatic Toxicology Unit
ATTACHMENTS
cc: Reb-�relbs/ Mooresville Regional Office
John Lesley/ Mooresville Regional Office
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
One
Nor. ihCarolina
Natitrally
An Equal Opportunity 1 Affirmative Action Employer

STATE OF NORTH CAROLINA
COUNTY OF CLEVELAND
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST
KINGS MOUNTAIN -PILOT CREEK WWTP
NPDES PERMIT NO. NCO020737
FILE NO
Having been assessed civil penalties totaling
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
TX-2009-0016
for violation(s) as set
forth in the assessment document of the Director 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 , 2009.
BY
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: TX-2009-0016 County: Cleveland
Assessed Party: Kings Mountain -Pilot Creek WWTP
Permit No. (if applicable): NC0020737 Amount Assessed: $
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, 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-282.1(b)
were wrongfully 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:

AyCo02-
o?3�
SEP i 5 2009
SYSTEM PERFORMANCE
ANNUAL REPORT
FOR
CITY OF KINGS MOUNTAIN
PILOT CREEK WPCF
DULY O19 2008 - JUNE 309 2009

The Pilot Creek wastewater treatment facility is owned and
operated by the City of Kings Mountain. The facility was
established in 1963.
The responsible parties including contact phone numbers are
as follows:
TOWN MAYOR
Mr. Rick Murphrey 704-734-4604
CITY MANAGNER
Mrs. Marilyn Sellers
CITY COUNCIL
Mr. Mike Butler
Mr. Huston Corn
Mr. Rodney Gordon
Mr. Keith Miller
Mr. Jerry Mullinax
Mr. Dean Spears
Mr. Howard Shipp
704-734-4606
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333

WATER RESOURSE DIRECTOR
Mr. Dennis Wells
SUPERINTENDENUORC
Ms. Kim T. Moss
PRETREATMENT COORDINATOR
704-734-4525
704-739-7131
Mr. Brian Ramsey 704-739-7131
FACILITY OPERATORS
Mr. Donald Mark Campbell ( Back-up Operator) 704-739-7131
Mrs. Brenda Kay Barker (Laboratory Technician) 704-739-7131
Ms. Kathy June Moses (Chief Operator) 704-739-7131
Mr. Ricky Parton (Operator I) 704-739-7131
Mr. Joshua Slycord (Operator I in training) 704-739-7131

The State of North Carolina regulates the treated wastewater which is
discharged into the Buffalo Creek. The (NPDES) Permit Number for this
facility is NC0020737. This facility is located off of highway 74, west of
Kings Mountain.
PROCESS DESCRIPTION
When wastewater is discharged from a home, industry, etc... it travels
through miles of underground lines by gravity or by pumps. This process is
called a Collection System, which is described more in detail in the
Collection's Annual Report.
Once the wastewater enters this facility it contains organic and
inorganic material which consist of thirty percent (30%) Industrial waste.
The wastewater is lifted approximately thirty two (32) foot by two (2)
Screw Pumps. Wastewater then travels through a Manual Bar Screen, where
debri is collected and removed for disposal. It then travels through a
Parshall Flume with a twenty four (24) inch throat which includes a staff
gauge and a flow meter all for measuring the incoming flow. As the
wastewater travels through the throat of the Parshall Flume a flow
proportional refrigerated twenty four (24) hour composite sample is
collected for analysis.
The wastewater then enters a Splitter Box that splits the flow into
three (3) Aeration Basin's based on their design flow. Once the fresh
wastewater enters the aeration basin the organic material is consumed by the
microorganism. The aeration basins are equipped with floating diffusers
which supplies oxygen and mixing for the microorganism to survive. The
detention time in these basins are from eighty four (84) to one sixty eight
(168) hours. This process is called activated sludge.

The activated sludge then enters the center well of a circular clarifier,
which is where the microorganism settle at the bottom to digest the organic
material that they consumed in the aeration basin. The detention time in
these clarifiers are approximately two (2) to four (4) hours. As the activated
sludge settles in the clarifier's, a portion of it is either returned to the head of
the aeration basin (RAS) or wasted (WAS) to the aerobic holding tank for
disposal by pumps.
As the treated wastewater leaves the clarifier's, it then enters a
Chlorine Contact Basin where Chlorine Gas is injected to kill the disease
causing bacteria before leaving the facility. These contact chambers are
equipped with. baffles (walls) to provide enough contact time. The flow
exit's these chambers over a rectangular weir or a V-Notch weir, which has
a staff gauge and a flow meter that sends a signal to a totalizer.
As the three (3) effluent flows combine into a manhole, Sulfur
Dioxide Gas is injected to remove the residual chlorine. The flow continues
to travel to the plants effluent flow proportional twenty four (24) hour
refrigerated composite sampler where a sample is collected for laboratory
analysis.
This facility is also equipped with a waste pump station that has two
(2) grinder pumps that conveys the floatable solids from the clarifiers back
to the head of the Influent.
Also included is a wash water pump station that pumps treated
wastewater to the Belt Filter press which is used to operate our 2.2 meter
Klamp Press. This Klamp Press is used to dewater the waste activated
sludge. This press produces a dry sludge cake of approximately 15 to 18%.
A dry polymer is used in the polymer system that mixes with the waste
sludge to form a floc so the water can drain through the pores in the belts.
The disposal process also includes two (2) aerobic holding tanks
which are gravity feed to the disposal sludge pump station. These pumps
convey the waste sludge to the belt filter press for operation.
Once the dry cake leaves the belt press, it travels up a conveyor belt,
through a hopper, into a tandem truck and is hauled to the Cleveland County
Landfill for final disposal.

VIOLATIONS OR DEFICIENCIES
FOR
JULY 019 2008 - JUNE 309 2009
MONTH/YEAR RESULTS
JULY 2008 NONE
AUGUST 2008 NONE
SEPTEMBER 2008
N/C (Cadmium)
OCTOBER 2008
N/C (Cadmium)
NOVEMBER 2008
N/C (Cadmium)
DECEMBER 2008
NONE
JANUARY 2009
N/C (Toxicity)
FEBRUARY 2009
N/C (Toxicity)
MARCH 2O09
NONE
APRIL 2009 N/C (Toxicity)
MAY 2009 N/C (Toxicity)
JUKE 2009 N/C (Cadmium)

VIOLATIONS/DEFICIENCIES
FOR
JULY 019 2008 — JUNE 309 2009
During this period there were no violations issued for monitoring,
reporting, illegal bypass, or sanitary overflows from this facility. However
there were some monthly/weekly violations for Cadmium and Toxicity
results. Pretreatment Coordinator is sampling and reviewing/updating limits
on industries. Notice of Violations has been issued to industries exceeding
limits.
NOTIFICATION
This Annual Report can be reviewed on the internet. If there are any
questions concerning this report, please feel free to contact the Water
Resource Director or the Superintendent/ORC.

CERTIFICATION STATEMENT
I certify that this report is accurate to the best of my knowledge.
SUPERINTENDENUORC

R—CDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
cc:
I
September 14, 2009
Ms. Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: Notice of Violation — Effluent Limitations
Tracking #: NOV-2009-LV-0401
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
Dear Ms. Sellers:
Dee Freeman
Secretary
A review of the June 2009 self -monitoring report for the subject facility revealed a violation of the
following parameter at Outfall 001:
Date Parameter Reported Value Permit Limit
Week ending 6/27/09 Total cadmium 6.5 µg/L 6.1 µg/L (Weekly average)
Remedial'actions, if not already implemented, should be taken to correct any problems. 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. Marcia Allocco of this Office for additional information.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me at
[phone].
Sincerely,
Robert B. Krebs
Surface Water Protection
Regional Supervisor
Point Source Branch
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748 NorthCarolina
Internet: www.ncwaterquality.org Natyt y a /l„

Beverly Eaves Perdue
Governor
NCD►ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins Dee Freeman
Director Secretary
July 23, 2009
CERTIFIED MAIL: 7007 1490 0004 5537 9933
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, North Carolina 28086-0429
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NCO020737
Kings Mtn. — Pilot Creek WWTP
Cleveland County
Dear Mr. Wells:
we
JUL 2 8 2009
This is to inform you that a review of your toxicity self -monitoring report form for the month of May
2009 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -
specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
As stated in a previous letter, we are recommending that Copper and Zinc limits be added to the
facility's permit.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting your
Discharge Monitoring Reports (DMRs) and Aquatic Toxicity (AT) Test Forms. We encourage you to review
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One 1
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607 NorthCarofina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
An Equal Opportunity 1 Affirmative Action Employer vv J

L7
this information; if it would be helpful to discuss this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. John Giorgino with this office at [phone].
cerely,
64 P
Cindy A. Moore
Supervisor, Aquatic Toxicology Unit
cc: Rob Krebs//Mooresville Regional Office
Tohn: Wiley/`Nlooresv l'le Region al=0ffice--
Jackie Nowell- Point Source Branch
Karen Rust- Point Source Branch
Vanessa Manuel- Point Source Branch
Marshall Hyatt- Water Management Division, USEPA Region IV
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:llh2o.enr.state.nc.uslesb/
One
NorthCarolina
N%timally
An Equal Opportunity \ Affirmative Action Employer

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.
John Giorgino 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).
➢ 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.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: hftp://h2o.enr.state.nc.uslesb/
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An Equal Opportunity l Affirmative Action Employer

Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: http:llh2o.enr.state.nc.uslesbl
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THE CITY OF DINGS MOUNTAIN
NORTH CAROLINA
P.O. BOX 429-KINGS MOUNTAIN, NORTH CAROLINA, 28086
DENNIS WELLS, WATER RESOURCES DIRECTOR
Phone [phone]
Fax[phone]
E-mail [e-mail]
July 16, 2009 JUL 1 7 2009
Mr. John Lesley
NCDENR
Mooresville Regional Office
610 East Center Ave., Suite 301
Mooresville, NC 28115
Subject: June 22, 2009 letter
Compliance Evaluation Inspection
Tracking No. NOV-2009-PC-0556
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Dear Mr. Lesley,
In response to the NOV dated June, 22, 2009, please accept the following information concerning the
discrepancy:
Secondary clarifiers #3 and #4 being modified by removing the skimmer mechanisms from the rake arm
• Unfortunately both of the skimmers had broken and have to be replaced. Our maintenance
staff will be replacing both of the skimmers. I will follow up with pictures when this is
completed.
The Risk Management Plan.
• The Risk Management Plan is on site. Kim Moss and I had reviewed this on June 4, 2009 so
that the new RPM could be completed. The new RPM was submitted on June 12, 2008.
I hope this answer the concerns referred to in the NOV. If you need further information please let me
know.
The Historical City

Sincerely,
Dennis Wells
Water Resources Director
City of Kings Mountain
Kings Mountain, NC
Cc: Marilyn Sellers, City Manager, City of Kings Mountain
Kim Moss, ORC/Supervisor, Pilot Creek WWTP

HCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Ms. Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Ms. Sellers:
Division of Water Quality
Coleen H. Sttllins
Director
June 22, 2009
Subject: Notice of Violation
Tracking No. NOV-2009-PC-0556
G.S. 143-215.1(a)(6)
Compliance Evaluation Inspection
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on June 18, 2009 by John Lesley of this Office. Please inform the facility's Operator -in -
Responsible Charge of our findings by forwarding a copy of the enclosed report.
The inspection found the following deficiencies:
1. Secondary clarifiers #3 and #4 have been modified by removing the skimmer mechanisms from
the rake arms resulting in significant scum and trash accumulation on the clarifiers and in the
chlorine contact basins. Effluent quality has been degraded as a result. In addition, the Division
was not notified of the modifications to the skimmer mechanisms.
2. The Risk Management Plan was not available for inspection. Be advised that a copy of the Risk
Management Plan must remain on site.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
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It is requested that a written response be submitted by no later than July 21, 2009 that details actions
taken to address the deficiencies noted above. Please address your response to the attention of Mr. Lesley of
this office.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley at [phone].
Sincerely,
`� q V -®-
Robert B. Krebs
Surface Water Protection Section
Regional Supervisor
Enclosure
cc: Point Source Branch
Jackie Nowell, Western NPDES Program

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 15I 3I . NC0020737 111 1.21 09/06/17 117 181 CI. 191 SI 20111
Remarks
2,111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 1311 QA ---- --Reserved----------
67 I 3.0 169 701 21 711 NJ 721 NJ 73 I I 174 751 I I I I I I 180
W
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 09/06/17
04/05/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
01:30 PM 09/06/17
08/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Dennis Wells/Director/704-734-4525 /
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis Wells,PO Box 429 Kings Mountain NC 280860429//704-734-4525/
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 Find in /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
John E Lesl /./ MRO WQ//704-663-1699 Ext.2198/
C.�
a
S' ature of Management Q A Revie r Agency/Office/Phone and Fax Numbers Date.��1
li
Marcia llocco MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NCO020737 I11 12I 09/06/17 117 18I c I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Monthly self -monitoring reports were reviewed for the period April 2008 through March 2009. Violations
were reported for toxicity test failures in January and February 2009. Cadmium limit violations were
reported in September, October, and November 2008. Notices of violation were sent for the violations.
Page # 2

r 'N
Permit: NCO020737
Inspection Date: 06/17/2009
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ■ .
0 Cl
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ® fl fl
Judge, and other that are applicable?
Comment: Decommissioned surface aerators, a discarded heating fuel tank, and
building debris are stored on the site but do not interfere with the operation of the
WWTP. A scrap metal dealer has been contracted to remove the aerators and other
scrap metal. There is no written housekeeping plan.
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■ n n n
Is the facility as described in the permit?
❑ ■ n fl
# Are there any special conditions for the permit?
■ n n n
Is access to the plant site restricted to the general public?
■ n n n
Is the inspector granted access to all areas for inspection?
■ ❑ 0 0
Comment: The facility utilizes diffused air aeration, the draft permit description refers
to surface mechanical aeration. The renewed permit will list diffused air aeration. The
clarifiers have been modified to remove skimming functions in #3 and #4 clarifier. The
Division was not informed of the equipment modification (see Secondary Clarifier and
Gas Disinfection Sections of this report).
Record Keeping
Yes
No
NA
.NE
Are records kept and maintained as required by the permit?
■
❑
0
0
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
Are analytical results consistent with data reported on DMRs?
■
❑
❑
[I
Is the chain -of -custody complete?
■
n
n
n
Dates, times and location of sampling
S
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?
■
Has the facility submitted its annual compliance report to users and DWQ?
■
n
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
Page # 3

r I '
Permit: NCO020737 Owner - Facility: Pilot Creek WVVrP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Record Keeping Yes .No NA NE
Is the ORC visitation log available and current? ®❑ ❑ 0.
Is the ORC certified at grade equal to or higher than the facility classification? ® ❑ ❑ D
Is the backup operator certified at one grade less or greater than the facility classification? ■ D D D
Is a copy of the current NPDES permit available on site? ■ D Cl D
Facility has copy of previous year's Annual Report on file for review? ■ D D
Comment: The facility currently has a waiver of the 24/7 staffing requirement found in
15A NCAC 2H .0124. A request for the continuance of the waiver has been received
and is under review at this time. A Verbatim Dial -A -Log System and a Cimtec
Monitoring System (text messaging via cell phone) are used to signal high water alarms,
power failures, and equipment failure. The systems offer no ability to operate the facility
components remotely (not a SCADA system).
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
D
D
❑
Is flow meter calibrated annually?
■
Is the flow meter operational?
■
D
D
❑
(If units are separated) Does the chart recorder match the flow meter?
■
D
D
D
Comment: The flow meter was destroyed by a fallen tree on 6/16/09. John Lassiter,
Laboratory Instrument Services, replaced the flow meter and calibrated it on 6/17/09.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
-D
D
D
Is the mixing adequate?
■
D
D
D
Is the site free of excessive foaming in the tank?
D
■
D
D
# Is the odor acceptable?
■
D
D
D
# Is tankage available for properly waste sludge?
■
D
D
D
Comment: A white sudsy foam covered the surface of the aerobic sludge storage tank.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
D
D
D
■
Is the chemical feed equipment operational?
❑
D
D
■
Is storage adequate?
■
Cl
D
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
D
■
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
D
D
D
■
Page # 4

