WQ0003902_Regional Office Historical File Pre 2018 (11)

=. E=' ROY COOPER
lv
do
GovernorMICHAEL S. REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
March 7, 2018
Mr. James Wentz, Public Works Director
City of Newton -
P.O. Box 550
Newton, North Carolina 28658 ,
Subject: Acknowledgement of Receipt of the 2016 Annual Report
City on Newton — Permit No.: WQ0003902
Land Application of Residuals
Catawba County
Dear Mr. Wentz:
The Mooresville Regional Office (MRO) received and reviewed the 2017 Annual Report for the
above permit.
The information provided in the annual report appears to be complete and in compliance with the
permit.
Should you have any questions, please contact Edward Watson at [phone] ext. 2198,.or by email
at [e-mail].
Sincerely,
Edward Watson, Hydrogeologist '
Mooresville Regional Office
Water Quality Regional Operations Section
r Division of Water Resources, NCDEQ
f
CC: Eric Jones, WWTP Superintendent (via email)
Eric Bruce, Synagro, LA Backup ORC (via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Water Resources
Environmental Quality
ROY COOPER
Governor
MICHAEL S. REGAN
-. Secretary
S. JAY ZIMMERMAN
Director
March 6, 2017
Mr. James Wentz, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Subject: Acknowledgement of Receipt of the 2016 Annual Report
City on Newton — Permit No.: WQ0003902
Land Application of Residuals
Catawaba County
Dear Mr. Wentz:
The Mooresville Regional Office (MRO) received and reviewed the 2016 Annual Report for the
above permit.
The facility was found to be in compliance with permitted activities. The attached inspection report
should be self-explanatory:
However, should you have any questions or concerns regarding the fmdings of the attached
report, please feel free to contact Edward Watson by email at [e-mail], or
phone at [phone].
Sincerely,
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section':
Division of Water Resources, NCDEQ
Attachments: Inspection Report
CC: Eric Jones, WWTP Superintendent (via email)
Eric Bruce, Synagro, LA Backup ORC (via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Compliance Inspection Report
Permit: WQ0003902 Effective: 06/01/15 Expiration: 05/31/20 owner: City of Newton 1
SOC: Effective: Expiration: Facility: City of Newton Residuals Land Application Program
County: Catawba PO Box 550
Region: Mooresville
Newton NC 28658
Contact Person: Martin D Wilson Title: Public Works Director Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/06/2017
Primary Inspector: Edward Watson
Secondary Inspector(s):
Certification: Phone:
Entry Time: 11:OOAM Exit Time: .03:OOPM
Phone:
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page: 1

Permit: WQ0003902 Owner - Facility: City of Newton
Inspection Date: 03106/2017 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
This is an AR review only. The information submitted appears to be in compliance with the permit.
The review also indicates that A&L Eastern Laboratoires is now Waypoint Analytical.
Sampling is conducted by Waypoint Analytical. Waypoint does not provide a C.O.0 to the facility.
Page: 2

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Permit: WQ0003902 Owner - Facility: City of Newton
Inspection Date: 03/06/2017 Inspection Type: Annual Report Review Reason for Visit: Routine
Record Keeping Yes No NA NE
Do lab sheets support data reported on Residual Analysis Summary? M ❑ ❑ ❑
Are hauling records available? ❑ ❑ ❑
Are hauling records maintained and up-to-date? ❑ ❑ ❑ 0
# Has permittee been free of public complaints in last 12 months? M ❑ ❑ ❑
Has application occurred during Seasonal Restriction window? ❑ 0 ❑ ❑
Comment: This is an review of the 2016:Annual Report only. A site inspection was performed in late
January of this year.
Treatment
Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
Compost
❑
Drying Beds
❑
Other
❑
Comment:
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Page: 4

unv rnnuFu
�5
Water Resources
Environmental Quality
November 6, 2017
Mr. Martin D. Wilson, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658:
Subject: Inspection Report
City on Newton —Permit No.:
Land Application of Residuals
Catawaba County
Dear Mr. Wentz:
Governor
MICHAEL S. REGAN
Secretary
LMA CULPEPPER
Interim Director
WQ0003902
The Mooresville Regional Office (MRO) performed a routine compliance inspection for the
above mention_ facility The facility was found to be incompliance with permitted activities.
The attached inspection report should be self-explanatory. However, should you have any
questions or concerns regarding the findings of the attached report, please feel free to contact
Edward Watson by email at [e-mail], or phone at.[phone].
Sincerely,
4UwarZdCats-
on; �?d=�logist
Mooresville Regional. Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachments: Inspection Report
CC: Eric Jones, WWTP Superintendent (via email)
Eric Bruce, Synagro; LA Backup ORC (via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Compliance Inspection Resort
Permit: WQ0003902 Effective: 06/01/16 Expiration: 05/31/20 Owner: City of Newton .
SOC: Effective: Expiration: Facility: City of Newton Residuals Land Application Program
PO Box 550
County: Catawba
Region: Mooresville
Newton NC 28658
Contact Person: Martin D Wilson Title: Public Works Director Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/26/2017 Entry Time: 10:OOAM Exit Time: 12:OOPM
Primary Inspector: Edward Watson Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Land Application Site Pathogen and Vector Attraction Storage
Transport
(See attachment summary)
Page: 1

permit: W00003902
Inspection Date: 10/26/2017
Owner - Facility: City of Newton
Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On October 27, 2017, a review of the RLAP for the City of Newton, NC was performed by MRO staff.
During the site visit the digesters were reviewed prior to traveling to the application fields.
There is significant build up on the side walls of Digester 2 which is reducing the holding capacitiy of the tank. Please
reduce the caked material to maximize tank capacity.
During the site visit fields, 7 & S received residual materials. The fields were buffered in accordance with permit directives.
The residual material appeared to be being applied in an even manner and care was taken not to allow residual material to
be tracked onto the road upon traveling to a separate field.
It was requested that an additional sign be placed at the enterance to the field on Hickory - Lincoln Highway
Page: 2

Permit WQ0003902 Owner - Facility: City of Newton
Inspection Date: 10/26/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ M ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ 0 ❑
Are there any GW quality violations?
❑ ❑ N ❑
Is GW-59A certification form completed for facility?
❑ ❑ M ❑
Is a copy of current permit on -site?
0 ❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
0 ❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
M ❑ ❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑ ❑ ❑ M
Are there pH records for alkaline stabilization?
M ❑ ❑ ❑
Are there pH records for the land application site?
❑ ❑ ❑
Are nutrient/crop removal practices in place?
❑. ❑ ❑ M
Do lab sheets support data reported on Residual Analysis Summary?
0 ❑ ❑ ❑
Are hauling records available?
M ❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has pernittee been free of public complaints in last 12 months?
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑ M ❑ ❑
Comment: VAR is by lime stabilization. The lab analytical data was reviewed durinq the site visit and
appears to be in order. No exceedances were noticed in the laboratory analytical data.
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
❑ ❑ 0 ❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class 8<2.0'10E6 CFU/dry gram
❑
Fecal coliform SM 9222 D (Class B only)
❑ ❑ 0 ❑
Geometric mean of 7 samples per monitoring period for class B<2.0'10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑ 0 ❑ ❑
c. pH records for alkaline stabilization (Class B)
M ❑ ❑ ❑
Temperature corrected
Page: 3

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permit: WO0003902 Owner - Facility: City of Newton
Inspection Date: 10/26/2017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Is the application site free of odors or vectors? ❑ ❑ ❑ \
Have performance requirements for application method been met?
For injection? ❑ ❑ M ❑
For incorporation? ❑ ❑ 0 ❑
Does permit require monitoring wells? ❑ 0 ❑ ❑
Have required MWs been installed? ❑ ❑ 0 ❑
Are MWs properly located wl respect to RB and CB? ❑ ❑ 0 ❑
Are MWs properly constructed (including screened interval)? ❑ ❑ M ❑
Is the surrounding area served by public water? ❑ 0 ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ M ❑
Are soil types consistent w/ Soil Scientist report/evaluation? 0 ❑ ❑ ❑
Is the water table greater than V/3' bls. ❑ ❑ ❑ M
Is application occurring at the time of the inspection? M ❑ ❑ ❑
Comment: The soil readily absorbed the applied material Some flys were noticed during the land
application event However they were not present in signifcant numbers. No odor was present
except at immediate application The areas where application had already been performed did
not have any odor. No run-off was observed during the site visit.
Page: 5

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
January 28, 2002
Jay C. Stowe, PE
City of Newton
P.O. BOX 550
Newton, NC 28658
Ad
NCD.ENW
OF F:F1VM.t1NWAEMT
R.I3`. . ',!R.CES
NORTH CAROLINA DEPARTMEWK,61F'11�' ^'r`s~iIC`G
ENVIRONMENT AND NATURAL RESOURCES
Subject: Annual Monitoring and Reporting Requirements =
Treatment and Land Application of Residuals
Permit Number: WQ0003902
City of Newton
Catawba County
Dear Jay C. Stowe, PE,
E E 0 0 4 2002
The purpose of this letter is a reminder that the monitoring reports required by the subject permit must be
submitted as an Annual Report for calendar year 2001 by no later than March 1, 2002. The report must be
submitted (in triplicate) to the following address:
DENR/DWQ/Water Quality Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Due to limitations in storage space, please submit the reports in bound form rather than in notebook form.
Permittees are subject to civil penalty for failing to submit the Annual Report as required by their permit.
Enclosed are the summary and certification sheets that must be used for your annual report depending on
whether your residual is Class A or Class B. Please complete the nessesarry sheets and if necessary make
copies of the blank forms if extras are needed. "The forms have not changed since last year (although minor
aesthetic changes have been made) so you may use those you already have on hand.
You will however note that the forms include information required by EPA as outlined in 40 CFR Part
503. Since the requirements of 40 CFR Part 503 are self implementing, they are legally binding and
enforceable Federal requirements for all persons subject to the requirements of 40 CFR Part 503, even if
these requirements are not currently contained in the state permit. The annual reports for the EPA must be
received by EPA at the following address on or before February 19, 2002.
Hector Danois
Clean Water Act Enforcement Section
Water Programs Enforcement Branch
Water Management Division
U.S.EPA Region 4
61 Forsyth Street, S.W.
Atlanta, Ga. 30303-3104
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Annual Monitoring and Reporting Requirements
Page 2
If there is a need for any information or clarification on the State reporting requirements, please do not
hesitate to contact Daryl Merritt at [phone] extension 581. For further information on the Federal
requirements, you should call Madolyn Dominy of the Environmental Protection Agency at 404-562-9305.
Sincerely,
DaryMerritt,
Environmental Specialist I
cc: Vince Miller, EPA Region IV
MRO Water Quality Supervisor
Non Discharge Compliance / Enforcement File
Central Files

L L,
� a
Water Resources
Environmental Quality
January 31, 2017
Mr. James Wentz, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Dear Mr. Wentz:
ROY. COOPER
Governor
MICHAEL S. REGAN
Secretary
S. JAY ZEVIMERMAN
Director
Subject: Inspection Report
City on Newton — Permit No.: WQ0003902
Land Application of Residuals
Catawaba County .
The Mooresville Regional Office (MRO) performed a routine compliance inspection for the
above. mention facility The facility was found to be in compliance with permitted. activities.
The attached inspection report should be self-explanatory. However, should you have any
questions or concerns regarding the findings of the attached report, please feel free to contact
Edward Watson by email at edward.watson&,ncdenr.gov, or phone at [phone].
Sincerely,
Edward Watson, drogeologist
Mooresville, Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachments: Inspection Report
CC: Eric Jones, WWTP Superintendent (via email)
Eric Bruce, Synagro; LA Backup ORC (via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East'Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Compliance Inspection Report
Permit: WQ0003902 Effective: 06/01/15 Expiration: 05/31/20 owner: City of Newton
SOC: Effective: Expiration: Facility: City of Newton Residuals Land Application Program
County: Catawba PO Box 550
Region: Mooresville
Newton NC 28658
Contact Person: Martin D Wilson Title: Public Works Director Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/27/2017
Primary Inspector: Edward Watson
Secondary Inspector(s):
Entry Time: 01:44PM
Certification:
Phone:
Exit Time: 04:OOPM
Phone:
Maria Schutte
Reason for Inspection: Routine Inspection Type: Compliance Evaluation.
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Land Application Site Pathogen and Vector Attraction
(See attachment summary)
Page: 1

Permit: WQ0003902 Owner - Facility: City of Newton
Inspection Date: 01/27/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On January 27, 2017, staff of the MRO performed a routine compliance inspection for the Newton WWTP Land Application
of Residuals Program. The permit was reviewed along with the residuals process.
This facility produces a Class B residual product and vector and pathogen reduction is performed by lime stabilization.
During the site visit, the digesters were reviewed. pH stabilization is not performed on the residual material until just before
land application is scheduled to occur. This would account for the odor present in the digesters.
It was noted that the digesters were near the two foot free board limit. Mention was made that the side wall built up in the
digesters needed to be cleaned up after the land application was completed to be able to maintain adequate free board in
the digesters.
Field NC-CA-20-09 was observed during the site visit. Previous application of residuals had occured, but was not
completed on this field. The buffers were clearly marked and appeared to be in compliance with the permit.
Overall, the facilty was found to be in compliance with the permit
Page: 2

Permit: WQ0003902 Owner - Facility: City of Newton
Inspection Date: 01/27/2017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Land Application Site Yes No NA NE
Is a copy of the permit on -site during application events? ❑ ❑ []
Is the application site in overall good condition?
Is the site free of runoff/ponding? 0 El El Q
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
El El 0 El
Are there access restrictions and/or signs?
moo R
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
0 El M El
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
M
Is the surrounding area served by public water?
El M El R
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
❑ M
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
❑
Comment: Application field was is good condition. Rain gauge was in place. Buffers seems to be
adequately established.
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
El
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
0 ❑
Temperature corrected
Page: 3

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Permit: WQ0003902 Owner - Facility: City of Newton
Inspection Date: 01/27/2017 Inspection Type : Compliance Evaluation
Sampling
Describe sampling:
Sampling of residuals was perfomed prior to application. Sampling data was reviewed to the extent that data
was available.
Is sampling adequate?
Is sampling representative?
Comment: Sampling was not observed.
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: Reduction by Lime Stabilization.
Type
Distribution and Marketing
Land Application
Reason for Visit: Routine
Yes No NA NE
❑❑■❑
❑❑■❑
Yes No NA NE
Yes No NA NE
Page: 5

North Carolina Department of Environmental Quality � -L3
Pat McCrory
Governor
Mr.James Wentz, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Dear Mr. Wentz:
Donald R. van der Vaart
Secretary
October 19, 2015
Subject: Non -Discharge Permit Inspection
City of Newton - Permit No.: WQ0003902
Land Application of Residuals
Lincoln County
Maria Sc u to of the Moo Ulf Regional Office (MRO) viewed a.land application event on October 15u', 2015 at field
ID # NC 19-01 in County, which is the first inspection of a land application of residuals from Newton's
Clark Creek WWTP, since their 2014 permit renewal. The WWTP facility was not inspected.
f—
Field conditions noted at time of inspection:
Y-yes N-no NE -not evaluated NA -not applicable
Y Permit on site during application
Y Buffers adequate
Y Site condition adequate
*N Signs of runoff / ponding
Y Signage posted
Y Spill plan on site
Y Cover crop specified in permit
N Documented exceedances of PAN limits
Y Rain gauge on site during application
Are there any limiting slopes on fields?
Y 10 % for surface application NA 18% for subsurface application
Odors present: Odors were detected. Vectors present: Flies were detected.
Comments: The City of Newton contracts with Synagro for land application. I would like to thank Mike Cox (Synagro)
for his time during the inspection. * This material is a lime stabilized liquid. The "fresh" application appears to pond,
but was not running. This source also typically has odors. A nearby field applied earlier in the week was viewed from
the road and odors were not detected on the apparently dried application.
I may be reached by phone at [phone] or email (maria.schutteCa)ncdenr.gov) should you have questions about
this inspection or the permit.
Sincerely, N
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
CC: James E. Jones, WWTP & LA ORC (email)
Will Hodges, Synagro (email)
Mike Cash, Catawba County Environmental Health (email)
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] \ Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer — Made in part by recycled paper

Pat McCrory
Governor
A44
-
NCDENR
North Carolina Department of Environment and Natural Resources
February 18, 2015
Mr. James Wentz, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Dear Mr. Wentz:
Donald van der Vaart
Secretary
Subject: Non -Discharge Permit Inspection
City of Newton — Permit No.: WQ0003902
Land Application of Residuals
Catawba County
Enclosed you will find the report for the compliance inspection that was conducted on
January 28th, 2015 in conjunction with the permit renewal for the City of Newton's land
application program. The inspection- included the WWTP residuals processing and storage
areas and a records review. I would like to thank Danny Sigmon for his time during the
inspection.
The updated "Water Pollution Control System Operator Designation Form", requested for
the land application program, was received from Mr. Sigmon via email on February 3rd
2015.
The attached report should be self-explanatory; however, should you have questions,
please contact me by phone [phone]) or email (maria.schutte(aD-ncdenr.gov).
Sincerely,
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
Attachment(s): WQ0003902 Inspection Report
cc: Danny Sigmon, WWTP Superintendent (email)
Ed Hardee, Residuals Management, CO-LAU (email)
Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115
Phone: [phone] / Fax: [phone]/Customer Service 1-877-623-6748
Internet: www.ncdenr.gov
An Fn-1 On. 4rt i+v 1 MR, +iv. Arlin. Fmn1— _ M.H. in n.r+ by m vnled nnnor

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Resources
Pat McCrory, Governor
Donald van der Vaart, Secretary
VRIA�
AP-
NGDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton County: Catawba
Permit No.: WQ0003902 Issued: 04/01/2010 Expiration: 05/31/2015
Permittee Contact: James Wentz (Public Works Director) Telephone No.: 828-695-4310
LA ORC Name: Robert"Mike" Cox (SYNAGRO) LA#13191 Telephone No.: 704-718-2804
LA B/U: Will Hodges (SYNAGRO) LA#997282 Telephone No.: 864-871-3157
Contact & LA B/U: DanU Si mon WWTP Supervisor) LA#25008 Telephone No.: 828-695-4346
Email: DSigmon a newtonnc. og_v
LA B/U: James -Jones (WWTP Operator) LA#25000 Telephone No.: 828-695-4370
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Date(s): ' January 28, 2015
Inspection Summary: (additional comments may be included on attached pages)
This inspection was conducted in conjunction with the permit renewal, and included a records review and
tour of residuals processing and storage at the Clark Creek WWTP.
Data records and internal logs were found to be in good order. The residuals storage was quite full. Land
application activities started the week before were halted by the contractor (SYNAGRO), while they
addressed concerns at another facility. LA activity for Newton was restarted the following week.
Please note:
• The City of Newton LA permit was recently renewed and will go into effect on June 1, 2015, with a
new expiration date of May 31, 2020.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary _yes X no
Inspector(s): Maria Schulte -Environmental Specialist
Telephone No.: 704-663-1699 Fax No.: 704-663-6040
Date of Inspection: January 28th, 2015

Residuals Inspection
WQ0003902 City of Newton - Catawba County
pg. 2
Type of Residual
X Land Application (class B)
Record Keeping
Y-yes N-no N/A -not applicable
Distribution and Marketing (class A)
N/E-not evaluated
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (see permit for frequency)
Y TCLP analysis, * Y SSFA (Standard Soil Fertility Analysis)
Y Nutrient and metals loading calculations (to determine most limiting parameter) YTD
Y Hauling records (# gal and/or ton hauled during calendar year to date)
* Y Field loading records, Y Field site maps and information (w/Renewal Package)
NA Records of lime purchased (Facility manufactures lime slurry onsite for lime stabilization)
Y Pathogen & Vector Attraction Reduction (Fecal analyses were done for the renewal application)
Comments: * Some information was reviewed as part of the 2013 Annual Report and was not reviewed
again during this inspection Residuals records appeared to be in good order at the time of inspection.
Pathogen & Vector Attraction Reduction (PVAR) records
Fecal coliform
_ SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0*10' CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0* 106 CFU / dry gram)
Salmonella (Class A, all tests must be < 3MPN / 4 grams dry
Time / Temp records
Digester (MCRT) Compost Class A lime stabilization
Volatile solids calculations
Bench -top aerobic/anaerobic digestion results
pH records for lime stabilization ( Class A or B) X
SOUR calculations
Treatment
X Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
X Alkaline Stabilization Lime Other -describe
Comments: This facility lime stabilizes residuals with slurry made in-house to meet PVAR requirements.
Odors and vectors were not detected at the time of this inspection.
Transport No land application was taking place during this inspection.
Spill control plan in transport vehicle? NA
Does transport vehicle appear to be maintained? NA

