NC0027197_Regional Office Historical File Pre 2018 (2)

Schutte, Maria
From: Smith, Eric
Sent: Wednesday, March 26, 2014 12:46 PM
To: Berry, Ron; Belnick, Tom
Cc: Pitner, Andrew; Parker, Michael; Watts, Debra
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
Attachments: Draft GW Monitoring Plan Template 3-24-14.docx
Ron & Tom:
Attached is the draft GW Monitoring Plan language that we have come up with for this particular permit. I had sent it to
Andrew Pitner and he was ok with the language and had a minor suggestion that I took care of. You can attach this to
the actual NPDES Plan and just refer to it. Attaching it is probably the best way so that we can make changes to the plan
periodically without having to open the entire NPDES permit.
Our other intention was that this language be used as a template for future GW Monitoring Plans of NPDES permits (i.e.
ash ponds). Let me know if you have any other suggestions or comments.
Thanks,
Eric G. Smith, P.G.
Eric G. Smith, P.G.
Hydrogeologist
NCDENR
Division of Water Resources
Water Quality Regional Operations Section
Groundwater Protection Branch '
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone: [phone]
Fax: [phone]
Website: http://portal.ncdenr.org/web/wq/aps
DISCLAIMER: Per Executive Order No. 150, all a -mails sent to and from this account are subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Watts, Debra
Sent: Wednesday, March 26, 2014 11:57 AM
To: Smith, Eric
Cc: Pitner, Andrew; Parker, Michael
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
Eric
Thanks for taking care of that. The shell looks good. Can you go ahead and send to NPDES staff -- see below for email
addresses for Tom Belnick and Ron Berry, and copy me. Also, can you let them know it's still acceptable to attach the
GW Monitoring plan, as with the ash ponds. Debra
1

From: Smith, Eric
Sent: Thursday, March 13, 2014 3:50 PM
To: Pitner, Andrew; Parker, Michael
Cc: Watts, Debra
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
Andrew and Michael:
Attached is the groundwater monitoring plan that we use for ash ponds. Please look at the plan as a template and edit it
to what you need for this permit.
-Eric G. Smith
Eric G. Smith, P.G.
Hydrogeologist
NCDENR
Division of Water Resources
Water Quality Regional Operations Section
Groundwater Protection Branch
1636 Mail Service Center
Raleigh, NC 27699-1636
Phone: [phone]
Fax: [phone]
Website: http://portal.ncdenr.org/web/wq/aps
DISCLAIMER: Per Executive Order No. 150, all a -mails sent to and from this account are subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Watts, Debra
Sent: Thursday, March 13, 2014 3:03 PM
To: Pitner, Andrew; Parker, Michael
Cc: Smith, Eric; Berry, Ron; Belnick, Tom; Berry, Ron
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
Andrew
The groundwater monitoring is already in RIMS — they have 4 active wells that are to be sampled 2ce a year. I've asked
Eric to draft the gw monitoring language, which he'll coordinate with you. Thanks! djw
From: Belnick, Tom
Sent: Thursday, March 13, 2014 2:54 PM
To: Berry, Ron
Cc: Watts, Debra; Parker, Michael; Pitner, Andrew; Smith, Eric
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
All- We looked as far back as 1998, and did not see any GW requirements in previous NPDES permits for Shelby WTP, so
I'm guessing it arose via the ATC construction permit.
Ron- can you add the GW Monitoring as a Special Condition to the Final permit, if that's what GW folks need. Will also
need to alert Permittee to new condition proposed for Final Permit, since it was not in Draft Permit and they did not
have opportunity to comment on the condition.

Debra/Andrew- please provide Ron with the Special Condition language to be inserted into the Final permit. Also, just
want to remind folks that NPDES does not maintain BIMS for any GW monitoring requirements/data/etc.
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
From: Berry, Ron
Sent: Thursday, March 13, 2014 1:12 PM
To: Belnick, Tom
Subject: FW: MRO copy of draft permit and fact sheet for Shelby WTP
Tom,
Another response from Debra Watts. None of the NPDES permits ever had any narratives associated with groundwater
monitoring. I have not responded to this email.
Ron
From: Watts, Debra .
Sent: Thursday, March 13, 2014 1:03 PM
To: Pitner, Andrew; Berry, Ron
Cc: Parker, Michael; Allocco, Marcia; Bell, Wes; Nagulapally, Sujatha R; Watts, Debra
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP
Ron
See the attached email. We updated the monitoring wells last September in accordance with the direction MRO gave to
the permittee. From Andrew's email below, it sounds like he wants the current groundwater monitoring plan
requirements to stay in the permit. Can you confirm this by sharing the draft permit language and/or monitoring
plan? Thanks!
Debra J. Watts, Supervisor
Groundwater Protection Branch
Water Quality Regional Operations Section
919-807-6338
Email correspondence to and from this address is 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.
From: Pitner, Andrew
Sent: Thursday, March 13, 2014 11:18 AM
To: Berry, Ron; Watts, Debra
Cc: Parker, Michael; Allocco, Marcia; Bell, Wes; Nagulapally, Sujatha R
Subject: RE: MRO copy of draft permit and fact sheet for Shelby WTP

Hi Ron,
I don't see any reference to the groundwater monitoring at this facility in the draft permit. This has been an issue at this
facility for many years for a complicated set of reasons, and I'm attaching a string of emails and a letter MRO sent trying
to clarify this matter. Please review this material and let me know what's up. Thanks,
Andrew
Andrew Pitner, P.G. - [e-mail]
Division of Water Resources - Water Quality Regional Operations Section
Mooresville Regional Office (MRO)
North Carolina Department of Environment & Natural Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
MRO Main Phone: [phone]
Direct Office Phone: [phone]
MRO Fax: [phone]
DWR website: http://www.ncwater.org
NOTICE: Email correspondence to and from this address is 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.
From: Parker, Michael
Sent: Thursday, March 13, 2014 8:22 AM
To: Allocco, Marcia; Bell, Wes; Nagulapally, Sujatha R
Cc: Pitner, Andrew
Subject: FW: MRO copy of draft permit and fact sheet for Shelby WTP
Any comments, let Ron know.
try
Di Ion of Water Resource
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.
From: Berry, Ron
Sent: Thursday, March 13, 2014 8:19 AM
To: Parker, Michael
Subject: MRO copy of draft permit and fact sheet for Shelby WTP
Michael,
Attached are your copies for review and comment.

Ron
Ron Berry
Environmental Engineer I
Complex Permitting Unit
NCDENR/DWR/Water Quality Permitting Section
Phone: (919) 807 - 6396
Email: [e-mail]
Fax: (919) 807 - 6489
Location Address - Archdale Building, Office 925Y
512 N. Salibury St.
Raleigh, NC 27699
Mailing Address - Archdale Building, NCDENR/DWR
1617 Mail Service Center
Raleigh, NC 27669-1617

GROUNDWATER MONITORING PLAN
The permittee shall conduct groundwater monitoring as may be required to determine the compliance
of this NPDES permitted facility with the current groundwater Standards found under 15A NCAC 2L
.0200. The following items are an integral part of the groundwater monitoring plan:
1. WELL CONSTRUCTION & MAINTENANCE
a. Monitoring wells shall be constructed in accordance with 15A NCAC 02C .0108
(Standards of Construction for Wells Other than Water Supply) and any other
jd sdictional laws and regulations pertaining to well construction.
b. G �he 11 II(s) must be constructed by a North Carolina Certified Well Contractor,
t e property owner; or the property lessee according to General Statutes 87-
98.4: If the construction is not performed by a certified well contractor, the
property own r,or lessee, provided they are a natural person, must physically
perform/the actual well construction activities.
c; Withm !,°30 days of completes of well ,�,��d- nstruction, a. completed Well
Constction�R ce ord (Fo GW-1must be; for each monitoring well.
d. The Division of Water Resources Regional Office --shall approve-fhe�,Iecation-of
new monitoring wells prior to, installation The regional office shall be notified
at least 48 hours prior to the construct of any monitoring well.
e. The monitoring wells shall be regularly maintained. Such maintenance shall
include ensuring that the well caps are rust -free and locked/at all times, the
outer casing is upright and undamaged, and the well does not
t serve as a conduit
for contamination.
2. REVIEW AND COMPLIANCE BOUNDARIES
a. The review boundary for the disposal system shall be specified in accordance
with 15A NCAC 02L .0108. When an exceedance of groundwater quality equals
or exceeds the standards at the review boundary, the permittee shall take
action in accordance with the provisions of 15A NCAC 02L .0106(c)(2)(A).
b. The compliance boundary for the disposal system shall be specified in
accordance with 15A NCAC 02L .0107. An exceedance of groundwater
standards at or beyond the compliance boundary is subject to remediation
action according to 15A NCAC 02L .0106(c) as well as .enforcement actions in
accordance with North Carolina General Statute 143-215.6A through 143-
215.6C.
3. SITE MAP
a. The Permittee shall submit an appropriately -scaled site map overlaid on the
most recent aerial photograph that shall include, at a minimum, the following
information:
i. The location and identity of each monitoring well.
ii. The location of major components of the waste disposal system.
iii. The location of property, review, and compliance boundaries.
iv. The elevation of the top of the well casing (i.e., measuring point)
relative to a common datum.
V. The depth of water below the measuring point at the time the
measuring point is established.
vi. Potentiometric surface contours showing relative groundwater flow
direction.
vii. The date the map is prepared and/or revised.
viii. Topographic contours in no more than ten (10) foot intervals.
NPDES Groundwater Monitoring Plan Page 1 of 2 DATE

PPPFFP'1 I -
b. The site map shall be updated and resubmitted when any of following occurs:
i. Any monitoring well is added or deleted from the monitoring network.
ii. A change to the major components of the waste disposal system such
that results change the review or compliance boundaries.
iii. A change in the property boundary.
4. MONITORING PARAMETERS AND FREQUENCY
a. The following wells shall be sampled MW-5, MW 6, MW 7 and MW-8�
b. The following parameters shall be sampled in each well: Aluminum, Specific
Conductivity_ pH, Total Dissolved Solids (TDS), and water level,
C. The ;wells shall be sampled for the parameters listed during the following
-months: ;July and November
5. GROUNDWATER, SAMPLING AND COMPLIANCE
a. Monitoring wells shall be sampled after construction and thereafter at the
frequencies and for the parameters as specified above.
b� Per 15A NCAC ,02H .0800, a Division certified' laboratory shall conduct all
laboratory analyses for.the required effluent, groundwater"-or°surface water
parameters. f
C. The measurement of water levels./shall be made prior to purging the wells. The
�, %depth to water in`each well shallobe-measured from the surveyed po.int_onythe_
top of the casing'. The measurement of fields parameters shall be made after
purging and prior to sampling,for the remaining parameters.
d. For all sampling events, the Permittee shall�fsubmit a Compliance Monitoring
Form (GW-59) listing this permit number and the appropriate monitoring well
identification number. L,''
e. Two copies of the monitoring well sampling and analysis results shall be
submitted on a Compliance Monitoring Form (GW-59), and received no later
than the last working day of the month following the sampling month. Copies of
the laboratory analyses shall be kept on site, and made available upon request.
f. One GW-59A certification form shall be submitted with each set of sampling
results.
NPDES Groundwater Monitoring Plan Page 2 of 2 DATE

U
QF W T�9 Michael F. Easley
O� QG Governor
co William G. Ross, Jr.,Secretary
] North Carolina Department of Environment and Natural Resources
p 'C Gregory J. Thorpe, Ph.D., Acting Director
Nam� Division of Water Quality
DIVISION OF WATER QUALITY
October 8, 2003
Mr. John Rhom
City of Shelby
P.O. Box 207
Shelby NC 28150
Subject: NPDES Permit No. NCO027197
Shelby WTP
Cleveland County, NC
Dear Mr. Rhom:
Our records indicate that NPDES Permit No. NCO027197 was issued on September 29, 2003
for the discharge of wastewater to the surface waters of the State from your facility. The purpose
of this letter is to advise you of the importance of the Permit and the liabilities in the event of failure
to comply with the terms and conditions of the Permit. If you have not already done so, it is
suggested that you thoroughly read the Permit. Of particular importance is Page 4.
. Page 4 sets forth the effluent limitations and monitoring requirements for your discharge.
Your discharge must not exceed any of the limitations set forth. The section headed "Monitoring
Requirements" describes the measurement frequencies, sample types and sampling locations. Upon
commencement of your discharge (or operation), you must initiate the required monitoring. The
monitoring results must be entered on reporting forms furnished or approved by this Agency. If you
have not received these forms, they should be arriving shortly. If you fail to receive the forms, please
contact this Office as.quickly as possible. I have enclosed a sample of the "Effluent" reporting form
(DWQ Form MR-1), plus instructions for completing the form. It is imperative that all applicable
parts be completed, and the original and one copy be submitted as required.
Please be advised that an annual administering and compliance monitoring fee may be
required for your facility. You will soon be receiving a statement from our Raleigh Office. It is
imperative that the fee be paid in a timely manner so as to prevent enforcement action or possible
revocation of your permit.
The remaining parts of the Permit set forth definitions, general conditions and special
conditions applicable to the operation of wastewater treatment facilities and/or discharge(s). The
conditions include special reporting requirements in the event of noncompliance, bypasses, treatment
unit/process failures, etc. Also addressed are requirements for a certified wastewater treatment plant
operator if you are operating wastewater treatment facilities. Any changes in operation of
NMENOR
Customer Service Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115 PHONE [phone]
1 800 623-7748 FAX [phone].