Permit: NCO020737 Owner - Facility: Pilot Creek VVVVTP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Solids Handling Equipment Yes No NA NE
The facility has an approved sludge management plan?
Comment: The belt press was not in operation at the time of this inspection.
Yes No NA NE
Is containment adequate?
■
Cl n
n
Is storage adequate?
■
Cl
n
Cl
Are backup pumps available?
Is the site free of excessive -leaking?
■
❑
❑
n
Comment: Chemicals are stored under roof in a self contained building. All drains in
the building go to the head of the WWTP.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
n
Cl
n
Is the wet well free of excessive grease?
■
❑
0
n
Are all pumps present?
❑
■
n
n
Are all pumps operable?
n
■
Are float controls operable?
■
❑
0
0
Is SCADA telemetry available and operational?
■
❑
❑
El
Is audible and visual alarm available and operational?
n
n
■
n
Comment: One of two screw pumps is out of service (a replacement screw has been
ordered). A portable pump is being used to assist the remaining screw in times of high
flow or in case the remaining screw fails. The portable pump bypassed the manual bar
screen.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
■
b. Mechanical
Are the bars adequately screening debris?
■
Cl
❑
11
Is the screen free of excessive debris?
■
❑
❑
Q
Is disposal of screening in compliance?
■
Cl
n
n
Is the unit in good condition?
■
❑
0
n
Page # 5

r
Permit: NCO020737
Inspection Date: 06/17/2009
Owner -Facility: Pilot Creek VWVrP
Inspection Type: Compliance Evaluation
Comment: The WWTP utilizes a manual bar screen, but, operates under a waiver 15A
NCAC 2H .0124 reliability requirements for 24/7 operation. Should the bar screen be
blocked, no safe guards are in effect to prevent a spill at the top of the influent screw
pumps.
Aeration Basins
Yes
No
NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
0
0
0
Are surface aerators and mixers operational?
❑
fl
®
❑
Are the diffusers operational?
■
.❑
❑
❑
Is the foam the proper color for the treatment process?
■
n
❑
n
Does the foam cover less than 25% of the basin's surface?
■
❑
❑
❑
Is the DO level acceptable?
■
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
❑
❑
❑
Comment: The aeration basins have no safety railing and may be a hazard to staff
and visitors.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
rl
fl
Is the site free of excessive buildup of solids in center well of circular clarifier?
n
■
n
❑
Are weirs level?
❑
■
fl
❑
Is the site free of weir blockage?
❑
■
❑
❑
Is the site free of evidence of short-circuiting?
❑
■
❑
❑
Is scum removal adequate?
n
o
❑
n
Is the site free of excessive floating. sludge?
❑
■
❑
❑
Is the drive unit operational?
n
■
❑
❑
Is the return rate acceptable (low turbulence)?
■
❑
n
❑
Is the overflow clear of excessive solids/pin floc?
❑
■
0
❑
Is the sludge blanket level acceptable? (Approximately'% of the sidewall depth)
n
■
❑
❑
Page # 6

Permit: NC0020737 Owner -Facility: Pilot Creek VM(rP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Comment: The scum rakes have been removed from clarifiers #3 and #4. Clarifier #2
is out of service. Clarifier #1 does not have scum removal capability. Trash, grease,
floating solids, duck weed, and other debris were in abundance on the surface of the
clarifiers. Weirs were blocked with trash causing short circuting in the clairifiers
resulting in the loss of solids. Trash and scum were also prevelant in the chlorine
contact chambers.
Pumps-RASMAS
Yes
No
NA
NE
Are pumps in place?
®
0
❑
❑
Are pumps operational?
0
Are there adequate spare parts and supplies on site?
®
n
n
n
Comment: The RAS pump was leaking badly.
Disinfection -Gas
Yes
No
NA
-.NE
Are cylinders secured adequately?
fl
fl
fl
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
❑
❑
0
Is the level of chlorine residual acceptable?
0
00
Is the contact chamber free of growth, or sludge buildup?
❑
0
❑
❑
Is there chlorine residual prior to de -chlorination?
■
n
n
n
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
■
n
n
n
If yes, then is there a Risk Management Plan on site?
1­1
®
n
n
If yes, then what is the EPA twelve digit ID Number? (1000- - )
0005-8965
If yes, then when was the RMP last updated? 06/18/2004
Comment: The Risk Management Plan was not available for inspection. An update of
the plan is required.
The chlorine contact chambers were covered with trash and scum. The effluent
discharge was gray and very turbid.
De -chlorination
Yes
No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
■
11
Cl
0
Is storage appropriate for cylinders?
0
❑
0
# Is de -chlorination substance stored away from chlorine containers?
❑
❑
❑
Comment:
Are the tablets the proper size and type?
n
n
■
n
Page # 7

Permit: NCO020737 Owner - Facility: Pilot Creek VWdTP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Are tablet de -chlorinators operational? ❑ ❑ ® ❑
Number of tubes in use?
Comment: The chlorine gas and S02 cylinders are connected to an automatic
switching device.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
■
❑
❑
❑
Is the generator tested by interrupting primary power source?
❑
❑
❑
Is the generator tested under load?
■
❑
❑
0
Was generator tested & operational during the inspection?
❑
❑
❑
■
Do the generator(s) have adequate capacity to operate the entire wastewater site?
❑
■
❑
0
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■
❑
❑
❑
Is the generator fuel level monitored?
■
❑
❑
❑
Comment: The Standby Generator will operate one influent screw pump, one blower
in each basin, the RAS pump, the clarifiers, and the Lab Building. The Generator is
serviced by Carolina Power Solutions two times per year. Royster Oil supplies fuel for
the generator.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
❑
❑
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 less than or equal to 6.0 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?
■
❑
❑
❑
Comment: Conventional and field parameters are tested by the on -site lab
(Certification No. 222). PAR Labs (Certificate No. 20) performs all metals, nutrients,
chlorides, and oil and grease. ETT Environmental conduct toxicity testing.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
®❑
❑
❑
Is proper volume collected?
■
❑
❑
M
Is the tubing clean?
■
Cl
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
e
❑
❑
❑
Page # 8

Permit: NC0020737
Inspection Date: 06/17/2009
Owner -Facility: Pilot Creek VWVfP
Inspection Type: Compliance Evaluation
Influent Sampling
Yes
No
NA
NE
Is sampling performed according to the permit?
®
n
fl
0
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
®
n
n
n
Is sample collected below all treatment units?
®❑
❑
fl
Is proper volume collected?
®❑
.❑
Is the tubing clean?
■
n
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to.6.0 degrees Celsius)?
■
n
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
n
Comment:
Upstream / Downstream Samplina
Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ D ❑ 0
Comment:
Page # 9

.41
If
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Ms. Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Ms. Sellers:
Division of Water Qualify
Coleen H. Sullins
Director
June 22, 2009
Subject: Notice of Violation
Tracking No. NOV-2009-PC-0556
G.S. 143-215.1(a)(6)
Compliance Evaluation Inspection
Kings Mountain Pilot Creek.WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the
subject facility on June 18, 2009 by John Lesley of this Office. Please inform the facility's Operator -in -
Responsible Charge of our findings by forwarding a copy of the enclosed report.
The inspection found the following deficiencies:
1. Secondary clarifiers 93 and 94 have been modified by removing the skimmer mechanisms from
the rake arms resulting in significant scum and trash accumulation on the clarifiers and in the
chlorine contact basins. Effluent quality has been degraded as a result. In addition, the Division
was not notified of the modifications to the skimmer mechanisms.
2. The Risk Management Plan was not available for inspection. Be advised that a copy of the Risk
Management Plan must remain on site.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 23115
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-377-623-6743
Internet: wtivw.ncwatcrquality.org
An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/10%Post Consumer paper
One
NorthCarohna
Aahirally

U
It is requested that a written response be submitted by no later than July 21 2009 that details actions
taken to address the deficiencies noted above. Please address Your response to the attention of Mr. Leslev of
.t,_ _rr_
Li11J U111CC.
The report should be self-explanatory; however, should you have any questions concerning this report,
please do not hesitate to contact Mr. Lesley at [phone].
Sincerely,
Robert B. Krebs
Surface Water Protection Section
Regional Supervisor
Enclosure
cc: Point Source Branch
Jackie Nowell, Western NPDES Program

V
United States Environmental Protection Agency
Form Approved.
Washington, D.C. 20460
EPA
OMB No. 2040-0057
Water Compliance Inspection Report
Approval
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I N1 2 1 51 31 N00020737 1 11 121 09/06/17 117 181 CI 191 S1 201 1 1
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 I I I I I I I I I I I I I I I I I I I I I I I I I l l I I I i i i i
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA —Reserved----------
671 3.0 169 70121 711 NJ 721 N I 73I I W 174 - 751 I I I I I Li
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 09/06/17
04/05/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
01:30 PM 09/06/17
08/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Dennis We11s/Director/704-734-4525 /
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis We11S,PO Box 429 Kings Mountain NC 280860429//704-734-4525/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 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
John E Les,"MRO WQ//704-663-1699 Ext.2198/
John f
S' ature of Management Q A Revie r Agency/Office/Phone and Fax Numbers Date, �
9 ^ <:�
Marcia llocco MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I N00020737 I11 12I 09/06/17 117 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Monthly self -monitoring reports were reviewed for the period April 2008 through March 2009. Violations
were reported for toxicity test failures in January and February 2009. Cadmium limit violations were
reported in September, October, and November 2008. Notices of violation were sent for the violations.
Page # 2

t
w:.
Permit: NCO020737
Inspection Date: 06/17/2009
Owner -Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping? ❑ ® ❑ rl
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge IN fl ❑ 0
Judqe, and other that are applicable?
Comment: Decommissioned surface aerators, a discarded heating fuel tank, and
building debris are stored on the site but do not interfere with the operation of the
VW TP. A scrap metal dealer has been contracted to remove the aerators and other
scrap metal. There is no written housekeeping plan.
Permit
(if the present permit expires in 6 months or less). Has the permittee submitted a new application? ■ ❑ ❑ Q
is the facility as described in the permit? ❑ ■ ❑ ❑
# Are there any special conditions for the permit? ■ n El ❑
Is access to the plant site restricted to the general public? ■ 0 0 n
Is the inspector granted access to all areas for inspection? ■ ❑ Q Q
Comment: The facility utilizes diffused air aeration, the draft permit description refers
to surface mechanical aeration. The renewed permit will list diffused air aeration. The
clarifiers have been modified to remove skimming functions in #3 and #4 clarifier. The
Division was not informed'of the equipment modification (see Secondary Clarifier and
Gas Disinfection Sections of this report).
Record Keeping
Yes No
NA
.NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
®❑
fl
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
fl
❑
Are analytical results consistent with data reported on DMRs?
■
(_I
rl
Is the chain -of -custody complete?
■
Q
0
Q
Dates, times and location of sampling
Name of individual performing the sampling
S
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
e
Transported COCs
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
■
Cl
0-0
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator on each shift?
■
n
n
Page # 3

6
Permit: NCO020737 Owner - Facility: Pilot Creek V W rP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is the ORC visitation log available and current? ®n n n
Is the ORC certified at grade equal.to or higher than the facility classification? ®n n n
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? ■ n n n
Facility has copy of previous year's Annual Report on file for review? ■ n n n
Comment: The facility currently has a waiver of the 24/7 staffing requirement found in
15A NCAC 2H .0124. A request for the continuance of the waiver has been. received
and is under review at this time. A Verbatim Dial -A -Log System and a Cimtec
Monitoring System (text messaging via cell phone) are used to signal high water alarms,
power failures, and equipment failure. The systems offer no ability to operate the facility
components remotely (not a SCADA system).
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
n
n
I_I
Is the flow meter operational?
r
■
❑
❑
n
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment: The flow meter was destroyed by a fallen tree on 6/16/09. John Lassiter,
Laboratory Instrument Services, replaced the flow meter and calibrated it on 6/17/09.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
n
n
n
Is the mixing adequate?
■
❑
❑
Is the site free of excessive foaming in the tank?
❑
■
n
n
# Is the odor acceptable?
■
n
n
n
# Is tankage available for properly waste sludge?
■
n
00
Comment: A white sudsy foam covered the surface of the aerobic sludge storage tank
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
n
n
n
■
Is the chemical feed equipment operational?
n
n
❑
■
Is storage adequate?
■
n
n
n
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
n
n
n
■
Is the site free of sludge buildup on belts and/or rollers of filter press?
■
n
n
n
Is the site free of excessive moisture in belt filter press sludge cake?
n
n
n
■
Page # 4