Residuals Inspection pg. 3
WQ0003902 City of Newton - Catawba County
Storage
Number of days/weeks/months of storage: Per prior inspections the time frame is uncertain - approximately
several months. Newton typically land applies every 2-3 months.
Describe storage: The Clark Creek WWTP has our sludge holding tanks (per previous inspection reports
220 000 gallons each), but one is used for Conover sludge residuals, until they are sent to the Hickory
compost facility. The remaining three tanks store in-house residuals.
Odors present N Vectors present N
Comments: Odors and vectors were not detected at the time of inspection; however, odors are typical
with this lime -stabilized product.
Sampling
Describe Sampling: There was no active LA at the time of inspection — sampling was not observed.
Sampling and analyses for the lime stabilization are conducted in-house. Additional residuals sampling
requirements are conducted by their LA contractor, SYNAGRO.
Is sampling adequate? Y Is sampling representative? NE ff protocol is followed than sampling should be
representative. )
Field Sites (end use for class B biosolids) There was no active land application at the time of this
inspection.
Field Identification: NA
Permit on site during application _ Spill plan on site
_ Buffers adequate _ Cover crop specified in permit
Documented exceedances of PAN limits_ Site condition adequate
Signs of runoff / ponding _ Rain Gauge on site during application
Are there any limiting slopes on fields?
10 % for surface application _ 18% for subsurface application
Monitoring well(s) Y/N: NA
If yes, location of well(s):
Comment: This permit currently does not require groundwater monitoring. There were MWs associated
with this facility at one time; however, per conversation with Danny Sigmon those fields predated the
existing LA program and have been out of their permit for years. He was unsure of the Ws status.
Odors/vectors No active land application was taking place duringthspection.
Describe any nuisance conditions and any corrective actions needed. NA
Odors present NA
Vectors present NA
Other noted conditions

'v
4-
Way%
CDE R
N TI 14a C��
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory Thomas A, Reeder John Skvarla
Governor Director Secretary
January 30, 2014
Mr. Wilce B. Martin, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Subject: Non -Discharge Permit Inspection
City of Newton - Permit No.: WQ0003902
Land Application of Residuals
Catawba County
Dear Mr. Martin:
Enclosed you will find the report for the compliance inspection that was conducted on
January 9th, 2014 for the City of Newton's land application program. The inspection included the
WWTP residuals processing and storage, and a land application event at field NC-CA-20-07. The
MRO would like to thank Matt Herman (VW TP operator) for his time touring the facility, and Will
Hodges (SYNAGRO) for his time at the application site.
The land application event appeared to meet requirements of the permit at the time of
inspection; however, there are a couple of issues to address at the WWTP facility to maintain
overall compliance with the conditions of your permit.
• A copy of the current permit with the Operation and Maintenance Plan, which includes
the spill plan, should be kept in a location easily accessible to all employees. The
MRO was unable to view the permit and all recent analytical data at the facility, because files
were in a locked office. The MRO recognizes this issue was the result of unforeseen
circumstances, and appreciates the effort your staff (Jim Rumley and Jennifer Lane) put forth
in attempting to locate a key; however, the situation emphasizes the main point.
• All residuals storage units should maintain 2 feet of freeboard. Storage tank #1
appeared to be within the 2 foot limit at the time of inspection.
• Please note the current permit is set to expire on 05131/2015, which means the renewal
application package is due for submittal by 11/30/2014 (180 days prior to expiration).
The attached report should be self-explanatory; however, if you have any questions
concerning this report or your' permit renewal, I may be reached at [phone].
Division of Water Resources / Water Quality Regional Operations Section / Mooresville Regional Office One 1'
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 NQ1'Ci1CaTOI111a
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 /
Internet: www.nGwater.org Na'ttra'`L �/
An Equal Opportunity1 Affirmative Action Employer �/

Sincerely, n
Maria Schulte
Environmental Specialist
cc: Danny Sigmon, WWTP Superintendent (email)
Will Hodges, Synagro (email)
Chonticha McDaniel, Residuals Management, CO-LAU (email)

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Resources
Pat McCrory, Governor
John Skvarla, Secretary
Thomas A. Reeder, Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton County: Catawba
Permit No.: WQ0003902 Issued: 04/01/2010 Expiration: 05/31/2015
Permittee Contact: Wilce B. Martin (Public Works Director) Telephone No.: 828-695-4310
LA-ORC Name: Danny Sigmon #25008 Telephone No.: 828-695-4313
LA-B/U ORC Name: James Eric Jones #25000 Telephone No.: 828-695-4313
LA Contractor: William K. Hodges #997282 (SYNAGRO) Telephone No.: 864-871-3157
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Date(s): December 5, 2013
Inspection Summary: (additional comments may be included on attached paces)
This inspection covers permit #WQ0003902 (Class B - 503 Residuals), and included a records review,
residuals handling and storage at the Clark Creek WWTP, and a land application event at field NC-CA-
20-07.
The Mooresville Regional Office (MRO) was able to review a copy of the permit and some records at the
land application site, and lime stabilization records at the WWTP lab, all of which appeared to be in order
and meet permit requirements; however, as noted in the cover letter, not all records were available for
review, as they were located in a locked office. The MRO recommends at the very least, a cop o� f the
current permit and spill plan be located in an area easily accessible to all emplovees, in case of a shill
incident.
The land application event at field NC-CA-20-07 appeared to be in accordance with permit requirements.
These residuals are lime stabilized and some strong odors were noted in the field and at the WWTP storage
tanks. Residuals tank #1 appeared to be within the two foot freeboard, and as noted in the cover letter,
residuals/freeboard levels should be maintained accordingly to remain compliant.
The current permit will expire on 05/31/15. A renewalapplication is due 180 days prior to expiration.
Is a follow-up inspection necessary _yes X no
Inspector(s): Maria Schulte - Environmental Specialist
Telephone No.: 704-663-1699 Fax No.: 704-663-6040
Date of Inspection: January 9 h, 2014

Residuals Inspection pg 2
WQ0003902 City of Newton
Type of Residual
X Land Application (class B)
Record Keeping
Y-yes N-no NE -not evaluated
NA -not applicable
Distribution and Marketing (class A)
N Copy of current permit available at residual generating site
* Y Current metals and nutrient analysis (see permit for frequency)
N TCLP analysis, * Y SSFA (Standard Soil Fertility Analysis)
Y Nutrient and metals loading calculations (to determine most limiting parameter) YTD
N Hauling records (# gal and/or ton hauled during calendar year to date)
* Y Field loading records, * Y Field site maps and information
NE Records of lime purchased
* Y Pathogen & Vector Attraction Reduction
* Comments: Soil analyses and field loading sheets were reviewed in the 2012 Annual Report and were not
requested for review during this inspection. Some records were viewed at the application site and lime
stabilization records were available at the WWTP. Due to unforeseen circumstances most records at the
acility were unavailable for review, as they were located in a locked office. The MRO recommends that the
current permit and spill plan be available for easy access by all employees.
Pathoizen & Vector Attraction Reduction records
Fecal coliform
SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0* 106 CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0* 106 CFU / dry gram)
Salmonella (Class A, all tests must be < 3MPN / 4 grams dry
Time / Temp records
Digester (MCRT) Compost Class A lime stabilization
Volatile solids calculations
Bench -top aerobic/anaerobic digestion results - 30 day benc
pH records for lime stabilization ( Class A or B) X
SOUR calculations
Comments:
Treatment
X Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
X Alkaline Stabilization Lime Other -describe
Comments: This facility lime stabilizes residuals, with slurry made in-house, to meet PVAR requirement.
Residuals do exhibit a strong odor, but vectors were not detected in the treatment/storage areas or at the land
application site.

Residuals Inspection pg 3
WQ0003902 City of Newton
Transport Active application was taking place at the time of inspection. A copy of the permit and spill plan
was available at the field site with SYNAGRO representative, Will Hodges, but was not requested from the
transport vehicle.
Spill control plan in transport vehicle? NE
Does transport vehicle appear to be maintained? Y
Storage
Number of days/weeks/months of storage: Time frame is uncertain, approx. several months of storage. Newton
typicallyland and applies every 2-3 months.
Describe storage: The Clark Creek WWTP has four sludge holding tanks (per previous inspection reports
220,000 gallons each), but one is used for Conover sludge residuals until they are sent to the Hickory compost
facility. The remaining three tanks store in-house residuals.
Odors present Y Vectors present N
Comments:
Sampling
Describe Sampling: Residuals sampling is handled by SYNAGRO in accordance with the permit
requirements.
Is sampling adequate? Y Is sampling representative? NE
Field Sites (end use for class B biosolids) See comments
Field identification:
Y Permit on site during application
Y Buffers adequate
N Documented exceedances of PAN limits
N Signs of runoff / ponding
Are there any limiting slopes on fields?
Y Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
Y Rain Gauge on site during application
Y 10 % for surface application 18% for subsurface application
* Comment: Active application was taking place during this inspection at field NC-CA-20-07. Buffers
appeared adequate and overall the field appeared to be in good condition. There are noticeable odors with this
material, but vectors were not detected at the time of inspection.
Monitoring well(s) Y/N: NA
If yes, location of well(s):
Comment: This permit does not require groundwater monitoring
Odors/vectors
Describe any nuisance conditions and any corrective actions needed. NA
Odors present Y
Vectors present N
Other noted conditions

Page 1 of 3
Google Maps 610 E Center Ave, Mooresville; NC 28115 to
1407 McKay Farm Rd, Newton, NC 28658
Drive 36.5 miles, 1 h
Imagery ©2015 Burke County, DigitalGlobe, Landsat, Orbis Inc, U.S. Geological Survey, USDA Farm Service Agency, .1 mi a °
Map data ©2015 Google
610 E Center Ave
Mooresville, NC 28115
Take NC-150 Wand E Maiden Rd to Maiden
Salem Rd in Lincolnton
-----4�ttn-(28.0 mi)
t 1. Head west on E Center Ave toward
Cedar St
5 mi
2.
Turn left onto S Church St
397 ft
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3.
Turn right onto E McLelland Ave
- 1 mi
41
4.
Turn left onto NC-150 W/E Plaza Dr
.Continue to follow NC-150 W
-- ---
14.7 mi
P'
5.
Turn right onto E Maiden Rd
-- 7.9 mi
6.
Merge onto E Main St
mi
7.
Turn left onto S Main Ave
mi
t
8.
Continue onto Golf Course Rd
--- ---- - -- 0.1 mi
r' 9. Turn right onto Salem Church Rd
1-.2 mi
t 10. Continue onto Summerow Rd
0.5 mi
Continue on Maiden Salem Rd. Drive to
Biggerstaff Rd in Jacobs Fork t
w ,
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1 n/mmni c

Page 2 of 3 ,
50 min (29.6 mi)
3900-4496 Biggerstaff Rd
Maiden,
NC 28650
t
13.
Head north on Biggerstaff Rd
toward Startown Rd
0.6 mi
rb,
14.
Turn right onto Startown Rd
mi
N
15.
Turn right onto W Maiden Rd
mi
+1
16.
Turn left onto Sigmon Dairy Rd
0.9 m i
TI
17.
Slight left to stay on Sigmon Dairy
Rd
mi
r*
18.
Turn right onto McKay Farm Rd
0 Destination will be on the right
__.
_ _.._--•----0.7 mi
10 min (6.9 mi)
1407 McKay Farm Rd
Newton, NC 28658
321
These directions are for planning purposes only. You may find that construction
projects, traffic, weather, or other events may cause conditions to differ from the
map results, and you should plan your route accordingly. You must obey all signs or
notices regarding your route.
1()/4/,)()1 5

Page 3 of 3
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Driving directions to W Finger St Exd, Maiden, NC 28650 3D
610 E Center Ave
Mooresville, NC 28115
1. Head west on E Center Ave toward E Statesville Ave
0.6 mi
2. Turn left onto S Main St
397 ft
3. Take the 1st right onto W McLelland Ave
1.0 mi
4. Turn left onto E Plaza Dr
0.4 mi
5. Keep left to continue on N Carolina 150 W/E Plaza Dr
Continue to follow N Carolina 150 W
14.2 mi
6. Turn right onto E Maiden Rd
7.9 mi
7. Continue onto E Main St
1.7 mi
8. Turn left onto S E Ave
0.2 mi
9. Turn right onto W Finger St
0.2 mi
10. W Finger St turns left and becomes W Finger St Exd
0.7 mi
W Finger St Exd
Maiden, NC 28650
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause conditions to differ from the map
results, and you should plan your route accordingly. You must obey all signs or notices regarding your route.
Map data ©2013 Google

610 E Center Ave, Mooresville, NC 28115 to 1407 McKay Farm Rd, Newton, NC 28658 - Google Maps Page 1 of 1
Map data ©2015 Google 1000 ft
https://www. google.com/maps/dir/610+E+Center+Ave,+Mooresville,+NC+28115/1407+McKay+Farm+Rd,+Newton,+NC+286... 1 /23/2015

AA
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NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Mr. Martin-Vkhlson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Dear Mr. Wilson:
Pt�a7YA E4tg
Resources
Dee Freeman
Secretary
AQUIFER PROTECTION SECTION
December 20, 2011
Subject: Land Application Inspection
City of Newton
Permit No. WQ0003902
Catawba County
A field inspection for the subject land application program was conducted on December 16, 2011. This
inspection reviewed the following items for land application field NC-CA-21, field 1.
N/E Permit on site/in trucks during application N/E Spill plan on site and in truck(s)
Y Buffers clearly marked/adequate Y Cover crop specified in permit
N/E Documented exceedances of PAN limits Y Site condition adequate
N Signs of runoff / ponding N/E Rain Gauge on site during application
N OdorsNectors N Nuisance conditions
Field conditions were found compliant. Earlier in the week, SYNAGRO field crew discovered a new
home had been built near the field after application had started. Buffers were re -flagged to include a bigger
buffer for the new house. Scott Berg, SYNAGRO, immediately informed the Mooresville office about the new
house, updated the application buffer map, and emailed it to the regional office. A copy of the new map is
enclosed.
This inspection report should be self-explanatory but should you have any questions, please call me at
704/235-2186.
Sincerely,
Ilen Huffman
Environmental Specialist
Cc: SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files, MRO files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 NorthCar®llna
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquaiity.org Naturally
An Equal Opportunity 1 Affirmative Action Employer

FILE
irCDERR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Dear Mr. Wilson:
- Coleen H. Sullins Dee Freeman
Director Secretary
AQUIFER PROTECTION SECTION
February 22, 2011
Subject: Land Application Inspection
City of Newton Land Application
Permit No. WQ0003902
Catawba County
Afield inspection for the subject land application program was conducted on February 11, 2011- This
inspection reviewed the following items for land application field NC-CA-20-10.
Y Permit on site during application Y Spill plan on site and in truck(s)
Y Buffers adequate Y Cover crop specified in permit
N/E Documented exceedances of PAN limits Y Site condition adequate
N Signs of runoff / ponding N Rain Gauge on site during application
N OdorsNectors N Nuisance conditions
Field conditions were found compliant, however, one of the SYNAGRO trucks had a (required) spill
plan but it was for another program. The other truck did not have a spill plan. There was no rain gauge on site,
also required. The SYNAGRO field manager stated that these issues would be corrected as soon as possible.
A phone call from Scotto Berg, SYNAGRO confirmed that these issues were corrected on Feb. 1.5, 2011.
This inspection report should be self-explanatory but should you have anyquestions, please call me at
704/235-2186.
Sincerely,
Ellen Huffman v
Environmental Specialist
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files, MRO files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 N®fthCarolina
Phone: [phone] \ FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer

+ ! f L /
'Questions about Newton Residuals Land Application Permit Renewal (WQ0003902)
1. There are four monitoring wells contained in BIMS for this project with no limits
provided. There is no sign of monitoring wells in the 2006 permit. The wells in
BIMS are marked as active. Are there in fact four monitoring wells? If not, should
they be removed from BIMS? This will affect Conditions 11.3, and IV.7 to IV.9.
2. Condition IV.2 lists parameters that are to be checked on an annual basis. There is a
sentence at the end stating that the Permittee may ask that the testing be reduced.
Readings for all parameters were non -detect, so there is not a problem with any of
these in the residuals. Would suggest that the requirement for testing be reduced to
once per permit cycle. What are your thoughts about that? Would the City of Newton
have any problem with that?
3. Is the O&M plan adequate?
z�
vs ��

AA "VILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION SECTION
December 14, 2010
Mr. Wilce Martin, Public Works Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
City of Newton Land Application
Permit No. WQ0003902
Catawba County
Dear Mr. Martin:
Enclosed is the inspection report for the inspection of the non -discharge Land Application that
was conducted on November 24, 2010. The report indicates compliance with the subject permit,
including lab data, and record keeping.
The attached report should be self-explanatory, however, if you have any -questions, please
contact me at [phone].
Sincerely,
qzl " "4
Ellen Huffman
Environmental Specialist
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files
MRO files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 FAX 3-6�TOne 7'„ul Phone: [phone] t 919-807-6492 t Customer Service: 1-877-62748 1 y orth r arola
Internet: s,�rrrr.nalatereuatibj.org "}N i'ag� �S� yra l
A. `=r-Peal (lrn�rtr�nih: F :.�rmaiiv= rfYr Fmr,:`nvcr �/ �8�1 KL

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly E. Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
A Y?WAA
IT
4
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: WQ0003902
Issuance Date: June 1, 2006
Permittee Contact: Wilce Martin
ORC Name: Danny Siqmon #25008
BU/ ORC: James Eric Jones # 25000
Reason for Inspection
County: Catawba
SOC Issuance Date(if applicable): N/A
Expiration Date: May 31, 2014
Telephone No.: 828/696-4346
Telephone No.: 828/695-4345
Telephone No.: 828/465-7480
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary:
All records were available for review. The truck loading area at the plant was neat and clean. A
review of the annual report for 2009 reflects compliance. Attachment A of the permit states
that the monitoring frequencies are based on actual dry tons applied per year. Newton's dry
ton averages for the last 5 years have required only quarterly monitoring.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection November 24,2010

Residuals Inspection
WQ0003902 Catawba County
July 14, 2009
Field Sites (end use for class B biosolids
pg 3
N/E Permit on site during application N/E Spill plan on site
Y Buffers adequate Y Cover crop specified in permit
N/E Documented exceedances of PAN limits Y Site condition adequate
N Signs of runoff /,ponding N/E Rain Gauge on site during application
Comment: NC-CA-17-09 had been land applied the week before this inspection.
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed:
No nuisance conditions were found during this inspection.