Mr. John Rhom
October 8, 2003
Page No. 2
wastewater treatment facilities, quantity and type of wastewater being treated or discharged,
expansions and/or upgrading of wastewater treatment facilities must be permitted or approved by
this Agency.
Failure to comply with the terms and conditions of an NPDES Permit subjects the Permittee
to enforcement action pursuant to Section 143-215.6 of the North Carolina General Statutes. A civil
penalty of up to $25,000 per violation (and/or criminal penalties) may be assessed for such
violations. If you find at any time that you are unable to comply with the terms and conditions of
the Permit, you should contact this Office immediately. A Special Order by Consent (SOC) may be
necessary while pursuing action to obtain compliance.
As a final note, an NPDES Permit is normally issued for a five-year period. Permits are not
automatically renewed. Renewal requests must be submitted to this Agency no later than 180 days
prior to expiration. Please make note of the expiration date of your Permit. This date is set forth on
Page 1 of the Permit. Also note that NPDES Permits are not automatically transferable. If you, as
the Permittee, cease to need this Permit, then you should request that the Division of Water Quality
rescind the Permit or request that DWQ reissue the Permit to another party, if necessary.
As mentioned previously, the purpose of this letter is to advise you of the importance of your
NPDES Permit. Please read the Permit and contact this Office at 704/663-1699 in Mooresville if
you have any questions or need clarification. We look forward to providing any assistance.
incerely,
EAbj '
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
DRG: dee

F WATF9P Michael F. Easley
Governor
O iC A �1l William G. Ross, Jr., Secretary
NCDENR North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
September 29, 2003
>} f Mr. John E. Rhom
City of Shelby
P.O. Box 207
Shelby, North Carolina 28150
Subject: Issuance of NPDES Permit NCO027197
Shelby W TP
Cleveland County
Dear Mr- Rhom:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are' forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on July 30, 2003.
This permit includes a TRC limit that will take effect on May 1, 2005. If you wish to install dechlorination
equipment, the Division has promulgated a simplified approval process for such projects. Guidance for approval of
dechlorination projects is attached. The Division strongly recommends connecting this discharge to the Town's
wastewater collection system, eliminating the need for this permit (and any expenditures related to dechlorination).
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If you have any questions concerning this permit, please contact Charles Weaver at telephone number (919)
733-5083, extension 511.
Sincerely,F
ORIGINAL
,L SIGNED By
Tom BeInick
Alan W. Klimek, P.E.
cc: Central Files
Mooresvilie. Regional Office/Water Quality Section
NPDES Unit
"i
.
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center: 1 800 623-7748

Permit NCO027197
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY ,
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended, the
City of Shelby
is hereby authorized to discharge wastewater from a facility located at the
Shelby WTP
801 West Grover Street northwest of Shelby
Cleveland County
to receiving waters designated as an unnamed tributary to the First Broad River in
the Broad River Basin in accordance with effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, II, II1 and IV hereof.
This permit shall become effective November 1, 2003.
This permit and authorization to discharge shall expire at midnight on August 31, 2008.
Signed this day September 29, 2003.
ORIGINAL SIGNED SY
Tom Deinick
Alan W. HIimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0027197
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of
this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the
exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements,
terms, and provisions included herein.
The City of Shelby is hereby authorized to:
1. Continue to operate a drinking -water treatment plant with a discharge of filter -
backwash wastewater. This facility is located at the Shelby WTP off West Grover
Street northwest of Shelby in Cleveland County.
2. Discharge from said treatment works at the location specified on the attached
map into an unnamed tributary to the First Broad River, classified C waters in
the Broad River Basin.

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Facility '
Quad: Shelby, N.C.
Q Y NCO027197
Subbasin:30804
City of Shelby WTP
Location'
Latitude: 35'18'23"
Longitude: 81'33'18"
North IFSCALE
1:24000
Receiving Stream: UT First Broad River
Stream Class: C

Permit NCO027197
A. (I.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge filter backwash from outfall 001. Such discharges shall be limited and monitored by
the Permittee as specified below:
EFFLUENT
CHARACTERISTICS
.LIMITS
MONITORING REQUIREMENTS
Mon# ly
Average ,. ;
Daily
- �,Mazimum ..
Measurement'
Frequency -
Sampie Type
Sample.Locatior t
Flow
Weekly
Instantaneous
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
Settleable Solids
0.1 ml/L
0.2 ml/L
Weekly
Grab
Effluent
Turbidity2
Weekly
Grab
Upstream & Downstream
Iron
Weekly
Grab
Effluent
Total Residual Chlorine3
17 Ng/L
Weekly
Grab
Effluent
Aluminum
Weekly
Grab
Effluent
Footnotes:
1. Upstream = at least 50 feet upstream from the outfall. Downstream = at least 50 feet downstream from the
outfall.
2. The discharge from this facility shall not cause turbidity in the receiving stream to exceed 50 NTU. If the
instream turbidity exceeds 50 NTU due to natural background conditions, the discharge cannot cause
turbidity to increase in the receiving stream.
3. Limit takes effect May 1, 2005. Until the limit takes effect, the permittee shall monitor TRC (with no
effluent limit).
All samples collected should be from a representative discharge event.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

NPDES Permit Requirements
Page 1 of 16
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events.
3/Week
Samples are collected three times per week on three separate calendar days.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which
is not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A 'sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 ml in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time
interval between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizer, and the preset gallon interval between sample collection fixed at no greater than 1 /24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used, in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters. Use of this method
requires prior approval by the Director.
Version 612012003

NPDES Permit Requirements
Page 2 of 16
In accordance with (4) above, influent grab samples shall not be collected more than once per hour.
Effluent grab samples shall not be collected more than once per hour except at wastewater treatment systems
having a detention time of greater than 24 hours. In such cases, effluent grab samples may be collected at
intervals evenly spaced over the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. However, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period. (40 CFR 122.3)
Daily Maximum
The highest "daily discharge." during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling. If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
EMC
The North Carolina Environmental Management Commission.
Facility Closure
The cessation of wastewater treatment at a permitted facility, or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 ml collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act.
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
Version 612012003

NPDES Permit Requirements
Page 3 of 16
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform, the geometric mean of such discharges.
Permit Issuing- Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The average of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act.
LP set
An incident beyond the reasonable control of the Pemuttee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action; for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal application [40 CFR 122.411.
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act, is subject to a civil penalty not to exceed $25,000 per day for each violation. [40 CFR 122.41 (a)
(2)]
c. The Clean Water Act provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or
405 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of
violation, or by imprisonment of not more than 2 years, or both. [40 CFR 122.41 (a) (2)]
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d. Any person who knomingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[40 CFR 122.41 (a) (2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a pemut issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both. An organization, as defined in section 309(c)(3)(13)(1) of the CWA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined
up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2)]
Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are
not to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class. II violations are not to exceed $10,000 per day for each- day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR
122.41 (a) (3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment
[40 CFR 122.41 (d)].
Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II. C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II. C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1319. Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liabilitv
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion- of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of th
permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remaind
of this permit, shall not be affected thereby [NCGS 15013-231.
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41 (h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41 (b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Pernuttee that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior to expiration, will subject
the Permittee to enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR 122.41 (k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in
charge of a principal business function, or any other person who performs similar policy or decision
making functions for the corporation, or (b) the manager of one or more manufacturing, production, or
operating facilities, provided, the manager is authorized to make management decisions which govern the
operation of the regulated facility including having the explicit or implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and regulations; the manager can ensure that
the necessary systems are established or actions taken to gather complete and accurate information for
permit application requirements; and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
3. The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 122.22]:
"7 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition [40 CFR 122.41 (0].
13. Permit Modification, Revocation and Reissuance or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of. the North Carolina
Administrative Code, Subchapter 2H .0100; and North Carolina General Statute 143-215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 2H.0105.(b) (4)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up ORCs who possess a currently valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must:
➢ Visit the facility at least weekly
➢ Comply with -all other conditions of 15A NCAC 8G.0204.
The ORC of each Class II, III and IV facility must:
➢ Visit the facility at least daily, excluding weekends and holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 8G.0204.
Once the facility is classified, the Permittee shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within 60 calendar days prior to wastewater being introduced into a new system
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b. Within 120 calendar days of:
➢ Receiving notification of a change in the classification of the system requiring the designation of a
new ORC and back-up ORC
➢ A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Permittee shall at all tunes provide the operation and maintenance resources necessary to operate the existing
facilities at optimum efficiency. The Permittee shall at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41
(c)]•
4. ByDassinp, of Treatment Facilities
a. z Bypass not exceeding limitations [40 CFR 122.41 (m) (2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41 (m)' (3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass.as required in Part
II. E. 6. (24-hour notice).
c. Prohibition of Bypass
0) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41 (n) (2)1: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met. No determination made during administrative review of claims that
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noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. Conditions necessary for a demonstration of upset: A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II. E. 6. (b) (B) of this permit.
(4) The Permittee complied with any remedial measures required under Part II. B. 2. of this permit.
d. Burden of proof [40 CFR 122.41 (n) (4)]: The Permittee seeking to establish the occurrence of an
upset has the burden of proof in any enforcement proceeding.
Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The
Permittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge (when
promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the
requirement. The Permittee shall notify. the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 21-1.0124 —
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority [40 CFR 122.41 (j)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR)- Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the 28th day following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I
of this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to
NCGS 143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304(g), 33 USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in
the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be
reported down to the minimum detection or lower reporting level of the procedure. If no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used.
5. Penalties for Tampering
The Clean Water Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years, or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information, including:
➢ all calibration and maintenance records
➢ all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Pernuttee shall record
the following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
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e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a. Enter upon the Permittee's premises where a regulated facility or activity is located or conducted, or where
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable tunes, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as
additions to the permitted facility [40 CFR 122.410)].
soon as possible of any planned. physical alterations or
Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42 (a) (1).
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices,
and such alternation, addition or change may justify 'the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.410) (2)].
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permit to document the change of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.410) (3)].
5. Monitorine Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.410) (4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR.
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6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CFR 122.41 (1) (6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II. E. 5 and 6. of this permit at
the time monitoring reports are submitted. The reports shall contain the information listed in Part Il. E. 6. of
this permit [40 CFR 122.41 (1) (7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director; it shall promptly submit
such facts or information [40 CFR 122.410) (8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b.. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this permit, including
monitoring reports or reports of.compliance or noncompliance shall, upon conviction, be punished by a fine of
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not more than $25,000 per violation, or by imprisonment for not more than two years per violation, or by both
[40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1C).
The report shall summarize the performance of the collection or treatment system, as well as the extent to wlch
the facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) pen -nit. Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Pert ittee and approved by the Division.
Section B. Groundwater Monitoring
The Pern ittee shall, upon written notice from the Director of the Division of Water Quality, conduct groundwater
monitoring as may be required to determine the compliance of this NPDES permitted facility with the current
groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels';
(1) One hundred micrograms per liter 000 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 µg/L) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and one milligram per liter
0 mg/L) for antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter 0 mg/L) for antimony,
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this permit. The Division may require specific measures during deactivation of the system to prevent
Version 612012003

NPDES Permit Requirements
Page 13 of 16
adverse impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit
continue at the permitted facility.
PART IV
SPECIAL CONDITIONS FOR MUNCIPAL FACILITIES
Section A. Publicly Owned Treatment Works (POTWs)
All POTWs must provide adequate notice to the Director of the following-
1 - Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to
section 301 or 306 of CWA if it were directly discharging those pollutants; and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger
as influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of
effluent introduced into the POTW, and (2) any anticipated impact of the change on the quantity or quality
of effluent to be discharged from the POTW.
Section B. Municipal Control of Pollutants from Industrial Users.
Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from
industries using the municipal system may be present in the Permittee's discharge. At such time as
sufficient information becomes available to establish limitations for such pollutants, this permit may be
revised to specify effluent limitations for any or all of such other pollutants in accordance with best
practicable technology or water quality standards.
2. Under no circumstances shall the Permittee allow introduction of the following wastes in the waste
treatment system: -
a. Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees
Centigrade using the test methods specified in 40 CFR 261.21;
b. Pollutants which will cause corrosive structural damage to the POTW, but in no case Discharges
with pH lower than 5.0, unless the works is specifically designed to accommodate such Discharges;
C. Solid or viscous pollutants in amounts which will cause obstruction to the flow in the POTW
resulting in Interference;
d. Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow
rate and/or pollutant concentration which will cause Interference with the POTW,
e. Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in
no case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C
(104°F) unless the Division, upon request of the POTW, approves alternate temperature limits;
f. Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in amounts that will
cause interference or pass through;
g. Pollutants which result in the presence of tonic gases, vapors, or fumes within the POTW in a
quantity that may cause acute worker health and safety problems;
h. Any trucked or hauled pollutants, except at discharge points designated by the POTW.
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the
Permittee to supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to
ensure compliance by the Permittee with all applicable effluent limitations. Such actions by the Permittee
may be necessary regarding some or all of the industries discharging to the municipal system.
4. The Permittee shall require any industrial discharges sending influent to the permitted system to meet
Federal Pretreatment Standards promulgated in response to Section 307(b) of the Act. Prior to accepting
wastewater from any significant industrial user, the Permittee shall either develop and submit to the
Version 612012003

NPDES Permit Requirmerits
Page 1F of 1 6
Division a Pretreatment Program for approval per 15A NCAC 2H .0907(a) or modify an eistit7 g
Pretreatment Program per 15A NCAC 2H .0907(b).
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved
POTW Pretreatment Program or to include a compliance schedule for the development of a IDTW
Pretreatment Program as required under Section 402(b)(8) of the Clean Water Act and implervatir-lg
regulations or by the requirements of the approved State pretreatment program, as appropriate.
Section C. Pretreatment Programs
Under authority of sections 307(b) and (c) and 402(b)(8) of the Clean Water Act and implementing regulations 40
CFR Part 403, North Carolina General Statute 143-215.3 (14) and implementing regulations 15A NC -AC, 21-1
.0900, and in accordance with the approved pretreatment program, all provisions and regulations containd and
referenced in the Pretreatment Program Submittal are an enforceable part of this permit.
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the Clean
Water Act, the Federal Pretreatment Regulations 40 CFR Part 403, the State Pretreatment Regulatiors 151A
NCAC 2H .0900, and the legal authorities, policies, procedures, and financial provisions contained in its
pretreatment program submission and Division approved modifications there of Such operation shall include
but is not limited to the implementation of the following conditions and requirements:
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program.
2. Industrial Waste Survey (ITS)
The Permittee shall update its Industrial Waste Survey (IWS) to include all users of the sewer collection
system at least once every five years.
3. Monitoring_ Plan
The Permittee shall implement a Division approved Monitoring Plan for the collection of facility specific
data to be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of
specific pretreatment local limits. Effluent data from the Plan shall be reported on the DMRs (as required
by Part II, Section D, and Section E.5.).
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a Headworks Analysis (HWA) at least once every five
years, and as required by the Division. Within 180 days of the effective date of this permit (or any
subsequent permit modification) the Permittee shall submit to the Division a written technical evaluation
of the need to revise local limits (i.e., an updated HWA or documentation of why one is not needed) [40
CFR 122.42]. The Permittee shall develop, in accordance with 40 CFR 403.5(c) and 15A NCAC 214.0909,
specific Local Limits to implement the prohibitions listed in 40 CFR 403.5(a) and (b) and 15A NCAC 2H
.0909.
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all significant industrial users, permits for
operation of pretreatment equipment and discharge to the Permittee's treatment works. These permits
shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control
technologies to assure that their wastewater discharge will meet all applicable pretreatment standards and
requirements. The Permittee shall maintain a current Allocation Table (AT) which summarizes the results
of the Headworks Analysis (HWA) and the limits from all Industrial User Pretreatment Permits (IUP).
Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA.
Version 612012003