Permit: NCO020737 Owner - Facility: Pilot Creek VWVfP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Solids Handling Equipment Yes No NA NE
The facility has an approved sludge management plan? ■ ❑ rl ❑
Comment: The belt press was not in operation at the time of this inspection.
Yes No NA NE
Is containment adequate?
190110
Is storage adequate?
®
n
n
n
Are backup pumps available?
®❑
rl
fl
Is the site free of excessive leaking?
®❑
❑
❑
Comment: Chemicals are stored under roof in a self contained building. All. drains in
the building go to the head of the VWVTP.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
n
❑
n
Is the wet well free of excessive grease?
■
❑
0
0
Are all pumps present?
fl
■
Are all pumps operable?
❑
■
0
n
Are float controls operable?
WOOD
Is SCADA telemetry available and operational?
■
n
n
n
Is audible and visual alarm available and operational?
n
n
■
n
Comment: One of two screw pumps is out of service (a replacement screw has been
ordered). A portable pump is being used to assist the remaining screw in times of high
flow or in case.the remaining screw fails. The portable pump bypassed the manual bar
screen.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
■
b.Mechanical
Are the bars adequately screening debris?
■
fl
Is the screen free of excessive debris?
■
n
n
n
Is disposal of screening in compliance?
■
n
n
n
Is the unit in good condition?
■
fl
❑
❑
Page # 5

Permit: NC0020737 Owner - Facility: Pilot Creek VWVrP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Bar Screens
Yes
No
NA
NE
Comment: The v v V Y 1 utilizes a manual bar scr eel 1, but, operates uI lder a waiver I JA
NCAC 2H .0124 reliability requirements for 24/7 operation. Should the bar screen be
blocked, no safe guards are in effect to prevent a spill at the top of the influent screw
Dumas.
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
■
❑
Are the diffusers operational?
■
.❑
❑
❑
Is the foam the proper color for the treatment process?
■
❑
rl
❑
Does the foam cover less than 25% of the basin's surface?
■
❑
❑
❑
Is the DO level acceptable? a
■
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
❑
fl
❑
Comment: The aeration basins have no, safety railing and maybe a hazard to staff
and visitors.
Secondary Clarifier
Yes
No
NA
NE
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?
[I
■
❑
❑
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?
❑
■
0
0
Is the return rate acceptable (low turbulence)?
®
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
❑
■
❑
n
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
n
■
❑
n
Page # 6

Permit: NC0020737
Inspection Date: 06/17/2009
Owner - Facility: Pilot Creek V\NVTP
Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Comment: The scum rakes have been removed from clarifiers #3 and #4. Clarifier #2
is out of service. Clarifier #1 does not have scum removal capability. Trash, grease,
floating solids, duck weed, and other debris were in abundance on the surface of the
clarifiers. Weirs were blocked with trash causing short circutinq in the clairifiers
resulting in the loss of solids. Trash and scum were also prevelant in the chlorine
contact chambers.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
®❑
fl
rl
Are pumps operational?
®
0
❑
0
Are there adequate spare parts and supplies on site?
■
n
[I
rl
Comment: The RAS pump was leaking badly.
Disinfection -Gas
Yes
No
NA
.NE
Are cylinders secured adequately?
■
Cl
n
n
Are cylinders protected from direct sunlight?
■
❑
❑
fl
Is there adequate reserve supply of disinfectant?
■
n
n
n
Is the level of chlorine residual acceptable?
■
n
❑
Is the contact chamber free of growth, or sludge buildup?
❑
■
❑
0
Is there chlorine residual prior to de -chlorination?
■
n
n
n
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
■
n
n
n
If yes, then is there a Risk Management Plan on site?
❑
■
n
n
If yes, then what is the EPA twelve digit ID Number? (1000- -_)
0005-8965
If yes, then when was the RMP last updated? 06/18/2004
Comment: The Risk Management Plan was not available for inspection. An update of .
the plan is required.
The chlorine contact chambers were covered with trash and scum. The effluent
discharge was gray and very turbid.
De -chlorination
Yes No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
■ n
n
n
Is storage appropriate for cylinders?
■ rl
fl
# Is de -chlorination substance stored away from chlorine containers?
■ n
n
n
Comment:
Are the tablets the proper size and type?
n n
■
fl
Page # 7

Permit: NCO020737 Owner - Facility: Pilot Creek VWVTP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Are tablet de -chlorinators operational? n n ® n
Number of tubes in use?
Comment: The chlorine gas and S02 cylinders are connected to an automatic
switching device.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
■
n
❑
n
Is the generator tested by interrupting primary power source?
❑
❑
❑
Is the generator tested under load?
■
❑
❑
❑
Was generator tested & operational during the inspection?
DOOM
Do the generator(s) have adequate capacity to operate the entire wastewater site?
n
■
n
n
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■
❑
❑
n
Is the generator fuel level monitored?
MOOD
Comment: The Standby Generator will operate one influent screw pump, one blower
in each basin, the RAS pump, the clarifiers, and the Lab Building. The Generator is
serviced by Carolina Power Solutions two times per year. Royster Oil supplies fuel for
the generator.
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?
■
n
n
n
# Is the facility using a contract lab?
®❑
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
■
n
❑
n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
■
n
n
n
Comment: Conventional and field parameters are tested by the on -site lab
(Certification No. 222). PAR Labs (Certificate No. 20) performs all metals, nutrients,
chlorides, and oil and grease. ETT Environmental conduct toxicity testing.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
n
n
n
Is sample collected above side streams?
e
n
n
n
Is proper volume collected?
■
❑
n
❑
Is the tubing clean?
■
❑
❑
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Page # 8

Permit: NC0020737 Owner - Facility: Pilot Creek VWVTP
Inspection Date: 06/17/2009 Inspection Type: Compliance Evaluation
Influent Sampling
Yes
No
NA
NE
Is sampling performed according to the permit?
■
n
n
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
®
n
n
n
Is sample collected below all treatment units? -
■
Q
❑
0
Is proper volume collected?
fl
rl
Is the tubing clean?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to:6.0 degrees Celsius)?
■
n
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
ri:
Comment:
Upstream / Downstream Samnlina
Yes
No
NA
NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ 0 ❑ ❑
Comment:
Page # 9

To:
Jackie Nowell
From:
Rob Krebs
By:
John Les]
Date:
6/19/2009
Re: Kings Mountain Pilot Creek VVVVTP NC0020737
John Lesley, MRO, conducted a Compliance Evaluation Inspection of the subject facility on June 18,
2009. Below are the findings of the inspection:
One of the influent screw lift pumps is out of service, leaving only one screw lift pump operable.
A gasoline powered six-inch portable pump is currently being used as a backup influent pump
during periods of high flow or in the event of the remaining screw pump failing. The backup
pump bypasses the bar screen.
2. The facility is monitored by two telemetry systems. The systems notify a person on call after
equipment failure has occurred or if a high water alarm is activated. The systems offer no.
remote operational control. The ORC could not demonstrate how the Cirrtec system worked
on-line via the Internet. The ORC indicated that the Cimtec system sent text message by cell
phone. The Verbatim system is a dialer call up system that gives a prerecorded code
designation for an equipment failure.
3. Standby power is insufficient to operate the entire VVWTP site. The generator will run one of two
influent screw pumps (only one screw pump is currently in service), one blower for diffused air
operation on each of the three aeration basins (six blowers were in operation on day of this
inspection), RAS pumps, the chlorine feed equipment, SO2 feed equipment, the clarifiers (see
next comment), and the operators' office/lab.
None of the clarifiers have skimming capability. The skimmingdevices on #3 and #4 have been
removed, clarifier# 1 is not equipped with a skimming device, and clarifier#2 is out of service.
5. The RAS pump was leaking badly
6. A large amount of scum composed of a mat of paper, plastic, grease, etc. has greatly impacted
the chlorine contact chambers and diminished the effluent quality. The effluent discharge was
gray and very turbid.
7. A copy of the facility's Risk Management Plan was not available for inspection:
8. The facility is only marginally staffed. One Grade 4 ORC, one Grade 3 back up ORC, a Grade 2
lab tech, a Grade 2 operator, one Grade 1 operator, and one Grade 1 in training.

9. The Aquatic Toxicology Unit has indicated that copper and zinc limits will be recommended for
the facility. MRO also recommends the addition of the copper and zinc limits. A 2006 Toxicity
Identification Evaluation concluded that zinc was a toxicant in the discharge. The facility
reported zinc concentrations above the recommended 497.2 ug/I limit on five occasions in
February and March 2009.
10. Long term monitoring plan data from October -December 2008 indicates that arsenic in
concentrations as high as 420 ug/I were present -in the wastewater discharge from the facility.
The reasonable potential analysis data only includes data through August 2008 and indicates
levels of arsenic over 184 ug/I would lead to chronic impacts on the receiving stream. Evonik
Energy Services is a SIU that cleans air scrubbers for coal fired power plants, which would be a
likely new source of arsenic and selenium (selenium is not included in the LTMP).
11. The facility has requested a waiver from the 24/7operation requirement in 15A NCAC2H.0124.
Because of the above noted significant maintenance issues, the age of the infrastructure (40 +
years) of the WWTP, a poor compliance record — several cadmium and toxicity limit violations in
the past 12-month period, and a marginal staff, this office recommends denial of the request.
0 Page 2

Tuesday June 17, 2009 @ 12:03 A.M.
Hi John,
I guess you have heard about our tornados hitting here in Kings Mtn., we got it pretty bad
here at the plant. We have trees down and one of them fell on our flow meter. John
Lassiter is coming in the morning to repair our flow meter, and we were wondering if you
would consider postponing our inspection for a later date. We would like to get the trees
and other debris clean up. I will call you at eight in the morning on Wednesday June 17,
2009 to see if you will be able to postpone the inspection.
Sincerely
Kay Barker,
Requested for
Dennis Wells

Beverly Eaves Perdue
Governor
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
t;:
CERTIFIED MAIL: 7007 1490 0004 5538 2520
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, North. Carolina 28086-0429
Dee Freeman
Secretary
April 28, 2009 �
a
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NCO020737
Kings Mountain — Pilot Cr. WWTP
Cleveland County
Dear Mr. Wells:
APli ? 0 9L,,;;I,
M-S
r i
urf ; ° tf 'rr i i~ i,,Aon
This is to inform you that a review *of your toxicity self -monitoring report form for the month of February 2009 indicates a
violation of the toxicity limitation specified in your NPDES Permit. You should undertake necessary actions to eliminate or
reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper and Zinc Action Level Policy.
The correspondence included a prospective permit limit for copper at 58.0 µg/L. We have now added a prospective
limit for zinc at 497.2 uQ/L, and adiusted the prospective limit for conger to 56.7 ua/L from 58.0 ue/L. We stated that
the trigger for implementing the policy would be two or more WET limit violations, which occur during a toxicity testing
calendar quarter. Please note that the second WET limit violation has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and zinc permit limit. Notification is due by May
28, 2009.
OR
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by May 28, 2009. DWQ approval
of options 1-3 below is not necessary as the Division expects work to rule out copper and zinc as a causative effluent
toxicant to begin immediately upon the second WET permit limit violation that occurred during February 2009.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet hftp:/ih2o.enr.state.nc.us/esb/
One
NorthCarol.ina
NaturallY
An Equal Opportunity 1 Affirmative Action Employer

1. Instream measurements of dissolved metal during low flow conditions that demonstrate compliance with the
Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with existing or additional
monitoring data demonstrates compliance with the Action Level standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and zinc as a cause of effluent
toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper and zinc are not causes
of toxicity
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Section;
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit documentation that
eliminates copper and zinc as causative effluent toxicants. Your final report should be comprehensive and
include all data used to',suppart your conclusion. The report is due by January 28, 2010.
Three copies of the final report shall be submitted to:
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Failure to notify DWQ of your acceptance of copper and zinc limits, failure to notify DWQ of your option
selection or failure to make acceptable demonstration to DWQ that copper and zinc are not causative effluent
toxicants within the stated time frames will result in reopening of the NPDES Permit to include a numeric
copper and zinc permit limitations, as appropriate.
If the effluent is toxic, then we expect work to commence immediately with toxic effluent samples. Failure to initiate work with
toxic effluent samples during the study period is unacceptable and will be considered a failure to make acceptable demonstration
as cited above. We recommend a minimum of three separate sampling events during the nine month period to definitively rule
out copper and zinc as causative effluent toxicants.
Additional information regarding the Division's Copper and Zinc Action Level Policy can be found at the following web site -
http://www.esb.enr.state.nc.us/. Click on the Aquatic Toxicology Unit and go to the prompt "AT Downloadable Files" located at
the bottom of the page.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621 One
4401 Reedy Creek Road, Raleigh, North Carolina 27607 NortllCarol.ina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 n Internet: http:llh2o.enr.state.nc.uslesbl
An Equal Opportunity %Affirmative Action Employer

V
If you have any questions concerning this correspondence, please contact Ms. Cindy Moore at [phone] or Mr. John Giorgino at
(919) 743- 8441.
MOA.V'-�J-
Cindy Moore
Supervisor, Aquatic Toxicology Unit
cc: Rob Krebs -Mooresville Regional Office
John,Lesley-M ooresville`.Regional, Office
Vanessa Manuel -Point Source Branch
Jackie Nowell -Point Source Branch
Marshall Hyatt -Water Management Division, USEPA Region IV, 61 Forsyth St., SW, Atlanta, GA 30303
Central Files
Aquatic Toxicology Unit Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: http:/ih2o.enr.state.nc.us/esb/
NorthCarolina
;%turalilf
An Equal Opportunity 1 Affirmative Action Employer

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70
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FoINT SOURCE sPu►xCFI
1617 MAIL sERVICH CE
RAUIGK NC 27699.1617
919-807-6300
j FAX: 919,807-6495
aoanog uiod 0 0
l0'd 99.9 60OZ .8 unr 96b9L0'8616:xeA