LT 15 WA
w"'I L E
L�—
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins. Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION SECTION
December 10, 2010
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
City of Newton Land Application
Permit No. WO0003902
Catawba County
Dear Mr. Wilson:
Enclosed is the inspection report for the inspection of the non -discharge Land Application that
was conducted on November 24, 2010. The report indicates compliance with the subject permit,
including lab data, and record keeping.
The attached report should be self-explanatory, however, if you have any questions, please
contact me at [phone].
Si ce-rely,
z �
"V-__,
'-Ellen Huffman ��� �i�
Environmental Specialist
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files
MRO files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 1�TOne 1 �'„
Phone: 91M07-63001 FAX: [phone] Customer Service: 1-877-623-6748 1� orthCarolina
Internet: .%vww.ncwaterquality.org a,49AW 111

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly E. Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
MN ;
4 "Jio
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: WQ0003902
Issuance Date: June 1, 2006
Permittee Contact: Martin Wilson
ORC Name: James Richards #13257
BU/ ORC: Dennis Murdock #13249
Reason for Inspection
County: Catawba
SOC Issuance Date(if applicable): N/A
Expiration Date: May 31, 2011
Telephone No.: 828/695-4346
Telephone No.: 828/6954345
Telephone No.: 8281465-7480
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary:
All records were available for review. The truck loading area at the plant was neat and clean. A
review of the annual report for 2009 reflects compliance. Attachment A of the permit states
that the monitoring frequencies are based on actual dry tone applied per year. Statesville's dry
ton averages for the last 5 years have required only quarterly monitoring
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection November 24,2010

Residuals Inspection
WQ0003902 Catawba County
Type of Residual
X Land Application (class B)
Y-yes N-no N/E-not evaluated N/A -not applicable
Record Keeping
Y/N
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (frequency -every 60 days*)
Y TCLP analysis (annual), N/E SSFA (Annual Soil Analysis)
Y Nutrient and metals loading calculations
Y Hauling records
Y Field loading records, Y Field site maps and information
Y Records of lime purchased
Y Pathogen & Vector Attraction Reduction (frequency -quarterly)
P9 2
Comment: The records for lime stabilization included temperature adjustment as required.
*Attachment A of the permit states that the monitoring frequencies are based on actual dry tone
applied per year. Newton's dry ton averages for the last 5 years have required only quarterly
monitoring.
Pathogen & Vector Attraction Reduction
Y Lime stabilization
Y 30 day bench
Treatment (check treatment type(s) used)
Y Aerobic digestion
Y Alkaline Stabilization class B
Transport *There was no land application activity at the time of this inspection.
Spill control plan in transport vehicle? N/E
Does transport vehicle appear to be maintained? N/E
Stora e
Number of days/weeks/months of storage:
Describe. storage: four tanks, 220,000 gallons each
Sampling not evaluated during this inspection
Is sampling adequate? Is sampling representative?

Residuals Inspection
WQ0003902 Catawba County
July 14, 2009
Field Sites (end use for class B biosolids)
N/E Permit on site during application
Y Buffers adequate
N/E Documented exceedances of PAN limits
N Signs of runoff / ponding
pg 3
N/E Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
N/E Rain Gauge on site during application
Comment: NC-CA-17-09 had been land applied the week before this inspection.
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed:
No nuisance conditions were found during this inspection.

CITY OR
• •
P.O. Box 550 Newton, NO 28658 (828} 465 7400 Fax [phone]
� i�a oN cara a
January 8, 2010
Technical Assistance and Certification Unit
WPCSOCC
161.8 Mail Service Center
Raleigh, NC 27699-1618
NPDES #: NCO039196
LA#: WQ0003902
Dear Sirs,
Effective February 1, 2010 I am retiring from the City of Newton. I will no longer be the
Clark Creek Wastewater Treatment Plant ORC or the land application ORC. Please remove me
from these designations.
Thank you,
a'g'"
ames A. Richards
Supervisor / ORC
Clark Creek WWTP
City of Newton
101d S8V49968Z8 81.MM'NO1M3N'd0'A1I3 Wki 60:60 0i0Z-$i-Nkil

:i
Water Pollution Control System Operator Designation Form
WPICISMIC
NC'.A,C ISA 8G.0201
Per)inittee Owner/Officer Name: r
Mailing Address:
City: _ State:Z, •--•- ..�_
Signature:
Facility lame:
I'ermit #: NCB /
SUBMIT A SEPARATE FORM t`Uli E:AC'H TYPE: OF SY;�'! HIW t
Fat;jlity''i"ylac Bt Gradc:
7 vie _ (.Lade .
V.._ �...__ _ •._.
' Surfuca Irrigation
1'hysuui/Clicmical � i.dncl Applicati.art
C'nllection System ,"'�._ —_... • --....
................................................
Operator in Responsible Ch trge (ORC)
Print Full Name: or
Certificate_ 'f'ype / Cir:lde I ,�luta1h be,,., �wrP l _ Wclrk Phone #:
Signature ,,."•,�--•_..._.__,�,..` l�tur:; l%t
"I certify that 1 agree to . designation: ;1% 11, Opertut,t' t;cC n tuhl f.' - -
ntivs and iliac 1 ui„nc p+ .n f I s NIrme I'nl' the litoihN noted. I under,:.;i'd ; 'd �s,:' ••1,:,:•., ;
sru,iraing tit [tie resrarnwihiiirieti ;u'thr ORC eL l,:;at in 15A M'A(' d8C, .O.NNo_1 trill l;u:;):
Dilwiplinan. Action, hp the WLt�r }>oliutinn C,"Itrul C)fx�r;nur` ('�r;iii�;t:um c_',yun:itirum...:.: u
.......................... I ........................ I... .............. .,
Rack -Up Operator in Responsible Charge (HU ORCI ..•... ...
Print f-uil N ilijo; gplc
Ccrtiri�'ate ^l'yp` / itade / Nulzabcr: I'd/�U 1P /D-ZI% Work Ithune 4: 1
Sigrtutut'c: G Date:
•'f Celli C). uuLL I ;r a to my deaignatiun ;IS J B1 Clc^ap t)FYCrtlil)I' in Ftevoilmille "frugu for tit+, l0cilllti H ill :,hide Ly
file rule, and rego""utis PUT1L1""14 tot Lilt: reSpurrsibiiities' of the Rk" i)KC ;le .el 1'urlti in I5A NC•AC•' Ilttli .r..L, S a;t,l I'.iilna: •t doe I'tsgll Ily r.}Itieiplillafy Actiolu by the Witter Pollution (°(obit, sysl�:nl Opermors C.'emiliea,.7 ei;ntrull �'t111inti>4iUn."
............................................................
Mull QX Fax to: WPCISOC.'C.'.
1618 Mall Service CctitQP
Raleigh, W 27699-1618
Fax. [phone] /-Iecres'cville (7QY) 6 63 -306 o
5cr next MU for d88ianmion Alf additir,rirtl hrt,;k•kip +:peraftin. 11rsiNoa8iw1 .,f m„rc dlan one: hriwk•ut+ t,l,er:uul' 1s npthoull.l
Z0'd TStr199vSZS d1MM'N01M9N'd0'A1I0 WV OT:60 0T0Z-2T—NVr

Additional Back-up ORC': denigriuiion.
Facility .Name: Zair . li e C --- Permit #:
Back -Up Operator in Responsible Charge (BU ORC)
Faint Full Name: „- FAY
Certificate Type / Grade 1 Number: Work .Phone #: � .
Signature: Daw;
"I certify that I ugr¢e to Illy LINigriatlan as a Back-up Operator irl Rcsponsihlc C:hurgc fur t.hv ravility nowd, 1 understand ;uld wll] t1hidc u)
the rules and regulations pertaining to the rosponsibilitivs ol'the HLI ORC as set t1onli in 15A NC,AC 08Q .1),�65 till+; filling tsl cttr
result in blwipiinaty Actions by the Water Pollution Control System Opelalurs Cerli(walion Cornilli mion-"
Back -Up Operator in Responsible Charge (11V ORC)
Print Full Name:
Certificate Tyw4-Grade / Number:
Si
V
Work Phone #:
Date: / - 9- f.
"I ecrtify that I agree to my degignation as a Rack -up Opmwr in Recponr'ble Charge for thv fuciIky noted. I andCrswnd wid wiH ;rbido by
'thc rules and regulations pertaining to the mriponmibilities oflhc BLI ORC as set Ririh in i5A Nv 'AC (180 .0?05 an,l I'MI111 S tli do NO Con
tumult in Disciplinary Actions by the Water Pollution Control System Operulnrs C,vnirication C:onlnlission."
Hack -Up Operator in Responsible Charge (BU ORC)
Print Full Name: ----
Certificate 'I' / CTrade / Number. WW '3 Work Plulne #: Ms
Signature: Date:��
"I ceI•til-y- that I agree w Ill}' as a Bgvk-µp Operutor In Rcspoiislble C`,harSe For the faiziliiy nowd. i urlkicl'11a11l :old wil; ithidc by
the rules and replations pcilaining to the responsibilities of -the BU ORC a+ vct tonh in 15A N AC: 08C.i',0210+ tuid r„ilm,: w do ..o ion
result in Discipilmiry Actions by the WUIM- Pollution C'ontrW System Oparaturg CCn11lCaliclll Corilniigl.ion."
Back -Up Operator in Responsible Charge (SU ORC)
Print Full Name: L 1Ir1�
Certificate Type / Grade !, umber, 00 � DWork Phone: #: LL:;kq�w„
Signature: Date:-._._._%_�l�
"I certify that 1 agree to my dcrtignati►m as a k-up Operator in Responsibia Charge for the I'avility howd, 1 underswod Mid will abide by
the rules and regulations pertaining to the resperosibililics of the BU ORC ag met forth lit 15A NC'AC: $G .UZ1tli ;ttr;l tailing it tin stl van
result in Aiseiftlinary Aviloin by the Water Pollulinll COMIT31 System Opt:rators C'nrtilication C:utllnligAun."
201d i8vL99v8Z8 81MM-N01MElN-d0'A1I8 WJ 0i:60 0i0Z-2i—N0r

Additional Sack -up ORC designadaim
Facility Name;1��. Perntsit #t
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Nttme:. � „�•�-'C ,� ....____...__ ..,, ..., .
t
Certificate Type / Cirade /Numb/erg: Work Phone •k: t$,
Signature: _,v.�- �;(a`R.1�r Dti,x,•._ .._� ~._ �..-.._._._.......:........... —
"T certify that t agrek! it, my tlesignatibn as a Suck -up C:lperwor in Responsibie iCharge for the i eility 11(iMl •I ;rnuer Wild tu16 Will
the rules and mguiadon% Pertaining to the responsibilities of the 1AI ORC; as set foilh in 15A NC AC; U$C; ,u.105 and fallrr"• to 6, „•:;.,;.
result in Disciplinary Actions by the Water Pollution Control SN'S19111 Opernwr% Certification CorluniNi4ion."
Back -Up Operator in Responsible Charge (BU ORC'.)
Print Full Naive:
Certificate Type IGrade. / Number: W(.)rk Phone: #: --_--
Signature:_.-- — .. Date:
" I certify that I i4grrc to my designation at: a Duck -up Operatne in Rvsponsibie C,hai•ge The the .facility noted, i unjer,umd n%.,l ,, ;;! .tiaitl.: bN
the rules and regulations lVriaining to the responsibilities ul the: BU ORC us %ct lorih in 1:+A INC .,NC 1:1 G .u2w., ;{nti i;iii in}t w • ,.
result in Distiplinary Actions by tile• Water Pollution Control System C)perators C'ertifiolli4.itt Commission,"
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Name:
Certificate Type / Grade / Number:
Signature:
Date:
"I certify that 1 aerce to my designation as a Suck -up Operator in Responsible L'hargo tier ilia (ycility nested. I w1durtiit1nd wid will ubide by
the rule% and regulations pertaining to the responsibilities of ilia BU ORC as sct forih in 15A NC'.U: I)AG .020i ono wilin,; to ;h. ,,, c in
result in Disciplinary Actions by the Water Pollution Convol System Operawm C'er'titit goon Cuntmissiutl."
.......... I.......................*...................,...•..................,................4................................................
Back -Up Operator in Responsible Charge (BU ORC)
Print Full Namc:
Certificate Type / Gracie I Number.
Work Phoatt #: i_..a_..}.._.._P,,. ,.._.,.......__._. .
Signature:
"I Certify that I ogee lu my designation as a Back-up Operator iri Responsible Charge for tlic t'acility noted. I wi.lct: Law un,l �%HI abitlt; by
the rules and regulations pertaining to the responsibilities of the BU ORC as set -forth in 15A NCAC 08"'; .0203 and 1;rihn.g it, do xu e".11
result in Disciplinan, Actions by the Water Pollution C:ontrul System Operulot, Certification C'ntnrniK${ 7n."
Vo"Cl T8VLG9v8z8 d1MM'N01M3N'd0'A1I3 WJ TT:60 0I0z_2T_H0r

If
U
�F�►FILE
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
AQUIFER PROTECTION SECTION
July 21, 2009
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
City of Newton Land Ap JiGation
Permit No. WQ00.0-7-486
Catawba County 3 � o /`
Dear Mr. Wilson:
Enclosed is the inspection report for the land application program inspection conducted on July 14,
1009. This inspection reviewed record keeping and the field application activity for field #NC-CA-17.
A review of the annual report for 2008 reflects compliance. There have been no complaints during the
last three years reviewed and there were no compliance issues found during this inspection.
Sincerely, ;
Ellen Huffman
Environmental Specialist
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files
MRO files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 N rthCarohna
Internet: www.ncwaterquality.org 'A7,,,f„L,,,.//41

11
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly E. Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
,&44 VI*
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: WQ0003902
Issuance Date: June 1, 2006
Permittee Contact: Martin Wilson
ORC Name: James Richards #13257
BU/ ORC: Dennis Murdock #13249
County: Catawba
SOC Issuance Date(if applicable): N/A
Expiration Date: May 31, 2011
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
Telephone No.: 828/465-7480
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary:
All required records were available for review. Sludge storage and loading area appeared to
be clean and maintained. Field inspection on NC-CA-17-09 reflects compliance.
Is a fol/ow-
necess
X no
Inspector Name/Title: Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection July 14, 2009

:1P
Residuals Inspection
WQ0003902 Catawba County
Type of Residual
X Land Application (class B)
Y-yes N-no N/E-not evaluated N/A -not applicable
Record keeping
Y/N
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (frequency -annual)
Y TCLP analysis (annual), N/E SSFA (Annual Soil Analysis)
Y Nutrient and metals loading calculations
Y Hauling records
Y Field loading records, Y Field site maps and information
Y Records of lime purchased
Y Pathogen & Vector Attraction Reduction
Comments:
Pathogen & Vector Attraction Reduction
Y Lime stabilization
Treatment (check treatment type(s) used)
Aerobic digestion
Y Alkaline Stabilization class B
30 day bench
Transport *There was no land application activity at the time of this inspection.
Spill control plan in transport vehicle? N/E
Does transport vehicle appear to be maintained? N/E
Storage
Number of days/weeks/months of storage:
Describe storage: four tanks, 220,000 gallons each
Sampling not evaluated during this inspection
Is sampling adequate? Is sampling representative?
.. .

N
Residuals Inspection
WO0003902 Catawba County
July 14, 2009
Field Sites (end use for class B biosolids)
N/E Permit on site during application
Y Buffers adequate
N/E Documented exceedances of PAN limits
N Signs of runoff / ponding
pg 3
N/E Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
N/E Rain Gauge on site during application
Comment: NC-CA-17-09 had been land applied the week before this inspection.
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed:
No nuisance conditions were found during this inspection.
Monitoring well(s) Y/N: N
If yes, location of well(s)

FEB - 2 2009 D
Attn: Ellen Huffman
NCDENR - Division of Water Quality
Mooresville Regional Office
610 E. Center St.
Mooresville N.C. 28115
Re: Change of land application programs
Dear Madam:
Sidney Turbyfill
Turbyfill Properties, LLC
4300 Biggerstaff Road
Maiden NC 28650
30 January, 2009
Enclosed please find my letter to Wilce Martin, Public Works Director for Newton NC, requesting
withdrawal from their land application program.
I, also, signaled our intention to procure solid waste from the Lincolnton plant.
The bureaucratic process for transitioning to Lincolnton's program is a mystery to me. However, I
assume that Synagro will assist me with that process.
Feel free to contact me if a follow-up is necessary.
Sincerely, "
Sidney Turbyfill, Manager
Turbyfill Properties, LLC
Site# NC-CA-35
Newton Land Application Permit No. WQ0003902
828-428-1424
cc. Scott D. Berg, Synagro Central, LLC

Wilce B. Martin
City of Newton
PO Box 550
Newton NC 28658
F E B - 2 2009
NC DENR NI O
DWQ -A uiTer Rrotection
Re: Withdrawal from Newton land application program
Dear Sirs:
Sidney Turbyfill
Turbyfill Properties, LLC
4300 Biggerstaff Road
Maiden NC 28650
30 January, 2009
Let me take a moment to thank you for the excellent results we have achieved on the pastures and hay
fields of our farm — as a result of utilizing sludge application of waste water from your Newton plant.
With crude oil prices exploding, and consequent radical inflation of fertilizer prices, we were grateful
to have saved so substantially.
Recently, I began a review of our farm practices which included a study of the soil test results from past
years, along with a thorough investigation of recommendations for supplementing soil to achieve
optimum production. Unfortunately, data, from recent soil test reports, indicate an unsatisfactory rise
in the Ph of soils treated with sludge from your facility.
Consultation with other farm businesses and agribusiness consultants has revealed the availability of
non lime -stabilized sludge at the Lincolnton facility that would accominodate our needs more equitably
at this time.
Consequently, the owners of this property have decided to request withdrawal of our property (Site#
NC-CA-35; Newton Land Application Permit No. WQ0003902) from the Newton land application
program, effective as of this date.
Again, we greatly appreciate the past benefits of your program.
Thank you for your assistance.
Sincerely yours,
Sidney Turbyfill, Manager
Turbyfill Properties, LLC
cc. Ellen Huffiilan, NCDENR - Division of Water Quality

�F W ATFq Michael F. Easley, Governor
William G. Ross Jr., Secretary
\OC
6� pG North Carolina Department of Environment and Natural Resources
f FILE Coleen Sullins, Director
Division of Water Quality
O "C
September 15, 2008
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
City of Newton Land Application
Permit No. WQ0007486
Catawba County
Dear Mr. Wilson:
Enclosed is the inspection report for the land application program inspection conducted on September
24, 2007. This inspection only reviewed the field application activity for field #NC-CA-17, and sludge record
keeping.
A review of the annual report for 2007 reflects compliance. There have been no complaints during the
last three years reviewed and there were no compliance issues found during this inspection.
Sincerely,
Ellen Huffman
Environmental Specialist
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files
MRO files
Nne
oAhCarolina
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] Naturally
Ja�ut,,/
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Internet: http://gw.ehnr.state.nc.us (/ V ly

'1
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr. Secretary
Coleen H. Sullins, Director
A4 0
MN)-
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No:: W00003902
Issuance Date: June 1, 2006
Permittee Contact: Martin Wilson
ORC Name: James Richards #13257
BU/ ORC: Dennis Murdock #13249
Reason for Inspection
County: Catawba
SOC Issuance Date(if applicable): N/A
Expiration Date: May 31, 2011
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
Telephone No.: 828/465-7480
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summarv: (additional comments may be included on attached pages)
This inspection reviewed sludge analyses and field application site. The sludge application on
site NC-CA-17, field 7, was flagged appropriately. Sludge application was even and there was
no evidence of ponding. Odors were minimal and typical for land application. There were no
nuisance conditions present. Review of the application map showed that buffers were marked
appropriately
Is a
necessary _yes X no
Inspector Name/Title: Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection September 3, 2008

i
Residuals Inspection
WQ0003902 Catawba County
Type of Residual
X Land Application (class B) Distribution and Marketing (class A)
Record Keepin not evaluated during this inspection
Y/N
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (frequency -annual)
Y TCLP analysis (annual), N SSFA (Standard Soil Fertility Analysis)(annual)
Y Nutrient and metals loading calculations
Y Hauling records
Y Field loading records, Y Field site maps and information
N/E Records of lime purchased
Y Pathogen & Vector Attraction Reduction
Comments:
Pathogen & Vector Attraction Reduction Records
X Lime stabilization
Treatment (check treatment type(s) used)
Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
X Alkaline Stabilization class B other -describe
Transport
Spill control plan in transport vehicle? N/E
Does transport vehicle appear to be maintained? N/E
Operation & Maintenance
N/E
Storage
Number of days/weeks/months of storage: 30 days
Describe storage: four tanks, 220,000 gallons each
Pg 2