NPDES Permit Requirements
Page 15of16
6. Authorization to Construct (A to C)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable
industrial users for the construction or modification of any pretreatment facility. Prior -to the issuance of
an AtC, the proposed pretreatment facility and treatment process must be evaluated for its capacity to
comply with all Industrial User Pretreatment Permit (IUP) limitations.
7. POTW Inspection & Monitoring_of their SIUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved. pretreatment program in order to determine, independent of information supplied by industrial
users, compliance with applicable pretreatment standards. The Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year; and
b. Sample all Significant Industrial Users (SIUs) at least twice per calendar year for all permit -
limited pollutants,- once during the period from January 1 through June 30 and once during the
period from July 1 through December 31, except for organic compounds which shall be sampled
once per calendar year;
8. SIU Self Monitoring and Reporting
The Permittee shall require all industrial users to comply_ with the applicable monitoring and reporting -
requirements outlined in the Division approved pretreatment program, the industry's pretreatment permit,
or in 15A NCAC °2H .0908.
9. -Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the Clean Water Act (40 CFR 405 et. seq.), prohibitive
discharge standards as set forth in 40 CFR 403.5 and 15A NCAC 2H .0909, and specific local limitations. -
All enforcement' actions shall be consistent with the Enforcement Response Plan (ERP) approved by the
Division.
10. " Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 2H .0908. In lieu of submitting
annual reports, Modified Pretreatment Programs developed under 15A NCAC 2H .0904 (b) may be
required to meet with Division personnel periodically to discuss enforcement of pretreatment requirements
and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual
Report (PAR) describing its pretreatment activities over the previous twelve months to the Division at the
following address:
NC DENR / DWQ / Pretreatment Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
These reports shall be submitted according to a schedule established by the Director and shall contain the
following.
a.) Narrative
A brief discussion of reasons for, status of, and actions taken for all Significant Industrial
Users (SIUs) in Significant Non -Compliance (SNC);
b.) Pretreatment Program Summar(PPS), .
A pretreatment program summary (PPS) on specific forms approved by the Division;
c.) Significant Non -Compliance Report (SNCR)
The nature of the violations and the actions taken or proposed to correct the violations on
specific forms approved by the Division
d.) Industrial Data Summary Forms (IDSE)
Version 612012003

NPDES Permit Rec-
Monitoring data from samples collected by both the POTW and the SigxiEic�- ,
User (SIU). These analytical results must be reported on Industrial Data Sumrria_
(IDSF) or other specific format approved by the Division;
e.) Other Information
Copies of the POTW's allocation table, new or modified enforcement conpliance schedules,
public notice of SIUs in SNC, and any other information, upon regcest, which in the
opinion of the Director is needed to determine compliance with the pretreatment
implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Significant Industrial Users (SIUs) that �r<re in Significant
Non -Compliance (SNC) as defined in the Permittee's Division approved Sewer Use Ordiriance with
applicable pretreatment requirements and standards during the previous twelve month period. This list
shall be published within four months of the applicable twelve-month period.
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities end results, along
with support information including general records, water quality records, and records of industrial impact
on the POTW.
13. Funding and Financial Report
The Permittee shall maintain adequate funding and staffing levels to accomplish the objectives of its
approved pretreatment program.
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits
modifications, POTNV monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan
modifications, shall be considered a permit modification and shall be governed by 15 NC -AC 2H .0114 and
15A NCAC 2H .0907.
Version 612012003

CDENR
North Carolina Department of Environment and Natural Resources'
Beverly Eaves Perdue
Governor
City of Shelby Utilities
Post Office Box 207
Shelby, North carolina 28151
Attention: David Hux, Assistant Utilities Director
Dear Mr. Hux:
Division of Water Quality
Coleen H. Sullins
Director
RE: Request to Modify Groundwater Monitoring
City of Shelby WTP — Alum Sludge Lagoons
NCO027N -1 7
Cleveland County
Dee Freeman
Secretary
August 26, 2010
This letter is in response to your request to consider changes to the groundwater compliance monitoring schedule that
has been associated with the referenced permit. A review of DWQ files revealed that in 1990, the city installed
monitoring wells associated with two alum sludge lagoons at the facility. These wells were required in the original
Authorization to Construct because the lagoons were built on a former city landfill. Several constituents of concern
(coliform, VOCs) were quickly detected in the samples from these wells. Additional monitoring wells were installed to
assess groundwater contamination believed to be associated with the landfill. The city has continued to monitor six of
these wells in accordance with language in previous versions of its permit. However, the current permit issued August 29,
2008, lacks specific language regarding sampling requirements.
Many of the parameters that have been sampled for and reported are related to the suspected former landfill impacts and
not directly associated with the lagoons. In the last year or so, the landfill has come under the regulatory authority of the
Division of Waste Management through its Pre -Regulatory Landfill Unit (Facility #NCD986176451). This group will direct
any further groundwater investigation related to the landfill.
In consideration of these factors, this office prescribes the following sampling schedule for the alum sludge lagoons:
1. Sample wells MW-5, MW-6, MW-7 and MW-8 in July and November.
2. Measure the water level in each well and conduct field monitoring (pH, Specific Conductivity) prior to sampling.
3. Sample each well for TDS and Aluminum
4. Submit a Form GW-59 for each well and a Form GW-59A for each sampling event to the DWQ Information
Processing Unit by the last day of August and December.
Should you have any questions, feel free to call me at 704/235-2183 or contact me via email at peg gy.finley(7a.ncdenr.gov.
Sincerely,
Pegy`,Inley
Environmental Specialist
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.ncwaterqual4.org
Nne
orthCarolina
An Equal Opportunity 1 Affirmative Action Employer— 50% Recycled/10% Post Consumer paper

City of Shelby
August 26, 2010
Page Two
Enclosure — Form GW-59 (1/07)
Cc: Debra Watts - APS Groundwater Protection Unit
Charles Weaver - SWPS NPDES Permitting/BIMS
Rob Krebs - MRO Surface Water Protection Section
MAF/City of Shelby gw mon req 8-26-10

Finley, Peggy
From: Marks, Cheryl
Sent: Thursday, August 26, 2010 12:50 PM
To: Finley, Peggy
Subject: RE: City of Shelby's Former Landfill
Thank you, I'll place the letter in the file.
From: Finley, Peggy
Sent: Thursday, August 26, 2010 11:36 AM
To: Marks, Cheryl
Subject: RE: City of Shelby's Former Landfill
Cheryl:
The attached letter is FYI and provides an explanation for my inquiry about this facility. Thanks for your help.
Peggy
From: Marks, Cheryl
Sent: Tuesday, August 24, 2010 10:42 AM
To: Finley, Peggy
Subject: RE: City of Shelby's Former Landfill
This site is not a program priority at this time. Our program has about 670 sites cataloged and ranked by risk with the
greatest risk being addressed first. It may be a few years before this program addresses this site.
Best regards,
Cheryl Marks, Pre -Regulatory Landfill Unit Supervisor
Inactive Hazardous Sites Branch, Superfund Section
1646 Mail Service Center
Raleigh, NC 27699-1646
[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.
From: Finley, Peggy
Sent: Tuesday, August 24, 2010 9:37 AM
To: Marks, Cheryl
Subject: City of Shelby's Former Landfill
Dear Cheryl:
I understand that your group now has regulatory authority over this site (NCD986176451).
I'd like know what its status is at this time.
As you may be aware, two alum sludge lagoons were built over the former landfill under the authority of a DWQ permit
(NC0027197). We'd just like to keep up-to-date on what might be going on with any groundwater investigation.
Thanks.
Peggy

Please note the change in email address
Peggy Finley - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Aquifer Protection Section
Iredell County Government Center
610 E Center St., Suite 301
Mooresville, NC 28115
Ph: [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.

610 E Center Ave, Mooresville, NC 28115 to 801 W Grover St, Shelby, NC 28150 - Goo... Page 1 of 1
Directions to 801 W Grover St, Shelby, NC
Goosle Maps 28150
- 68.7 mi - about 1 hour 21 mins _
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610 E Center Ave, Mooresville, NC 28115
1. Head west on E Center St toward E Statesville Ave
go 0.6 mi
About 1 rain
total 0.6 mi
2. Turn left at S-Main St
go 0.4 mi
About 2 mins
total 1.0 mi
3. Turn right at W Wilson Ave
go 1.4 mi
About 3 mins
total 2.4 mi
4. Turn left at US-21 S
go 2.2 mi
21 About 4 mins
total 4.6 mi
5. Merge onto 1-77 S/US-21 S via the ramp to Charlotte
go 13.2 mi
Continue to follow 1-77 S
total 17.8 mi
About 12 mins
. ; 6. Take exit 18 toward 1-486 S/Interstate 486 Outer S
go 0.1 mi
total 17.9 mi
7. Take exit 19B to merge onto 1485 S/Interstate 486 Outer S toward Spartanburg
go 11.4 mi
About 11 mins
total 29.3 mi
8. Take exit 10-9 to merge onto 1-85 S toward Spartanburg/Gastonia
go 20.3 mi
About 19 mins
total 49.6 mi`
9. Take exit 10B to merge onto Andrew Jackson Hwy/US-74 W toward Kings Mountain/
go 17.6 mi
%4 Shelby
total 67.2 mi
Continue to follow US-74 W
About 26 mins
26 10. Turn right at N Carolina 226 N/Polkville Rd
go 0.7 mi
About 1 min
total 67.9 mi
11. Take the 1st right onto W Grover St/State Rd 1861
go 0.8 mi
Destination will be on the right
total 68.7 mi
About 2 mins
801 W Grover St, Shelby, NC 28150
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause
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801 West Grover Street, Shelby, NC 28150 - Google Maps
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http://maps.google.com/maps?hl=en&tab=wl 8/23/2010

F
,Request to Remove GW Monitoring
ubject: Shelby WTP, Request to Remove GW Monitoring
From: Bruce Parris <[e-mail]>
Date: Tue, 29 Jun 2004 10:08:03 -0400
To: [e-mail]
CC: [e-mail], [e-mail]
Debra,
We received a request from the City of Shelby, through Mr. John Burke of
the Div. of Pollution Prevention and Environmental Assistance (DPPEA),
that they would like to have the groundwater monitoring requirements
removed from their Water Treatment Plant's alum.sludge storage lagoon
(NPDES 0027197). Unfortunately, this is not exactly a simple request.
The storage lagoon was originally built sometime around 1985 on a former
City of Shelby inactive landfill and the groundwater monitoring wells
associated with the WTP alum storage pond have consistently detected
constituents which appear to be associated with the landfill more than
the alum sludge lagoon (arsenic and some low level chlorinated solvent
VOCs). The MRO-GWS long ago assigned an incident number (3637) to the
detections found within the monitoring wells. However, a detailed file
review reveals that the MRO-GWS has also long felt that the detections
in the monitoring wells were more likely the result of the previous
landfill activities than the alum sludge lagoon for which the monitoring
wells were installed. The MRO-GWS has previously attempted to obtain
assistance from the Inactive Sites Group of the DWM without success.
According to the file, and according to my recent conversations with
Charlotte Jesnick and John Walch of the Inactive Sites Group, the DWM
policy is that that they will not accept a landfill site upon which DWQ
has an active permitted wastewater disposal unit. Both the MRO-GWS file
and Mr. Walch expressed concerns that the alum storage pond could create
enough hydraulic loading within the former landfill to mobilize and
cause contaminants to migrate off -site more rapidly than perhaps they
normally would. However, the file review also reveals that these
concerns were addressed by the GWS when the WTP was originally built and
the compromise was to install a 1 ft thick clay liner with a hydraulic
conductivity no greater than 1 x 10-6 cm/sec and have groundwater
monitoring associated with the alum st.errage pond. The GWS NPDES permit
conditions were included in the Authorization to Construct on 12/18/85.
As previously mentioned., Arsenic and VOCs were detected immediately in
the monitoring wells. At one point in the site's history, the MRO-GWS
requested that the WQS permit be rescinded and that the WQS require the
Town to hook up their WTP NPDES discharge to the municipal sewer system
so that the permitted storage pond could be taken out of service,
thereby allowing the Inactive Sites Group to step in and regulate the
former landfill. This request was apparently not supported by either
the CO-GWS or the WQS.
Since the initial installation of monitoring wells, several additional
monitoring wells have been installed by the permittee and they are
currently sampling six of those monitoring wells on a triannual basis.
The monitoring wells indicate that the constituents they are monitoring
are associated with the landfill. It is unclear whether or not
hydraulic leakage from the alum storage pond is causing a net increase
in constituent mobilization and transport within the landfill. Neither
a comprehensive site assessment or a corrective action plan has been
performed as the exceedances have always been approached as a permit
violation rather than by direct regulation of the former landfill. The
permittee has been unwilling to perform a CSA or CAP as they maintain
the constituents detected in their monitoring wells are associated with
the former landfill and not their permitted alum sludge pond. The
MRO-GWS, although concerned about the constituents found in association
with the landfill, has apparently been unwilling to pursue the Town of
Shelby for the landfill because, 1) as a landfill it should be regulated
by the DWM Inactive Sites Group, and 2) it is a low priority site due to
1 of 3 1/23/2007 10:33 AM