�.: fit•:
JUN - 2 200E
Tim CITY of KiNGs Mouwww
NORTH CAROLUVA DENIM WATER Q
P.Q. BOX 429-X3MOS MOUNTAIN. NOkTHCAP ONA, 29096
NNLSWLLS,WATM=0URaSDlECV- POINT SOURCE B1
Phone [phone]'
7Fax 704-73"152
E-mail dennisw goiryn9am com
May 28, 2009 I
I
NCDEHWSurface JW ter Protection Point Source Branch
1617 Mail Service Center
Raleigh, NC 2769,i-1617
AT. Jacquelyn M. ATowell
SUBJECT: Reply �o the Draft NPDES Permit No. NCO020737
Dear Ms. Nowell:
We have received i the draft copy NPDES Permit No. NCO020737 for Pilot Creek
Wastewater Treatnient Facility.
We are sufimitting our comments for the new modifications outlined in our Draft
NPDES Permit. $klow is tbe, following request:
CADMIUM: We would like to request that the Monitoring Frequency for Cadmium be
reduced to twice a month (2/month) with no limit. Rowever, if the data
should show to have a potential lbag term exposure, then at this time the
permit could be modified to includo lxmats,
MERCURY: We' ould like to request that the Monitoring Frequency for Mercury be
reduced to quaAerly instead of twice a month (2/month). This parameter
is p' sently being monitored through our Pretreatinent Program and our
Effluent Priozlty Pollutant Scan. After monitoring this parameter in the
past it was removed from our previous permit.
STAFFING: We h6reby request for an exemption from the 24 Hour Staffing
i
The Historical City
ZO'd 9s:8 600Z 6 unf 909LO8616:xeJ . aoinoS }u'Od DAG

STAFFWG: We hgreby request for an exemption from. the 24 Flour Staffing
Rule 1 5A NCAC 2H . 0124 (4) at the Pilot Creek'WWTP.
We at
adequ
updat
Weh
Dial
is the
point
callin
The C
on ca
pages
moll
and,
Guidelines for th
Telemetry Moni!
1) Areas to b
A-
B.
C.
D.
E.
Cx.
1.
FY.
K.
L.
M.
N.
; submitting information which we believe will demonstrate the
icy of our Telemetry Systems. We have spent thousands of dollars
xg our equipment to monitor all areas required in this rule.
ve two (2) Telemetry Systems in place, one being a Verbatim
-Log system and., the other is a Cimtec device. The newer of the two
;imtec device, which allows the operators to access all monitoring
through its web site. The Verbatim System can be accessed by
its dedicated phone line to hear the monitoring status.
ty has supplied cell phones or pagers to the Supervisor/CRC, which is
l 24/7 and, the stand-by certified operator on call. These phones or
are used to receive messages from both telemetry systems in case a
)ring point was to fail. The Verbatim System sends a voice response
ie Cirntec sends a text message that would identify the status.
issuance of a waiver for the 24 bour stsfrmg rule when utilizung a
ring System:
monitored by Telemetry monitoring system at the Pilot Creek WWTI'
tai WWTP Power Failure: YES
rScreen status: N/A (Manual Bar Screen)
lion equipment Operational. status: YES (Blowers)
Water Level Al =: YES
i4kling Filter Distribution Arm Operational Status. NIA
3 Drive Unit Operational status: N/A
C Mdary Clarifier Sludge Collection System Operational status: YES
Activated Sludge (RAS) Flow -Alarm set points on low flow: YES
lad Loss or High water level of Filters: N/A
[Is- ection System Operational. status: 'YES
-chlorination System Operational status: 'YES
an Flow - Alarm set points .at minimum/maximum Flows: YES
- ON, Stand - By Generator status: 'YES
- ON, Security Alarm status: YES
2) Requirement: A certified operator may be required to be on site during periods of
Fligh Flows (Based on maximum Plant Flow Alarm) due to
excessive Inflow.
Comment: , t any time a High Water Level Alarm is activated, a certified operator
%esponds and remains on site until the condition clears or unO another
ot)erator relieves them.
EO'd 99:8 600Z 6 un` SML09616:xei
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3) Requirement: e WWTP must have dual or standby power supply which shall be
euipped with an automatic transfer switch.
Comment: ' `Ire pilot Creek WWTP has a Stand -By Generator that is equipped
th an automatic transfer switch. The Generator provides stand-by
wer during, a power outage.
4) Requirement: lylechanical equipment failures, power failures, alarm conditions, etc.
must be relayed to a designated operator, who will respond
i nmediately to the problem area. A, designated certified operator shall
tt)e on call 24 hours a day, seven days a week. The system. shall provide
the'Regional and Central Offices the notification procedure and a
notification schedule of horny contacts will be made when problems are
orted and shall notify the Offices of any changes in the schedule.
Comment: All alarms are relayed to cell phones and. pagers. The alarms are
.splayed as Text messages and Voice announcements. The facilities
upervisor/ORC is on call 24 hours, 7 days a week. The alarm
messages will be sent to the ORC, Kim T. Moss, on call (Stand -By)
dertified operators, Collection ORC and the on call Collection and
ump maintenance (Stand By) operators. The'V'oice announcements 1
1 also be relayed to all facility operators home phone.
5)
6)
Comment:
Failure of the automatic monitoring system to detect a
Malfunction. The failure of the monitoring system in
reporting a maLfunction, or failure of an operator in responding
to a problem must be documented and reported to the appropriate
Regional Office within 24 hours of the next working day_ Any of
the above failures will require the WWTP to initiate 24 hour
staffing until such malfunctions have been corrected to the
Division's satisfaction.
We understand and accept this requirement.
The WWTP must provide the Director a schedule for testing the
Telemetry monitoring system. Documentation must be kept of
each testing event. Failure of a monitoring device or failure to
respond to a problexx� will not be a mitigating factor in any
enforcement action.
The schedule for the systems to be tested is twice a month_
b0'd
9s:8 60OZ D Unr S6b9t08616:X6J aoinoS }uiod OAG

v ,
We have tal�, en every action possible to correct any previous NO V`s at Our
facility. The facilitly is staffed with very' lfiaowledgeable operators that keep the plant
well operated, and r mentaoned.
The previm facility DiVections have been rated compliant, some which had
comments made bathe Inspector, which we immediately took actions to correct. Overall,
Y feel that we have made every effort in correcting any problems that have occurred.
The 3 Nlilhon Gallon spill in 2005 within our collection system was the first in
over 15 years WEI was caused by enormous amount of rainfall in a short time span.
After this incident �Ve made some new 4ustments to our Telemetry System which Will
detect the facility's Influent Low water Level <300,000 gallons.
Therefore, ving submitted this information, we would like to request that all of
our comments afor mentioned in this letter be considered before issuiug the Final Permit.
If you should need further information, please feel free to contact me at
704,734.4525. '
i
Respectfully Sub ' 'tted, .
2
Dennis R. Wells
Water Resource D�rector
50'd L9:9 600Z 6 unr 56V9L08616:xej aoanoS �u'Od DMO

DEN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 16, 2009 r yn f
A lu ,7
17
CERTIFIED MAIL: 7007 1490 0004 5537 9827
RETURN RECEIPT REQUESTED JUN 17 2009
Mr. Dennis Wells .
Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, North Carolina 28086-0429
Subject: NOTICE OF VIOLATION
Effluent Toxicity Testing
NPDES Permit No. NCO020737
Kings Mtn. — Pilot Creels WWTP
Cleveland County
Dear Mr. Wells:
DWO-Suit I U V�V of
This is to inform you that a review of your toxicity self -monitoring report form for the month of April
2009 indicates a violation of the toxicity limitation specified in your NPDES Permit.
You should take whatever remedial actions are necessary to eliminate the conditions causing the effluent
toxicity violation(s). Your efforts may include conducting a Toxicity Reduction Evaluation (TRE), a site -
specific study designed to identify the causative agents of effluent toxicity, isolate the sources of toxicity,
evaluate the effectiveness of toxicity control options, and confirm reductions in effluent toxicity. Please be
aware that North Carolina General Statutes provide for assessment of civil penalties for violations of NPDES
permit limitations and requirements.
On April 28, 2009 a second notice of violation letter (February non-compliance) concerning
implementation of the Division's Copper and Zinc Action Level policy was sent to you via certified mail. It
was received by your facility on May 1, 2009. The first letter was sent March 26, 2009 (January non-
compliance).
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
NorthCarol.ina
An Equal Opportunity % Affirmative Action Employer

The second letter contained a written notification deadline of May 28, 2009. We have not received a
response concerning what option the facility wished to pursue in regard to Copper and Zinc limitations.
As stated on page -two of the letter, failure to notify the Division automatically results in reopening the
permit. This office is now recommending.that Copper and Zinc limits be added to the facility's permit.
The reverse side of this Notice contains important information concerning your Whole Effluent Toxicity
Monitoring and Reporting Requirements. Please note appropriate mailing addresses for submitting your
Discharge Monitoring Reports. (DMR.$) and Aquatic Toxicity (AT) Test Forms. We encourage you to review
this information; '1d'it would be helpful to discuss. this situation or possible solutions to resolve effluent toxicity
noncompliance, please contact Mr. John Giorgino with this office at [phone].
Sincerely,
Cindy A. Moore
_.� Supervisor, Aquatic Toxicology Unit
cc: Rob Krebs/ Mooresvi-l-le Regional Office
of n_Le's'le_y/ 1VlooresvillQw_ gionar Office y
Jackie Nowell- point Source Branch
Karen Rust- Point Source Branch
Vanessa Manuel- Point Source Branch
Marshall Hyatt- Water Management Division, USEPA Region IV
Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
No thCarolina
Naturally
An Equal Opportunity 1 Affirmafive Action Employer

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.
John Giorgino 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).
➢ 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 consider submitting your toxicity test
results certified mail, return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
one
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
North Caryyo//l.ina
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: hftp://h2o.enr.state.nc.us/esb/
CttlCl?Lf-i ��
An Equal Opportunity t Affirmative Action Employer

Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
NorthCarolina
Naturallif
An Equal Opportunity t Affirmative Action Employer

Beverly Eaves Perdue
Governor
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
April 28, 2009
CERTIFIED MAIL: 7007 1490 0004 5538 2520
RETURN RECEIPT REQUESTED
Mr. Dennis Wells
Director -
City of Kings Mountain
P.O. Box 429
Kings Mountain, North Carolina 28086-0429
SUBJECT: NOTICE OF VIOLATION
Whole Effluent Toxicity (WET) Testing
Copper and Zinc Action Level Policy
NPDES Permit No. NCO020737
Kings Mountain — Pilot Cr. WWTP
Cleveland County
Dear Mr. Wells:
Dee Freeman
Secretary
� t 4e fi I y"F 7
APR 3 0 2009
T.
M-Surface Water Noil"ac ion
This is to inform you that a review'of your toxicity self -monitoring report form for the month of February 2009 indicates a
violation of the toxicity limitation specified in your NPDES Permit. You should undertake necessary actions to eliminate or
reduce effluent toxicity to acceptable levels.
Previous correspondence was sent to you concerning implementation of the Division's Copper and Zinc Action Level Policy.
The correspondence included a prospective permit limit for copper at 58.0 µg/L. We have now added a prospective
limit for zinc at 497.2 uQ/L. and adiusted the prospective limit for conger to 56.7 ug/L from 58.0 ug/L. We stated that
the trigger for implementing the policy would be two or more WET limit violations, which occur during a toxicity testing
calendar quarter. Please note that the second WET limit violation has occurred and you must provide:
a) Written notification indicating acceptance of the prospective copper and zinc permit limit. Notification is due by May
28, 2009.
OR
b) Written notification indicating your choice of option(s) 1-4 below. Notification is due by May 28, 2009. DWQ approval
of options 1-3 below is not necessary as the Division expects work to rule out copper and zinc as a causative effluent
toxicant to begin immediately upon the second WET permit limit violation that occurred during February 2009.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemet: hftp://h2o.enr.state.nc.us/esb/
NorthCarolina
aturatlil
An Equal Opportunity 1 Affirmative Action Employer

'14
1. Instream measurements of dissolved metal during low flow conditions that demonstrate compliance with the
Action Level standard
2. A revision of the prospective permit limit using improved inputs that in concert with existing or additional
monitoring data demonstrates compliance with the Action Level standard
3. Toxicity Identification Evaluation (TIE) results that definitively rule out copper and zinc as a cause of effluent
toxicity
4. Demonstration by an alternative method approved by the Division and EPA that copper and zinc are not causes
of toxicity
Written notification (a or b above) shall be sent to:
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Please note that if you choose item b) above, you will be given nine months to submit documentation that
eliminates copper and zinc as causative effluent toxicants. Your final report should be comprehensive and
include all data used to support your conclusion. The report is due by January 28, 2010.
Three copies of the final report shall be submftted to:
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Failure to notify DWQ of your acceptance of copper and zinc limits, failure to notify DWQ of your option
selection or failure to make acceptable demonstration to DWQ that copper and zinc are not causative effluent
toxicants within the stated time frames will result in reopening of the NPDES Permit to include a numeric
copper and zinc permit limitations, as appropriate.
If the effluent is toxic, then we expect work to commence immediately with toxic effluent samples. Failure to initiate work with
toxic effluent samples during the study period is unacceptable and will be considered a failure to make acceptable demonstration
as cited above. We recommend a minimum of three separate sampling events during the nine month period to definitively rule
out copper and zinc as causative effluent toxicants.
Additional information regarding the Division's Copper and Zinc Action Level Policy can be found at the following web site -
http://www.esb.enr.state.nc.us/. Click on the Aquatic Toxicology Unit and go to the prompt "AT Downloadable Files" located at
the bottom of the page.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
NorthCarolina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

If you have any questions concerning this correspondence, please contact Ms. Cindy Moore at [phone] or Mr. John Giorgino at
(919) 743- 8441.
Cindy Moore
Supervisor, Aquatic Toxicology Unit
cc: [R06 Krebs- l2 Mooresvilleegi onal-Office
John Lesley -Mooresville Regional Office
Vanessa Manuel -Point Source Branch
Jackie Nowell -Point Source Branch
Marshall Hyatt -Water Management Division, USEPA Region IV, 61 Forsyth St., SW, Atlanta, GA 30303
Central Files
Aquatic Toxicology Unit Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemet http://h2o.enr.state.nc.us/esb/
Nne
orthCarohna
;Vatu,ratlll
An Equal Opportunity 1 Affirmative Action Employer