M
Residuals Inspection
WQ0003902 Catawba County
Sampling not evaluated during this inspection
Is sampling adequate? Is sampling representative?
Field Sites (end use for class B biosolids) Y/N
N/E Permit on site during application N/E Spill plan on site
Y Buffers adequate Y Cover, crop specified in permit
N Documented exceedances of PAN limits Y Site condition adequate
N Signs of runoff / ponding
pg 3
N/E Rain Gauge on site during application
Are there any limiting slopes on fields? Y/N
N 10 % for surface application N 18% for subsurface application
Comment: Field conditions were found to be very good. Sludge application appeared even.
Field entrance was clean. No nuisance conditions were noted.
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed: No nuisance conditions were
found during this inspection. Slight odors were detectable immediately down wind of the field site;
however, odors were minimal and intermittent. A review of the files revealed that the Mooresville
regional Office had received no (odor) complaints this year.
Monitoring well(s) Y/N: N
If yes, location of well(s)

U, —y wuuam u. Koss ir., Secretary
North Carolina Department of Environment and Natural Resources
Uj T' Coleen Sullins, Director
Lr
� Division of Water Quality
o �c
October 18, 2007
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
City of Newton Land Application
Permit No. W-QO0074BB— 3 9 d
Catawba County
Dear Mr. Wilson:
Enclosed is the inspection report for the land application program inspection conducted on September
24, 2007. This inspection only reviewed the field application activity for field #NC-CA-16, fields 1 & 2.
Scott Berg, SYNAGRO, inspected the field at the same time. A buffer change needed to be made after
a review of the application map. Flags were adjusted at the time of inspection. SYNAGRO's field inspection
was very thorough.
A review of the annual report for 2006 reflects compliance. There have been no complaints during the
last three years reviewed and there were no compliance issues found during this inspection.
Cc: Scott Berg, SYNAGRO
Ed Hardee, LAU Residuals Program Coordinator
Central Files
MRO files
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Sincerely, /
-fiW /
Ellen Huffman
Environmental Specialist
NorthCarolina
Phone: [phone] Fax: [phone]
Internet: Ja�u�,� //y
http://gw.ehnr.state.nc.us �/ Y l`

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr. Secretary
Coleen Sullins, Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: WQ0003902
Issuance Date: June 1, 2006
Permittee Contact: Martin Wilson
ORC Name: James Richards #13257
BU/ ORC: Dennis Murdock #13249
Reason for Inspection
County: Catawba
SOC Issuance Date(if applicable): N/A
Expiration Date: May 31, 2011
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
Telephone No.: 828/465-7480
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary: (additional comments may be included on attached pages)
This inspection only reviewed the field application activity. The sludge application appeared
evenly distributed. Application equipment was is good shape. Odors were typical and
acceptable for land application. Review of the application map showed a buffer that was not
marked properly. The contractor re flagged the area at the time of inspection and reviewed the
map with the equipment operator. Other buffers and boundaries were adequately marked for the
equipment operator.
Is a
X no
Inspector(s) Name(s)/Title(s) Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection September 24, 2007

•0
f.
Residuals Inspection
WQ0003902 Catawba County
Type of Residual
X Land Application (class B) Distribution and Marketing (class A)
Record Keeping not evaluated during this inspection
Y/N
_ Copy of current permit available at residual generating site
Current metals and nutrient analysis (frequency -annual)
TCLP analysis (annual), N SSFA (Standard Soil Fertility Analysis)(annual)
Nutrient and metals loading calculations
Hauling records
Field loading records, Y Field site maps and information
Records of lime purchased (contractor keeps lime purchase records)
_ Pathogen & Vector Attraction Reduction (annual)
Comments:
Pathogen & Vector Attraction Reduction Records
X Lime stabilization
Treatment (check treatment type(s) used)
Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
X Alkaline Stabilization class B other -describe
Pg 2
Comment: records for stabilization were not evaluated during this inspection. The annual report
for 2006 reflects compliance.
Transport
Spill control plan in transport vehicle? Y
Does transport vehicle appear to be maintained? Y
Operation & Maintenance
Condition of land application equipment on site: Equipment was clean and appeared to be well
maintained.
Storage
Number of days/weeks/months of storage: 30 days
Describe storage: four tanks, 220,000 gallons each

4.-
I
Residuals Inspection
WQ0003902 Catawba County
Sampling not evaluated during this inspection
Describe Sampling:
Is sampling adequate? Is sampling representative?
Field Sites (end use for class B biosolids) Y/N
Y Permit on site during application
Y Buffers adequate
N Documented exceedances of PAN limits
N Signs of runoff / ponding
Y Rain Gauge on site during application
pg 3
Y Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
(if no, improvements recommended)
Are there any limiting slopes on fields? Y/N
N 10 % for surface application N 18% for subsurface application
Comment: Field conditions were found to be very good. Sludge application appeared even.
Equipment was clean. Field entrance was clean. No nuisance conditions were noted. A buffer
map review concluded that several flags needed to be moved due to an on -site well.
Monitoring well(s) Y/N: N
If yes, location of well(s)
Comment:
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed: No nuisance conditions were
found during this inspection. Slight odors were detectable immediately down wind of the field site;
however, odors were minimal and intermittent. A review of the files revealed that the Mooresville
regional Office had received no (odor) complaints this year.

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initial wosonas application
Subject initial biosolids application_-!
From-*" S'igynon 6 y ! dsig [e-mail]>
Date: Tue, 11 Apr 2006 13:10:03 -0400 IF
To: <[e-mail]>
CC: "Burchins,Ed" <[e-mail]>, <[e-mail]>, "Scott Berg"
<[e-mail]>, "Richards James" <[e-mail]>, "Jones Eric"
<[e-mail]>
04/11/06
In accordance to Land Application of Residual Solids Perm t # WQ0003902,
I. Performance Standards, #10, I am providing notice to all , t--le
required persons of the first biosolids application to newly permit ed
land. The application is to commence Thursday April 13, 2006. The site
ID is NC-LT-119. The site is owned by Mr. Bobby Canipe of 3980 Killian
Road, Lincolnton NC 28092 and fields #2, 3 and 4 are operated by Mr.
Gordy Goins of 2924 Blackburn Bridge Road, Lincolnton NC 28092. The site
is located on the Hickory-Lincolnton Highway. If anyone has any
questions please do not hesitate to contact me at 828.695.4346.
Thanks,
Danny
Content -Type: application/ms-tnef
winmail.dat1
Content -Encoding: base64
1 of 1 8/30/2006 8:22 AM

OwAT �RQG Michael F. Easley
Governor
William G. Ross Jr., Secretary
>_ Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
June 23, 2004
Mr. Martin Wilson, Utilities Director CERTIFIED MAII.
�,��rA^AS <h Res RCE8
City of Newton:--- RETURN RECEIPT��E�UES�PED
; . ,., 4AL OFFICE
P. O. Box 550
Newton, NC 28658
SUBJECT: Assessment of Civil Penalties JUN 2 g 2004
for Violation of NCGS 143-215. (a) (9)
w.
dhd Permit_WQ00 3902 = �-
_Catawba_County '
File No. DV-2004-0008,dCTI®N
Dear Mr. Wilson:
This letter transmits notice of a civil penalty assessed against City of Newton in the amount of
$1,432.41 which includes $232.41 in investigative costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Quality. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made to the order of the Department of Environment
and Natural Resources. Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s). Do not include
the attached waiver form if making payment.
Please send payment to the attention of:
Mr. Ed Hardee
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Customer Service: Mailing Address: Telephone [phone]
1-877-623-6748 1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01
An Equal Opportunity/Affirmative Action Employer
50% recycled110% post -consumer paper
ht1p://h2o. enr.state. nc. us
r
IDEN
Location:
512 N. Salisbury St.
Raleigh, NC 27699-1617

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the reasonableness
of the amount of the penalty and is not the proper procedure for contesting the
accuracy of any of the statements contained in the assessment letter. Because a
remission request forecloses the option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute. You must execute and
return to this office the attached waiver form and the attached "Justification for
Remission Request" which should describe why you believe:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of:
Mr. Ed Hardee
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714

Mail or hand -deliver a copy of the petition to:
And to:
Mr. Dan Oakley
r:CDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Ed Hardee
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred
to the Attorney General's Office with a request to initiate a civil action to collect the penalty.
Please be advised that additional assessments may be levied for future violations which occur
after the review period of this assessment.
If you have any questions, please contact Mr. Ed Hardee at [phone], ext. 565 or Mr. Steve
Lewis at [phone], ext. 539.
Sincerely,
Jeffrey O. Poupart, Supervisor
Non -Discharge Compliance and Enforcement Unit
JOP/edh
ATTACHMENTS
cc: D. Rex Gleason, Mooresville Regional Supervisor w/ attachments
z Ellen_Huffman,=7M6o esville4RegiCFI; w./ attachments
File DV-2004-0008 w/ attachments
Central Files w/ attachments
Susan Massengale, PIO w/ attachments

STATE OF NORTH CAROLINA
loll) Q WK91 0 USNAV KIM /10
IN THE MATTER OF: )
CITY OF NEWTON )
FOR VIOLATIONS OF PERMIT)
NO. WQ0003902 AND )
NCGS 143-215.1 (a) (9) )
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
File No. DV-2004-0008
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to delegation provided by the Secretary of the Department of Environment and
Natural Resources and the Director of the Division of Water Quality, I, Jeffrey O. Poupart, Supervisor of the
Non -Discharge Compliance and Enforcement Unit of the Division of Water Quality (DWQ), make the
following:
I. FINDINGS OF FACT:
A. The City of Newton is an incorporated municipality organized and existing under the laws of
the State of North Carolina.
B. On November 6, 2002, DWQ issued Water Quality Permit No. WQ0003902 to the City of
Newton for the operation of a wastewater residuals land application program. The source of
the residuals is the City's Clark Creek Wastewater Treatment Plant. Permitted disposal sites
are located in Catawba County.
C. On May 17, 2004 the contractor for the City of Newton (SYNAGRO) land applied WWTP
residuals onto land that was not permitted for sludge disposal.
D. On May 21, 2004, DWQ staff in the Mooresville Regional Office were informed of the
violation by telephone notification from Mr. Danny Sigmon, WWTP Superintendent, City of
Newton.
E. Said permit contains the following relevant conditions:
• Permit Condition I.8 states only sites listed in the most recently certified Attachment B of
the permit are approved for residuals land application.
F. A Notice of Violation/Notice of Recommendation for Enforcement was sent to the City of
Newton by DWQ's Mooresville Regional Office on June 7, 2004.
G. The cost to the State of the enforcement procedures in this matter totaled $232.41.

Based upon the above.Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The City of Newton is a "person" within the meaning of G.S.143-215.6A pursuant to G.S.
143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition of same at
G.S. 143-213(10) or G.S. 143-213(17).
C. A permit approval is required for the disposal of wastewater residuals pursuant to G.S. 143-
2.15.1(a)(9) and Part I, Condition No. 8 of DWQ Permit No. WQ0003902.
D. The City of Newton violated G.S. 143-215. 1 (a)(9) and Part I, Condition No. 8 of DWQ
Permit No. WQ0003902 by failing to properly operate and maintain a non -discharge land
application system.
E. The City of Newton may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand
dollars per violation may be assessed against a person who is required but fails to apply for or
to secure a permit required by G.S. 143-215.1(a)(9), or who fails to comply with the conditions
of the permit.
F. The State's enforcement costs in this matter may be assessed against the City of Newton
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Supervisor of the Non -Discharge Compliance and Enforcement Unit, Division of Water
Quality, pursuant to delegation provided by the Secretary of the Department of Environment
and Natural Resources and the Director of the Division of Water Quality, has the authority to
assess civil penalties in this matter.

10
Based upon the above Findings of Fact, I make the following:
in. DECISION:
Accordingly, the City of Newton is hereby assessed a civil penalty of:
$ 1,200.00 for failing to comply with NCGS 143-215. (a) (9) and Permit No. WQ0003902
Condition I. 8, which requires that only sites listed in the most recently
certified Attachment B of the permit are approved for residuals land
application.
$ 232.41 Enforcement costs
$ 1,432.41 TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have considered the
factors listed in G.S. 143B-282. I (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
(Date)
Jeffrey O. Poupart, Supervisor
Non -Discharge Compliance and Enforcement Unit
Division of Water Quality

STATE OF NORTH CAROLINA ,
COUNTY OF CATAWBA
IN THE MATTER OF ASSESSMENT )
OF CIVIL PENALTIES AGAINST )
CITY OF NEWTON )
PERMIT NO. WQ0003902 )
ENVIRONMENTAL MANAGEMENT
COMMISSION
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. DV-2004-0008
Having been assessed civil penalties totaling $1,432.41 for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated June 23.2004
the undersigned, desiring to seek remission of the civil
penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty
(30) days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the
day of
ADDRESS
TELEPHONE
SIGNATURE

,JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: DV-2004-0008 County: Catawba
Assessed Party: City of Newton
Permit No. (if applicable):WQ0003902 Amount Assessed: $1,432.41
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the five factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties. for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance).
EXPLANATION (attach additional pages as necessary):

Date: June 16, 2004
Memorandom to: Jeff Poupart G
From: D. Rex Gleason
V -
Prepared by: Ellen Huffman 0?
Subject: Recommendation for Enforcement
Violation ofNCGS 143-215.1 (a) (9) and Permit No. WQ0003902
City of Newton, Catawba County
Attached is the enforcement report/recommendation package concerning the violation of NCGS 143-215.1 (a)
(9) and the subject permit. The violation concerns the application of sludge by the contractor for the City of
Newton on land not permitted for sludge disposal. This is the third such incident of this nature. The Water
Quality Enforcement Tracking System indicates that the permittee was cited for two similar violations (1998,
2003); however, the 1998 case was combined with an over -application of Nickel. The City was only assessed
for the Nickel. A penalty of $10,830.70 was paid and the case closed on 01/31/00. The City was also cited on
January 31, 2003 for applying sludge to an unpermitted site. A penalty of $2,232.41 was paid and the case
closed on 07/21/03. The attached information should be self-explanatory; however, if you have any questions,
please contact Mrs. Ellen Huffinan or me.
Attachments
ebh

Summary
On Friday, May 21, 2004, Mr. Danny Sigmon, WWTP Superintendent, City of Newton, called the
Mooresville Regional Office of the Division of Water Quality to report that the City's residuals contractor,
SYNAGRO, had land applied sludge on land not permitted for sludge application. The incident occurred on
5/17/04 but was not discovered until an inspection by the City on 5/21/04. The City called Ms. Ellen Huffman
with MRO/DWQ and reported their findings the same day. On 5/25/04, Ms. Huffman met with James
Richards, Eric Jones, and Danny Sigmon, with the City of Newton, and Frankie Singleton and Roy Whittaker
with SYANGRO at the land application site to review the situation. Ms. Huffman's investigation confirmed
that the area receiving the sludge was not a permitted field. An explanation of the event from SYNAGRO was
received by e-mail on May 26, 2004 (attached).
Chronology of Events/Correspondence
May 21, 2004 - Mr. Danny Sigmon, City of Newton, called the MRO to report that the City's contractor,
SYNAGRO, had land applied sludge on a non -permitted field (area near field NC-CA-14-1) on the 05/17/04.
May 25, 2004 - A site visit was conducted by Ms. Huffman.
May 26, 2004 — A letter from SYNAGRO was received by MRO/DWQ (via e-mail) explaining the
circumstances of the event.
June 8, 2004 — An NOV/NRE was sent by MRO/DWQ via certified mail to the City of Newton.
June 14, 2004 - Response to the NOV/NRE was received from the City.

CHECKLIST FOR PERMIT VIOLATIONS
A copy of the Permit (#WQ0003902) is attached.
2. The violator is the City of Newton. Mr. Martin Wilson is the Utilities Director
for the City.
Mr. Martin Wilson, Utilities Director
City of Newton.
Post Office Box 550
Newton, North Carolina 28658
3. This enforcement does not include effluent limit violations. It involves a violation of non -
discharge Permit No. WQ0003902 and NCGS 143-215.1 (a) (9).
4. Copies of correspondence are attached.
5. There are no chain -of -custody samples.
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violation(s) chronic and/or due to a single operational upset?
This is the third violation reported by the City for application of residuals on a non -permitted
site. The other violations occurred in January 2003 and November 1998.
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NRE was sent to the City of Newton on May 8, 2004, for the reported violation and
indicated that an enforcement recommendation would be prepared by the MRO.
9. Cost of the investigation:
4 hours by Ellen Huffman for preparation
of enforcement report at $20.38/hour = $81.52
1 hour by D. Rex Gleason for supervisory review
at $39.96/hour = $39.96
1 hour for clerical processing at $10.93/hour = $10.93
Administrative Cost for processing report =$100.00
Total $232.41

CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
CASE NAME: City of Newton
ASSESSMENT FACTORS:
A. CAUSE OF THE VIOLATIONS)
The violation is the result of the City's land application contractor, SYNAGRO, failing to
comply with the terms and conditions of the City's land application Permit.
Permit Condition I. 8. states only sites listed in the most recently certified Attachment B of the
permit are approved for residuals land application.
B. THE DEGREE AND EXTENT OF HARM CAUSED BY THE VIOLATION(S)
No harm documented. Residuals did not appear to have entered surface waters.
C. DURATION OF THE VIOLATIONS)
The violation occurred on Monday May 17, 2004.
D. EFFECT OF VIOLATION(S) ON WATER, PUBLIC HEALTH AND FISH OR
WILDLIFE
There is no documented effect on water or public health as a result of the violations.
E. EFFECTIVENESS OF ANY PREVENTIVE OR RESPONSIVE MEASURE TAKEN
BY THE VIOLATOR
The City immediately reported the violation as soon as they discovered it.
F. COST OF RECTIFYING THE DAMAGE OR INFORMATION THAT WOULD BE
NEEDED TO DETERMINE THE COST, SUCH AS PROCESS RATES, CLEAN UP
COSTS
Cost of damage was not determined.
G. THE ALLEGED VIOLATOR'S PREVIOUS RECORD OF COMPLIANCE OR
NONCOMPLIANCE
The City of Newton was assessed a civil penalty for a previous similar violation that occurred
on January 16, 2003. The penalty amount was $2,232.41 and was paid in full. The City was
also assessed a penalty on November 5, 1998 for high Nickel concentrations in sludge that had
been land applied (some was applied on land that was not permitted. This was mentioned in the
assessment document but not included in the penalty). The penalty amount was $10,830.70,
and was paid in full.

H. MITIGATING, AGGRAVATING FACTORS, IF ANY
The area permitted for sludge disposal was completely fenced in.. The equipment operator had
to go through a gate to get to the unpermitted area.
This is the third such incident of applying sludge to land that was not permitted for such. The
City's land application contractor, SYNAGRO was apparently at fault for the violations
occurring on May 17, 2004 (the most recent) and January 16, 2003. The City's previous land
application contractor, Sigmon Environmental, had a similar violation on Nov. 5, 1998. The
City was not assessed for the application on un-permitted land, but was assessed for a Nickel
violation that occurred on the same date. The City has been quick to report any violations as
soon as they have been discovered. See attached responses from the City and'SYNAGRO.

STATE OF NORTH CAROLINA
COUNTY OF CATAWBA
IN THE MATTER OF: )
CITY OF NEWTON )
FOR VIOLATIONS OF PERMIT)
NO. WQ0003902 AND )
NCGS 143-215.1 (a) (9) )
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
File No. PC
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to delegation provided by the Secretary of the Department of Environment and
Natural Resources, I, Alan W. Klimek, -P.E., Director of the Division of Water Quality, make the
following:
I. FINDINGS OF FACT:
A. The City of Newton is an incorporated municipality organized and existing under the laws of
the State of North Carolina.
B. On November 6, 2002, DWQ issued Water Quality Permit No. WQ0003902 to the City of
Newton for the operation of a wastewater residuals land application program The source of
the residuals is the City's Clark Creek Wastewater Treatment Plant. Permitted disposal sites
are located in Catawba County.
C. On May 17, 2004 the contractor for the City of Newton (SYNAGRO) land applied WWTP
residuals onto land that was not permitted for sludge disposal.
D. On May 21, 2004, DWQ staff in the Mooresville Regional Office were informed of the
violation by telephone notification from Mr. Danny Sigmon, WWTP Superintendent, City of
Newton.
E. Said permit contains the following relevant conditions:
• Permit Condition I.8 states only sites listed in the most recently certified Attachment B of
the permit are approved for residuals land application.
F. A Notice of Violation/Notice of Recommendation for Enforcement was sent to the City of
Newton by DWQ's Mooresville Regional Office on June 7, 2004.
G. The cost to the State of the enforcement procedures in this matter totaled $232.41.

Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The City of Newton is a "person" within the meaning of G.S.143-215.6A pursuant to G.S.
143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition of same at
G.S. 143-213(10) or G.S. 143-213(17).
C. A permit approval is required for the disposal of wastewater residuals pursuant to G.S. 143-
215.1(a)(9) and Part I, Condition No. 8 of DWQ Permit No. WQ0003902.
D. The City of Newton violated G.S. 143-215.1(a)(9) and Part I, Condition No. 8 of DWQ Permit
No. WQ0003902 by failing to properly operate and maintain a non -discharge land application
system
E. The City of Newton may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
per violation may be assessed against a person who is required but fails to apply for or to
secure a permit required by G.S. 143-215.1(a)(9), or who fails to comply with the conditions of
the permit.
F. The State's enforcement costs in this matter may be assessed against the City of Newton
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Director, Division of Water Quality, pursuant to delegation provided by G.S. 143-
215.6A(a)(2), has the authority to assess civil penalties in this matter.

III. DECISION:
Accordingly, the City of Newton is hereby assessed a civil penalty of:
$ for failing to comply with NCGS 143-215. (a) (9) and Permit No. WQ0003902
Condition I. 8, which requires that only sites listed in the most recently certified
Attachment B of the permit are approved for residuals land application.
$ 232.41 Enforcement costs
$ TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have considered the
factors listed in G. S. 143B-282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which
the Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
(Date) Alan W. Klimek, P.E. Director
Division of Water Quality

SYNAGRO
A Residuals Management Company
Via E-mail.Transmission,
May 26, 2004
Ellen Huffman
NCDENR
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
RE: Application of biosolids to non -permitted area —Newton, NC
Permit Number - WQ0003902
Dear Ellen:
I am writing in regards to the application of biosolids to non -permitted land at the B.R. Lee
site in Catawba County. Please see the following:
On May 21, 2004, James Richards and Eric Jones, City ofNewton, made a follow-up
visit to B_K Lee (Site NC -CA 14-1) after having discovered a potential violation from
a visit on May 17th to the site. Subsequent to inspecting the site finther, it appeared
that biosolids had been applied to a non -permitted area of Field 1.
Our regional Synagro office was informed by both our Operations Manager and the
City staff of the likely violation. After discussing the situation over the phone with the
Operations Manager, it was confirmed that a violation had occurred. The City of
Newton then contacted the regional DENR office to inform you of the violation.
The reason for the application in the non -permitted area was because the Operations
Manager did not interpret the application map properly. The map clearly denotes this
area as a non -permitted area. The Operations Manager has been released from his
duties at the Newton project to prevent any other violations under his management.

The City suggested adding aerial photographs to assist any future Operations
Managers in correctly interpreting the application areas. Synagro will be submitting
the land application permit renewal for the City during the first few months of 2005.
During this process, the technical staff will be updating the site information to include
an aerial photograph along with the application area maps for each field.
Albeit a violation, there should not be any negative environmental impact with this
application into a non -permitted area. The field has sufficient groundcover to hold the
material, as well as utilize the nutrients in the biosolids. Also, the field is
approximately 400 feet from nearest intermittent stream and nearly 1,800 feet from the
Catawba River.
We regret this application of biosolids to an area that is not permitted and Synagro feels the
above measure will avoid any future occurrences. Please call us with questions or comments.
Sincerely,
��" s��� �
Frankie Singleton
Senior Operations Manager
c: Danny Sigmon
James Richards
Eric Jones
Roy Whitaker
Jonathan Hill
Eric Dollyhigh
0 Page 2

CITY OF
"THE HEART OF CATAWBA COUNTY"
r
06/11/04
jUN 1 4 200
Mr. Rex D. Gleason P.E. 'L y
NCDENR-Mooresville Office J
919 North MainStreet Nn .�
Mooresville, NC 28115 �-
P.O. Box 550 a Newton, NC 28658 a [phone]
Subject: Receipt of Notice of Violation, Incident # 200401136, NOV # 2004-DV-0020
Dear Mr. Gleason:
Per the June 8, 2004 Division letter, the City of Newton acknowledges receipt of an NOV
per the Land Application permit #WQ0003902. As discussed with Ms. Ellen Huffman
with the Division, Mr. James Richards the WWTP ORC, Mr. Frankie Single and Mr. Roy
Whitiker with Synagro Inc. and myself it was agreed that Synagro would respond to this
violation. Mr. Singleton e-mailed Ms. Huffman on May 26, 2004 informing her of the
violation and the measures taken by Synagro to avoid the application of bio-solids on
non -permitted land in the future. I have forwarded the NOV to Mr. Singleton today and if
needed, he will respond to any additional concerns the Division may have.
If you have any questions please do not hesitate to contact me at 828.695.4346 UJi
Respectfully,
Dann Si on
City of Newton
WWTP Superintendent ,,"
� c
Cc: Non -Discharge Compliance/Enforcement Unit
Non -Discharge Permitting Unit
Frankie Singleton, Synagro
v

0� rt c9 Michael F. Easley, Governor
o
Q William G. Ross Jr., Secretary
7 North Carolina Department of Environment and Natural Resources
> Alan W. Klimek, P.E. Director
r Division of Water Quality
June 8, 2004
Certified Mail
Return Receipt Requested
Mr. Martin Wilson, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Subject: Notice of Violation and
Recommendation for Enforcement
Incident #200401136
NOV# 2004-DV-0020
City of Newton
Land Application Permit # WQ0003902
Catawba Countv
Dear Mr. Wilson:
Mr. Danny Sigmon with the City of Newton called the Mooresville Regional Office on May
21, 2004 and spoke with Ms. Ellen Huffman of my staff. He reported to Ms. Huffman that on May 21,
2004, James Richards and Eric Jones (both with the City), during a routine inspection of the land
application contractor, discovered that the contractor had applied sludge on a site not permitted for
sludge application. The application of sludge on land not permitted for such disposal is a violation of
NCGS 143-215.1a (9). It should be noted that the City of Newton was cited for similar violations on
January 31, 2003, and February 18, 1999.
It is requested that the City respond to this Notice within ten (10) working days of receipt of
this letter. The response should include any mitigating factors concerning the violation and any
actions/procedures that will be implemented to prevent recurrence. Please reference the subject permit
number when providing your response.
The City of Newton may be assessed civil penalties in this matter pursuant to NCGS 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
($25,000.00) per violation per day may be assessed against a person who violates any permit
condition, classification, standard, limitation, or management practice established pursuant to G.S.
143-214.1, 143-214.2 or 143-215.
;A
IZDE R
Customer Service
1 800 623-7748
Mooresville Regional Office
919 North Main Street, Mooresville, NC 28115
PHONE [phone]
FAX [phone]

M
page 2
,F If you have any questions regarding this Notice, please do not hesitate to call Ms. Huffman or me
at 704-663-1699.
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Danny Sigmon, City of Newton
Frankie Singleton, SYNAGRO
Sincerely,
P, /?, /' 1-�
D. Rex Gleason, P.E.
Mooresville Region Water Quality Supervisor

of vv rF(K
\O� RAG ) Michael F. E;Ie4
GovernorWilliam G. RosSecretary
North Carolina Department of Environment and Natural Resources
> Alan W. Klimek, P.E. Director
Division of Water Quality
June 8, 2004
Certified Mail'
Return R T7pt Requested
Mr. Martin Wilson, Public Works Director 7003 2260 00013550 1694
City of Ne _
P.O. Box `5
Newton, N6itarolina 28658
,z
Subject: Notice of Violation and
Recommendation for Enforcement
Incident #200401136
NOV#.2004-DV-0020
City of Newton
Land Application Permit # WQ0003902
Catawba County
Dear Mr. Wilson:
Mr. Danny Sigmon with the City of Newton called the Mooresville Regional Office on May
21; 2004 and spoke with Ms. Ellen Huffman of my staff. He reported to Ms. Huffman that on May 21,
2004, James Richards and Eric Jones (both with the City), during a routine inspection of the land
application contractor, discovered that the contractor had applied sludge on a site not permitted for
sludge application. The application of sludge on land not permitted for such disposal is a violation of
NCGS 143-215.1 a (9). It should be noted that the City of Newton was cited for similar violations on
January 31, 2003, and February 18, 1999.
It is requested that the City respond to this Notice within ten (10) working days of receipt of
this letter. The response should include any mitigating factors concerning the violation and any
actions/procedures that will be implemented to prevent recurrence. Please reference the subject permit
number when providing your response.
The City of Newton may be assessed civil penalties in this matter pursuant to NCGS 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
($25,000.00) per violation per day may be assessed against a person who violates any permit
condition, classification, standard, limitation, or management practice established pursuant to G.S.
143-214.1, 143-214.2 or 143-215.
NCDENR
Customer Service
1 800 623-7748
Mooresville Regional Office PHONE [phone]
919 North Main Street, Mooresville, NC 28115 FAX [phone]

■ Complete items 1, 2, and.3. Also complete A. Si ture
item 4 if Restricted Delivery is desired. .y ❑Agent
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so that we can return the card to you. 7ece1vedby Pnnted Name) C. Date of Delivery■ Attach this card to the back of the mailpiece, j B� ,—L).-)
or on the front if space permits. V~_,
D. Is delivery address different frp dern 1Yes I
1. Article Addressed to: If YES, enter delivery add ow:1
MR MARTIN WILSON'.PUBLIC _WORKS.DIR.
CITY OF NEWTON
PO BOX 550 `��
NEWTON NC 28658 •service Type
Certified Mail ❑ Express Mail
wq/eh 6/8/04 ❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2. 7003 2260 0001 3550 1694
PSI Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1540
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o LSeW7MR MARTIN WILSON,PWTON IC ORICS DIR.
oCITY OF NE -- -_____PO BOX 550 28658----------
NEWTON NC
wq/eh 6/8/04

page 2
If you have any questions regarding thi�Notice, please do not hesitate to call Ms. Huffinan or me
at 704-663-1699.
Sincerely,
D. Rex Gleason, P.E.
Mooresville Region Water Quality Supervisor
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Danny Sigmon, City of Newton
Frankie Singleton, SYNAGRO

WA Fig Michael F. Easley, Governor
Q William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 7, 2004
Certified Mail
Return Receipt Requested
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Nov �6�J
Z004
00-7,0
Subject: Notice of Violation and .
Recommendation for Enforcement
City of Newton
Land Application Permit # WQ0003902
Catawba County --
Dear Mr. Wilson:
Mr. Danny Sigmon with the City of Newton called the Mooresville Regional Office on May 21,
2004 and spoke with Ms. Ellen Huffman of my staff. He reported to Ms. Huffman that on May 21, 2004,
James Richards and Eric Jones (both with the City), during a routine inspection of the land application
contractor, discovered that the contractor had applied sludge on a site not permitted for sludge application.
The application of sludge on land not permitted for such disposal is a violation of NCGS 143-215.1 a (9).
It should be noted that the City of Newton was cited for similar violations on January 31, 2003, and
February 18, 1999.
It is requested that the City respond to this Notice within ten (10) working days of receipt of this
letter. Your response should include any mitigating factors concerning the violation and any
actions/procedures that will be implemented to prevent recurrence. Please reference the subject permit
number when providing your response.
The City of Newton may be assessed civil penalties in this matter pursuant to NCGS 143-
215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
($25,000.00) per violation per day may be assessed against a person who violates any permit condition,
classification, standard, limitation, or management practice established pursuant to G.S. 143-214.1, 143-
214.2 or 143-215.
Customer Service
1 800 623-7748
Mooresville Regional Office
919 North Main Street, Mooresville, NC 28115
PHONE [phone]
FAX [phone]

1 4

page 2
If you have any questions regarding this Notice, please do not hesitate to call Ms. Huffman or me
at 704-663-1699.
Sincerely,
D. Rex Gleason, P.E.
Mooresville Region Water Quality Supervisor
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Danny Sigmon, City of Newton
Frankie Singleton, SYNAGRO

d.,

W AT �9QG
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
p 'C
07/21/2002
"V Martin Wilson
City of Newton
�201 West 4th Street
Newton, NC 28658
SUBJECT: PAYMENT ACKNOWLEDGMENT
CIVIL PENALTY ASSESSMENT
City of Newton Residuals Land Application Program
Catawba County
Permit No: WQ0003902
PC-2003-0004
Dear Mr. Martin:
Alan W. Klimek, P.E. Director
Division of Water Quality
AHO NATO P�,_ FT'QOuRCE8
This letter is to acknowledge receipt of check No. 237490 in the amount of $2,232.41 received
from you dated July 14, 2003. This payment satisfies in full the civil assessment levied against the
subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call Daryl Merritt at 919-733-5083 Ext.581.
Sincerely,
f6v een llins, Chief
Water Quality Section
cc: Enforcement File #: PC-2003-0004
ffrzeuS_pervisor
Central Files
iNCEI
1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service 1 800 623-7748

■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
s Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
MR MARTIN WILSON, DIRECTOR --
CITY OPNEWTON
PO BOX J5.0
ON NC 1)
A. Signature / _
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B. Received by (P ' ted Name C. 2 6f y elivery
D. Is delivery address different frpT [he i EleS<
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If YES, enter delivery address<'below:
NEWT , . Service Type
WQ/eh 1/16/03 _ _ _ _ "'9 Certified Mail ❑ Express Mail
❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
7001 2530 ;0005 0.287 9535, ;
PS Form 3811,'August 2001. Domestic Return Receipt 102595-01-M-2509
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Postage
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Certified Fee6stmarku7
Return Receipt Feep (Endorsement Required)4Mere
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MR MARTIN WILSON, DIRECTOR
fly
Sent
CITY OF NEWTON
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NEWTON NC 28658
.-----------
WQ/eh 1/16/03

�A'4 U)NAM,n . ,�v�oJi fi7 uti7%
w�'0'��8�1/tr
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p�O� W A T �RQG
CO
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o -mac
Martin Wilson
City of Newton
201 West 4th Street
Newton, North Carolina 28658
[Uft 2 4 2003
Michael F. Easley
Governor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
SUBJECT: Assessment of Civil Penalties
for VIOLATION OF NON -DISCHARGE PERMIT
PERMIT No. WQ0003902
Catawba County
File No. PC 2003-0004
Dear Mr. Wilson:
This letter transmits notice of a civil penalty assessed against City of Newton in the amount of
$2,232.41 which includes $232.41 in investigative costs. Attached is a copy of the assessment
document explaining this penalty.
This action was taken under the authority vested in me by delegation provided by the Secretary
of the Department of Environment and Natural Resources and the Director of the Division of
Water Quality. Any continuing violation(s) may be the subject of a new enforcement action,
including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following three items:
1. Submit payment of the penalty:
Payment should be made to the order of the Department of Environment
and Natural Resources. Payment of the penalty will not foreclose further
enforcement action for afly continuing or new violation(s). Do not include
the attached waiver form if making payment.
Please send payment to the attention of:
Mr. Daryl Merritt
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617p
�JCDENR
Customer Service: Mailing Address: Telephone [phone] Location:
1-877-623-6748 1617 Mail Service Center Fax [phone] N. Salisbury St.
Raleigh, North Carolina 27699-1617 State Courier #52-01-01 Raleigh, NC 27699-1617
An Equal Opportunity/Affirmative Action Employer
50% recycled / 10% post -consumer paper
ht1p://h2o. enr.state.nc. us

2. Submit a written request for remission or mitigation including a
detailed justification for such request:
A request for remission or mitigation is limited to consideration of the reasonableness
of the amount of the penalty and is not the proper procedure for contesting the
accuracy of any of the statements contained in the assessment letter. Because a
remission request forecloses the.option of an administrative hearing, such a request
must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute. You must execute and
return to this. office the attached waiver form and a detailed statement which you
believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b)
were wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from
the violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please submit this information to the attention of.
Mr. Daryl Merritt
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
"
Rex Gleason
919 North MAin Street
Mooresville, North Carolina, 28115
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any portion of the civil penalty assessment, you must request an
administrative hearing. This request must be in the form of a written petition to the
Office of Administrative Hearings and must conform to Chapter 150B of the North
Carolina General Statutes. You must file your original petition with the:

Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
AND
Mail or hand -deliver a copy of the petition to:
Mr. Dan Oakley
NCDENR
Office of General Counsel
1601 Mail Service Center
Raleigh, NC 27699-1601
Mr. Daryl Merritt
DWQ
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Failure to exercise one of the options above within thirty days, as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred
to the Attorney General's Office with a request to initiate a civil action to collect the penalty.
Please be advised that additional assessments may be levied for future violations which occur
after the review period of this assessment.
If you have any questions, please contact Mr. Daryl Merritt at [phone], ext. 581.
JKW/ddm
ATTACHMENTS
cc:
Sincerely,
ent Wiggins, Acting ervisor
Non -Discharge Compliance and Enforcement Unit
Ellen Huffman, MRO w/ attachments
File # PC 2003-0004 w/ attachments
Central Files w/ attachments
Public Information Officer w/ attachments

STATE OF NORTH CAROLINA NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
COUNTY OF CATAWBA
File No. PC 2003-0004
IN THE MATTER OF
CITY OF NEWTON )
FINDINGS AND DECISION
FOR VIOLATION OF ) AND ASSESSMENT OF
15A NCAC 2H .0217 AND ) CIVIL PENALTIES
N.C.G.S 143-215.1 )
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water Quality, I, J. Kent
Wiggins, Acting Supervisor of the Non -Discharge Compliance and Enforcement Unit of the
Division of Water Quality (DWQ), make the following:
I. FINDINGS OF FACT:
A. THE City of Newton is an incorporated municipality organized and existing under
the laws of the State of North Carolina.
B. On November 6, 2002, DWQ issued Water Quality Permit No. WQ0003902 to
the City of Newton for the operation of a wastewater residuals land application
program. The source of the residuals is the Clark Creek Wastewater Treatment
Plant. Permitted disposal sites are located in Catawba County.
C. On January 13, 2003 the City of Newton land applied WWTP residuals onto land
that was not permitted for disposal.
D. On January 14, 2003, DWQ staff in the Mooresville Regional Office were
informed of the violation by telephone notification from Mr. Danny Sigmon, City
of Newton.
E. Said permit contains the following relevant conditions:
CP
Permit Condition I.8 states that only sites listed in the most recently certified
Attachment B of the permit are approved for residuals land application.

Permit Condition II.7 states that specific application area boundaries be clearly
marked on each site prior to and during application.
F. A Notice of Violation/Notice of Recommendation for Enforcement was sent to
the City of Newton by DWQ's Mooresville Regional Office on January 16, 2003.
G. The cost to the State of the enforcement procedures in this matter totaled $232.41.
Based upon the above Findings of Fact, I make the following:
II. CONCLUSIONS OF LAW:
A. The City of Newton is a "person" within the meaning of G.S.143-215.6A pursuant
to G.S. 143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition
of same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the disposal of wastewater residuals pursuant to G.S. 143-
215.1(a)(9) and Part I, Condition No. 8 of DWQ Permit No. WQ0003902.
D. The City of Newton violated G.S. 143-215.1(a)(9) and Part I, Condition No. 8 of
DWQ Permit No. WQ0003902 by failing to properly operate and maintain a non -
discharge land application system.
E. The City of Newton violated Part II, Condition No. 7 of DWQ Permit No.
WQ0003902 which requires that specific residual application area boundaries be
clearly marked on each site prior to and during application. Not all buffers were
marked clearly as required.
F. The City of Newton may be assessed civil penalties in this matter pursuant to G.S.
143-215.6A(a)(2), which provides that a civil penalty of not more than twenty five
thousand dollars per violation may be assessed against a person who is required
but fails to apply for or to secure a permit required by G.S. 143-215.1(a)(9), or
who fails to comply with the conditions of the permit.
F. The State's enforcement costs in this matter may be assessed against the City of
Newton pursuant to G.S. 143-215.3(a)(9) and G.S. 14313-282.1(b)(8).
G. The Acting Supervisor of the Non -Discharge Compliance and Enforcement Unit,
Division of Water Quality, pursuant to delegation provided by the Secretary of the
Department of Environment and Natural Resources and the Director of the
Division of Water Quality, has the authority to assess civil penalties in this matter.