P, Request to Remove GW Monitoring
lack of nearby supply wells.
Another issue that I discovered in the file review is that since 1998,
reissuances of the NPES permit have not even included any direct
reference to the groundwater monitoring plan requirements. Groundwater
monitoring requirements in the 1998 and 2003 NPDES permit copies simply
require the permittee to conduct "any groundwater monitoring that is
required by the Director". Previous permit copies referenced the
groundwater monitoring requirements found in the A to C, and subsequent
revisions to that plan. I have to wonder if the permittee is even
currently required, under their NPDES permit, to continue with the
monitoring plan. I don't think the City of Shelby has considered this
particular issue.
I've reviewed the monitoring data for the facility and the constituents
values were considerably higher in concentration when the monitoring
wells were first installed, though Arsenic is still quite high, with a
value of 220 ppb in monitoring well Q74G11 as of 11/15/03. My previous
experiences with alum sludge at WTP's does not lead me to believe that
the arsenic and low level chlorinated solvent VOCs are directly the
result of the alum sludge storage pond. It is also my opinion, from a
regulatory perspective, that the groundwater exceedances have not been
handled by the MRO-GWS in the most legally correct manner. Trying to
regulate landfill constituents through an NPDES permitted storage pond
just doesn't make sense to me. I could argue that the storage pond
should have a synthetic liner to eliminate all reasonable possibility of
hydraulically influencing the landfill constituents, however, the file
review clearly indicates these concerns were addressed by the GWS during
the WTP's original permitting in 1985, and that a clay liner was
accepted as a compromise. Therefore, I would feel my position is weak
for asking the permittee to undergo the expense of installing a
synthetic liner. Alternatively, we could require the Town to have an
engineer verify the integrity of the clay liner, but I don't know if
this would provide realistically valuable data as to the clay liner's
actual integrity across the entire storage pond.
Since the Town wants to have the groundwater monitoring discontinued for
the NPDES permit, and since the Inactive Sites Group will not regulate
the landfill, we are left with a difficult situation. I propose that
the GWS dramatically reduce, or suspend groundwater monitoring
requirements for NPDES permit. However, I also propose that the MRO-GWS
should subsequently send an NOV to the Town for 2L exceedances that
appear associated with their former landfill. Although much more
appropriate from a regulatory track, this strategy has a drawback. As a
low priority incident site, if the Town refuses to perform a CSA or CAP
for the landfill, the GWS would then lose any tracking of the
constituent values at this site as it is unlikely we would continue
pursuit of enforcement against the Town. To deal with this possibility,
I propose that we request the WQS to alter the NPDES permit to read:
Monitoring wells Q74G5, Q74G6, Q74G7, Q74G8, Q74G11, and Q74G14 be
monitored once per year for: Water levels, VOCs, aluminum, and'arsenic
(both Total and Dissolved).
This partially addresses the Town's desire to eliminate monitoring from
the NPDES permit. If the Town is cooperative in complying with the NOV
that they will receive from the GWS for the Landfill issues, -we can
revisit complete elimination of groundwater monitoring requirements from
their WTP NPDES Permit.
Does the CO-GWS Permitting Group support this strategy? Thank you very
much for your time. This unfortunately had to be long-winded given the
complexities and long site history.
Sincerest Regards,
Bruce Parris
2 of 3 1/23/2007 10:33 AM

P, Request to Remove GW Monitoring
Bruce Parris - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality - Ground Water Section
919 N. Main St.
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
Bruce Parris <Bruce.Parris(a),ncmail.net>
Hydrogeologist
Div. of Water Quality - Ground Water Section
NC DENR - Mooresville
3 of 3 1/23/2007 10:33 AM

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PART III
OTHER REQUIREMENTS
A. Construction
No construction of wastewater treatment facilities or additions to add to the plant's treatment
capacity or to change the type of process utilized at the treatment plant shall be begun until Final
Plans and Specifications have been submitted to the Division of Water Quality and written approval
and Authorization to Construct has been issued.
B. Groundwater Monitoring
The permittee shall, upon written notice from the Director of the Division of Water Quality, conduct
groundwater monitoring as may be required to determine the compliance of this NPDES permitted
facility with the current groundwater standards.
C. Changes in Discharges of Toxic Substances
The permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe:
a.That any activity has occurred or will occur which would result in the discharge, on a routine or
frequent basis, of any toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels';
(1) One hundred micrograms per liter (100 ug/1);
(2)Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five hundred
micrograms per liter (500 ug/1) for 2.4-dinitrophenol and for 2-methyl-4.6-dinitrophenol; and
one milligram per liter (1 mg/1) for antimony;
(3) Five (5) times the maximum concentration value reported for that pollutant in the permit
application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine
or infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will
exceed the highest of the following "notification levels';
(1) Five hundred micrograms per liter (500 ug/1);
(2) One milligram per liter (1 mg/1) for antimony;
(3) Ten (10) times the maximum concentration value reported for that pollutant in the permit
application.
D. Rgquirement to Continually Evaluate Alternatives to Wastewater Discharges
The permittee shall continually evaluate all wastewater disposal alternatives and pursue the most
environmentally sound alternative of the reasonably cost effective alternatives. if the facility is in
substantial non-compliance with the terms and conditions of the NPDES permit or governing rules,
regulations or laws, the permittee shall submit a report in such form and detail as required by the
Division evaluating these alternatives and a plan of action within sixty (60) days of notification by the
Division.

Part II
Page 14 of 14
Persons reporting such occurrences by telephone shall also file a written report in letter form within
5 days following first knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3(a)(2) or Section 308 of the
Federal Act, 33 USC 1318, all reports prepared in accordance with the terms shall be available for
public inspection at the offices of the Division of Water Quality. As required by the Act, effluent
data shall not be considered confidential. Knowingly making any false statement on any such
report may result in the imposition of criminal penalties as provided for in NCGS 143-215.1(b)(2) or
in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement,
representation, or certification in any record or other .document submitted or required to be
maintained under this permit, including monitoring reports or reports of compliance or
noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation,
or by imprisonment for not more than two years per violation, or by both. '

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OF
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N.C. DEFT. OF
ALTi'
ENVI ,ONMENT, - - �r q NA.TL'FE�EI�ESCU
'BY.
JU�9 1 ®1996
CITY OF S H E L B Y
DNI VOORE NUI REGl0h�GFFIC�
BOX 207 - WASHING,TON AT GRAHAM ST. - SHELBY NORTH CAROLINA 28151 - 0207
June 7, 1996
Mr. Charles Pippen
Division of Environmental Management
919 North Main Street
Mooresville, NC 28115
Re: Notice of Violation
15A NCAC 2L Classifications and Water Quality
Standards Applicable to the Groundwaters
City of Shelby
NPDES Permit No. NCO027197
Cleveland County, NC
Dear Mr. Pippen:
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
The substance of Mr. Overcash's letter of May 15, 1996 is a rehash of the
same situation that was thoroughly investigated by DEM and the NC Superfund
Section some 6 years ago with the conclusion by DEM that "the old landfill, and not
the permitted lagoons, is the source of groundwater contamination." I, therefore,
respectfully request you withdraw or cancel the referenced Notice of Violation.
Based on monitoring results over the past se�ieral years, there is no consistent
indication that groundwater contamination is any greater now than it was in 1990.
Monitoring Well G-5 is upgradient but not within the disturbed area, boundaries of the
old landfill. Therefore this well is not a valid basis for judging acceleration of
groundwater contamination.
It was previously determined that the contamination found in the landfill has
little or no chance of leaving the area due to its location. The nearest water well is
approximately one (1) mile from the site at a higher elevation than the old landfill.
FORMi1054XM

Mr. Charles Pippen
Page 2
June 7, 1996
For these reasons and others, the City would contend that the rules stated in
Mr. Overcash's May 15 letter should not be applied in this instance. No modeling
information or plan for alteration or site assessment report should be required. In fact,
the City is in a budgetary squeeze and would like to reduce the frequency of
monitoring at the site in order to reduce operating costs.
I am willing to schedule a meeting with you and review this situation at your
request. I can be reached by telephone at 704-484-6840.
Sincerely,
sot"_
Don Rhom
Plant Engineer
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State of North Carolina
Department of Environment,
• Health and Natural Resources 1 • •
' Mooresville Regional Office
OM%
James B. Hunt, Jr., Governor p E H N
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 15, 1996
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
City of Shelby
Post Office Box 207
Shelby, North Carolina 28150
Attention: Mr. Don Rhom
RE:. Notice of Violation
15A NCAC 2L Classifications and
Water Quality Standards Applicable
to the Groundwaters
City of Shelby
NPDES Permit W NCO027197
Cleveland County, N.C.
Dear Mr. Rhom:
Chapter 143, North Carolina General Statutes, authorizes and
directs the Environmental Management Commission of the Department
of Environment, Health, and Natural Resources to protect and
preserve the water and air resources of the State. The Division
of Environmental Management has the delegated authority to
enforce adopted pollution control rules.
Based upon a review of your groundwater compliance
monitoring data submitted on January 24, and May 3, 1996 as a
requirement of the subject permit, the Division has reason to
believe that the permitted -activities have resulted in the
groundwater standards being exceeded. The standards can be found
at 15A NCAC 2L. Condition W I(4) of your permit states:
The issuance of this permit shall not relieve the Permittee
of the responsibility for damages to surface or groundwaters
resulting from the operation of this facility.
Specific constituents which are exceeding the groundwater
standards are as follows:
919 North Main Street, ���C FAX [phone]
Mooresville, North Carolina 28115 An Equal Opportunity/Affirmative Action Employer
Voice 704-663-1699 50% recycled/10% post -consumer paper

City of Shelby
May 15, 1996
Page Two
Constituent . WELL
Total Coliform G-6
G-7
G-8
Arsenic
G-6
G-11
G-7
Vinyl Chloride
G-7
G-8
G-14
Benzene
G-8
G-14
Chloroform
G-7
Date Sampled
Concentration*.2LStandard*
11/29/95
6.9
1 per 100 mL
3/27/96
9.2
1 per 100 mL
11/29/95
23
1 per 100 mL
3/27/96
2.2
1 per 100 mL
11/29/95
723
1 per 100 mL
3/27/96
2.1
1 per 100 mL
11/29/95
0.077
0.05
11/29/95
0.7
0.05
3/27/96
0.139
0.05
11/29/95
0.0066
0.000015
11/29/95
0.001
0.000015
11/29/95
0.0047
0.000015
11/29/95
0.0014
0.001
11/29/95
0.0021
0.001
11/29/95
0.0046
0.00019
*Concentrations reported in parts per million, except coliform
Please note that the treatment lagoons are believed to be
accelerating groundwater contamination, based on the absence of
the above constituents observed in monitoring well G-5. Monitor
well G-5 is upgradient and within the boundaries of the old
landfill.
Commission Rule 15A NCAC 2L .0106(d) states:
Any person conducting or controlling an activity which
results in an increase in the concentration of a substance
in excess of the groundwater standards as a result of
activities conducted under the authority of a permit issued
by the state, shall, where such concentrations are detected:
1. at or beyond a review boundary demonstrate, through
predictive calculations or modeling, that natural site
conditions, facility design and operational controls
will prevent a violation of standards at the
compliance boundary; or submit a plan for alteration of
existing site conditions, facility design or
operational controls that will prevent a violation at
the compliance boundary, and implement that plan upon
its approval by the Director.
2. at or beyond a compliance boundary, assess the cause,
significance and extent of the violation of groundwater
quality standards and submit the results of the
investigation, a plan, and schedule for groundwater
quality restoration to the Director. The permittee
shall implement the plan as approved by and in

City of Shelby
May 15, 1996
Page Three
accordance with a schedule established by the Director.
In establishing a schedule the Director shall consider
any reasonable schedule proposed by the permittee.
The modeling information or a plan for alteration must be
submitted within thirty (30) days of -receipt of this letter.
The site assessment report should be completed in accordance
with the attached guidelines and should be received in this
Office within ninety (90) days of receipt of this letter.
You should be aware, however, that a violation of 15A NCAC
2L may subject you to a civil penalty assessment under the
authority of G.S. 143-215.6A of up to $10,000 per rule violation.
Each day that a violation continues may be considered a separate
violation. Failure to respond within the time specified and to
voluntarily achieve compliance may result in the recommendation
of enforcement action, including the issuance of a Special Order
against you under the authority of General Statute 143-215.2
and/or revocation of your permit.
Your response and/or questions should be directed to Charles
Pippin at [phone] ext. 26.8.
Sincerely,
B. eith Overcash, P.E.
Re ional Supervisor
Attachments: Groundwater Assessment and Remediation at Non -Hazardous
Waste Sites
cc: Bob Cheek, Permits and Compliance Unit
Rex Gleason, Mooresville Water Quality Section
CGP

l—%-P
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
May 15, 1996
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
City of Shelby
Post Office Box 207
Shelby, North Carolina 28150
Attention: Mr. Don Rhom
RE: Notice of Violation of Permit Conditions
Permit W NCO027197
Cleveland County, N.C.
Dear Mr. Rhom:
A review of the subject permit and your compliance
monitoring data indicates that you are in violation of the
following permit condition(s):
Permit Condition W III(B) states the permittee shall,
upon written notice from the Director of the Division
of Environmental Management, conduct groundwater
monitoring as may be required to determine the
compliance of this NPDES permitted facility with the
current groundwater standards. On October 11, 1995,
the City of Shelby received a Notice of Regulatory
Requirements addressing the absence of analytical
results for volatile organic compounds by EPA Method
502.2 for wells G-7, G-8 and G-14 and for dissolved
arsenic for well G-11. A review of the compliance
monitoring data for the March 1996 sampling event
revealed that the City of Shelby again failed to submit
analytical results for volatile organic compounds by
EPA Method 502.2 for wells G-7, G-8, G-14 and for
dissolved arsenic for well G-11.
You are requested to submit analytical results for volatile
organic compounds for wells G-7, G-8 and G-14 and for dissolved
arsenic for well G-11 within 30 days of receipt of this letter or
919 North Main Street, ��W� FAX [phone]
Mooresville, North Carolina 28115 �� An Equal Opportunity/Affirmative Action Employer
Voice 704-663-1699 50% recycled/10% post -consumer paper

1�
City of Shelby
May 15, 1996
Page Two
an explanation of why you cannot comply. It should be noted that
the violations cited above and any additional documented
violations could result in the initiation of an enforcement
action by'this Office in accordance with General,Statute 143-
215.6A, which provides for a $10,000 assessment of civil
penalties for each violation. Each day that the violations
continue may be considered a separate violation.
Should you have any questions concerning this Notice,
contact Charles Pippin at [phone], ext. 268.
Sincerely,
B. K ith Overcash, P.E.
Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
CGP