4
NCDENR-
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 20, 2009
MARILYN SELLERS
CITY OF KINGS MOUNTAIN
PO BOX 429
KINGS MOUNTAIN NC 28086-0429
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Pilot Creek WWTP
Permit Number: NCO020737
Case Number: LV-2009-0040
Cleveland County
Dear Ms. Sellers:
I41A R 2 5 2,909
non
This letter is to acknowledge receipt of check number 64488 in the amount of $583.64 received from you dated
March 16, 2009. This payment satisfies in full the above 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 919-807-6398.
Sincerely,
6CJovtonahWeeden
cc: Central Files
DWQ t oMeM l Regicrrra° Office Supervisor
1617 Mail Service Center, Raleigh, North Carolina27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748 NorthCarol na
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer ����

F,
Beverly Eaves Perdue
Governor
AjZA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
February 16, 2009
CERTIFIED MAIL 70071490 0004 45101742
RETURN RECEIPT REQUESTED
Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Ms. Sellers:
SUBJECT: Notice of Violation and Assessment of Civil
Dee Freeman
Secretary
Penalty for Violations of N.C. General Statute
143-215.1(a)(6) and NPDES Permit No. NCO020737
Kings Mountain Pilot Creek WWTP
Cleveland County
Case No. LV-2009-0040
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of
$583.64 ($500.00 civil penalty + $83.64 enforcement costs) against the City of Kings Mountain.
This assessment is based upon the following facts: A review has been conducted of the self -
monitoring data reported for October 2008. This review has shown the subject facility to be in
violation of the discharge limitations found in NPDES Permit No. NC0020737. The violations are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that the City of Kings Mountain
violated the terms, conditions, or requirements of NPDES Permit No. NCO020737 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, Robert B. Krebs, Surface Water Protection Regional
Supervisor for the Mooresville Region, hereby make the following civil penalty assessment against
the City of Kings Mountain:
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] t Customer Service: 1-877-623-6748 NOrthCaxo11na
Internet: wmv.ncwaterquality.org %���¢y�y���l'/
An Equal Opportunity'\ Affirmative Action Employer— 50% Recycleoil0% Post Consumer paper 6/ y t t L 1

$ 500.00 For 1 of the one (1) violation of G.S. 143-
215.1(a)(6) and NPDES Permit No. NC0020737, by
discharging waste into the waters of the State in
violation of the permit weekly average effluent limit
for cadmium.
$ 500.00 TOTAL CIVIL PENALTY
$ 83.64 Enforcement costs.
$ 583.64 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

F.
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
W.
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:
Ms. Mary Penny Thompson, 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

F, -
operation and/or maintenance problems and you anticipate remedial construction activities then
you may wish to consider gpplyin 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 of the Mooresville Regional Office at 704/663-1699.
2-111
.�51,
(Date) Robert B. Krebs
Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT A
CASE NO. LV-2009-0040
Outfall Date Parameter Reported Value
001 Week ending Cadmium 7.5 µg/L
10/11/08
* Denotes civil penalty assessment
Permit Limit
6.1 µg/L (Weekly average)

F_
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 PENALTY AGAINST ) ADMINISTRATIVE HEARING AND
THE CITY OF KINGS MOUNTAIN ) STIPULATION OF FACTS
PERMIT NO. NCO020737 )
FILE NO. LV-2009-0040
Having been assessed civil penalties totaling $583.64 for violation(s) as set forth in the
assessment document of the Division of Water Quality dated February 16, 2009, 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 , 2009
BY - -
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2009-0040
Assessed Party: The City of Kings Mountain
County: Cleveland
Permit Number: NC0020737
Amount Assessed: $583.64
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission 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-282.1(b) were
wrongfully 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: (use additional pages as necessary)

NORTH CAROLINA DIVISION OF WATER QUALITY
ASSESSMENT FACTORS
Violator: The Cijy of Kings Mountain
Facility: Kings Mountain Pilot Creek WWTP
County: Cleveland
Case Number: LV-2009-0040
Permit Number: NCO020737
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;
The cadmium weekly average concentration of 7.5 µg/L for the week ending October 11,
2008, exceeded the permit limit of 6.1 µg/L.
2) The duration and gravity of the violation;
The cadmium weekly average permit limit was exceeded by 23.0% for the week ending
October 11, 2008. The permittee had cadmium exceedances during September 2008
(daily maximum and weekly average) and all cadmium concentrations reported during
October 2008 were above the detection limit. The permittee had reported < 2.0 µg/L
cadmium concentrations in the effluent from the WWTP at the beginning of September
2008.
3) The effect on ground or surface water quantity or quality or on air quality;
The effect on the receiving stream is unknown as in -stream monitoring of cadmium is not
required by the permit. Cadmium is considered as a. toxic substance to aquatic
organisms and the water quality standard for Class C freshwater is 2.0 µg/L. The Kings
Mountain Pilot Creek WWTP discharges into Buffalo Creek, which is classified as C
waters in the Broad River basin.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved by noncompliance is unknown.
6) Whether the violation was committed willfully or intentionally;
The Division of Water Quality has no evidence that the violations were committed willfully
or intentionally. A review of the influent cadmium concentrations at the WWTP found the
highest concentration was 5.0 µg/L on October 15, 2008.

7)
8)
The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
There have been 14 other CPAs against the City of Kings Mountain for the Pilot Creek
WWTP during the life of the permit with one CPA issued in the past twelve months as
detailed below.
Case Number
Description
LV-2009-0023
$583.64 LV for cadmium. Penalty is within the 30-dayresponse window.
The cost to the State of the enforcement procedures.
The cost to the Mooresville regional Office was $83.64.
zZ-,
Date
RO Supervisor
Division of Water Quality

MONITORING REPORT(MR) VIOLATIONS for: Report Date: 02/09/09 Page: 6 of 16
PERMIT: NC0004685 FACILITY: PPG Industries Fiber Glass Products Inc - PPG - Shelby COUNTY: Cleveland REGION: Mooresville
facility ,mot
Limit Violation
MONITORING OUTFALL/
REPORT PPI LOCATION
PARAMETER
VIOLATION
DATE
FREQUENCY
UNIT OF
MEASURE
LIMIT
CALCULATED <s o
VALUE VIOLATION TYPE
VIOLATION ACTION
10 -2008 001 Effluent
Oil & Grease
10/22/08
Weekly
mg/I
15
17.1 Daily Maximum Exceeded
None
PERMIT: NCO020737
FACILITY: City of Kings Mountain - Pilot Creek WWTP
COUNTY: Cleveland REGION: Mooresville
Limit Violation
MONITORING OUTFALL / VIOLATION
REPORT PPI LOCATION PARAMETER DATE
10 -2008 001 Effluent Cadmium, Total (as Cd) 10/11/08
FREQUENCY
Weekly
UNIT OF
MEASURE
ug/I
LIMIT //
u/
6.1
CALCULATED u
VALUE VIOLATION TYPE
C,•'
7.5 ,�.`f;Weekly Average Exceeded
VIOLATION ACTION
None
PERMIT: NC0004812
FACILITY: Pharr Yarns Inc - Pharr Yarns Industrial WWTP
COUNTY: Gaston REGION: Mooresville
Limit Violation
MONITORING OUTFALL/
REPORT PPI LOCATION
PARAMETER
VIOLATION
DATE
FREQUENCY
UNIT OF
MEASURE
LIMIT
CALCULATED
VALUE VIOLATION TYPE
VIOLATION ACTION
10 -2008 001 Effluent
Coliform, Fecal MF, M-FC
Broth,44.5C
10/01/08
Weekly
#/100ml
400
900 Daily Maximum Exceeded
None
10 -2008 001 Effluent
Coliform, Fecal MF, M-FC
Broth,44.5C
10/16/08
Weekly
#/100ml
400
1,537 Daily Maximum Exceeded
None
10 -2008 001 Effluent
Solids, Total Suspended
10/31/08
' Weekly
Ibs/day
147.7
155 Monthly Average Exceeded
None

NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 12, 2009
CERTIFIED MAIL 70071490 0004 4510 3258
RETURN RECEIPT REQUESTED
Marilyn Sellers, City Manager
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Ms. Sellers:
Natural Resources
Subject: Notice of Violation - Effluent Limitations
Tracking #: NOV-2009-LV-0098
Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County
A review of the November 2008 self -monitoring report for the subject facility revealed a
violation of the following parameter:
Outfall
Parameter
Reported Value
Permit Limit
001
Cadmium
7.0 µg/L
6.1 µg/L (Weekly average)
Dee Freeman
Secretary
Remedial actions, if not already implemented, should be taken to correct any problems. 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.
If you have questions concerning this matter, please do not hesitate to contact Ms. Allocco or me
at 704/663-1699.
Sincerely,
obert B. Krebs
Regional Supervisor
lllrrr Surface Water Protection
cc: Point Source Branch
MA Cleveland County Health Department
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 One
Internet: www.ncwaterquality.org Nor�thC arollina
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycledi10% Post Consumer paper A ghIM4

©�©� vv f�^QG Michael F. Easley, Governor
1 f 3 William G. Ross Jr., Secretary
t ~ crCr a Nt aro D artment of Environment and Natural Resources
r , rya ��'._
Coleen H. Sullins, Director
- Division of Water Quality
RL
January, 200� 2008
Mr. Dennis Wells �! ' E �t., (�+�RO
A N 2 5 2008 1
City of Kings Mountain p Y }p���+ •p fkj�
¢p.C`ti � 3,.�4"t '� profC 4d�f®11^.T�—`-`L!T�i SEC:TiON
Post Office Box 429 ® �...! .,,� :� y>{M,a .:9 A.1, F,
Kings Mountain, North Carolina 28086 __.. x. `'._.
SUBJECT: Authorization to Construct
A to C No. 020737AOI
City of Kings Mountain
Pilot Creek WWTP
Cleveland County
Dear Mr. Wells:
A letter of request for Authorization to Construct was received August 29, 2007, by the
Division, and final plans and specifications for the subject project have been reviewed and found
to be satisfactory. Authorization is hereby granted for the construction of modifications to the
existing 6.0 MGD Wastewater Treatment Plant, with discharge of treated wastewater into
Buffalo Creek in the Broad River Basin.
This authorization results in no increase in design or permitted capacity and is awarded
for the construction of the following specific modifications:
Replacement of surface aerators in basin 1 with 15 floating fine bubble units and
two 1,080 SCFM blowers; replacement of surface aerators in basin 3 with 30
floating fine bubble units and two 2,070 SCFM blowers; and replacement of
surface aerators in basin 4 with 32 floating fine bubble units and two 2,188 SCFM
blowers, in conformity with the project plans, specifications, and other supporting
data subsequently filed and approved by the Department of Environment and
Natural Resources.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of
NPDES Permit No. NCO020737 issued March 31, 2004, and shall be subject to revocation unless
the wastewater treatment facilities are constructed in accordance with the conditions and
limitations specified in Permit No. NC0020737.
One spare blower of each size in addition to the installed blowers must maintained in
good working order on site at all times.
NoAhCarolina
JVgtA(ral1!1
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterauaiitY.om 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/t 0% Post Consumer Paper

Mr. Dennis Wells
January 17, 2008
Page 2
The sludge generated from these treatment facilities must be disposed of in accordance
with G.S. 143-215.1 and in a manner approved by the North Carolina Division of Water Quality.
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, `he-Permittee shall take immediate:corrpctive action, including those as may
be required by this Division, srrh as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Asheville Regional Office, telephone number [phone], shall be notified at
least forty-eight (48) hours in advance of operation of the installed facilities so that an on site
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m.. on Monday through Friday, excluding State
Holidays.
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted facility
has been installed in accordance with the NPDES Permit, this Authorization to Construct and the
approved plans and specifications. Mail the Certification to Cecil G. Madden, Jr., P.E.,
Construction Grants & Loans, DWQ / DENR, 1633 Mail Service Center, Raleigh, NC 27699-
1633.
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to or greater than the classification assigned to the wastewater treatment
facilities by the Certification Commission.
The Permittee must also employ a. certified back-up operator of the appropriate type and
grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each
Class I facility at least weekly and each Class II, III and IV facility at least daily, excluding
weekends and holidays, must properly manage the facility, must document daily operation and
maintenance of the facility, and must comply with all other conditions of TI5A:8G.0202.
A copy of the approved plans and specifications shall be maintained on file by the
Permittee for the life of the facility.
During the construction of the proposed additions/modifications, the permittee shall
continue to properly maintain and operate the existing wastewater treatment facilities at all times,
and in such a manner, as necessary to comply with the effluent limits specified in the NPDES
Permit.
You are reminded that it is mandatory for the project to be constructed in accordance
with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North
Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's
responsibilities shall be in complying with these Acts.