Based upon the above Findings of Fact and Conclusions of Law, I make the following:
M. DECISION:
Accordingly, City of Newton is hereby assessed a civil penalty of:
$ for failing to comply with Permit Condition I. 8, which
requires that only sites listed in the most recently certified
Attachment B of the permit are approved for residuals land
application.
$ o e d for failing to comply with Permit Condition 111.7, which
requires that specific residual application area boundaries
be clearly marked on each site prior to and during
application. Not all buffers were marked clearly as
required.
$ Enforcement costs
$Z 7� �l TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
(Date) J. Kent Wiggins, Ac ' upervisor
Non -Discharge Co p lance and Enforcement Unit
Division of Water Quality

STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF Catawba
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
PERMIT NO. W00003902 ) STIPULATION OF FACTS
Having been assessed civil penalties totaling $ 2,232.41 for
violation(s) as set forth in the assessment document of the Director of the Division of Water Quality
dated, 06/19/2003 , the undersigned, desiring to seek remission of the civil penalties, does
hereby waive the right to an administrative hearing in the above -stated matter and does stipulate that
the facts are as alleged in the assessment document.
The undersigned further understands that all evidence presented in support of remission of
this civil penalty must be submitted to the Director of the Division of Water Quality within thirty
(30) days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allowed after thirty (30) days from the receipt of the civil penalty assessment.
This the day of , 20_
SIGNATURE
ADDRESS
TELEPHONE

toF WA7F9
Q
\Q (� Michael F. Easley, Governor
Cq i i William G. Ross, Jr.,Secretary North Carolina Department of Environment and Natural Resources
0 Y Alan W. Klimek, P.E., Director
Division of Water Quality
May 7, 2003
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
Permit No. WQ0003902
City of Newton
Catawba County
Dear Mr. Wilson;
Enclosed is the land application inspection report for the inspection conducted on May 1, 2003 by
Ms. Ellen Huffman with this Office. This is an inspection of a new land application site (CA 32-1) approved
in the latest version of the permit (dated 11/12/02).
The inspection report should be self-explanatory, however, if you have any questions, please contact
Mrs. Huffman or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Attachment
cc: Non -discharge compliance
Frankie Singleton, SYNAGRO
eAM
NCDENR
Mooresville Regional Office, 919 North Main Street, Mooresville, NC 28115
PHONE [phone] Customer Service
FAX [phone] 623-7748

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr. Secretary.
Alan W. Klimek, P.E. Director
161, una, ? FAA
Ar4i 0 2
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: WQ0003902
Last Amended Date: November 12, 2002
SOC Issuance Date(if applicable): N/A
Permittee Contact: Martin Wilson
ORC Name: James Richards
ORC Cert.#: #13257
Reason for Inspection
County: Catawba
Issuance Date: September 8, 2000
Expiration Date: August 31, 2005
Expiration Date: N/A
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
BU/ ORC: Dennis Murdock #13249
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary: (additional comments may he included on attached pages)
This is an inspection of a new land application site ( CA 32-1) approved in the latest version of
the permit (dated 11/12/02). The sludge application appeared evenly distributed. Application
equipment was is good shape. Buffers and boundaries were adequately marked for the equipment
operator. Due to the unpredictability of the weather lately, the operator applied sludge further
back from the flagged boundary for extra protection from run-off.
Is a follow-up inspection necessary _yes X no
Inspector(s) Name(s)/Title(s} Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection May 1, 2003

Residuals Inspection
WQ0003902 Catawba County
Tvpe of Residual
_X Land Application (class B) Distribution and Marketing (class A)
Record Keening not evaluated during this inspection
Y/N
Copy of current permit available at residual generating site
Current metals and nutrient analysis (frequency -annual)
TCLP analysis (annual), N SSFA (Standard Soil Fertility Analysis)(annual)
Nutrient and metals loading calculations
Hauling records
Field loading records, Y Field site maps and information
Records of lime purchased (contractor keeps lime purchase records)
Pathogen & Vector Attraction Reduction (annual)
Comments:
Pathogen & Vector Attraction Reduction Records
X Lime stabilization
Comments:
Treatment (check treatment type(s) used)
Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
X Alkaline Stabilization class B other -describe
Comment: records for stabilization were not evaluated during this inspection,
Transport
Spill control plan in transport vehicle? Y
Does transport vehicle appear to be maintained? Y
pb 2
Operation & Maintenance
Condition of land application equipment on site: Equipment was clean and appeared to be well
maintained.

Residuals Inspection
WQ0003902 Catawba County
Storage
Number of days/weeks/months of storage: 30 days
Describe storage: four tanks, 220,000 gallons each
pg 3
Sampling - not evaluated during this inspection
Describe Sampling:
Is sampling adequate? Is sampling representative?
Field Sites (end use for class B biosolids) Y/N
Y Permit on site during application
Y Buffers adequate
N Documented exceedances of PAN limits
N Signs of runoff/ ponding
Y Rain Gauge on site during application
Y Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
(if no, improvements recommended) _
Are there any limiting slopes on fields? Y/N
N 10 % for surface application N 18% for subsurface application
Comment: Field conditions were found to be very good. Sludge application appeared even.
Equipment was clean. Field entrance was clean. No nuisance conditions were noted.
Monitoring well(s) Y/N: N
If yes, location of well(s)
Comment:
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed: No nuisance conditions were
found during this inspection. Slight odors were detectable immediately down wind of the field site;
however, odors were minimal and intermittent. A review of the files revealed that the Mooresville
regional Office had received no (odor) complaints in 2002.

WA7',j�,6
OTC
Michael F. Easley, Governor
QG
William G. Ross Jr., Secretary
O�
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
O
January 31, 2003
MEMORANDUM TO: Kent Wiggins
FROM: `� D. Rex Glea.soJn Ilps
PREPARED BY: Ellen Huffman
SUBJECT: Recommendation for Enforcement
Violation of NCGS 143-215.1 (a) (9) and Permit No. WQ0003902
City of Newton
Attached is the enforcement report/recommendation concerning violation of NCGS 143-
215.A (9) and the subject permit. The violation concerns the application of sludge by the
City of Newton on land not permitted for sludge. This is the second such incident by the
City. The Water Quality Enforcement Tracking System indicates that the permittee was
cited for the first disposal incident; however, that case was combined with one involving
an over -application of Nickel. The City was assessed only for the Nickel over -
application. A penalty of $10,830.70 was paid and the case closed on 01/31/00.
The attached information should be self-explanatory; however, if you have any questions,
please contact Mrs. Ellen Huffman or me.
Attachments
95ENUR
Customer Service
1 Rnn R7'k-77AR
luloto:
r4� c
Mooresville Regional Office
Q1Q IUnrtFh Main Ctraot Mnn—cuillc Wr'.9R115
PHONE [phone]
PAY t7nd1 RR2 Rndn

kwl
Summary
On Tuesday, January 14, 2003, Mr. Danny Sigmon, City of Newton, called the
Mooresville Regional Office of the Divison of Water Quality to report. that the City's
residuals contractor, SYNAGRO, had land applied sludge on land not permitted for
sludge application. The incident occurred on the previous day (1/16/03). On January 17,
2003, Ms. Ellen Huffinan with MRO/DWQ received a fax from James Richards, City of
Newton, concerning the event. A hard copy of the fax was received by MRO on January
23, 2003.
A file review confirmed that the area receiving the sludge was not a permitted field. -
Chronology of Events/Correspondence
Jan. 14, 2003 Mr. Danny Sigmon called the MRO to report that the City's contractor,
SYNAGRO, had land applied on a non -permitted field (area near field
35-3) on the previous day.
Jan. 17, 2003 Ms. Huffinan received a fax from James Richards confirming the event.
The fax included a map of the site and a letter from SYNAGRO
concerning the event.

G�
0,
CHECKLIST FOR PERMIT VIOLATIONS
1. A copy of the Permit (#WQ0003902) is attached.
2. The violator is the City of Newton. Mr. Martin Wilson is the Utilities Director
for the City.
Mr. Martin Wilson, Utilities Director
City of Newton.
Post Office Box 550
Newton, North Carolina 28658
3. This enforcement does not include effluent limit violations. It involves violations
of non -discharge Permit No. WQ0003902 and NCGS 143-215.1(a) (9).
4. Copies of correspondence are attached.
5. There are no chain -of -custody samples.
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violation(s) chronic and/or due to a single operational upset?
This is the second violation reported by the City for application of residuals on a.
non -permitted site. The first violation occurred on Nov. 4, 1998.
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NRE was sent to the City of Newton on January 16, 2003, for the
reported violation and indicated that an enforcement recommendation would be
prepared by the MRO.
9. Cost of the investigation:
4 hours by Ellen Huffman for preparation
of enforcement report at $20.38/hour = $81.52
1 hour by D. Rex Gleason for supervisory review
at $39.96/hour = $39.96
1 hour for clerical processing at $10.93/hour = $10.93
Administrative Cost for processing report =$300.00
Total $432.41

10,
CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
CASE NAME: City of Newton
ASSESSMENT FACTORS:
A. CAUSE OF THE VIOLATION(S)
The violation is the result of the City's contractor, SYNAGRO, failing to comply with
the terms and conditions of the City's land application Permit.
Permit Condition I. 8. requires that specific residual application area boundaries
be clearly marked on each site prior to and during application. The field was not
flagged/marked clearly. The field equipment operator applied in the wrong areas.
B. THE DEGREE AND EXTENT OF HARM CAUSED BY THE VIOLATION(S)
No harm documented. Residuals did not appear to have entered surface waters.
C. DURATION OF THE VIOLATION(S)
The violation occurred on Monday, January 13, 2003.
D. EFFECT OF VIOLATIONS) ON WATER, PUBLIC HEALTH AND FISH
OR WILDLIFE
There is no documented effect on water or public health as a result of the
violations.
E. EFFECTIVENESS OF ANY PREVENTIVE OR RESPONSIVE MEASURE
TAKEN -BY THE VIOLATOR
SYNAGRO did not take any immediate preventive or responsive action.
F. COST OF RECTIFYING THE DAMAGE OR INFORMATION THAT
WOULD BE NEEDED TO DETERMINE THE COST, SUCH AS PROCESS
RATES, CLEAN UP COSTS
Cost of damage was not determined.

i
G. THE ALLEGED VIOLATOR'S PREVIOUS RECORD OF COMPLIANCE
OR NONCOMPLIANCE
The City of Newton was not assessed a civil penalty for a previous identical
violation that occurred on November 5, 1998. However, the City was assessed for
high Nickel concentrations in sludge that had been applied. The penalty amount
was $10,830.70, and was paid in full.
H. MITIGATING, AGGRAVATING FACTORS, IF ANY,
This is the second such incident of applying sludge to Iand that was not permitted
for such. The City's previous land application contractor, Sigmon
Environmental, made the same error on Nov. 5, 1998. The City has been quick to
report any violations as soon as they have been discovered. See attached
responses from the City and SYNAGRO. Please note that there is a discrepancy
of the estimated volume of sludge land applied on non -permitted land. The City
reported 20,000-25,000 gallons and SYNAGRO estimated 5,000 gallons.

STATE OF NORTH CAROLINA
COUNTY OF CATAWBA
IN THE MATTER OF: )
CITY OF NEWTON )
FOR VIOLATIONS OF PERMIT }
NO. WQ0003902 AND )
NCGS 143-215.a (9) )
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
File No. PC
FINDINGS AND DECISION
AND ASSESSMENT
OF CIVIL PENALTY
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources, I, Alan W. Klimek, P.E., Director of the Division
of Water Quality, make the following:
I. FINDINGS OF FACT:
A. THE City of Newton is an incorporated municipality organized and existing under
the laws of the State of North Carolina.
B. On November 6, 2002, DWQ issued Water Quality Permit No. WQ0003902 to
the City of Newton for the operation of a wastewater residuals land application
program. The source of the residuals is the Clark Creek Wastewater Treatment
Plant. Permitted disposal sites are located in Catawba County.
C. On January 13, 2003 the City of Newton land applied WWTP residuals onto land
that was not permitted for disposal.
D. On January 14, 2003, DWQ staff in the Mooresville Regional Office were
informed of the violation by telephone notification from .Mr. Danny Sigmon, City
of Newton.
E. Said permit contains the following relevant conditions:
Permit Condition I.8 states that only sites listed in the most recently certified
Attachment B of the permit are approved for residuals land application.
Permit Condition 11.7 states that specific application area boundaries be
clearly marked on each site prior to and during application.

i
F. A Notice of Violation/Notice of Recommendation for Enforcement was sent to
the City of Newton by DWQ's Mooresville Regional Office on January 16, 2003.
G. The cost to the State of the enforcement procedures in this matter totaled
$432.41.
Based upon the above Findings of Fact, I make the following:
11. CONCLUSIONS OF LAW:
A. The City of Newton is a "person" within the meaning of G.S.143-215.6A pursuant
to G.S. 143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the defmition
of same at G.S. 143-213(10) or G.S. 143-213(17).
C. A permit is required for the disposal of wastewater residuals pursuant to G.S. 143-
215. 1 (a)(9) and Part I, Condition No. 8 of DWQ Permit No. WQ0003902.
D. The City of Newton violated G.S. 143-215.1(a)(9) and Part I, Condition No. 8 of
DWQ Permit No. WQ0003902 by failing to properly operate and maintain a non -
discharge land application system.
E. The City of Newton violated Part II, Condition No. 7 of DWQ Permit No.
WQ0003902 which requires that specific residual application area boundaries be
clearly marked on each site prior to and during application. Not all buffers were
marked clearly as required.
F. The City of Newton may be assessed civil penalties in this matter pursuant to G.S.
143-215.6A(a)(2), which provides that a civil penalty of not more than twenty
five thousand dollars per violation may be assessed against a person who is
required but fails to apply for or to secure a permit required by G. S. 143-
2 1 5.1(a)(9), or who fails .to comply with the conditions of the permit.
G. The State's enforcement costs in this matter may be assessed against the City of
Newton pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
H. The Director, Division of Water Quality, pursuant to delegation provided by G.S.
143- 15.6A(h), has the authority to assess civil penalties in this matter.
III. DECISION:

III. DECISION:
Accordingly, the City of Newton is hereby assessed a civil penalty of:
$ for failing to comply with Permit Condition I. 8, which requires
that only sites listed in the most recently certified Attachment B of
the permit are approved for residuals land application.
$ for failing to comply with Permit Condition 11.7, which requires
that specific residual application area boundaries be clearly
marked on each site prior to and during application. Not all
buffers were marked clearly as required.
$ 432.41 Enforcement costs
$ TOTAL A -MOUNT DUE
As required by G. S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.. S. 143B-282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory
authority; and
(8) The cost to the State of the enforcement procedures.
(Date) Alan W. Klimek, P.E. Director
Division of Water Quality

Payment
Remission
Petition
Collection
Settlement
Fast Track
Admin

CITY OF
P.O. Box 550 e Newton, NC 28658 a [phone]
"THE HEART OF CATAWBA COUNTY"
January 17, 2003
Mrs. Ellen Huffman
NC DENR
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Dear Mrs. Huffman,
JAN 2 3 2003
Subject: City of Newton
L.A. Permit # WQ0003902
Catawba County
On. Monday, January '13, 2003 Mr. Eric Jones,.one of my ORC. back-up operators, and I
went to inspect the land application event that was occurring at Field 35-3. We arrived at the site
shortly after 1100. We returned to the treatment plant and, while documenting our inspection,
discovered that bio-solids had been applied outside the permitted application area. I would
estimate that approximately 20,000 to 25,000 gallons were applied outside the permitted area,
with approximately 5,000 to 6,000 of this being on the small field. We notified Mr. Darren
Brittain, Synagro's project manager, and arranged to meet him at the site.
After inspecting the site, Mr. Brittain called Mr. Frankie Singleton, Synagro's Operations
Director. I talked to Mr. Singleton at this time also. Mr. Singleton and I agreed to meet
Wednesday January 15, so that he could inspect the site. Mr. Singleton, Mr. Brittain and I visited
the site on January 15. Mr. Singleton checked the slope on the site where bio-solids were applied
outside the application area and determined that is was less than 10%. Mr. Singleton and I agreed
that we would request this area be added to our permit. We also agreed that Synagro would
contact your office and write a letter explaining steps they plan to take to prevent this from
happening again.
Mr. Jones or I currently visit the land application site almost every day that an application
occurs. We inspect the application and, upon returning to the treatment plant, document where
the application occurred. I talk with Mr. Brittain and Mr: Singleton regularly concerning our
program. I know of nothing else that the City can do to ensure that the bio-solids application
meets the conditions of our permit. Any input from your office would be appreciated.

I have attached a copy of the letter that Synagro wrote and a map showing where the
application in question occurred. If I can be of further assistance, you can reach me at (828)-695-
4345.
Sincerely,
dI arao 0- P�"
es A. Richards
Supervisor / ORC
Clark Creek WWTP
cc: Mr. Frankie Singleton / Synagro
copy: Mr. Martin Wilson
Mr. Danny Sigmon
Mr. Eric Jones

TuRsiFiL.L. PP.6psime S F GELD SS-3
A'PfL%C.V%TIQIJ E)9JT60'0E: 1�2m IV" Ap,,F&
of 31oS=///

�� 1N)
,1 SYNAGR
A Residuals Management Company
Via E-mail Transmission
January 17, 2003
James Richards, Chief Operator, ORC
City of Newton Wastewater Treatment Plant
P.O. Box 550
Newton, NC 28658
Dear James:
I am writing in regards to your visit to the Turbyfill Properties (Bill Canipe) site. Please see
the following:
During the week of December 30g', Darren Brittain flagged out the field(s) at the
Turbyfill Properties and instructed our operator where to apply and where not to
apply.
In the succeeding days our operator began land applying the biosolids to the flagged
areas.
On Monday, Jan 13"', during the site visit, it was revealed that our operator had
inadvertently spread approximately 5,000 gallons of biosolids on a portion of the
property that was not permitted. There was a miscommunication during the initial
instructions by Darren and our operator. Our operator thought she was supposed to
apply to this area.