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Of
Sy�l�
CITY OF SHELBY
BOX 207 - WASHINGTON AT GRAHAM ST. - SHELBY NORTH CAROLINA 28151 - 0207
Ms. Barbara Christian April 29, 1996
Department of Environmental Management
Post Office Box 950 N.C. DEPT.OF
Mooresville, North Carolina 28115 ENVIRONUIVIENT, HEAITF1
& NATURAL, RESOURCES
RE: SHELBY WATER TREATMENT PLANT MAY Q 1 1996
GROUND WATER INCIDENT NO. 3637
CLEVELAND COUNTY, NORTH CAROLINA DIVISION OF U iRIN"AMA WMABEff
MOORRSM CAI
WE -
Dear Ms. Christian:
Enclosed is the report of the Laboratory Analysis for samples
collected from monitoring wells at the Alum Sludge Lagoons located
at the Shelby Water Treatment Plant.
The City has been sampling these wells and sending the results to
DEM three (3) times annually since 1992. There does not appear to
be any significant changes in the results or direction since we
started looking at this problem.
With this letter, I respectfully request that the sampling events
as they relate to this incident be reverted back to the original
four (4) wells; Numbers G.5, G.6, G.7 and G.8.
Thank you very much for your consideration on this matter.
If you have any questions you may call me at [phone].
Sinc rely,
Don Rhom
Plant Engineer
DFR : j wh

a
Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pa rm l0 n a bit" as l Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Shelby (City of) April 10, 1996
P.O. Box 207 PACE Project Number: A60327513
801 West Grover Street
Shelby, NC 28150
Attn: Mr. Jamie Shytle
Client Reference: Monitoring Wells
PACE Sample Number: 93 0190073
Date Collected: 03/27/96
Date Received: 03/27/96
Well #5
Parameter Units MDL METHOD DATE ANALYZED
(1)
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Aluminum
mg/L
0.10
ND
6010
04/02/96
Arsenic
mg/L
0.005
ND
7060
04/01/96
Cadmium
mg/L
0.001
ND
7131
03/29/96
Chloride
mg/L
1
5.6
325.3
03/28/96
Copper
mg/L
0.01
ND
6010
04/02/96
Nitrogen, Ammonia
mg/L
0.1
ND
350.3
04/02/96
Nitrogen, Nitrate in Wastewater
mg/L
0.1
ND
352.1
03/29/96
Phenol
mg/L
0.005
ND
420.1
04/04/96
Solids, Total Dissolved
mg/L
1
200
160.1
04/01/96
Total Organic Carbon
mg/L
0.5
5.7
5310C
04/01/96
Zinc
mg/L
0.01
0.104
6010
04/02/96
pH
Units
0.10
6.1
150.1
03/28/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax:[phone]
Mr. Jamie Shytle April 10, 1996
Page 2 PACE Project Number: A60327513
Client Reference: Monitoring Wells
PACE Sample Number:
Date Collected:
Date Received:
Client Sample. ID:
Parameter Units MDL
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
93 0190081
03/27/96
03/27/96
Well #6
METHOD DATE ANALYZED
(1)
Aluminum
mg/L
0.10
ND
6010
04/02/96
Arsenic
mg/L
0.005
ND
7060
04/01/96
Cadmium
mg/L
0.001
ND
7131
03/29/96
Chloride
mg/L
1
1.7
325.3
03/28/96
Copper
mg/L
0.01
ND
6010
04/02/96
Nitrogen, Ammonia
mg/L
0.1
ND
350.3
04/02/96
Nitrogen, Nitrate in Wastewater
mg./L
0.1
0.61
352.1
03/29/96
Phenol
mg/L
0.005
ND
420.1
04/04/96
Solids, Total Dissolved
mg/L
1
97
160.1
04/01/96
Total Organic Carbon
mg/L
0.5
1.2
5310C
04/01/96
Zinc
mg/L
0.01
0.073
6010
04/02/96
pH
Units
0.10
6.8
150.1
03/28/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
g�
54 Ravenscroft Drive
Pace Analytiral Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle April 10, 1996
Page 3 PACE Project Number: A60327513
Client Reference: Monitoring Wells
PACE Sample Number: 93 0190090
Date Collected: 03/27/96
Date Received: 03/27/96
Client Sample ID: Well #7
Parameter Units MDL METHOD DATE ANALYZED
(1)
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Aluminum
mg/L
0.10
ND
6010
04/02/96
Arsenic
mg/L
0.005
0.139
7060
04/01/96
Cadmium
mg/L
0.001
ND .
7131
03/29/96
Chloride
mg/L
5
140
325.3'
03/28/96
Copper
mg/L
0.01
ND
6010
04/02/96
Nitrogen, Ammonia
mg/L
0.1
2.4
350.3
04/02/96
Nitrogen, Nitrate in Wastewater
mg/L
0.1
ND
352.1
03/29/96
Phenol
mg/L
0.005
ND
420.1
04/04/96
Solids, Total Dissolved
mg/L
1
360
160.1
04/01/96
Total Organic Carbon
mg/L
0.5
7.9
5310C
04/01/96
Zinc
mg/L
0.01
0.114
6010
04/02/96
pH
Units
0.10
6.0
150.1
03/28/96
2
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle April 10, 1996
Page 4 PACE Project Number: A60327513
Client Reference: Monitoring Wells
PACE Sample Number: 93 0190103
Date Collected: 03/27/96
Date Received: 03/27/96
Client Sample ID: Well #8
Parameter Units MDL METHOD DATE ANALYZED
(1)
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Aluminum
mg/L
0.10
ND
6010
04/02/96
Arsenic
mg/L
0.005
0.007
7060
04/01/96
Cadmium
mg/L
0.001
ND
7131
03/29/96
Chloride
mg/L
5
110
325.3
03/28/96
Copper
mg/L
0.01
ND
6010
04/02/96
Nitrogen, Ammonia
mg/L
0.1
0.13
350.3
04/02/96
Nitrogen, Nitrate in Wastewater
mg/L
0.1
ND
352.1
03/29/96
Phenol
mg/L
0.005
ND
420.1
04/04/96
Solids, Total Dissolved
mg/L
1
360
160.1
04/01/96
Total Organic Carbon
mg/L
0.5
9.9
5310C
04/01/96
Zinc
mg/L
0.01
0.052
6010
04/02/96
pH
Units
0.10
6.0
150.1
03/28/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc,
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle April 10, 1996
Page 5 PACE Project Number: A60327513
Client Reference: Monitoring Wells
PACE Sample Number: 93 0190111
Date Collected: 03/27/96
Date Received: 03/27/96
Client Sample ID: Well #11
Parameter Units MDL METHOD DATE ANALYZED
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Arsenic, Dissolved
mg/L 0.40 3.76 7060 04/01/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax:[phone]
Mr. Jamie Shytle April 10, 1996
Page 6 PACE Project Number: A60327513
Client Reference: Monitoring Wells
PACE Sample Number: 93 0190120
Date Collected: 03/27/96
Date Received: 03/27/96
Client Sample ID: Well #14
Parameter Units MDL METHOD DATE ANALYZED
INORGANIC ANALYSIS
INDIVIDUAL PARAMETERS
Arsenic, Dissolved mg/L 0.005 ND
These data have been reviewed and are approved for release.
Barbara M. Miller
Supervisor, Inorganic Ciemistry
7060 04/01/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax:[phone]
Mr. Jamie Shytle FOOTNOTES April 10, 1996
Page 7 for pages 1 through 6 PACE Project Number: A60327513
Client Reference: Monitoring Wells
MDL Method Detection Limit
ND Not detected at or above the MDL.
(1) pH analysis exceeded hold time. Results not valid for NPDES Permit monitoring.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytocal Asheville, NC28801
Tel: [phone]
Fax:[phone]
Shelby, City of
P. 0. Box 207
Shelby, NC 28150
Attn: Mr. Jamie Shytle
Client Reference: Shelby
April 09, 1996
PACE Project Number: A60327513
PACE Sample Number: 93 0190090
Date Collected: 03/27/96
Date Received: 03/28/96
Well #7
Parameter Units MDL DATE ANALYZED
ORGANIC ANALYSIS
VOLATILE ORGANICS
Dichlorodifluoromethane
ug/L
1.0
ND
04/04/96
Chloromethane
ug/L
1.0
ND
04/04/96
Chloroethene (Vinyl chloride)
ug/L
1.0
5.8
04/04/96
Bromomethane
ug/L
1.0
ND
04/04/96
Chloroethane
ug/L
1.0
ND
04/04/96
Trichlorofluoromethane
ug/L
1.0
ND
04/04/96
1,1-Dichloroethene
ug/L
1.0
ND
04/04/96
Dichloromethane
ug/L
1.0
3.5 B
04/04/96
trans-1,2-Dichloroethene
ug/L
1.0
ND
04/04/96
1,1-Dichloroethane
ug/L
1.0
1.4
04/04/96
cis-1,2-Dichloroethene
ug/L
1.0
10
04/04/96
2,2-Dichloropropane
ug/L
1.0
ND
04/04/96
Chloroform
ug/L
1.0
ND
04/04/96
Bromochloromethane
ug/L
1.0
ND
04/04/96
1,1,1-Trichloroethane
ug/L
1.0
ND
04/04/96
1,1-Dichloro-l-propene
ug/L
1.0
ND
04/04/96
Carbon tetrachloride
ug/L
1.0
ND
04/04/96
1,2-Dichloroethane
ug/L
1.0
ND
04/04/96
1,1,2-Trichloroethene
ug/L
1.0
ND
04/04/96
1,2-Dichloropropane
ug/L
1.0
ND
04/04/96
Bromodichloromethane
ug/L
1.0
ND
04/04/96
Dibromomethane
ug/L
1.0
ND
04/04/96
cis-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/04/96
trans-1,3-Dichloro-l-pr-opene
ug/L
1.0
ND
04/04/96
1,1,2-Trichloroethane
ug/L
1.0
ND
04/04/96
1,3-Dichloropropane
ug/L
1.0
ND
04/04/96
Tetrachloroethene
ug/L
1.0
ND
04/04/96
Dibromochloromethane
ug/L
1.0
ND
04/04/96
1,1,1,2-Tetrachloroethane
ug/L
1.0
ND
04/04/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytoral Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle
Page 2
Client Reference: ShelbY
April 09, 1996
PACE Project Number: A60327513
PACE Sample Number: 93 0190090
Date Collected: 03/27/96
Date Received: 03/28/96
Client Sample ID: Well #7
Parameter Units MDL DATE ANALYZED
ORGANIC ANALYSIS
VOLATILE ORGANICS
Bromoform
ug/L
1.0
ND
04/04/96
1,1,2,2-Tetrachloroethane
ug/L
1.0
ND
04/04/96
1,2,3-Trichloropropane
ug/L
1.0
ND
04/04/96
Bromobenzene
ug/L
1.0
ND
04/04/96
2-Chlorotoluene
ug/L
1.0
ND
04/04/96
4-Chlorotoluene
ug/L
1.0
ND
04/04/96
1,3-Dichlorobenzene
ug/L
1.0
ND
04/04/96
1,4-Dichlorobenzene
ug/L
1.0
3.2
04/04/96
1,2-Dichlorobenzene'
ug/L
1.0
ND
04/04/96
1,2-Dibromo-3-chloropropane
ug/L
1.0
ND
04/04/96
1,2,4-Trichlorobenzene
ug/L
1.0
ND
04/04/96
Hexachlorobutadiene
ug/L
1.0
ND
04/04/96
1,2,3-Trichlorobenzene
ug/L
1.0
ND
04/04/96
Benzene
ug/L
1.0
2.4
04/04/96
Toluene
ug/L
1.0
1.5
04/04/96
Chlorobenzene
ug/L
1.0
ND
04/04/96
Ethylbenzene
ug/L
1.0
ND
04/04/96
Xylenes
ug/L
1.0
1.3
04/04/96
Styrene
ug/L
1.0
ND
04/04/96
Isopropylbenzene
ug/L
1.0
ND
04/04/96
n-Propylbenzene
ug/L
1.0
ND
04/04/96
1,3,5-Trimethylbenzene
ug/L
1.0
ND
04/04/96
t-Butylbenzene
ug/L
1.0
ND
04/04/96
1,2,4-Trimethylbenzene
ug/L
1.0
ND
04/04/96
s-Butylbenzene
ug/L
1.0
ND
04/04/96
4-Isopropyltoluene
ug/L
1.0
ND
04/04/96
n-Butylbenzene
ug/L
1.0
ND
04/04/96
Naphthalene
ug/L
1.0
ND
04/04/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
1 54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle
Page 3
Client Reference: Shelby
April 09, 1996
PACE Project Number: A60327513
PACE Sample Number: 93 0190103
Date Collected: 03/27/96
Date Received: 03/28/96
Client Sample ID: Well #8
Parameter Units MDL DATE ANALYZED
VOLATILE ORGANICS
Dichlorodifluoromethane
ug/L
1.0
ND
04/05/96
Chloromethane
ug/L
1.0'
ND
04/05/96
Chloroethene (Vinyl chloride)
ug/L
1.0
1.6
04/05/96
Bromomethane
ug/L
1.0
ND
04/05/96
Chloroethane
ug/L
1.0
ND
04/05/96
Trichlorofluoromethane
ug/L
1.0
ND
04/05/96
1,1-Dichloroethene
ug/L
1.0
ND
04/05/96
Dichloromethane
ug/L
1.0
3.0 B
04/05/96
trans-1,2-Dichloroethene
ug/L
1.0
ND
04/05/96
1,1-Dichloroethane
ug/L
1.0
ND
04/05/96
cis-1,2-Dichloroethene
ug/L
1.0
ND
04/05/96
2,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Chloroform
ug/L
1.0
ND
04/05/96
Bromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1-Trichloroethane
ug/L
1.0
ND
04/05/96
1,1-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
Carbon tetrachloride
ug/L
1.0
ND
04/05/96
1,2-Dichloroethane
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethene
ug/L
1.0
ND
04/05/96
1,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Bromodichloromethane
ug/L
1.0
ND
04/05/96
Dibromomethane
ug/L
1.0
ND
04/05/96
cis-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
trans-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethane
ug/L
1.0
ND
04/05/96
1,3-Dichloropropane
ug/L
1.0
ND
04/05/96
Tetrachloroethene
ug/L
1.0
ND
04/05/96
Dibromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1,2-Tetrachloroethare
ug/L
1.0
ND
04/05/96
Bromoform
ug/L
1.0
ND
04/05/96
1,1,2,2-Tetrachloroethane
ug/L
1.0
ND
04/05/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle April 09, 1996
Page 4 PACE Project Number: A60327513
Client Reference: Shelby
PACE Sample Number: 93 0190103
Date Collected: 03/27/96
Date Received: 03/28/9.6
Client Sample ID: Well #8
Parameter Units MDL DATE ANALYZED
ORGANIC ANALYSIS
VOLATILE ORGANICS
1,2,3-Trichloropropane
ug/L
1.0
ND
04/05/96
Bromobenzene
ug/L
1.0
NO
04/05/96
2-Chlorotoluene
ug/L
1.0
ND
04/05/96
4-Chlorotoluene
ug/L
1.0
ND
04/05/96
1,3-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,4-Dichlorobenzene
ug/L
1.0
5.2
04/05/96
1,2-Dichlorobenzene
ug/L
1.0 ,
1.3
04/05/96
1,2-Dibromo-3-chloropropane
ug/L
1.0
ND
04/05/96
1,2,4-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Hexachlorobutadiene
ug/L
1.0
ND
04/05/96
1,2,3-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Benzene
ug/L
1.0
1.8
04/05/96
Toluene
ug/L
1.0
ND
04/05/96
Chlorobenzene
ug/L
1.0
17
04/05/96
Ethylbenzene
ug/L
1.0
ND
04/05/96
Xylenes
ug/L
1.0
ND
04/05/96
Styrene
ug/L
1.0
ND
04/05/96
Isopropylbenzene
ug/L
1.0
ND
04/05/96
n-Propylbenzene
ug/L
1.0
ND
04/05/96
1,3,5-Trimethylbenzene
ug/L
1.0
ND
04/05/96
t-Butylbenzene
ug/L
1.0
ND
04/05/96
1,2,4-Trimethylbenzene
ug/L
1.0
ND
04/05/96
s-Butylbenzene
ug/L
1.0
ND
04/05/96
4-Isopropyltoluene
ug/L
1.0
ND
04/05/96
n-Butylbenzene
ug/L
1.0
ND
04/05/96
Naphthalene
ug/L
1.0
ND
04/05/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analitical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle
Page 5
Client Reference: Shelby
April 09, 1996
PACE Project Number: A60327513
PACE Sample Number: 93 0190120
Date Collected: 03/27/96
Date Received: 03/28/96
Client Sample ID: Well #14
Parameter Units MDL DATE ANALYZED
ORGANIC ANALYSIS
VOLATILE ORGANICS
Dichlorodifluoromethane
ug/L
1.0
ND
04/05/96
Chloromethane
ug/L
1.0
ND
04/05/96
Chloroethene (Vinyl chloride)
ug/L
1.0
4.1
04/05/96
Bromomethane
ug/L
1.0
ND
04/05/96
Chloroethane
ug/L
1.0
ND
04/05/96
Trichlorofluoromethane
ug/L
1.0
ND
04/05/96
1,1-Dichloroethene
ug/L
1.0
ND
04/05/96
Dichloromethane
ug/L
1.0
3.2 B
04/05/96
trans-1,2-Dichloroethene
ug/L
1.0
ND
04/05/96
1,1-Dichloroethane
ug/L
1.0
ND
04/05/96
cis-1,2-Dichloroethene
ug/L
1.0
1.5
04/05/96
2,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Chloroform
ug/L
1.0
ND
04/05/96
Bromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1-Trichloroethane
ug/L
1.0
ND
04/05/96
1,1-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
Carbon tetrachloride
ug/L
1.0
ND
04/05/96
1,2-Dichloroethane
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethene
ug/L
1.0
ND
04/05/96
1,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Bromodichloromethane
ug/L
1.0
ND
04/05/96
Dibromomethane
ug/L
1.0
ND
04/05/96
cis-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
trans-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethane
ug/L
1.0
ND
04/05/96
1,3-Dichloropropane
ug/L
1.0
ND
04/05/96
Tetrachloroethene
ug/L
1.0
ND
04/05/96
Dibromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1,2-Tetrachloroethane
ug/L
1.0
ND
04/05/96
Bromoform
ug/L
1.0
ND
04/05/96
1,1,2,2-Tetrachloroetha-ie
ug/L
1.0
ND
04/05/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle
Page 6
Client Reference: Shelby
April 09, 1996
PACE Project Number: A60327513
PACE Sample Number: 93 0190120
Date Collected: 03/27/96
Date Received: 03/28/96
Client Sample ID: Well #14
Parameter Units MDL DATE ANALYZED
� t\\11 ��1,11'�•�
1,2,3-Trichloropropane
ug/L
1.0
ND
04/05/96
Bromobenzene
ug/L
1.0
ND
04/05/96
2-Chlorotoluene
ug/L
1.0
ND
04/05/96
4-Chlorotoluene
ug/L
1.0
ND
04/05/96
1,3-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,4-Dichlorobenzene
ug/L
1.0
5.3
04/05/96
1,2-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,2-Dibromo-3-chloropropane
ug/L
1.0
ND
04/05/96
1,2,4-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Hexachlorobutadiene
ug/L
1.0
ND
04/05/96
1,2,3-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Benzene
ug/L
1.0
2.2
04/05/96
Toluene
ug/L
1.0
ND
04/05/96
Chlorobenzene
ug/L
1.0
13
04/05/96
Ethylbenzene
ug/L
1.0
ND
04/05/96
Xylenes
ug/L
1.0
ND
04/05/96
Styrene
ug/L
1.0
ND
04/05/96
Isopropylbenzene
ug/L
1.0
ND
04/05/96
n-Propylbenzene
ug/L
1.0
ND
04/05/96
1,3,5-Trimethylbenzene
ug/L
1.0
ND
04/05/96
t-Butylbenzene
ug/L
1.0
ND
04/05/96
1,2,4-Trimethylbenzene
ug/L
1.0
ND
04/05/96
s-Butylbenzene
ug/L
1.0
ND
04/05/96
4-Isopropyltoluene
ug/L
1.0
ND
04/05/96
n-Butylbenzene
ug/L
1.0
ND
04/05/96
Naphthalene
ug/L
1.0
ND
04/05/96
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
A 54 Ravenscroft Drive
An
alytical nalytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle April 09, 1996
Page 7 PACE Project Number: A60327513
Client Reference: Shelby
PACE Sample Number: 93 0190138
Date Collected: 03/27/96
Date Received: 03/28/96
Client Sample ID: Travel
Parameter Units MDL Blank DATE ANALYZED
ORGANIC ANALYSIS
VOLATILE ORGANICS
Dichlorodifluoromethane
ug/L
1.0
ND
04/05/96
Chloromethane
ug/L
1.0
ND
04/05/96
Chloroethene (Vinyl chloride)
ug/L
1.0
ND
04/05/96
Bromomethane
ug/L
1.0
ND
04/05/96
Chloroethane
ug/L
1.0
ND
04/05/96
Trichlorofluoromethane
ug/L
1.0
ND
04/05/96
1,1-Dichloroethene
ug/L
1.0
ND
04/05/96
Dichloromethane
ug/L
1.0
3.2 B
04/05/96
trans-1,2-Dichloroethene
ug/L
1.0
ND
04/05/96
1,1-Dichloroethane
ug/L
1.0
ND
04/05/96
cis-1,2-Dichloroethene
ug/L
1.0
ND
04/05/96
2,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Chloroform
ug/L
1.0
ND
04/05/96
Bromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1-Trichloroethane
ug/L
1.0
ND
04/05/96
1,1-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
Carbon tetrachloride
ug/L
1.0
ND
04/05/96
1,2-Dichloroethane
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethene
ug/L
1.0
ND
04/05/96
1,2-Dichloropropane
ug/L
1.0
ND
04/05/96
Bromodichloromethane
ug/L
1.0
NO
04/05/96
Dibromomethane
ug/L
1.0
ND
04/05/96
cis-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
trans-1,3-Dichloro-l-propene
ug/L
1.0
ND
04/05/96
1,1,2-Trichloroethane
ug/L
1.0
ND
04/05/96
1,3-Dichloropropane
ug/L
1.0
ND
04/05/96
TetrachloroetKene
ug/L
1.0
ND
04/05/96
Dibromochloromethane
ug/L
1.0
ND
04/05/96
1,1,1,2-Tetrachloroethane
ug/L
1.0
ND
04/05/96
Bromoform
ug/L
1.0
ND
04/05/96
1,1,2,2-Tetrachloroethane
ug/L 1.0 ND 04/05/96
REPORT OF LABORATORY ANALYSIS
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without the written consent of Pace Analytical Services, Inc.