Mr. Dennis Wells
January 17, 2008
Page 3
Prior to entering into any contract(s) for construction, the recipient must have obtained all
applicable permits from the State.
Failure to abi3e by the requirements contained in this Authorization to Construct may
subject the Permittee to an enft�r;ement action by the Division of Water Quality in accordance
with North Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Cecil G. Madden, Jr., P.E. at
telephone number [phone].
Sincerely,
Coleen H. Sullins
cgm
cc: Alvin Moretz, P.E., Moretz Engineering, Kings Mountain
Cleveland County Health Department
Technical Assistance and Certification Unit
Daniel Blaisdell, P.E.
Point Source Branch, NPDES Program
Cecil G. Madden, Jr., P.E.
ATC File

21
SYSTEM PERFORMANCE
CITY OF KINGS MOUNTAIN
PILOT CREEK WPCF
DULY 019 2007 - JUNE 309 2008
SEP 5
2008
TEN
WATER -CUA LiTy-
3,00PCE
SEP - 9

The Pilot Creek wastewater treatment facility is owned and
operated by the City of Kings Mountain. The facility was
established in 1963.
The responsible parties including contact phone numbers are
as follows:
TOWN MAYOR
Mr. Rick Murphrey 704-734-4604
CITY MANAGNER
Mrs. Marilyn Sellers
CITY COUNCIL
Mr. Mike Butler
Mr. Huston Corn
Mr. Rodney Gordon
Mr. Keith Miller
Mr. Jerry Mullinax
Mr. Bean Spears
Mr. Howard Shipp
704-734-4606
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333

WATER RESOURSE DIRECTOR
Mr. Dennis Wells
SUPERINTENDENUORC
Ms. Kim T. Moss
PRETREATMENT COORDINATOR
704-734-4525
704-739-7131
Mr. Brian Ramsey 704-734-4524
FACILITY OPERATORS
Mr. Donald Mark Campbell ( Back-up Operator) 704-739-7131
Mrs. Brenda Kay Barker (Laboratory Technician) 704-739-7131
Ms. Kathy June Moses (Chief Operator) 704-739-7131
Mr. Ricky Parton (Operator I in training) 704-739-7131
Mr. Stacy Lee Hopper (Operator I in training) 704-739-7131

The State of North Carolina regulates the treated wastewater which is
discharged into the Buffalo Creek. The (NPDES) Permit Number for this
facility This facility is located off of highway 74, west of
Kings Mountain.
PROCESS DESCRIPTION
When wastewater is discharged from a home, industry, etc... it travels
through miles of underground lines by gravity or by pumps. This process is
called a Collection System, which is described more in detail in the
Collection's Annual Report.
Once the wastewater enters this facility it contains organic and
inorganic material which consist of seventy five percent (75%) Industrial
waste.
The wastewater is lifted approximately thirty two (32) foot by two (2)
Screw Pumps. Wastewater then travels through a Manual Bar Screen, where
debri is collected and removed for disposal. It then travels through a
Parshall Flume with a twenty four (24) inch throat which includes a staff
gauge and a flow meter all for measuring the incoming flow. As the
wastewater travels through the throat of the Parshall Flume a flow
proportional refrigerated twenty four (24) hour composite sample is
collected for analysis.
The wastewater then enters a Splitter Box that splits the flow into
three (3) Aeration Basin's based on their design flow. Once the fresh
wastewater enters the aeration basin the organic material is consumed by the
microorganism. The aeration basins are equipped with floating diffusers
which supplies oxygen and mixing for the microorganism to survive. The
detention time in these basins are from twenty four (24) to forty eight (48)
hours. This process is called activated sludge.

The activated sludge then enters the center well of a circular clarifier,
which is where the microorganism settle at the bottom to digest the organic
material that they consumed in the aeration basin. The detention time in
these clarifiers are approximately two (2) to four (4) hours. As the activated
sludge settles in the clarifier's, a portion of it is either returned to the head of
the aeration basin (RAS) or wasted (WAS) to the aerobic holding tank for
disposal by pumps.
As the treated wastewater leaves the clarifier's, it then enters a
Chlorine Contact Basin where Chlorine Gas is injected to kill the disease
causing bacteria before leaving the facility. These contact chambers are
equipped with baffles (walls) to provide enough contact time. The flow
exit's these chambers over a rectangular weir or a V-Notch weir, which has
a staff gauge and a flow meter that sends a signal to a totalizer.
As the three (3) effluent flows combine into a manhole, Sulfur
Dioxide Gas is injected to remove the residual chlorine. The flow continues
to travel to the plants effluent flow proportional twenty four (24) hour
refrigerated composite sampler where a sample is collected for laboratory
analysis.
This facility is also equipped with a waste pump station that has two
(2) grinder pumps that conveys the floatable solids from the clarifiers back
to the head of the Influent.
Also included is a wash water pump station that pumps treated
wastewater to the Belt Filter press which is used to operate our 2.2 meter
Klamp Press. This Klamp Press is used to dewater the waste activated
sludge. This press produces a dry sludge cake of approximately 15 to 18%.
A dry polymer is used in the polymer system that mixes with the waste
sludge to form a floc so the water can drain through the pores in the belts.
The disposal process also includes two (2) aerobic holding tanks
which are gravity feed to the disposal sludge pump station. These pumps
convey the waste sludge to the belt filter press for operation.
Once the dry cake leaves the belt press, it travels up a conveyor belt,
through a hopper, into a tandem truck and is hauled to the Cleveland County
Landfill for final disposal.

VIOLATIONS OR DEFICIENCIES
FOR
JULY 019 2007 - JUNE 309 2008
MONTH/'YEAR RESULTS
JULY 2007 NONE
AUGUST 2007 NONE
SEPTEMBER 2007
NONE
OCTOBER 2007
NONE
NOVEMBER 2007
NONE
DECEMBER 2007
NONE
JANUARY 2008
NONE
FEBRUARY 2008
NONE
MARCH 2O08
NONE
APRIL 2008
NONE
MAY 2008
NONE
JUNE 2008
NONE

VIOLATIONS/DEFICIENCIES
FOR
JULY 019 2007 — JUNE 309 2008
During this period there were no violations issued for monitoring,
reporting, illegal bypass, or sanitary overflows from this facility.
NOTIFICATION
This Annual Report can be reviewed on the internet. If there are any
questions concerning this report, please feel free to contact the Water
Resource Director or the Superintendent/ORC.

CERTIFICATION STATEMENT
I certify that this report is accurate to the best of my knowledge.
SUPERINTENDENUORC
' SEP 5 2008 k
DPf'R - WATER QUALITY �

�WAT�RP
�c
>_ � e —I
o iii�-,;�
June 25, 2008
Mr. Dennis Wells
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Dear Mr Wells:
Michael F. Easley, Governor �14
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleco Sullins. Director
Division of Water Quality
Subject: Compliance Evaluation Inspection
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on June 24, 2008 by Mr. John Lesley of this Office. Whole
effluent samples were collected for use in a chronic Ceriodaphnia dubia pass/fail toxicity test.
Toxicity test results will be forwarded under separate cover when available. 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 Mr. Lesley or me at [phone].
Sincerely,
for Robert B. Krebs
Surface Water Protection
Regional Supervisor
Enclosure
cc: Central Files
Cleveland County Health Department
JL
T,orthCarolina
Naturally
N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

United States Environmental Protection Agency
Form Approved.
r
E^� Washington, D.C. 20460
r
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 15I 31 NCO020737 Ill 121 08/06/24 117 18I CI 191 SI 20III
Remarks
I 16
211 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA -------------------- ------ Reserved --------------- ------
67 I 3.0 169 701,1 71 I D I 72 NI 73 L _j 74 75I 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)
10:30 AM 08/06/24
04/05/01
Pilot Creek WWTP
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
03:00 PM 08/06/24
08/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Dennis Wells/Director/704-734-4525 /
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Dennis Wells,PO Box 429 Kings Mountain NC 28086//704-734-4525/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N 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
John E Lesley MRO WQ//704-663-1699 Ext.2198/
L.Signature of Management Q A vie er Agency/Office/Phone and Fax Numbers
1 Wren MRO WQ//704-663-1699 Ext.2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NCO020737 I11 12I 08/06/24 I17 18ICI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
No violations have been reported during the period April 2007 through March 2008.
The facility has been granted a variance of 15A NCAC 21-1.0124 (Reliability) that requires 24-hour staffing by
a certified operator. Part of the condition of the variance is that the RAS line, and the aeration system (at the
time of the variance the facility had surface aeration) was to be monitored by telemetry. This inspection
found that the diffused air system and RAS pumps 1 and 3 are not connected to a telemetry system. The
telemetry system is connected to standby power generator (cannot operate diffused air system), high water
at screw pumps, chlorine leak detection, sulfur dioxide leak detection, and the security system.
Page # 2

Permit: NCO020737
Inspection Date: 06/24/2008
owner - Facility: Pilot Creek VWVfP
Inspection Type: Compliance Evaluation
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Is the facility as described in the permit?
# 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?
Comment: Special Condition: The facility has an approved Industrial Pretreatment
Program.
The WWTP has been granted a variance of 15A NCAC 21-1.0124 that requires 24-hour
staffing of the facility by certified operators (see Summary: Page 2 above).
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
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?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
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?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
■000
■nnn
■nnn
■nnn
■nnn
■nnn
Page # 3

Permit: NCO020737
Inspection Date: 06/24/2008
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Record Keeping
Comment: Variance granted by Division June 24, 2004 to the 24-hour staffing rule
(See above).
Records and reports were well organized, readily accessible, and up-to-date.
14
Laboratory
Are field parameters performed by certified personnel or laboratory? ■ ❑ Q
Are all other parameters(excluding field parameters) performed by a certified lab? ®❑ ❑ 0
# Is the facility using a contract lab? ■
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ 0 ❑ 0
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ■ 0 n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ■ 0 ❑ n
Comment: The on -site laboratory (Certificate No. 222) conducts conventional and field
parameter testing. PAR Labs (Certificate No. 20) conducts metals analyses. ETT
Environmental performs the toxicity testing. Laboratory Instrument Service calibrated
and standardized all laboratory instruments on 5/27/08.
Yes
Operations & Maintenance
No
NA
NE
Is the plant generally clean with acceptable housekeeping? ■
n
n
n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■
n
n
n
Judge, and other that are applicable?
Comment: A comprehensive process control program is used at the WVVfP.
Influent Sampling Yes
No
NA
NE
# Is composite sampling flow proportional? ®
El
❑
01
Is sample collected above side streams?
■
n
n
n
Is proper volume collected?
■
n
n
n
■
❑
n
n
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
n
n
n
Is sampling performed according to the permit?
■
n
n
n
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
■
fl
0
Is sample collected below all treatment units?
■
n
n
n
■
n
n
n
Is proper volume collected?
n
n
n
Is the tubing clean?
Page # 4

Permit: NCO020737 Owner - Facility: Pilot Creek VW TP
Inspection Date: 06/24/2008 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ 0
00
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ ❑ Q
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ ❑ ❑ fl
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? ■ 0 0 n
Is flow meter calibrated annually? ■ 0 0 0
Is the flow meter operational? ■ (_1
(If units are separated) Does the chart recorder match the flow meter? ■ 0
Comment: The flow meter was last calibrated by Laboratory Instrument Service on
5/27/08.
Standby Power Yes No NA NE
Is automatically activated standby power available? ■ 0 0 ❑
Is the generator tested by interrupting primary power source? ■ Cl ❑ Q
Is the generator tested under load? ■ ❑ ❑ ❑
Was generator tested & operational during the inspection? ❑ ❑ n ■
Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ■ Q ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 0 ❑ ❑
Is the generator fuel level monitored? ■ 0 Q ❑
Comment: The on -site generator will not operate the blowers for the diffused air
aeration system.
Carolina Power Solutions services the generator semi annually.
Royster Oil is the fuel vendor for the facility.
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? ■ 0 Q ❑
Is the wet well free of excessive grease? ■ ❑ Q Q
Are all pumps present? ■ n Cl n
Are all pumps operable? ■ fl n ❑
Are float controls operable? ■ ❑ ❑ 0
Page # 5

Permit: NC0020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 06/24/2008 Inspection Type: Compliance Evaluation
Pump Station - Influent
Yes
No
NA NE
Is SCADA telemetry available and operational?
■
n
n Cl
Is audible and visual alarm available and operational?
■
Q
rl Q
Comment:
Bar Screens
Yes
No
NA NE
Type of bar screen
a.Manual
■
b.Mechanical
■
n
n n
Are the bars adequately screening debris?
■
n
n Cl
Is the screen free of excessive debris?
Is disposal of screening in compliance?
■
0
n n
Is the unit in good condition?
■
Q
Comment: The facility utilizes manual bar screen. The manual bar screen could
become clogged with debris (no night shift operators) and result in high water conditions
or possible overflow/bypass of facility. A manual bar screen as the only screening
option at a facility of this size in not recommended.
Yes
No
NA NE
Type of grit removal
n
a.Manual
n
b.Mechanical
n
n
■
n
Is the grit free of excessive organic matter?
n
n
■
n
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Q
❑
■
Comment: There is no grit removal process at this facility.
Aeration Basins
Yes
No
NA
NE
Ext.
Air
Mode of operation
Diffused
Type of aeration system
■
❑
Is the basin free of dead spots?
n
n
■
n
Are surface aerators and mixers operational?
■
❑
❑
❑
Are the diffusers operational?
Is the foam the proper color for the treatment process?
■
n
n
n
Does the foam cover less than 25% of the basin's surface?
■
Cl
n
n
Page # 6
11

Permit: NCO020737
Inspection Date: 06124/2008
Aeration Basins
Is the DO level acceptable?
Owner - Facility: Pilot Creek WWTP
Inspection Type: Compliance Evaluation
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Comment: The facility has recently installed diffused air aeration. A good aeration
pattern was observed on the basins, however, basin #3 has a space of approximately
25-30 feet from the last row of diffusers to the wall of the basin. Some settling of sludge
may be occurring in this area. It is recommended that the facility staff monitor basin #3
for potential problems such as sludge accumumlation. Aeration basin #2 is out of
service and not available for use.
The diffused air system is not connected to the telemetry system. Standby power is not
available for the blowers.
The aeration basins are constructed so that the water level is approximately 4-6 feet
below ground level: The basins have no safety railing.
Secondary Clarifier
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?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Comment: Clarifier #1 has no scum removal device and the weirs are rusted and
uneven. Clarifiers #3 and #4 appear to be in good condition. Clarifier #2 is out of
service.
Pumps-RASMAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: RAS pumps 1 and 3 are not connected to the telemetry system.
Aerobic Digester
Is the capacity adequate?
■nnn
Yes No NA NE
.nnn
■nnn
n■nn
■nnn
n■nn
■000
■nnn
nsnn
■pnn
®nnn
■000
Yes
No
NA
NE
■D0[1
■nnn
■nnn
Yes
No
NA
NE
■nnn
Page # 7

Permit: NC0020737
Inspection Date: 06/24/2008
Aerobic Digester
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment:
Solids Handling Equipment
Is the equipment operational?
Is the chemical feed equipment operational?
Owner -Facility: Pilot Creek VWVfP
Inspection Type: Compliance Evaluation
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Comment: The polymer mixer was out of service for repair and the dewatering system
was shutdown at the time of this inspection.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment: All information in the Risk Management Plan was still current.
The chlorine leak detection equipment is connected to a telemetry system.
Type of system ?
Yes No NA NE
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
■nnn
1000-0005-8965
Gas
Page # 8
11