We regret this application of biosolids to an area that is not permitted and Synagro has
implemented the following steps to hopefully avoid this in the future. In the past, Synagro has
not flagged a tree line, wood line, or hedgerow if there were no property or other buffer areas.
Our operators just simply use the tree line as a guide. In the future, Synagro staff will flag
along the tree line to confirm to the operator that area is the. application area. Also, our
operator will be continually trained on interpreting the application maps, should he or she have
any questions. Furthermore, Synagro technical will be submitting a permit modification to
include the area that received biosolids.
Again, we express regret for the incident above and feel confident the corrective measures
presented should alleviate future concerns. Please call us with questions or comments.
Sincerely,
F�aY& &�gl to'y lelwda Now y
Frankie Singleton Rhonda Money
Senior Operations Manager Technical Services Manager
c: Eric Jones
Danny Sigmon
Martin Mabe
Darren Brittain
0 Page 2

F wATF Michael F. Easley, Governor
O�0 RQG Wlriam G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
COW7
r Alan W. Klimek, P.E. Director
Division of Water Quality
January 16, 2003
Certified Mail
Return Receipt Requested
70012510 0005 0287 9535
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
Subject: Notice of Violation and Recommendation
for Enforcement
City of Newton
Land Application Permit # WQ0003902
Catawba County
Dear Mr. Wilson:
Mr. Danny Sigmon with the City of Newton called the Mooresville Regional Office on January 14,
2002. Mr. Sigman spoke with Ms. Huffman of my staff. He indicated that on January 13, 2003, the
City's land application contractor applied sludge on a site not permitted for sludge application.
The application of sludge on land not permitted for sludge disposal is a violation of NCGS 143-215.1 a (9).
It should be noted that the City of Newton was sited for the same violation on February 18, 1999.
It is requested that the City respond to this Notice within ten (10) working days of receipt of this
letter. Your response should include any mitigating factors concerning the violation and any
actions/procedures that will be implemented to prevent recurrence. Please reference the subject permit
number when providing your response.
Please be aware that the City of Newton may be assessed civil penalties in this matter pursuant to G.S.
143-215.6A(a)(2), which provides that a civil penalty of not more than twenty five thousand dollars
($25,000.00) per violation per day may be assessed against a person who violates any permit condition,
classification, standard, limitation, or management practice established pursuant to G.S. 143-214.1, 143-
214.2 or 143-215.
NOW
NN-MEW
Customer Service Mooresville Regional Office PHONE. [phone]
1 Ann 97�77AR Q1 Q Nnr+h Main C+ra=+ Mnnroavill0 N( 7Ri 1 ri FOX 17nA1 RRunAn

Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton; North Carolina 28658
page 2
If you have any questions regarding this Notice, please do not hesitate to call Mrs. Huffinan or me
at 704-663-1699.
Sincerely,
D. Rex Gleason, P.E.
Mooresville Region Water Quality Supervisor
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Danny Sigmon, City of Newton

Newton Waste Water Fax:[phone] Jan 17 '03 14:41 P.01
4. ft4k, I e W
CITY OF
City of Newton
P.O. Box 550
Newton, NC 28658
P.O. Box 550 . Newton, N.C. 28658 • [phone] . Fax, [phone]
Pacsimile'Message
NC i�vR
Fax Number:
Clark Creek
Wastewater Treatment Plant
Phone #
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410-494-8200 fax [phone]
www, imprintonline. com
Message: 66m /5 %l-c �ou- k 0LkEST t,0 .
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Newton Waste Water Fax:[phone]
Jan 17 '03 14:42 P.02
CITY OF
"THE HEART OF CATAWBA COUNTY"
January 17, 2003
Mrs. Ellen Huffinan
NC DENR
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
Dear Mrs. Huffman,
P.O. Box 550 • Newton, NC 28658 - [phone]
Subject: City of Newton
L.A. Permit # WQ0003902
Catawba County
On Monday, January 13, 2003 Mr. Eric:Jones, one of my ORC. back-up operators, and I
went to inspect the land application event that was occurring at Field 35-3. We arrived at the site
shortly after 1100. We returned to the treatment plant and, while documenting our inspection,
discovered that bio-solids had been applied outside the permitted application area. I would
estimate that approximately 20,000 to 25,000 gallons were applied outside the permitted area,
with approximately 5,000 to 6,000 of this being on the small field. We notified Mr. Darren
Brittain, Synagro's project manager, and arranged to meet him at the site.
After inspecting the site, Mr. Brittain called Mr. Frankie Singleton, Synagro's Operations
Director. I talked to Mr. Singleton at this time also. Mr. Singleton and I agreed to meet
Wednesday January 15, so that he could inspect the site. Mr. Singleton, Mr. Brittain and I visited
the site on January 15. Mr. Singleton checked the slope on the site where bio-solids were applied
outside the application area and determined that is was less than 10%. Mr. Singleton and I agreed
that we would request this area he added to our permit. We also agreed that Synagro would
contact your office and write a letter explaining steps they plan to take to prevent this from
happening again.
Mr. Jones or I currently visit the land application site almost every day that an application
occurs. We inspect the application and, upon returning to the treatment plant, document where
the application occurred. I talk with Mr. Brittain and Mr. Singleton regularly concerning our
program. I know of nothing else that the City can do to ensure that the bio-solids application
meets the conditions of our permit. Any input from your office would be appreciated.

Newton Waste Water Fax:[phone] Jan 17 '03 14:42 P.03
I have attached a copy of the letter that Synagro wrote and a map showing where the
application in question occurred. If I can be of further assistance, you can reach me at (828)-695-
4345.
Sincerely,
al� � - A."
es A. Richards
Supervisor / ORC
Clark Creek WWTP
cc: Mr. Frankie Singleton / Synagro
copy: Mr. Martin Wilson
Mr. Danny Sigmon
Mr. Eric Jones

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Newton Waste Water Fax:[phone] Jan 17 '03 14:46 P.06
We regret this application of biosolids to an area that is not permitted and Synagro has
implemented the following steps to hopefully avoid this in the future. In the past, Synagro has
not flagged a tree line, wood line, or hedgerow if there were no property or other buffer areas.
Our operators just simply use the tree line as a guide. In the future, Synagro staff will flag
along the tree line to confirm to the operator. that area is the application area..A,lso, our
operator will be continually trained on interpreting the application maps, should he or she have
any questions. Furthermore, Synagro technical will be submitting a permit modification to
include the area that received biosolids.
Again, we express regret for the incident above and feel confident the corrective measures
presented should alleviate future concerns. Please call us with questions or comments.
Sincerely,
Franlcie Singleton
Senior Operations Manager
Eric Jones
Darmy Sigmon
Martin Mabe
Darren Brittain
• Page 2
Rhonda Money
Technical Services Manager

Michael F. Easley, Govern r
Q William G. Ross, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
_v) ' r
_ Kerr T. Stevens, Director
O rs� Division of Water Quality
September 4, 2001
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application Inspection
Permit No. WQ0003902
City of Newton
Catawba County
Dear Moir. Wilson;
Enclosed is the land application inspection report for the inspection conducted on August 16,
2001 by Ms. Ellen Huffman with this Office. An odor complaint was received on the same day. The
inspection showed compliance with all permit conditions, including laboratory data, record keeping,
and field conditions.
The inspection report should be self-explanatory, however, if you have any questions, please
contact Mrs. Huffman or me at [phone].
Attachment
cc: Non -discharge compliance
Frankie Singleton, SYNAGRO
h:Newton0801.doc
NCDENR
Customer Service
1 800 623-7748
Sincerely,
D. Rex Gleason, P.E.
Water Quality Reb onal Supervisor
Mooresville Regional Office
919 North Main Street, Mooresville, NC 28115
PHONE [phone]
FAX [phone]

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: W00003902
Last Amended Date: February 11, 1998
SOC Issuance Date(if applicable): N/A
Permittee Contact: Martin Wilson
ORC Name: James Richards
ORC Cert.#: #13257
Reason for Inspection
County: Catawba
Issuance Date: September 8, 2000
Expiration Date: August 31, 2005
Expiration Date: N/A
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
BU/ ORC: Dennis Murdock # 13249
ROUTINE X COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System Spray Irrigation X Sludge Other
Inspection Summary: (additional comments may be included on attached paves)
The City of Newton is permitted to land apply 3,438 dry tons of sludge generated from the Clark
Creek WWTP. SYNAGRO is the current land application contractor. The inspection showed
the facility to be in compliance with the permit, and revealed good field conditions with minimal
odor. A file review showed no odor complaints were received by the MRO in 2000, and one
complaint received in 2001(08/06/01).
Is a follow-up inspection necessary _yes X no
Inspector(s) Name(s)/Title(s) Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection August 16, 2001

Residuals Inspection Cheek List
WQ0003902 Catawba County August 16, 2001
Type of Residual
X Land Application (class B) Distribution and Marketing (class A)
pg 1
Record Keeping The answers (below) include both WWTP's unless otherwise indicated.
Y/N
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (frequency -annual)
Y TCLP analysis (annual), N SSFA (Standard Soil Fertility Analysis)(annual)
Y Nutrient and metals loading calculations
Y Hauling records
Y Field loading records, Y Field site maps and information
N/A Records of lime purchased (contractor keeps lime purchase records)
Y Pathogen & Vector Attraction Reduction (annual)
Comments:
Pathogen & Vector Attraction Reduction Records
(check which methods apply)
Fecal coliform
SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0*106 CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0*106 CFU / dry gram)
Salmonella (Class A, all tests must be < 3MPN / 4 dry gram)
X Lime stabilization
Comments:
Time / Temp records
Digester (MCRT) Compost Class A lime stabilization
Volatile solids calculations
Bench -top aerobic/anaerobic digestion results
pH records for lime stabilization ( Class A or B ) Y-class B
SOUR calculations
Treatment (check treatment type(s) used)
Y Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
Alkaline Stabilization Lime other -describe

Residuals Inspection Check List pg 2
WQ0003902 Catawba County August 16, 2001
Compost (check treatment type used) N/A
Windrow Aerated Static Pile In vessel Other
Transport
Spill control plan in transport vehicle? Y
Does transport vehicle appear to be maintained? Y
Operation & Maintenance records
Condition of land application equipment on site: Equipment was clean and appeared to be well
maintained.
Stora e
Number of days/weeks/months of storage: 30 days
Describe storage: four tanks, 220,000 gallons each
Sampling
Describe Sampling: Metals and nutrient samples are collected as grab samples by the contractor
prior to land application in accordance with the permit and EPA standards. Lime stabilization is used
to meet pathogen reduction and VAR requirements .
Is sampling adequate? Yes Is sampling representative? Yes
Field Sites (end use for class B biosolids)
Y Permit on site during application
Y Buffers adequate
N Documented exceedances of PAN limits
N Signs of runoff / ponding
Y Rain Gauge on site during application
Y Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
(if no, improvements recommended) _
Are there any limiting slopes on fields? Y/N
N 10 % for surface application N 1 S% for subsurface application
Comment: All field conditions were found to be very good. Sludge application appeared even.
Equipment was clean. Field entrance was clean. No nuisance conditions were noted.
Monitoring well(s) Y N: N
If yes, location of well(s)
Comment:

Pb 3
Residuals Inspection Checklist
WQ0003902 Catawba County August 16, 2001
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed- No unusual nuisance
conditions were found during this inspection Slight odors were detectable immediately down wind
of the field site, however, odors were minimal and intermittent. A review of the files revealed that
the Mooresville regional Office had received no (odor) complaints in 2000.

Michael F. Easley, Govern
William G. Ross, Jr.,Secretary
North Carolina Department of Environment and Natural Resources
jr 7
J Kerr T. Stevens, Director
f: Division of Water Quality
September 4, 2001
Mr. Martin Wilson, Director
City of Newton
P.O. Box 550
Newton, NC 28658
Subject: Land Application inspection
Permit No. WQ0003902
City of Newton
Catawba County
Dear /r. Wilson;
Enclosed is the land application inspection report for the inspection conducted on August 16,
2001 by Ms. Ellen Huffman with this Office. An odor complaint was received on the same day. The
inspection showed compliance with all permit conditions, including laboratory data, record keeping,
and field conditions.
The inspection report should be self-explanatory, however, if you have any questions, please
contact Mrs. Huffman or me at [phone].
Attachment
cc: Non -discharge compliance
Frankie Singleton, SYNAGRO
h:Newton0801.doc
�7.
NCDENR
Customer Service
1 800 623-7748
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Mooresville Regional Office PHONE [phone]
919 North Main Street, Mooresville, NC 28115 FAX [phone]

State of North Carolina
Department of Environment
and Natural Resources
Division of Rater Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
NON -DISCHARGE COMPLLANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Newton
Permit No.: W00003902
Last Amended Date: February 11. 1998
SOC Issuance Date(if applicable): N/A
Permittee Contact: Martin Wilson
ORC Name: James Richards
ORC Cert.#: #13257
Reason for Inspection
ROUTINE X
Type of inspection
Collection System
County: Catawba
Issuance Date: September 8.2000
Expiration Date: August 31.2005
Expiration Date: N/A
Telephone No.: 704/465-7460
Telephone No.: 828/465-7480
BU/ ORC: Dennis Murdock #13249
COMPLAINT FOLLOW-UP
Spray Irrigation X Sludge
Other
Inspection Summarv: (additional comments may be included on attached pages)
The City of Newton is permitted to land apply 3,43 8 dry tons of sludge generated from the Clark
Creek WWTP. SYNAGRO is the current land application contractor. The inspection showed
the facility to be in compliance with the permit, and revealed good field conditions with minimal
odor. A file review showed no odor complaints were received by the MRO in 2000, and one
complaint received in 2001(08/06/01).
Is a follow-up inspection necessary _yes X no
Inspector(s) Name(s)/Title(s) Ellen Huffman/ Environmental Specialist
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection August 16, 2001

Residuals Inspection Check List
WQ0003902 Catawba County August 16, 2001
Type of Residual
X Land Application (class B) Distribution and Marketing (class A)
pg 1
Record 1Kegning The answers (below) include both W V P's unless otherwise indicated.
Y/N
Y Copy of current permit available at residual generating site
Y Current metals and nutrient analysis (frequency -annual)
Y TCLP analysis (annual), N SSFA (Standard Soil Fertility Analysis)(annual)
Y Nutrient and metals loading calculations
Y Hauling records
Y Field loading records, Y Field site maps and information
N/A Records of lime purchased (contractor keeps lime purchase records)
Y Pathogen & Vector Attraction Reduction (annual)
Comments:
Pathogen & Vector Attraction Reduction Records
(check which methods apply)
Fecal coliform
SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0*106 CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0*106 CFU / drygram)
Salmonella (Class A, all tests must be < 3MPN / 4 dry gram)
X Lime stabilization
Comments:
Time / Temp records
Digester (MCRT) Compost Class A lime. stabilization
Volatile solids calculations
Bench -top aerobic/anaerobic digestion results
pH records for lime stabilization ( Class A or B ) Y-class B
SOUR calculations
Treatment (check treatment type(s) used)
Y Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying_beds (may not meet 503's)
Alkaline Stabilization Lime other -describe

Residuals Inspection Check List pg Z
WQ0003902 Catawba County August 16, 2001
Compost (check treatment type used) N/A
Windrow Aerated Static Pile In vessel Other
Transport
Spill control plan in transport vehicle? Y
Does transport vehicle appear to be maintained? Y
Operation & Maintenance records
Condition of land application equipment on site: Eauipment was clean -and appeared to be well
maintained.
Storage
Number of days/weeks/months of storage: 30 days
Describe storage: four tanks, 220,000 gallons each
Sampling
Describe Sampling: Metals and nutrient samples are collected as crab samples by the contractor
prior to land application in accordance with the permit and EPA standards Lime stabilization is used
to meet pathogen reduction and VAR reauirements .
Is sampling adequate? Yes Is sampling representative? Yes
Field Sites (end use for class B biosolids)
Y Permit on site during application
Y Buffers adequate
N Documented exceedances of PAN limits
N Signs of runoff /ponding
Y Rain Gauge on site during application
Y Spill plan on site
Y Cover crop specified in permit
Y Site condition adequate
(if no, improvements recommended) _
Are there any limiting slopes on fields? Y/N
N 10 % for surface application N 18% for subsurface application
Comment: All field conditions were found to be very good. Sludge application appeared even.
Equipment was clean. Field entrance was clean. No nuisance conditions were noted.
Monitoring well(s) Y N: N
If yes, location of well(s)
Comment:

Residuals Inspection Checklist Pb 3
WQ0003902 Catawba County August 16, 2001
Odors/vectors
Odors present No
Vectors present No
Describe any nuisance conditions and any corrective actions needed: No unusual nuisance
conditions were found during this inspection. Slight odors were detectable immediately down wind
of the field site: however_ odors were minimal and intermittent. A review of the files revealed that
the Mooresville regional Office had received no (odor) complaints in 2000.

NOR AROLINA DEPARTMENT OF
. 4 ENVIRONMENT AND NATURAL RESOURCES
�7 MOORESVILLE REGIONAL OFFICE
NCDENR 919 NORTH MAIN STREET
MOORESVILLE, NC 281 15 i �.._...(a' ETT uOR
J'_5� Fo
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L seNDE't
UNDELIVERAP;LE
IS ADDRE,9SED
UNABLETo
FORWARD
Mr. Randy W. Frye
4100 Paint Shop Rd.

Newton Waste Water Fax:[phone]
Aug 23 ' 01 10 : 1 P. 01
CITY OF
WgMIMHEARTNI
City of Newton
P.O. Box 550
Newton, NC 28658
P.O: Box 550 • Newton, N.C. 28658 ■ [phone] , Fax: [phone]
Clark Creek
Wastewater Treatment Plant
Phonc # . (828)-465-7480
Fax # � �(828)-465-7481
Facsirnile'Message Cover Sheet
To-
Fax Number: 704-- 663-60�0--
Number of Pa es:� + Cover
Jute: o o
Frorn: rw � c

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 281 IS
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

City of Newton - Clank Creek Matewater Treatment Plant
Lime Stabilization of Blosollds --- Pathogen Reduction and Vector Attraction Reduction
Nickel
2001
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 Oho POST -CONSUMER PAPER

City of Newton — Clark Creek Wastewater Treatment Plant
Lime Stabilization of ®iosolids —Pathogen Reduction and Vector Attraction Reduction
Nickel
2001
Location
Grab Sam
Date Time dngind
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ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 281 15
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 281 15
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

UItY"nlewton -- Clark Creek Wastewater Treatment Plant
Lime Stabillzatlon of Biosolilds - Pathogen Redaction and Vector Attraction Reduction Hlckel
2001
Locafiop
G b Sample
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#1
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Grab
Data ime
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Origin
#2
Temp. wled
pH
Grab Sam e*3 CAM
IginW emp. u Date,
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12.33 20
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12.20
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1125 12.21 22 1212
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA,2811S
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - SO% RECYCLED/10% POST -CONSUMER PAPER

Newton Waste Water
g 2 '01 10:15 P.07
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA ZB115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER

Re: oil in biosolids
Subject: Re: oil in biosolids
Date: Thu, 31 May 2001 15:05:49 -0400
From: Kevin Barnett <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Ellen Huffman <[e-mail]>
CC: Shannon Thornburg <[e-mail]>,
Brian Wrenn <Brian. [e-mail]>
Yeah,
They could send it to Hickory, but they better let Hickory know (cause if it
messes up Hickory's compost process, then PSG can institute a pretreatment
requirement on Newton for introducing something they know may cause a problem).
Wouldn't it be easier and have less rick to just test the material for VOC's
and see what shows up?
Later,
Kevin
Ellen Huffman wrote:
> Hey, they cannot visually detect the oil and they are not sure if it is
> animal, vegetable or mineral. Could they send it to the Hickory composting
> facility????
> Ellen
> Kevin Barnett wrote:
> > Long hydrearbons like oil will show up on the TCLP test.
> > Newton should test this material (TCLP) prior to land application because
> > they have prior knowledge it may be a problem.
> > --kvin
> > Ellen Huffman wrote:
> > > City of Newton got a slug of some kind of oily substance at the wwtp.
> > > The oil floated on top of the final clarifiers and was returned to the
> > > head of the plant and it looks as if the oil precipitated out (at the
> > > primaries) with the sludge -the second time around. The sludge has been
> > > isolated into one of two sludge tanks. Mr Richards, City of Newton
> > > 828-465-7480-says that he can't see the oil now. The City wants to know
> > > what- if anything -they can test for to be sure the oil has broken down
> > > or gone away.
> > > E-
> > > Ellen Huffman - [e-mail]
> > > North Carolina Dept. of Environment & Natural Resources
> > > Div. of Water Quality
> > > 919 N. Main St.
> > > Mooresville, NC 28115
> > > Ph: 704.663.1699 Fax: [phone]
> Ellen Huffman - [e-mail]
> North Carolina Dept. of Environment & Natural Resources
> Div. of Water Quality
> 919 N. Main St.
> Mooresville, NC 28115
> Ph: 704.663.1699 Fax: [phone]
1 of 2 6/21/2001 11:40 AM

Re: oil i `biosolids,
Subject: Re: oil in biosolids
Date: Tue, 29 May 2001 13:25:42 -0400
From: Kevin Barnett <[e-mail]>
Organization: NC DENR - Asheville Regional Office
To: Ellen Huffman <[e-mail]>
CC: Shannon Thornburg <[e-mail]>,
Brian Wrenn <[e-mail]>
Long hydrearbons like oil will show up on the TCLP test.
Newton should test this material (TCLP) prior to land application because
they have prior knowledge it may be a problem.
--kevin
Ellen Huffman wrote:
> City of Newton got a slug of some kind of oily substance at the wwtp.
> The oil floated on top of the final clarifiers and was returned to the
> head of the plant and it looks as if the oil precipitated out (at the
> primaries) with the sludge -the second time around. The sludge has been
> isolated into one of two sludge tanks. Mr Richards, City of Newton
> 828-465-7480-says that he can't see the oil now. The City wants to know
> what- if anything -they can test for to be sure the oil has broken down
> or gone away.
> E-
> Ellen Huffman - [e-mail]
> North Carolina Dept. of Environment & Natural
> Div. of Water Quality
> 919 N. Main St.
> Mooresville, NC 28115
> . Ph : 704. 663. 1699 Fax': 704. 663. 6040
Resources
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1 of 1 5/29/2001 1:51 PM