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54 Ravenscroft Drive
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Tel: [phone]
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Mr. Jamie Shytle
Page 8
Client Reference: Shelby
PACE Sample Number:
Date Collected:
Date Received:
Client Sample ID:
Parameter Units MDL
ORGANIC ANALYSIS
VOLATILE ORGANICS
April 09, 1996
PACE Project Number: A60327513
93 0190138
03/27/96
03/28/96
Travel
Blank DATE ANALYZED
1,2,3-Trichloropropane
ug/L
1.0
ND
04/05/96
Bromobenzene
ug/L
1.0
ND
04/05/96
2-Chlorotoluene
ug/L
1.0
ND
04/05/96
4-Chlorotoluene
ug/L
1.0
ND
04/05/96
1,3-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,4-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,2-Dichlorobenzene
ug/L
1.0
ND
04/05/96
1,2-Dibromo-3-chloropropane
ug/L
1.0
ND
04/05/96
1,2,4-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Hexachlorobutadiene
ug/L
1.0
ND
04/05/96
1,2,3-Trichlorobenzene
ug/L
1.0
ND
04/05/96
Benzene
ug/L
1.0
ND
04/05/96
Toluene
ug/L
1.0
ND
04/05/96
Chlorobenzene
ug/L
1.0
ND
04/05/96
Ethylbenzene
ug/L
1.0
ND
04/05/96
Xylenes
ug/L
1.0
ND
04/05/96
Styrene
ug/L
1.0
ND
04/05/96
Isopropylbenzene
ug/L
1.0
ND
04/05/96
n-Propylbenzene
ug/L
1.0
ND
04/05/96
1,3,5-Trimethylbenzene
ug/L
1.0
ND
04/05/96
t-Butylbenzene
ug/L
1.0
ND
04/05/96
1,2,4-Trimethylbenzene
ug/L
1.0
ND
04/05/96
s-Butylbenzene
ug/L
1.0
ND
04/05/96
4-Isopropyltoluene
ug/L
1.0
ND
04/05/96
n-Butylbenzene
ug/L
1.0
ND
04/05/96
Naphthalene
ug/L
1.0
ND
04/05/96
REPORT OF LABORATORY ANALYSIS
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without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
Analytical
��
54 Ravenscroft Drive
Pace
f a c e A n a l yt 1 c a I Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle
Page 9
Client Reference: Shelby
These data have been reviewed and are approved for release.
&4W'V'M'M4
fa r
Walter L. Miller
General Manager
April 09, 1996
PACE Project Number: A60327513
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
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Mr. Jamie Shytle FOOTNOTES April 09, 1996
Page 10 for pages 1 through 9 PACE Project Number: A60327513
Client Reference: Shelby
B Analyte is found in the associated blank as well as in the sample.
MDL Method Detection Limit
ND Not detected at or above the MDL.
REPORT OF LABORATORY ANALYSIS
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Pace Analytical Asheville, NC28801
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Fax: [phone]
Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 11 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090, 93 0190103, 93 0190120, 93 0190138
METHOD BLANK:
Method
Parameter
Units
MDL
Blank
-Dichlorodifluoromethane
ug/L
1.0
NO
Chloromethane
ug/L
1.0
NO
Chloroethene (Vinyl chloride)
ug/L
1.0
ND
Bromomethane
ug/L
1.0
NO
Chloroethane
ug/L
1.0
ND
Trichlorofluoromethane
ug/L
1.0
ND
1,1-Dichloroethene
ug/L
1.0
ND
Dichloromethane
ug/L
1.0
3.2 (1)
trans-1,2-Dichloroethene
ug/L
1.0
NO
1,1-Dichloroethane
ug/L
1.0
NO
cis-1,2-Dichloroethene
ug/L
1.0
NO
2,2-Dichloropropane
ug/L
1.0
NO
Chloroform
ug/L
1.0
NO
Bromochloromethane
ug/L
1.0
NO
1,1,1-Trichloroethane
ug/L
1.0
NO
1,1-Dichloro-l-propene
ug/L
1.0
NO
Carbon tetrachloride
ug/L
1.0
NO
1,2-Dichloroethane
ug/L
1.0
NO
1,1,2-Trichloroethene
ug/L
1.0
NO
1,2-Dichloropropane
ug/L
1.0
ND
Bromodichloromethane
ug/L
1.0
NO
Dibromomethane
ug/L
1.0
NO
cis-1,3-Dichloro-l-propene
ug/L
1.0
NO
trans-1,3-Dichloro-l-propene
ug/L
1.0
NO
1,1,2-Trichloroethane
ug/L
1.0
ND
1,3-Dichloropropane
ug/L
1.0
ND
Tetrachloroethene
ug/L
1.0
ND
Dibromochloromethane
ug/L
1.0
ND
1,1,1,2-Tetrachloroethane
ug/L
1.0
NO
Bromoform
ug/L
1.0
ND
1,1,2,2-Tetrachloroethane
1,2,3-Trichloropropane
ug/L 1.0 NO
ug/L 1.0 NO
REPORT OF LABORATORY ANALYSIS
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without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 12 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090, 93 0190103,
93 0190120, 93
0190138
METHOD BLANK:
Method
Parameter
Units
MDL
Blank
Bromobenzene
ug/L
1.0
ND
2-Chlorotoluene
ug/L
1.0
ND
4-Chlorotoluene
ug/L
1.0
ND
1,3-Dichlorobenzene
ug/L
1.0
ND
1,4-Dichlorobenzene
ug/L
1.0
ND
1,2-Dichlorobenzene
ug/L
1.0
ND
1,2-Dibromo-3-chloropro)ane
ug/L
1.0
ND
1,2,4-Trichlorobenzene
ug/L
1.0
ND
Hexachlorobutadiene
ug/L
1.0
ND
1,2,3-Trichlorobenzene
ug/L
1.0
ND
Benzene
ug/L
1.0
ND
Toluene
ug/L
1.0
ND
Chlorobenzene
ug/L
1.0
ND
Ethylbenzene
ug/L
1.0
ND
Xylenes
ug/L
1.0
ND
Styrene
ug/L
1.0
ND
Isopropylbenzene
ug/L
1.0
ND
n-Propylbenzene
ug/L
1.0
ND
1,3,5-Trimethylbenzene
ug/L
1.0
ND
t-Butylbenzene
ug/L
1.0
ND
1,2,4-Trimethylbenzene
ug/L
1.0
ND
s-Butylbenzene
ug/L
1.0
ND
4-Isopropyltoluene
ug/L
1.0
ND
n-Butylbenzene
ug/L
1.0
ND
Naphthalene
ug/L
1.0
ND
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
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Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 13 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090, 93 0190103, 93 0190120, 93 0190138
SPIKE AND SPIKE DUPLICATE:
Spike
930190120
Spike
Dupl
Parameter
Units
MDL
Well #14
Spike
Recv
Recv
RPD
Dichlorodifluoromethane
ug/L
1.0
ND
20
85%
80%
6%
Chloromethane
ug/L
1.0
ND
20
105%
105%
0%
Chloroethene (Vinyl chloride)
ug/L
1.0
4.1
20
95%
85%
11%
Bromomethane
ug/L
1.0
ND
20
80%
80%
0%
Chloroethane
ug/L
1.0
ND
20
85%
85%
0%
Trichlorofluoromethane
ug/L
1.0
ND
20
85%
80%
6%
1,1-Dichloroethene
ug/L
1.0
ND
20
85%
80%
6%
Dichloromethane
ug/L
1.0
3.2 B
20
54%
54%
0%
trans-1,2-Dichloroethene
ug/L
1.0
ND
20
90%
90%
0%
1,1-Dichloroethane
ug/L
1.0
ND
20
90%
90%
0%
cis-1,2-Dichloroethene
ug/L
1.0
1.5
20
78%
78%
0%
2,2-Dichloropropane
ug/L
1.0
ND
20
80%
75%
6%
Chloroform
ug/L
1.0
ND
20
85%
85%
0%
Bromochloromethane
ug/L
1.0
ND
20
95%
90%
5%
1,1,1-Trichloroethane
ug/L
1.0
ND
20
95%
90%
5%
1,1-Dichloro-l-propene
ug/L
1.0
ND
20
95%
90%
5%
Carbon tetrachloride
ug/L
1.0
ND
20
95%
90%
5%
1,2-Dichloroethane
ug/L
1.0
ND
20
95%
95%
0%
1,1,2-Trichloroethene
ug/L
1.0
ND
20
95%
90%
5%
1,2-Dichloropropane
ug/L
1.0
ND
20
95%
95%
0%
Bromodichloromethane
ug/L
1.0
ND
20
90%
90%
0%
Dibromomethane
ug/L
1.0
ND
20
95%
95%
0%
cis-1,3-Dichloro-l-propene
ug/L
1.0
ND
20
95%
90%
5%
trans-1,3-Dichloro-l-propene
ug/L
1.0
ND
20
95%
90%
5%
1,1,2-Trichloroethane
ug/L
1.0
ND
20
95%
95%
0%
1,3-Dichloropropane
ug/L
1.0
ND
20
95%
90%
5%
Tetrachloroethene
ug/L
1.0
ND
20
95%
90%
5%
Dibromochloromethane
ug/L
1.0
ND
20
95%
95%
0%
1,1,1,2-Tetrachloroethane
ug/L
1.0
ND
20
75%
75%
0%
Bromoform
ug/L
1.0
ND
20
90%
85%
6%
1,1,2,2-Tetrachloroethane
ug/L 1.0 ND 20 85% 85% 0%
REPORT OF LABORATORY ANALYSIS
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Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 14 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090 93 0190103, 93 0190120, 93 0190138
SPIKE AND SPIKE DUPLICATE:
Spike
930190120
Spike
Dupl
Parameter
Units
MDL
Well #14
Spike
Recv
Recv
RPD
1,2,3-Trichloropropane
ug/L
1.6
ND
20
957.
95%
0%
Bromobenzene
ug/L
1.0
ND
20
95%
90%
5%
2-Chlorotoluene
ug/L
1.0
ND
20
95%
95%
0%
4-Chlorotoluene
ug/L
1.0
ND
20
95%
95%
0%
1,3-Dichlorobenzene
ug/L
1.0
ND
20
100%
95%
5%
1,4-Dichlorobenzene
ug/L
1.0
5.3
20
94%
94%
0%
1,2-Dichlorobenzene
ug/L
1.0
ND
20
95%'
95%
0%
1,2-Dibromo-3-chloropro)ane
ug/L
1.0
ND
20
85%
80%
6%
1,2,4-Trichlorobenzene
ug/L
1.0.
ND
20
95%
95%
0%
Hexachlorobutadiene
ug/L
1.0
ND
20
100%
105%
5%
1,2,3-Trichlorobenzene
ug/L
1.0
ND
20
100%
100%
0%
Benzene
ug/L
1.0
2.2
20
99%
99%
0%
Toluene
ug/L
1.0
ND
20
105%
110%
5%
Chlorobenzene
ug/L
1.0
13
20
95%
100%
5%
Ethylbenzene
ug/L
1.0
ND
20
100%
100%
0%
Xylenes
ug/L
1.0
ND
60
97%
100%
3%
Styrene
ug/L
1.0
ND
20
105%
105%
0%
Isopropylbenzene
ug/L
1.0
ND
20
90%
95%
5%
n-Propylbenzene
ug/L
1.0
ND
20
95%
95%
0%
1,3,5-Trimethylbenzene
ug/L
1.0
ND
20
100%
110%
10%
t-Butylbenzene '
ug/L
1.0
ND
20
100%
105%
5%
1,2,4-Trimethylbenzene
ug/L
1.0
ND
20
100%
100%
0%
s-Butylbenzene
ug/L
1.0
ND
20
110%
110%
0%
4-Isopropyltoluene
ug/L
1.0
ND
20
95%
95%
0%
n-Butylbenzene
ug/L
1.0
ND
20
95%
100%
5%
Naphthalene
ug/L
1.0
ND
20
95%
105%
10%
REPORT OF LABORATORY ANALYSIS
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Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 15 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090, 93 01901.03, 93 0190120, 93 0190138
LABORATORY CONTROL SAMPLE:
Reference
Parameter
Units
MDL
Value
Recv
Dic lorodifluoromethane
ug/L
1.0
20
80%-
Chloromethane
ug/L
1.0
20
135%
Chloroethene (Vinyl chl)ride)
ug/L
1.0
20
90%
Bromomethane
ug/L
1.0
20
90%
Chloroethane
ug/L
1.0
20
85%
Trichlorofluoromethane
ug/L
1.0
20
85%
1,1-Dichloroethene
ug/L
1.0
20
85%
Dichloromethane
ug/L
1.0
20
80%
trans-1,2-Dichloroethene
ug/L
1.0
20
90%
1,1-Dichloroethane
ug/L
1.0
20
85%
cis-1,2-Dichloroethene
ug/L
1.0
20
75%
2,2-Dichloropropane
ug/L
1.0
20
80%
Chloroform
ug/L
1.0
20
85%
Bromochloromethane
ug/L
1.0
20
90%
1,1,1-Trichloroethane
ug/L
1.0
20
90%
1,1-Dichloro-l-propene
ug/L
1.0
20
90%
Carbon tetrachloride
ug/L
1.0
20
90%
1,2-Dichloroethane
ug/L
1.0
20
95%
1,1,2-Trichloroethene
ug/L
1.0
20
90%
1,2-Dichloropropane
ug/L
1.0
20
95%
Bromodichloromethane
ug/L
1.0
20
90%
Dibromomethane
ug/L
1.0
20
90%
cis-1,3-Dichloro-l-propene
ug/L
1.0
20
90%
trans-1,3-Dichloro-l-propene
ug/L
1.0
20
90%
1,1,2-Trichloroethane
ug/L
1.0
20
95%
1,3-Dichloropropane
ug/L
1.0
20
90%
Tetrachloroethene
ug/L
1.0
20
95%
Dibromochloromethane
ug/L
1.0
20
95%
1,1,1,2-Tetrachloroethane
ug/L
1.0
20
70%
Bromoform
ug/L
1.0
20
90%
1,1,2,2-Tetrachloroethane
1,2,3-Trichloropropane
ug/L 1.0
ug/L 1.0
20 85%
20 95%
REPORT OF LABORATORY ANALYSIS
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Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pr ae AnaIytIraI Asheville, NC28801
Tel: [phone]
Fax: [phone]
Mr. Jamie Shytle QUALITY CONTROL DATA April 09, 1996
Page 16 PACE Project Number: A60327513
Client Reference: Shelby
VOLATILE ORGANICS
Batch: 92 45355
Samples: 93 0190090, 93 0190103, 93 0190120, 93 0190138
LABORATORY CONTROL SAM KE:
Reference
Parameter
Units
MDL
Value
Recv
Bromobenzene
ug/L
1.0
20
90%
2-Chlorotoluene
ug/L
1.0
20
95%
4-Chlorotoluene
ug/L
1.0
20
90%
1,3-Dichlorobenzene
ug/L
1.0
20
100%
1,4-Dichlorobenzene
ug/L
1.0
20
90%
1,2-Dichlorobenzene
ug/L
1.0
20
90%
1,2-Dibromo-3-chloropropane
ug/L
1.0
20
80%
1,2,4-Trichlorobenzene
ug/L
1.0
20
95%
Hexachlorobutadiene
ug/L
1.0
20
110%
1,2,3-Trichlorobenzene
ug/L
1.0
20
100%
Benzene
ug/L
1.0
20
105%
Toluene
ug/L
1.0
20
115%
Chlorobenzene
ug/L
1.0
20
105%
Ethylbenzene
ug/L
1.0
20
105%
Xylenes
ug/L
1.0
60
103%
Styrene
ug/L
1.0
20
110%
Isopropylbenzene
ug/L
1.0
20
95%
n-Propylbenzene
ug/L
1.0
20
95%
1,3,5-Trimethylbenzene
ug/L
1.0
20
115%
t-Butylbenzene
ug/L
1.0
20
105%
1,2,4-Trimethylbenzene
ug/L
1.0
20
105%
s-Butylbenzene
ug/L
1.0
20
110%
4-Isopropyltoluene
ug/L
1.0
20
100%
n-Butylbenzene
ug/L
1.0
20
100%
Naphthalene
ug/L
1.0
20
110%
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