PF
Permit: NC0020737
Inspection Date: 06/24/2008
Owner - Facility: Pilot Creek WVVfP
Inspection Type: Compliance Evaluation
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Comment: The S02 leak detector is connected to a telemetry system.
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
00■O
0
Page # 9

Michael F. Easley, Governor
William G. Ross Jr.. Secretary
North Carolina Department of Environment and N�V tt :ql esources
I taB�1Hl1'l�Je�lJaa `dam W
August 24, 2007
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
PO Box 429
Kings Mountain, North Carolina 28086
SUBJECT: Acknowledgement of Request for an
Authorization to Construct
City of Kings Mountain
Pilot Creek WWT.P
Diffuser Installation
NPDES Permit No. NCO020737
Dear Mr. Wells:
The Construction Grants and Loans Section received your request for an Authorization to
Construct and the supporting documentation on August 21, 2007. We will notify you and your
engineer upon completion of our review. Your project has been assigned to Michelle McKay,
E.I. She can be reached at [phone].
If you have any questions concerning this matter, please contact me at [phone].
Sincerely, ; 3
Cecil'G. Madden, Jr., P.E.,(-Supervisor
Construction Grants and Loans Section
Design Management Unit
AR/dr
cc: Alvin B._Moretz, P.E. — Moretz Engineering, Kings Mountain
�'Q�ticirt°allcllt�iOf fs c
WQ Central Files
Michelle McKay, E.I.
Anita Reed, E.I.
ATC Files
Construction Grants and Loans Section
1633 Mail Service Center Raleigh NC 27699-1633
Phone: [phone] / FAX: [phone] / Internet: wAv,nccgl.net
Nne
o thCar©lina
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AUG 2 8 2007
SYSTEM PERFORMANCE
ANNUAL REPORT
FOR
CITY OF KINGS MOUNTAIN
PILOT CREEK WPCF
JULY 019 2006 - JUNE 309 2007
i0j'L
NOV ) p 2,n7
NC DENR fop�j,)
DWQ-Surfac"
p 'u'
t'Y'c

. The Pilot Creek wastewater treatment facility is owned and
operated by the City of Kings Mountain. The facility was
established in 1963.
The responsible parties including contact phone numbers are
as follows:
TOWN MAYOR
Mr. Rick Murphrey 704-734-4604
CITY MANAGNER
Mrs. Marilyn Sellers
CITY COUNCIL
Mr. Mike Butler
Mr. Huston Corn
Mr. Rodney Gordon
Mr. Keith Miller
Mr. Jerry Mullinax
Mr. Dean Spears
Mr. Howard Shipp
704-734-4606
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333
704-734-0333

a
WATER RESOURSE DIRECTOR
Mr. Dennis Wells
SUPERINTENDENUORC
Ms. Kim T. Moss
PRETREATMENT COORDINATOR
704-734-4525
704-739-7131
Mr. Brian Ramsey 704-734-4524
FACILITY OPERATORS
Mr. Donald Mark Campbell ( Back-up Operator) 704-739-7131
Mrs. Brenda Kay Barker (Laboratory Technician) 704-739-7131
Ms. Kathy June Moses (Plant Operator) 704-739-7131
Mr. William Mark McKenzie (Plant Operator) 704-739-7131

The State of North Carolina regulates the treated wastewater which is
discharged into the Buffalo Creek. The (NPDES) Permit Number for this
facility is'`kT-@-'0®'� This facility is located off of highway 74, west of
Kings ounta'
PROCESS DESCRIPTION
When wastewater is discharged from a home, industry, etc... it travels
through miles of underground lines by gravity or by pumps. This process is
called a Collection System, which is described more in detail in the
Collection's Annual Report.
Once the wastewater enters this facility it contains organic and
inorganic material which consist of seventy five percent (75%) Industrial
waste.
The wastewater is lifted approximately thirty two (32) foot by two (2)
Screw Pumps. Wastewater then travels through a Manual Bar Screen, where
debri is collected and removed for disposal. It then travels through a
Parshall Flume with a twenty four (24) inch throat which includes a staff
gauge and a flow meter all for measuring the incoming flow. As the
wastewater travels through the throat of the Parshall Flume a flow
proportional refrigerated twenty four (24) hour composite sample is
collected for analysis.
The wastewater then enters a Splitter Box that splits the flow into
three (3) Aeration Basin's based on their design flow. Once the fresh
wastewater enters the aeration basin the organic material is consumed by the
microorganism. The aeration basins are equipped with floating aerators and
mixers which supplies oxygen and mixing for the microorganism to survive.
The detention time in these basins are from twenty four (24) to forty eight
(48) hours. This process is called activated sludge.

i
The activated sludge then enters the center well of a circular clarifier,
which is where the microorganism settle at the bottom to digest the organic
material that they consumed in the aeration basin. The detention time in
these clarifiers are approximately two (2) to four (4) hours. As the activated
sludge settles in the clarifier's, a portion of it is either returned to the head of
the aeration basin (RAS) or wasted (WAS) to the aerobic holding tank for
disposal by pumps.
As the treated wastewater leaves the clarifier's, it then enters a
Chlorine Contact Basin where Chlorine Gas is injected to kill the disease
causing bacteria before leaving the facility. These contact chambers are
equipped with baffles (walls) to provide enough contact time. The flow
exit's these chambers over a rectangular weir or a V-Notch weir, which has
a staff gauge and a flow meter that sends a signal to a totalizer.
As the three (3) effluent flows combine into a manhole, Sulfur
Dioxide Gas is injected to remove the residual chlorine. The flow continues
to travel to the plants effluent flow proportional twenty four (24) hour
refrigerated composite sampler where a sample is collected for laboratory
analysis.
This facility is also equipped with a waste pump station that has two
(2) grinder pumps that conveys the floatable solids from the clarifiers back
to the head of the Influent.
Also included is a wash water pump station that pulls treated
wastewater from the chlorine contact chamber to the Belt Filter press which
is used to operate our 2.2 meter Klamp Press. This Klamp Press is used to
dewater the waste activated sludge. This press produces a dry sludge cake
of approximately 15 to 18%. A dry polymer is used in the polymer system
that mixes with the waste sludge to form a floc so the water can drain
through the pores in the belts.
The disposal process also includes two (2) aerobic holding tanks
which are gravity feed to the disposal sludge pump station. These pumps
convey the waste sludge to the belt filter press for operation.
Once the dry cake leaves the belt press, it travels up a conveyor belt,
through a hopper and into a tandem truck and hauled to the Cleveland
County Landfill for final disposal.

VIOLATIONS OR DEFICIENCIES
FOR
JULY 019 2006 - JUNE 309 2007
MONTH/YEAR RESULTS
JULY 2006 Chronic Toxicity
AUGUST 2006 Chronic Toxicity
SEPTEMBER 2006
NONE
OCTOBER 2006
NONE
NOVEMBER 2006
NONE
DECEMBER 2006
NONE
JANUARY 2007
NONE
FEBRUARY 2007
NONE
MARCH 2O07
NONE
APRIL 2007
NONE
MAY 2007
NONE
J UNE 2007
NONE

VIOLATIONS/DEFICIENCIES
FOR
DULY 019 2006 — JUNE 309 2007
This facility exceeded the permitted limits for Chronic Toxicity
during this period on two (2) occasions.
During this period there were no violations issued for monitoring,
reporting, illegal bypass, or sanitary overflows from this facility.
The Chronic Toxicity Violations that occurred during this period had
no impact on the receiving stream.
The parameter ZINC was determined to be the cause for our Toxicity
violations.
NOTIFICATION
This Annual Report can be reviewed on the internet. If there are any
questions concerning this report, please feel free to contact the Water
Resource Director or the Superintendent/ORC.

CERTIFICATION STATEMENT
I certify that this report is accurate to the best of my knowledge.
SUPERINTENDENUORC

PP f
City of Kings Mountain
Pilot Creek WPCF
RT 6, 200 Potts Creek Road
Kings Mountain, NC 28086
June 8, 2007
Ms. Marcia Allocco
Division of Water Quality
610 East Center. Ave. Suite 301
Mooresville, NC 28115
Dear Ms. Allocco:
AND NATU7? A' r ,`.OGU+R0ES
HOORE ' L P r r.; t3s
.ass �:�."4
JUN 1 i 2007 °
The following information is in reference to the Compliance Evaluation
Inspection performed by Mr. Wes Bell on May 15, 2007.
COMMENT: Only'one Effliient`Nickel value°(2'/month required) was reported
for Deceinlier' 2006"
RESPONSE: I apologize'for this violation: I/we cari nbt determine how'this
happen: I know without a doubt; this was'not
intentional. I can only say that it was a honest mistake that Uwe
overlooked. To "my knowledge this is the first time this. has happen
and, I/we will strive to keep it from happening again. Once again
I apologize for this violation:
COMMENT: The facility was collecting time -based composite samples
constant time/ constant volume):
RESPONSE: This problem was resolved on May 22, 2007. New composite
samplers were received and installed on March 06, 2007. These
samplers were not programmed exactly the way they should have
been. Therefore, T contacted Mr., John Lassiter with Laboratory
Instrument Service which performs, our flow meter calibrations to
come outand re -program our' new samplers:= ' The samplers were
collecting at 60 pulses/sample'and the'corrected'calculations based
on our flow data indicated that the samplers should have be
collecting ar40 pulses/sample.
I have attached the work. sheet which includes.these calculations.
I apologize for this error.
T.111,11

"Ir"
Laboratory Instrument Service
403 Campbell Avenue
Landrum, South Carolina 29356-1837
[phone]
Pilot Creek WWTP
City of Kings Mountain, NC
,7 l,n
L es4e,i_
Setup calculations to use Sigma 900 samplers in flow proportional mode.
Average daily flow:
Maximum daily flow:
Minimum sample size:
Maximum sample interval
Flow meter 100% :
Sampler input 100%
2.25 million gallons
6.00 million gallons
125 ml.
60 minutes
15 MGD
10 pulses/minute
INFLUENT SAMPLER
Influent sample container: 18 liters (5 gallons)
Influent sample size : 125 ml
( 6MGD X 10 pulses/ min X 1440 mint day)
15MGD 40 pulses/ sample
( (18000 ml l day) )
(125 ml l sample )
EFFLUENT SAMPLER
Effluent sample container: 21.6 liters (6 gallons)
Effluent sample size : 150 ml
( 6MGD X 10 pulses/min X 1440 mint day )
15MG0 ( (21600m1/day) =40 pulses/ sample
)
(150 ml /sample )
May 22, 2007

PpIrr; ampling at Pilot Creek
Subject: Flow proportional sampling at Pilot Creek
From: John Lassiter<[e-mail]>
Date: Fri, 15 Jun 2007 10:05:01 -0400
To: Wes Bell <[e-mail]>
Hi Wes -
Looked over my figures for the flow -proportional sampling at Pilot Creek.
Each pulse represents 1041.67 gallons
Multiply that by 40 pulses per sample and you find that a sample is taken every 41,666 gallons.
It would be simple to have each sample represent fewer gallons.
Presently, samples are taken every 40 pulses. By taking a sample for every 20 pulses, for example,
each sample would represent 20, 833 gallons. This would fill your sample container after 3 million
gallons.
Regards,
John Lassiter
Laboratory Instrument Service
403 Campbell Avenue
Landrum, SC 29356
864-457-6377
864-457-4878
1 of 1 6/18/2007 2:31 PM

HCDENR
North Carolina Department of Environment ako 'Natuea( Resources,.
Division of Water
Michael F. Easley, Governor t William G.�Ross; Jr.I Secretary
Cole°en H. Sullins, Director
June 8, 2007 JUN 7 r,
Mr. Dennis Wells
City of Kings Mountain
P.O. Box 429 q
Kings Mountain NC 28086
SUBJECT: Advance Notice of Renewal Application Requirements
Permit NCO020737
Pilot Creek WWTP
Dear Permittee:
Your NPDES permit for a municipally owned/operated WWTP expires on August 31, 2008. This notice is
being sent to explain the requirements for your permit renewal application.
You are receiving this advance notice because your facility has a permitted flow at or above 1
MGD, or the facility receives industrial [pretreatment] wastewater. If either of these criteria no
longer applies, contact the NPDES Unit before submitting a renewal application.
Federal (40 CFR 122) and state (15A NCAC 2H.0105(e)) regulations require that permit renewal
applications be filed at least 180 days prior to expiration of the current permit. Your renewal application is
due to the Division postmarked no later than March 4, 2008. Failure to apply for renewal by the
appropriate deadline may result in a civil penalty assessment or other enforcement activity at the discretion
of the Director.
The U.S. EPA revised and expanded the application requirements for municipal permits, effective August 1,
2001. EPA form 2A is attached to this Notice, and must be used for your permit renewal application. The
new application requirements mandate additional effluent testing:
1. Conduct three Priority Pollutant Analyses (PPAs) and submit results with your renewal
application. Collect samples for the PPAs in conjunction with sampling for your current
quarterly toxicity test. The new PPA requirements differ from previous versions. Each PPA
must include:
➢ Analyses for all total recoverable metals listed in Part D of form 2A. This includes metals
that are not normally monitored through your NPDES permit.
➢ Analyses for total phenolic compounds and hardness.
➢ Analyses for all of the volatile organic compounds listed in Part D.
➢ Analyses for all of the acid -extractable compounds listed in Part D.
➢ Analyses for all base -neutral compounds listed in Part D.
➢ Analyses for Total Mercury must be performed using EPA Method 1631.
2. Conduct four toxicity tests for an organism other than Ceriodaphnia and submit results with
your renewal application. The tests should be conducted quarterly, with samples collected on the
same day as your current toxicity test. Call the Aquatic Toxicology Unit at [phone] for
guidance in conducting the additional tests.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One 1
512 North Salisbury Street, Raleigh, North Carolina 27604 NOrthCarollna
Phone: [phone] / FAX [phone] / Internet: h2o.enr.state.nc.us Naturally
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Renewal Notice for Permit NC0020737
Cleveland County
Page 2
The pollutant and toxicity scans described above must accompany your permit renewal application,
or any major permit modification request. The Division cannot draft your permit without the additional
data. Any data submitted cannot be over 41/2 years old, and must account for seasonal variation
(samples cannot be collected during the same season each year if collected over multiple years).
PLEASE NOTE: If your permit already contains a requirement for an annual effluent pollutant
scan, additional scans are not required [provided you have conducted at least 3 scans prior to submitting
your application].
If any wastewater discharge will occur after the current permit expires, this NPDES permit must be
renewed. Discharge of wastewater without a valid permit would violate Federal and North Carolina law.
Unpermitted discharges of wastewater could result in assessment of civil penalties of up to $25,000 per day.
Use the checklist below to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If all wastewater discharge has ceased at this facility and
you wish to rescind this permit, please contact me. My telephone number, fax number and e-mail address
are listed at the bottom of the previous page.
Sincerely,
l
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
NPDES File
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 EPA Form 2A application (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 the
Authorized Representative (see Part II.B.11.b of the existing NPDES permit).
o 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. This information can be included in the cover letter.
Send the completed renewal package to:
Mrs. Frances Candelaria
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