Pace Analytical Services, Inc.
54 Ravenscroft Drive
Pace Analytical Asheville, NC28801
Tel: [phone]
Fax:[phone]
Mr. Jamie Shytle FOOTNOTES April 09, 1996
Page -17 for pages 11 through 16 PACE Project Number: A60327513
Client Reference: Shelby
B Analyte is found in the associated blank as well as in the sample.
MDL Method Detection Limit
ND Not detected at or above the MDL.
RPD Relative Percent Difference
(1) Common laboratory contaminant.
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
1 •
® E H
DIVISION OF ENVIRONMENTAL
October 10, 1995
City of Shelby
Post Office Box 207
Shelby, North Carolina 28150
Attention: Mr. Don Rhom
RE: Notice of Regulatory Requirements
Permit N2 NCO027197
Incident #3637
Cleveland County, N.C.
Dear Mr Rhom:
A review of the subject permit and your compliance
monitoring data for March, July and November of 1994 and
and July of 1995 indicates that you are in violation of
following permit condition:
Permit Condition W III(B).states the permittee shall,
written notice from the Director of the Division of
Environmental Management, conduct groundwater monitor
may be required to determine the compliance of this N
permitted facility with the current groundwater stand
To date, analytical results for volatile organic comp
by EPA Method 502.2 have not been received for the da
listed above for wells G-7, G-8 and G-14. In additio
sample results for dissolved arsenic have not been re
for any of the dates listed above for well G-11.
The monitoring results also indicate that the total c
levels exceed the North Carolina 15A NCAC 2L groundwater s
of 1 per 100 milliliters. To ensure proper sampling of th
groundwater, you should closely monitor your QA/QC procedu
during the upcoming November sampling event.
ng as
DES
rds.
unds
es
01
eived
liform
andard
es
919 North Main Street, Mooresville, North Carolina 28115 , Telephone [phone] FAX 704.
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

You are requested to submit the analytical results li
above within 14 days of receipt of this letter or an expla
of why you cannot comply. It should be noted that the vio
cited above and any additional documented violations could
in the initiation of an enforcement action by this Office
accordance with General Statute 143-215.6A, which provides
$10,000 assessment of civil penalties for each violation.
day that the violation continues may be considered a separ
violation.
Should you have any questions concerning this Notice,
contact Steven Bograd at [phone], ext. 241.
Sincerely,
B. Keith Overcash, P.E.
Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
SEB
ted
ation
ation
result
n
for a
Each
to

State of North Carolina
Department of Environment,
Health and Natural Resources A14 • ie
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B._Howes, Secretary E H N
A. Preston Howard, Jr., P.E., Director
DIVISION OF ENVIRONMENTAL
October 10, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
City of Shelby
Post Office Box 207
Shelby, North Carolina 28150
Attention: Mr. Don Rhom
RE: Notice of Regulatory Requirements.
Permit If NCO027197
Incident #3637
Cleveland County, N.C.
Dear Mr Rhom:
A review of the subject permit and your compliance
monitoring data for March, July and November of 1994 and Ma:
and July of 1995 indicates that you are in violation of the
following permit condition:
Permit Condition W III(B) states the permittee shall,
written notice from the Director of the Division of
Environmental Management, conduct groundwater monitori
may be required to determine the compliance of this NP
permitted facility with the current groundwater standa
To date, analytical results for volatile organic compo
by EPA Method 50'2.2 have not been received for the dat
listed above for wells G-7, G-8 and G-14. In addition
sample results for dissolved arsenic have not been rec
for any of the dates listed above for well G-11.
ch
pon
g as
ES
ds.
nds
s
ived
The monitoring results also indicate that the total co iform
levels exceed the North Carolina 15A NCAC 2L groundwater standard
of T per 100 milliliters. To ensure proper sampling of the
groundwater, you should' -closely monitor your QA/QC procedures
during the upcoming November sampling event.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX 919-7X
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

You are requested to submit the analytical results li
above within 14 days of receipt of this letter or an expla.
of why you cannot comply. It should be noted that the vio
cited above and any additional documented violations could
in the initiation of an enforcement action by this Office
accordance with General Statute 143-215.6A, which provides
$10,000 assessment of civil penalties for each violation.'
day that the violation continues may be considered a separ
violation..
Should you have any questions concerning this Notice,
contact Steven Bograd at [phone], ext. 241.
Sincerely,
B. Keith Overcash, .E.
Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
SEB
ted '
ation
ation
result
n .
for a
Each
to

Of SyE,��.c
? sy�C�v. �G
CITY OF SHELBY
BOX 207 - WASHINGTON AT GRAHAM ST. - SHELBY NORTH CAROLINA 28151 - 0207
ENVIRONMENT; HEALTH,
& NATURAL RESOURCES
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. B. Keith Overcash, P.E.
Regional Supervisor
Post Office Box 950
919 North Main Street
Mooresville, North Carolina 28115
Dear Mr. Overcash:
OCT 1 6 1995
DIVISION OF I'tiV;itGi� � L L I. MIANI KIVNI7
MOORESVII.LE R;IrGINI, L OFF.TF
October 13, 1995
Enclosed.are the monitoring data for March, July, and November of
1994 and March and July of 1995.
I cannot explain the reasons for your not having these results; all
indications are that they were sent to DEM in a timely fashion.
I will assure you that all future data will be handled as specified
in Permit No. NC0027197, Section II, B.
Sinc.rely,
/�-
Don Rhom
Plant Engineer
DR j wh
Enclosures

ace.
I N C O R P O R A T E D
ENVIRONMENTAL LABORATORIES
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Additional Comments
Report To: / 1'"L le,
Bill To:
P.O. # / Billing Reference
Project Name / No.
CE PRESERVATIVES ANALYSES 11
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Pace Project Manager Pace Project No. 8 &o 2 J Z7r _) 3
'Requested Due Date:
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SEE REVERSE SIDE FOR INSTRUCTIONS

1. Complete all Client Information at top of sheet: name, address, phone, contact (person to whom
report will be sent and contact can be made if questions arise), billing information if different from
clierit, PO#, Project Name and/or Project Number as it will appear on the report.
2. PACE Client No., Project Manager and Project No. will be completed by PACE.
3. A separate COC must be filled out for each day of sample collection.
4. Sampler should print their name in the space provided -and sign their name followed by the date of
the sampling event.
5. Complete Sample Description as it will appear on the laboratory report; include time of sampling;
sample matrix, no. of containers and container types. i
6. Analysis Requested: Complete analysis on the lines provided and place a check in the column for
the samples requiring the analysis. It may be necessary to use the space provided for additional
comments or include attachments for extended lists of parameters.
7. Indicate method of shipment used for return of samples and date sent.
8. Submission of samples to laboratory: Indicate Item Number of. those samples being transferred;
sign relinquished by, and include your affiliation.
Standard Turnaround Time is 3-4 weeks.- If this does not satisfy your requirements,
arrangements must be made prior to samples being submitted to the laboratory. Contact your:
project manager.
Special Pgirements such as Low Level Detection Limits or level of QC reported must
be indicated on the chain of custody. (Use Additional Comments Section.)

DIVISION OF ENVIRONMENTAL MANAGEMENT
November 1, 1995
MEMORANDUM TO: Bob Cheek
FROM: Steven Bograd
SUBJECT: City of Shelby WWTP
The City of Shelby lagoon treatment facility was constructed
in December, 1985 on top of the old city landfill. The
Groundwater Section currently receives groundwater monitoring
reports from the permitted alum sludge lagoon system. The
reports are required as a condition of the North Carolina NPDES
Permit W 0027197. I have attached a summary of groundwater
monitoring results from March, 1992 to present and a site
location map. The data indicate that the elevated levels are
originating from the old landfill site and that water from the
lagoons is enhancing groundwater contamination. It does not
appear that the lagoons are lined.
On December 1, 1993, Rob Krebs, of the Mooresville Regional
Office, sent a similar memorandum to the Water Quality Section.
He stated that the State Superfund Section indicated a
willingness to be the lead agency addressing clean-up activities
at this site. However, they would only assume the responsibility
if the permitted activity ceased.
On June 1, 1994, NPDES Permit W NC0027917 was renewed to the
City of Shelby and will remain effective through December 31,
1998. Based on the past monitoring data and previous
recommendations from the Groundwater Section, it is recommended
that this permit not be renewed in 1998, or if possible be
revoked, so a cleanup of contaminated groundwater can be
initiated.
If you concur with this recommendation, please forward this
memorandum to the Water Quality Section, Central Office.
Should you have any questions, please feel free to call me
at 704/663-1699, extension 241.
attachments
SEB

DIVISION OF ENVIRONMENTAL MANAGEMENT
December 1, 1993
.MEMORANDUM TO: Coleen Sullins
Supervisor Permits and Engineering
Water Quality Section,.Raleigh
FROM: Robert Krebs
Groundwater Section
Mooresville Regional Office
THROUGH: Barbara Christian 4cl-
Groundwater Supervisor J13
Mooresville Regional Office
SUBJECT: City of Shelby
Al
Water Treatment Plant
NPDES Permit W NC0027197
The City of Shelby lagoon treatment facility was constructed
in December 1985 on top of the old city landfill. The
Mooresville Groundwater Section currently receives groundwater
monitoring reports from the permitted alum sludge lagoon system.
The reports are required as a condition of the North Carolina
NPDES Permit W 0021197. I have attached a summary of recent
groundwater, monitoring results with a site location map. The
data analysis suggests that the elevated contamination levels are
originating from the old landfill site and that water from the
lagoons is enhancing groundwater contamination from the landfill.
As you are aware the permit will expire on December 31, 1993 if
not renewed. The Groundwater Section has been in contact,with
the State Superfund Section regarding the clean-up
responsibilities for the subject site. They have indicated they
will be the lead agency addressing clean-up activities, but only
when the permitted activities have ceased. We therefore request
that the NPDES permit renewal be denied to the City of Shelby so
that the clean-up of the former city landfill can begin.
If you have any.questions, or need further information,
please feel free to contact me at [phone], ext. 241.
Attachments
cc: Bob Cheek - Groundwater Section, Raleigh
Tom Power - State Superfund Section
_RB,Kf TSiC

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DIVISION OF ENVIRONMENTAL MANAGEMENT
September 13, 1993
MEMORANDUM TO: Mike Kelly
State Superfund Section
Dexter Mathews
Solid Waste Section
FROM: Ro K brie s_0'_-'
Groundwater Section
Mooresville Regional Office
THROUGH: Barbara Christian
Groundwater Supervisor
Mooresville Regional Office
SUBJECT: City of Shelby
Water Treatment Plant
The City of Shelby lagoon treatment facility was constructed
in December 1985, on top of the old city landfill. The
Mooresville Groundwater Section currently receives groundwater
monitoring reports from the Alum Sludge Lagoon system. The
reports are required as a condition of North Carolina NPDES
Permit N2 0027197. I have attached a summary of recent
groundwater monitoring results with a site location map. The
data analysis suggests that the elevated contamination levels are
originating from the old landfill site. Therefore, jurisdiction
for the remediation and clean-up must be coordinated through the
proper agencies for environmental compliance.
If you have any questions, or need further information,
please feel free to contact me at [phone], ext. 241.
Attachments
RBK/sc
0

4'
DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM TO: Mike Kelly
State Superfund Section
Dexter Mathews
Solid Waste Section
FROM: Rob Krebs
Groundwater Section
Mooresville Regional Office
SUBJECT: Review of Potential Superfund, RCRA,
or Solid Waste Sites
. Please review the following site listed below, check one of the
boxes, and return a signed xerox copy to this Office.
This site qualifies as a Federal Superfund site, and the
State Superfund Section will be the lead agency.
This site qualifies as a State Superfund site, and the State
Superfund Section will be the lead agency.
This site qualifies as a RCRA site, and the Hazardous Waste
Section will be the lead agency.
This site qualifies as a closed or active solid waste
management facility and the Solid Waste Section will be the
lead agency.
The Division of Solid Waste Management will take this site
under study to determine if any Section will be the lead
agency and will respond in writing to Groundwater Mooresville
Regional Office immediately upon making the determination.
The site listed does not come under our jurisdiction and is
being referred back to the Mooresville Regional Office
Groundwater Section for investigation.
Signed IzC + -e�- Date 9 L 3 /93
Site to be Reviewed:
Name: Shelby Water Treatment Plant (Old City of Shelby
Landfill)
Location: SR 1305 Mailing Address:
Shelby, North Carolina 28150 City of Shelby
PO Box 207
Shelby, NC 28150
Attn: Don Rohm
MRO Contact: Robert B. Krebs
Contamination: See Attached
✓ Material Attached
c
Should you have any questions, please contact this Office at (704) 663-
1699.

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AUG Q 1993 yetay, �.
►��� �°' OF S H E L B Y
BOX 207 - WASHINGTON AT GRAHAM ST. - SHELBY, NORTH CAROLINA 28150
Mr. Rob Krebs August 4, 1993
DEM
919 North Main Street
Mooresville, North Carolina 28115
Dear Mr. Krebs:
In response to your letter dated July 27, 1993, I have enclosed a
map as you requested. This shows boundaries and well locations.
As you know these wells were placed in an old abandoned landfill
and the City had no control over what was buried there. The
analysis of the water taken from these wells reflect materials that
were already present and not anything that we may be discharging.
The two lagoons at the top of the hill receive the filter backwash
from the Water Treatment Plant; and do not contribute any hazardous
materials to the ground water.
If I can be of any assistance to you, please call me at
[phone].
Sincerely,
Don Rhom
Plant Engineer
DR:Jwh
I�
Enclosure

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O APPP-DX- L-OCAT/D/V 'OF SD/L -rE57- I30R/JVG APPP%jDX. SCALE, FT.

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Vivian Burke, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
July 27, 1993
CERTIFIED MAIL
RETURN RECEIPT REOUESTED
Shelby Water Treatment Plant
Post Office Box 207
801 West Grover Street
Shelby, North Carolina 28150
Attention: Don Rohm
RE: Notice of Regulatory Requirements
15A NCAC 2L Classifications and
Water Quality Standards Applicable
to the Groundwaters
Shelby Water Treatment Plant
NPDES Permit W NCO027197
Cleveland County, N.C.
Dear Mr. Rohm:
Chapter 143, North Carolina General Statutes, authorizes and
directs the Environmental Management Commission of the Department
of Environment, Health, and Natural Resources to protect and
preserve the water and air resources of the State. The Division of
Environmental Management has the delegated authority to enforce
adopted pollution control rules.
Based upon a review of your groundwater compliance monitoring
data submitted on May 6, 1993 as a requirement of the subject
permit., the Division has reason to believe that the permitted
activities have resulted in the groundwater standards being
exceeded. The'standards can be found at 15A NCAC 2L. National
Pollutant Discharge Elimination System Permit W NCO027197 Part II,
Section B(2) states:
The permittee shall take all reasonable steps to minimize
or prevent any discharge in violation of this permit
which has a reasonable likelihood of adversely affecting
human health or the environment.
Specific constituents which are exceeding the groundwater
standards are as follows:
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Shelby Water Treatment Plant
July 27, 1993
Page Two
Constituent
& Well No.
Date Sampled Concentration* 2L Standard*
Vinyl Chloride-G7
3/23/92
.0097
.000015
Vinyl Chloride-G8
3/23/92
.0062
.000015
Vinyl Chloride-G14
3/23/92
.0140
.000015
1,4-Dichlorobenzene-G7
3/23/92
.0048
.0018
1,4-Dichlorobenzene-GB
3/23/92
.0054
.0018
1,4-Dichlorobenzene-G14
3/23/92
.0059
.0018
Benzene-G14
3/23/92
.0025
.001
Arsenic-G7
3/23/92
.391
.05
Arsenic-G14
3/23/92
.326
.05
1,1,2-Trichloroethylene-G7
3/23/92
.0011
ND
Cumene-G8
3/23/92
.0080
ND
1,3,5-Trimethylbenzene-G14
3/23/92
.00081
ND
Total Coliformsi-G5
3/23/92
23
1.0
Total Coliformsi-G6
3/23/92
23
1.0
Total Coliformsi-G7
3/23/92
3.6
1.0
Total Coliformsi-G8
3/23/92
23
1.0
*Concentrations reported in parts per million
Total coliforms reported in colonies/100 milliliters
ND Not permitted in detectable concentrations
To achieve compliance with the above -cited laws or regulations
and your permit conditions, you are required to submit a
topographic map drawn to scale depicting the location of the waste
boundaries, all property boundaries, all monitor wells, and all
water supply wells located within 1500 feet of the permitted
activity. The above should be submitted within 60 days of receipt
of this letter. Based upon this information, the Groundwater
Section staff will determine what further actions, if any, are
required.
You should be aware, however, that a violation of 15A NCAC 2L
may subject you to a civil penalty assessment under the authority
of G.S. 143-215.6A of up to $10,000 per rule violation. Each day
that a violation continues may be considered a separate violation.
Failure to respond within the time specified and to voluntarily
achieve compliance may result in the recommendation of enforcement
action, including the issuance of a Special Order against you under
the authority of General Statute 143-215.2 and/or revocation of
your permit.

Shelby Water Treatment
July 27, 1993
Page Three
Your response and/or questions should be directed to Rob
Krebs.
Sincerely,
j
Brenda J. Smith, P.G.
Regional Supervisor
cc: Bob Cheek, Permits and Compliance Unit
Rex Gleason, Mooresville Water Quality Section
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Cy Of SyF�
yFtBY, MAR 1 8 1991
CITY OF SHELB YNOD � ON RESVIlEE REGIONAL OFFICI
BOX 207 - WASHINGTON AT GRAHAM ST. - SHELBY, NORTH CAROLINA 28150
March 15, 1991
Mr. Tony McManus
State of North Carolina
Division of Environmental Management
919 North Main Street
Mooresville, North Carolina 28115
Dear Mr. McManus:
In response to your letter of March 6, 1991, regarding the
monitoring wells and levels of total coliform.
As you know these monitoring wells are located in an old
abandoned land fill. Since we began monitoring them several years
ago, the coliform in these wells has fluctuated from none detected
to too numerous to count.
The results in question from samples collected during our last
sampling period were reported incorrectly. They should have been
reported as >16/100. As there were five (5) positive tubes per
well.
Your stiggestions concerning our QA/Qc procedures are well
t aken .
Thank you for your consideration in this matter.
Zerely,
Don Rhom,
Plant Engineer
DR:Jw
7 T pr>dlcAM
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gc 4,� a4c-

State of North Carolina
Department of Environment, Health, and' Natural Resources
Mooresville Reg oval Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT
March 6, 1991
Mr. Donald F. Rhom
City of Shelby
801 North Grover Street
Shelby, North Carolina 28150
Subject: Permit No. NCO027197
Groundwater Monitoring
Water Treatment Plant
City of Shelby
Cleveland County, N.C.
Dear Mr. Rhom:
The Groundwater Section of the Mooresville Regional Office
received the groundwater compliance monitoring reports for the
above referenced site on January 7, 1991. The results indicate
that the total coliform levels exceeds the North Carolina 15A NCAC
2L groundwater standard of 1 per 100 milliliters. All four wells
were reported with levels greater than 2400 per 100 milliliters.
To ensure proper sampling of the groundwater, you should
closely monitor your QA/QC procedures during your March sampling.
You are also required to submit a written explanation to this
Office by March 27, 1991 addressing this problem.
If you have any questions regarding this matter, I can be
reached at [phone].
Sincerely,
Tony McManus
Hydrogeological Technician
cc: Rex Gleason, Mooresville Water Quality Section
Bob Cheek, Groundwater Permitting and Compliance
TLM/pl