Michael F. Easley, GovV," l7V44
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
May 22, 2007
CERTIFIED MAID
RETURN RECEIPT REQUESTED
Mr. Dennis Wells, Water Resources Director
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject:
Dear Mr. Wells:
7006 2760 0001 8493 8023
Notice of Violation
Tracking #: NOV-2007-PC-0352
Compliance Evaluation Inspection
Kings Mountain Pilot Creek WWTP
NPDES Permit No. NCO020737
Cleveland County, NC
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on May 15, 2007 by Mr. Wes Bell of this Office. Please advise
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) due to a monitoring violation
(effluent nickel/December 2006) and the facility's failures to collect flow proportional composite
samples in violation of the subject NPDES Permit and North Carolina General Statute (G.S.)
143-215.1, as detailed in the Influent Sampling and Effluent Sampling sections of the attached
report. Pursuant to 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 G.S.
143-215.1.
It is requested that a written response be submitted to this Office by June 12, 2007
addressing the above -noted violations. In responding, please address your comments to the
attention of Ms. Marcia Allocco.
0*
NCDENR
Mooresville Regional Office Division of Water Quality Phone [phone]
Internet: www.ncwatergtiality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
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orehCarolina
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Customer Service
1-877-623-6748

Mr. Dennis Wells
Page Two
May 22, 2007
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Mr. Bell or me at [phone].
Sincerely,
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure
cc: Cleveland County Health Department

t
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 U ul 2 15I 3I NCO020737 111 121 07/05/15 117 181 rt 191 GI 201I
LJ tJ L! J
Remarks
21111111111111111111111111111111111111111111111U6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------------------------- Reserved ----------------------
67I 1.5 169 701 31 71 I N I 72I N I 731 I 174 751 I I I I I I 180
1
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)
Pilot Creek WWTP
09:30 AM 07/05/15
04/05/01
Exit Time/Date
Permit Expiration Date
200 Potts Creek Rd
Kings Mountain NC 28086
01:03 PM 07/05/15
08/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kim Teresa Moss/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Dennis We11s,P0 Box 429 Kings Mountain NC 28086//704-734-9525/ ContactedNo
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 Find in /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
Wesley N Bell lMRO WQ//704-663-169.9 Ext.231/ ;r
§janature of Management Q-A Reviewer Agency/Office/Phone and Fax Numbers Date
MaJ."'. MRO WQ//704-235-2204/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NCO020737 I11 12I 07/05/15 I17 18I_'
LJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page # 2

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 05/15/2007 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?
.0
n
■
n
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
❑
❑
■
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
■
❑
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
In
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
❑
❑
❑
Is the chain -of -custody complete?
■
❑
n
Cl
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
❑
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
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
❑
Is a copy of the current NPDES permit available on site?
■
❑
n
n
Facility has copy of previous year's Annual Report on file for review?
■
n
n
n
Page # 3

Permit: NCO020737 Owner - Facility: Pilot Creek VWVTP
Inspection Date: 05/15/2007 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Comment: DMRs were reviewed for the period June 06 through February 07. Effluent
chronic toxicity violations were reported in July 06 and August 06. The Division has
separately addressed these violations by issuances of NOVs. The facility staff must
ensure all "<" values are properly calculated to determine the monthly average values.
In addition, the facility staff must ensure all composite samples are collected during a
24-hour time period.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
0
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
■
0
Q
Q
# Is the facility using a contract lab?
■
❑
0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
0
Q
O
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0:2 degrees?
❑
❑
Q
■
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Q
Q
Q
■
Comment: Influent and effluent analyses are performed by the on -site laboratory
(certification #222). Par Labs (certification #20) has also been contracted to provide
analytical support.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
❑
■
00
Is sample collected above side streams?
■
Q
❑
0
Is proper volume collected?
■
❑
Is the tubing clean?
❑
■
Q
0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
Is sampling performed according to the permit?
E!
■
Q
❑
Comment: The facility was collecting time -based composite samples (constant
time/constant volume). In addition, the sampler tubing needed to be either cleaned or
replaced.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
■
❑
❑
Is sample collected below all treatment units?
■
❑
0
13
Is proper volume collected?
■
❑
Q
Q
Is the tubing clean?
■
❑
❑
Q
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
11
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
0
■
❑
I]
Page # 4

Permit: NCO020737
Inspection Date: 05/15/2007
Owner - Facility: Pilot Creek WVVTP
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: The facility was collecting time -based composite samples (constant
time/constant volume). Only one effluent nickel value (2/m required) was reported for
December 06.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ fl Q Q
Comment:
Operations &a Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ Q 0
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment: The facility appeared to be properly operated and well maintained. The
facility staff incorporate a comprehensive process control program. The Division issued
a conditional exemption to the 24-hour staffing requirement on 6/29/04.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
fl
n
n
Is the wet well free of excessive grease?
■
❑
Q
0
Are all pumps present?
®
n
n
n
Are all pumps operable?
■
❑
❑
❑
Are float controls operable?
■
n
n
Is SCADA telemetry available and operational?
■
n
n
n
Is audible and visual alarm available and operational?
❑
fl
■
011
Comment: The facility utilizes two screw pumps rated at 7.5 MGD and 8.0 MGD.
o__ L-------.
Yes
No
NA
NE
Type of bar screen
a.Manual
■
b.Mechanical
❑
Are the bars adequately screening debris?
■
Q
n
n
Is the screen free of excessive debris?
■
n
n
Is disposal of screening in compliance?
®
0
❑
f_I
Is the unit in good condition?
■
n
❑
n
Comment:
Aeration Basins
Yes
No
NA
NE
Page # 5

Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 05/15/2007 Inspection Type: Compliance Evaluation
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?
■
❑
❑
❑
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?
❑
❑
❑
Is the DO level acceptable?
■
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
■
❑
❑
❑
Comment: The facility utilizes three aeration basins. Each aeration basin is equipped
with operational aerators and mixers.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
Cl
❑
Are weirs level?
■
❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
■
❑
❑
0
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?
■
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately '/< of the sidewall depth)
■
Cl
❑
❑
Comment: The facility utilizes three clarifiers. Although no short-circuiting was
observed, the deteriorated weirs and leakages between the weir plate and concrete
structure should be repaired within the near future.
Disinfection -Gas
Yes
No
NA
NE
Are cylinders secured adequately?
■
❑
❑
❑
Are cylinders protected from direct sunlight?
■
❑
❑
❑
Is there adequate reserve supply of disinfectant?
■
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
■
Page # 6

Permit: NCO020737
Inspection Date: 05/15/2007
Owner - Facility: Pilot Creek VVVVfP
Inspection Type: Compliance Evaluation
Disinfection -Gas
Yes
No
NA
NE
Is the contact chamber free of growth, or sludge buildup?
■
n
n
n
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
■
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
■
n
n
n
If yes, then is there a Risk Management Plan on site?
■
n
n
n
If yes, then what is the EPA twelve digit ID Number? (1000- - )
1000-0005-8965
If yes, then when was the RMP last updated?
06/18/2004
Comment:
De -chlorination
Yes
No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
■
❑
❑
❑
Is storage appropriate for cylinders?
■
❑
n
❑
# Is de -chlorination substance stored away from chlorine containers?
■
n
n
❑
Comment:
Are the tablets the proper size and type?
❑
❑
■
❑
Are tablet de -chlorinators operational?
❑
❑
■
❑
Number of tubes in use?
Comment:
Flow Measurement- Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
n
❑
❑
Is the flow meter operational?
■
n
n
n
(if units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment: The flow meters are calibrated once per year and were last calibrated on
10/23/06 by Laboratory Instrumentation Service.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
■
n
❑
❑
Is the mixing adequate?
■
❑
❑
❑
Is the site free of excessive foaming in the tank?
■
n
n
n
# Is the odor acceptable?
■
❑
❑
❑
# Is tankage available for properly waste sludge?
■
❑
❑
❑
Page # 7

Permit: NC0020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 05/15/2007 Inspection Type: Compliance Evaluation
Aerobic Digester
Yes
No
NA
NE
Comment: The facility utilizes an aerobic digester and sludge holding tank.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
■
❑
Q
Is the chemical feed equipment operational?
■
n
n
n
Is storage adequate?
■
11
n
n
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
Cl
■
Is the site free of sludge buildup on belts and/or rollers of filter press?
0
Q
0
■
Is the site free of excessive moisture in belt filter press sludge cake?
n
n
Cl
■
The facility has an approved sludge management plan?
■
n
n
n
Comment: The facility was not operating the belt press at the time of the inspection
Standby Power Yes No NA NE
Is automatically activated standby power available? ■ Q
Is the generator tested by interrupting primary power source? ■ 0 Cl
Is the generator tested under load? ■ 0 ❑ El
Was generator tested & operational during the inspection? rl ❑ Cl ■
Do the generator(s) have adequate capacity to operate the entire wastewater site? rl ■ 0 fl
Is there an emergency agreement with a fuel vendor for extended run on back-up power? ■
Is the generator fuel level monitored? ■ ❑
Comment: The generator is tested weekly and put under load every other month. The
generator does not automatically power the aerators and sludge return pumps. The
sludge return pumps have to be manually reactivated during power outages.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? 11 ❑ Ll ■
Are the receiving water free of foam other than trace amounts and other debris? Ll ❑ Q ■
If effluent (diffuser pipes are required) are they operating properly? [l 0 ■ [I
Comment: The facility staff must ensure the outfall location is accessible for
inspection. The effluent appeared "tea colored" with trace suspended solids and no
foam.
Page # 8

Michael F. Easley, Governor
William G. Ross Jr., Secretary 111JJJ
North Carolina Department of Environment and Natural Resources
April 18, 2007
Mr. Brian Ramsey
Pretreatment Program Coordinator
City of Kings Mountain
Post Office Box 429
Kings Mountain, North Carolina 28086
Subject: PAR Review
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County, NC
Dear Mr. Ramsey:
Alan W. Klimek, P. E. Director
Division of Water Quality
Mooresville Regional Office staff has reviewed your Pretreatment Annual Report (PAR)
for the reporting period of January through December 2006. Based on the review, it appears that
the POTW completed the PAR in accordance with 15A NCAC 2H .0908(b) requirements and
guidelines set forth in Comprehensive Guidance for North Carolina Pretreatment Programs. The
next PAR will be due March 1, 2008.
If you have any questions concerning your PAR, please do not hesitate to contact me at
[phone] or by email at [e-mail].
Since,ely,
'—John Lesley
Mooresville Regional Office Contact
Cc: Monti Hassan, PERCS Unit
Central Files
NorLhCarolina
,aturally
N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 [phone] Customer Service
1-877-623-6748

�0�- W ATF94, Michael F. Easley, Governor
William G. Ross Jr., Secretary
C� r North Carolina Department of_Enyironment,j-d Natural Resources
T. YAlan'Wr Klimek, P.E. Director
Division•ofWater Quality
February 9, 2007
The Honorable Rick Murphy
Town of Kings Mountain
Kings Mountain City Hall
P.O. Box 429 M
Kings Mountain, North Carolina 28086 b ;;• ,1`
Subject: NPDES Phase II Stormwater Program
State Designation Process
Town of Kings Mountain, Cleveland County
Dear Mayor Murphy:
Pursuant to Session Law 2006-246, Section 5, we are writing this letter to provide you with
information on activities related to state designation of public entities under the National Pollution
Discharge Elimination System (NPDES) stormwater. program and the potential implications for your
community. Included with this letter is documentation giving background information on the NPDES
Municipal Stormwater Program. Under the provisions sited above, your community has been identified
for consideration under the state designation procedures. Please note that this does not mean your
community has been designated at this point. Various pieces of information, including public and
community input will be considered before making decisions on any state designations. Public notice of
potential designation will be given and comments on potential designation will be accepted through
March 31, 2007.
For more information, visit:
[http://l12o.enr.state.ne.us/su/stonnwater.html]
If you have any questions about this letter, please feel free to contact Mike Randall at (919)-733-
5083, ext. 545 or [e-mail]
Sincerely,
f 11
Alan W. Klimek, P.E.
cc: Central Files
Stormwater and General Permits Unit Files
0o e i li D-aJZO�f cum
One
NorthCarohna
Xitarally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncivaterquali!y.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Memo To:
DIVISION OF WATER QUALITY
August 6, 2007
Cecil Madden
Design Management Unit
Construction Grants and Loans Section
From: Robert B. Krebs`�C
Prepared By: Michael Parker a
Subject: City of Kings Mountain WWTP Upgrades
Authorization to Construct
NPDES Permit No. NCO020737
Cleveland County
This Office has conducted a review of the subject document and supporting information
received by this Office on July 25, 2007 from the City of Kings Mountain (the City), and offers
the following comments and/or recommendations.
The City has requested an Authorization to Construct in order to allow for an upgrade to
the aeration basins at the City's Pilot Creek WWTP. This upgrade involves the replacement of
the existing floating aerators and mixers with a fine bubble, diffused aeration system. The
proposed aeration system will help reduce energy cost, improve oxygen transfer efficiency by.
allowing for adjustments to influent day-to-day loadings, and reduce the costs and amount time
necessary to repair the current deteriorating aeration system by the WWTP operators.
This Office has no objection to this proposed WWTP upgrade and recommends issuance
of the ATC.
If you have any questions, please advise.
/mlp
hAat6atc07\kingsmtn.atc