�► Newton Waste Water Fax:[phone] Jun 21 '01 8:08 P.01
CITY or
PA Sox 560 . Newton, N.C. 2865E • [phone] . Fax: [phone]
VAKM TM HEART IS!
City of Newton Clark Creek
P.O. Box 550 Wastewater Treatment Plant
Newton, NC 28658 Phone # [phone]
Fax # [phone]
Facsimile Message Cover Sheet
tlt ('c_c Nd-
Fax Number: L 7 v 3- ,104 0
Number of Wages; j + Cover
Date:- 6 & 12-1 -16 1
From -
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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
P.O Box 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLVO., RALEIGH, NC, 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 O% POST -CONSUMER PAPER

Newton Waste Water
Fax:[phone] Jun 21 '01 8:09 P.02
Client,
FrojKt:
Client Sample M!
38111plO C4Dlleetiwt:
MERITECH, IN(;.
Environmental Laboratories
A Qivislon of Water Technology and Controls, Inc.
City of Newton
92608
/#2 Thickener,
06/05/01
Merlterh ID#! 06050198
Analysis; 06/15/01
Anitlyat: JSS
SWmr 1
Benzene < 20 ug/L Cis-1,3-Dichluropropene < 20 ug/L
Btomobenzene < 20 ug/L trom-0-nich1oropropene < 20 ug/L
Bromodiohluromethanc < 20 ug/L Ethyl benmia 33.2 ug/L
BromoohluralnothAne < 20 ug/L Hexachlambutadlene < 20 ug/L
Bmmufonn < 20 ug/L ISOPMpylbomr-ne < 20 ug/L
Hsomomethaue G 100 ug(L p-banpropyltoluene 4.11.2 ug/L
n-Buty%enzene < 20 ug/1d Methyicnc Olorldc < 20 ug/L
soo-Butylbaozone C 20 ug/L Naphthallene < 20 pg/L
ter(-Butylbenzeue < 20 ug/L n-?ropylbenrene < 20 ag/L .
Carbon 'retraohloride < 20 Us/L styrene < 20 ug/L
t:hloroi nzbnc C 20 uy/L. 1,1,1,2-Tetrachloroahane < 20 ug/L
Cltiloroethave < 100 ug/L 1,1,22-'ratr4ch1orocthape < 20 uSIL.
2-Chlorocthylvinyl Ether < 100 ug/L Tetrac'Moramhone < 20 ug/L
Chloroform < 20 ug/L Toluene 42.2 ug/L
C.hlaromathane < 100 U91L 1,1,1-Triehloroeth4up, < 20 ug/L
2-CblorotoluejoC < 20 uglL 1,1,24dohloroothane < 20 uZr,1L
4-Chlarotoluene < 20 ug/L Trichloroathene < 20 ug/L
Dibromochloromethace < 20 ug/L 1,2.3-Trlohlorobonzene < all ug/L
t,Z-lbibrettto•3-chldroprnpaule G 20 ug/ice i.,2.421'richlorobenzene < 20 ug/L
1,2-.1;3i1aramc�cthtane (JEDB) < 20 ug/L 1,2,3-T'r1oh1ar,'olttopanc U uglt_
Dibroma,uetbanc < 20 ug/L Trichlorotluoromethane C C i20 ug/L
Dichlo arluommelhane < 100 ug/L 1,2,4-Trlmethyll enc < 20 ugh,
1,1.Oicblhlomethttnc < 20 ug/L 1,3,5-Trimethy1bcnzene < 20 ug/L
1,2-Dichloroethane < 20 ug/L Vinyl cbloride < 100 a /L1,4-Dhlarubatzene 98.Eug /L h/Pe1,2-Dichlomboaene < ?A ug/L aXylescs 160 ug/L 20 ug/L �i.6 uC/1G
1.3.lohto,etsrnYG„a
1,1 •D1C$IOR)6t]iCpe < 20 ug/L
eis-1,2-,Dichloroethene < 20 Ug/I.,
trAns-1,2-171ulilnroe6enc < 20 ug/L
14-Divhloropr9panc < 20 ug/L
1,3-Dicb1oroprupane < ZQ ug/l'.
2,2-Dichloropropane t 20 ug/L
1,1-Dichloroprapene < 20 ug/L
1,2-Diohloropropene < 20 ug/L
l l+ereby 94;nkfy theft 1 havo rcviewW and approve these data,
Laborao1y eptwentxhvs
642 Tame ROAd w Reidsville, NC 27320
[phone] Ph * [phone] Past -

s
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
P.O BOX 29578, RALEIGH, NC 27626-0578 - 2728 CAPITAL BLVD., RALEIGH, NC, 27604
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/1 O% POST -CONSUMER PAPER
;`" 1

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Kerr T. Stevens, Director
ate•
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
January 12, 2001
JAY C. STOWE, PE
NEWTON, CITY -A SLUDGE FACILIT
P.O. BOX 550 FEB 0 6 20W
NEWTON, NC 28658
Subject: Annual Monitoring and Reporting Requirements
Treatment and Land Application of Residuals , IZ i,l J �J PR L
Permit Number: WQ0003902
NEWTON, CITY -A SLUDGE FACILIT
CATAWBA County
Dear JAY C. STOWE, PE,
The purpose of this letter is a reminder that the monitoring reports required by the subject permit must be submitted
as an Annual Report for calendar year 2000 by no later than March 1, 2001. The report must be submitted (in
triplicate) to the following address:
DENR/DWQ/Water Quality Section
Non -Discharge Compliance Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
Due to limitations in storage space, please submit the reports in bound form rather than in notebook form.
Permittees are subject to civil penalty for failing to submit the Annual Report as required by their permit.
Enclosed are the summary and certification sheets that must be used for your annual report. Please complete these
sheets and if necessary make copies of the blank forms if extras are needed. The forms have not changed since last
year, so you may use those you already have on hand.
You will however note that the forms include information required by EPA as outlined in 40 CFR Part 503. Since the
requirements of 40 CFR Part 503 are self implementing, they are legally binding and enforceable Federal
requirements for all persons subject to the requirements of 40 CFR Part 503, even if these requirements are not
currently contained in the state permit. The annual reports for the EPA must be received by EPA at the following
address on or before February 19, 2001.
Hector Danois
Clean Water Act Enforcement Section
Water Programs Enforcement Branch
Water Management Division
U.S.EPA Region 4.
61 Forsyth Street, S.W.
Atlanta, Ga. 30303-3104
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Annual Monitoring and Reporting Requirements
Page 2
If there is a need for any information or clarification on the State reporting requirements, please do not hesitate to
contact Brian Wrenn at [phone] extension 529. For further information on the Federal requirements, you
should.call Madolyn Dominy of the Environmental Protection Agency at 404-562-9305.
Brian L. Wrenn,
Environmental Specialist III
cc: Vince Miller, EPA Region IV
MRO Regional Supervisor
Non Discharge Compliance / Enforcement File
Central Files

46-1�1-11

3
DIVISION OF WATER QUALITY
February 18, 1999
MEMORANDUM TO: Jeffrey Poupart
FROM: D. Rex Gleason
PREPARED BY: - Michael Parker9jy
SUBJECT: Recommendation for Enforcement
Violation ofNCGS 143-215.1(a)(9) and
DWQ Permit No. WQ0003902
City of Newton.
Land Application of Wastewater Residuals
Catawba County, North Carolina
Attached is a suggested fast track enforcement report concerning a violation of the subject
Permit and General Statute. Since this Office did not have a shell document from which to
develop the attached Findings and Decision (F&D), a similar type F&D was modified to fit the
specific violation. Such being the case, it may be appropriate to coordinate the review of this
recommendation with the Attorney General's Office. Additional supporting material, including
digital photographs on disks, are included with this enforcement recommendation request.
The violation for which this enforcement recommendation is being submitted is the result
of the City of Newton applying wastewater residuals to a site not authorized (permitted) by the
City s non -discharge perm it.
The attached material should be self-explanatory; however, if you have any questions, please
contact Mr. Parker or me.
Attachment
mlp
h:\enf\newtcn.enf �:

STATE OF NORTH CAROLINA
COUNTY OF CATAWBA
IN THE MATTER OF:
- CITY -OF NEWTON
FOR VIOLATIONS OF PERMIT
NO. WQ0003902 AND
NCGS 143-215.1.(a)(9)
DISPOSING OF WASTEWATER
RESIDUALS WITHOUT A PERMIT
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
File No. OP
.. FINDINGS AND DECISION
AND ASSESSMENT OF CIVIL PENALTY
Acting pursuant to North Carolina General Statute (G.S.) 143-215.6A, I, A. Preston
Howard, Jr., P.E., Director of the Division of Water Quality (DWQ), of the North Carolina
Department of Environment and Natural Resources, make the following:
A. The City of Newton (City) is an incorporated municipality organized and existing
under the laws of the State of North Carolina.
B., On June 24, 1998, DWQ issued Water Quality Permit No. WQ0003902 to the City
which allows the land application of wastewater residuals on various sites located in
Catawba County, North Carolina. Part VI, Condition No. 4 of the Permit lists the
various sites approved for the land application of wastewater residuals. NCGS 143-
215.1(a)(9) states that no person shall dispose of wastewater residuals resulting from
the operation of a treatment works without first having applied for and obtained the
appropriate permit.
C. ,On November 4, 1998, DWQ staff from the Mooresville Regional Office observed
ihe disposal of wastewater residuals from a treatment works on a site off SR 2022
(Herter Road) in Catawba County. The wastewater residuals were generated at a
treatment works owned and operated by the City.
D. The City had not received approval from the DWQ for the residuals disposal at the
site described in Part I (C.) above.
E. The cost to the State of the enforcement procedures in this matter totaled S250.39.

Based upon the above Findings of Fact, I make the following:
A. The City is a "person within the meaning of G.S.143-215.6A pursuant to G.S. 143-
212(4).
B. The disposal system cited in Findings of Fact C. above falls within the definition of
same at G.S..143-213(10) or G.S. 143-213(17).-
C: A permit is required for the disposal of wastewater residuals pursuant to G.S*. 143-
215.1(a)(9) and Part VI, Condition No. 4 of DWQ Permit No. WQ0003902.
D. The City violated G.S. 143-215.1(a)(9) and Part VI, Condition No. 4 of DWQ
Permit No. WQ0003902 by disposing of wastewater residuals on SR 2022 (Herter
Road) in Catawba County between September 28th and October 26, 1998.
E. The City may be assessed civil penalties in this matter pursuant to G.S. 143-
215.6A(a)(2), which provides that a civil penalty of not more than ten thousand
dollars per violation may be assessed against a person who is required but fails to
apply for or to secure a permit required by G.S. 143-215.1(a)(9).
F. The State's enforcement costs in this matter may be assessed against the City
pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
G. The Director, Division of Water Quality, pursuant to delegation provided for by G.S.
143-215.6A(h), has the authority to assess civil penalties in this matter.
Accordingly, the City is hereby assessed a civil penalty of:
$ for failing to apply for or to secure a permit as required by
G.S. 143-215.1(a)(9) and Part VI, condition No. 4 of DWQ
Permit No. WQ0003902 for the disposal of wastewater
residuals.
$ TOTAL, CML PENALTY, which is percent of the
maximum penalty authorized by G.S. 143-215.6A.
$ ?50.39 Enforcement costs
$ TOTAL AMOUNT DUE

As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.1(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The.amount_of money _saved by noncompliance;
(6) , Whether the violation was committed willfully or intentionally;.
(7)- The prior recordofthe violator in'complyina or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
(Date) A. Preston Howard, Jr., P.E., Director
Division of Water Quality

Summary
On Thursday, November 3, 1998, the Mooresville Regional Office received notification
from the City of Newton that wastewater residuals (residuals) had been applied to a site off SR
2022 (Herter Road) in Catawba County without having first obtained approval for the disposal of
the residuals from the Division. Subsequent to this notification, an investigation was conducted of
1.7
the aforementioned site by Mr. Michael Parker with this Office on Wednesday, November 4, 1998.
Observations made by Mr. Parker during the investigation found that residuals had been
applied to a site not authorized by the City's Land Application permit. As set forth in the
-;- notification provided -by the -City,. the- unauthorized residuals. application was Ahe result of an error
by.the contractor.hireiflby the City to conduct the City's land_application operations.. From all- ;
indications, it appearYs that the contractor had conformed to all applicable buffers that would have
applied had the site been part of the City's Land Application permitted land application program.
On November 5, 1998, a Notice of Violation and Recommendation for Enforcement was
sent to Mr. Jay C. Stowe, P.E., Director, City of Newton Public Works and Utilities concerning
the documented Permit and NCGS violation and the intent of this Office to pursue an enforcement
recommendation.

Chronology of Events/Correspondence
October 27, 1998 Faxed letter received in MRO from Mr. James Richards, ORC, City
of Newton WWTP concerning the unpermitted disposal of
wastewater residuals from the City's WWTP. A follow-up report
was to follow. Telephone notification was also made by Mr. Chuck
Willis, Willis Engineers, for the City of Newton to Rex Gleason,
Water Quality Regional Supervisor, MRO.
_ ... ovember. 2 1998 , Follow-up report from Mr. Willis. and Mr._ Richards concerning the
-- -
i. unpermitted.residuals disposal._ ha,summary, the City's.residuals_ :
- -_" disposal contractor mistakingly applied residuals to a site that was
not included in the City's Land Application Permit.
November 4, 1998 Investigation of unpermitted residuals disposal site by Mr. Michael
Parker with the DWQ. Photographs were taken of the site. All
buffers as established in the City's permit appear to have been
followed during the application of the residuals.

CHECKLIST FOR PERMIT VIOLATIONS
l . A copy of the Permit is attached.
2. The violator is the City of Newton. Mr. Jay C. Stowe, is the Director of Public Works and
Utilities for the City.
Mr. Jay C. Stowe, P.E. Director
City of Newton
Post Office Box 550
Newton, North Carolina 28658
This; enforcement -does: not include effluent` limit violations. It involves a violation of a
_ _ ..
IDWQ =Permit and X.C: General__Statute� ;
4. Copies of all correspondence are attached.
5. There are no chain -of -custody samples.
6. The violation is not due to a power failure or by-pass of any treatment facility.
7. Are violation(s) chronic and/or due to a single operational upset?
The violation is not considered to be chronic. The violation appears to be isolated.
8. Were any specific notifications submitted concerning noncompliance?
A NOV/NRE was sent on November 5, 1998, which documented the Permit and NCGS
violation, and advised that an enforcement recommendation would be prepared.
9. Cost of the investigation:
4 hours by Michael Parker for preparation
of enforcement report at $25.44/hour=$101.76
1 hour by D. Rex Gleason for supervisory review
at S37.70/hour = 37.70
`khour for clerical processing at $10.93/hour = 10.93
Administrative Cost for processing report = 100.00
Total $250.39

CIVIL PENALTY ASSESSMENT FACTORS FOR WATER QUALITY CASES
CASE NAME: City of Newton
ASSESSMENT FACTORS:
A. CAUSE OF THE VIOLATION(S)
The violation is the result of the City of Newton (City) illegally applying wastewater
residuals (residuals) to a site without first applying for and obtaining approval for the use of
the site as a receiver for residuals disposal. According to the City, the unauthorized activity
was the result of an error by the City's residuals disposal contractor who applied the
residuals _to a'site thatwaw not_incIuded in the City's-Land Application permit.
B. THE DEGREE AND- EXTENT OF HARM CAUSED BY THE VIOLATION(S)
There was no harm to the environment documented as a result of the unauthorized residuals'
disposal. The City's residuals contractor appeared to follow all applicable buffers as set forth
in the City's Land Application permit. There was no runoff observed nor did the residuals
appear to have been applied in excessive amounts.
C. DURATION OF THE VIOLATION(S)
The violation occurred sometime on or after September 28, 1998 and ended on October 26,
1998.
D. EFFECT OF VIOLATION(S) ON WATER, PUBLIC HEALTH AND FISH OR
WILDLIFE
There is no documented effect on water, public health, fish or wildlife as a result of the
violation
E. EFFECTIVENESS OF ANY PREVENTIVE OR RESPONSIVE MEASURE TAKEN
BY THE VIOLATOR
Upon discovering that residuals were in the process of being applied to a site not authorized
in the City's Permit, the City's Utilities Department staff immediately suspended further
residuals application and notified the MRO. There was no other responsive measures taken
since there was no evidence that a water quality violation or any other negative effect on the
environment had occurred.
F. COST OF RECTIFYING THE DAMAGE OR INFORMATION THAT WOULD BE
NEEDED TO DETERMINE THE COST, SUCH AS PROCESS RATES, CLEAN UP
COSTS
Damage costs are not an issue since clean-up was not undertaken nor was any damage
documented.

Civil Penalty Assessment Factors
Citv of Newton
Page Two
G. THE ALLEGED VIOLATOR'S PREVIOUS RECORD OF COMPLIANCE OR
NONCOMPLIANCE
The City has not been assessed any other penalties for violations of their non -discharge
permit.
MI'I'IGATING;:AG.GRAVATING FACTORSJYANY_ - -
The only mitigating factor that could be considered in this case is the fact the City
discovered and reported the violation promptly before the entire field had been covered. In
addition, the City plans to add the unpermitted field to their land application permit since it
appears to meet the criteria that would make it acceptable to permit for residuals application.

A �-`d / - -z 3 99 Ems` t—c-
CITY OF
P.O. Box 550 • Newton, NC 28658 ® [phone] • Fax [phone]
ME HF iRT OF CATA WBA COUNTY
June 14, 1999
r
Mr. Kevin Barnett
State of North Carolina Department of
Environment and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, N.C. 27626
PUBLIC WORKS AND UTILITIES DEPARTMENT
RECEIVED
vuwb , 0 ,Yy9
WATER QUAL ► SECTION
Non-C s' 0"-93 CcmPllance Enf.
RE: Response to Notice of Violation and Recommendation for Enforcement Dated May 17, 1999
City of Newton-Biosolids
Permit Number: WQ0003902
Land Application of Biosolids
Catawba County
Dear Mr. Barnett:
I am writing this letter as the official response to the notice of violation sent to the City of Newton May 17,
1999. The letter stated that the N.O.V. was for nickel concentration above the allowable concentration of
420mg/kg for the biosolids tested on November 19, 1998. The nickel tested that date had a concentration of
679.6mg/kg as reported in our 1998 Annual Report of Land Application Activities.
The process before this problem occurring was for our staff to collect samples as they were hauling the solids
to the field. We believe this allowed some high levels of nickel to be applied to the field before we knew the
test results. Since this problem came to our attention on December 3, 1998 we have been using a batch
process with our thickeners. We take a sample from a thickener before applying any solids from that
thickener. If the limits are acceptable, we allow the solids to be hauled to the fields and applied. If the
samples show a problem, we will not put the solids on the fields. We describe this process in an attached
letter dated December 9, 1998 to Mr. Rex Gleason, P.E. as an initial response to this violation.
I have also included a letter dated March 25, 1999 along with the results of the samples from the fields. This
letter explains the results of the soil samples taken on the fields in question. We submitted it as an
amendment to the 1998 Annual Report of Land Application Activities. Based on these lab results, I do not
believe that the nickel concentration of the biosolids applied to the fields in November affected the land.
Based on your letter, I understand that you will review this issue for further enforcement action. I do not
believe any additional enforcement is warranted because we have taken the appropriate measures to correct
the problem. Beyond changing our sampling procedure in the thickeners before allowing the solids out of the
plant, I have outlined several measures below which we have taken.
As a response to our first N.O.V. in November 1998 we hired Willis Engineers to complete a comprehensive
study of our solids management program. As a result of that report, we have promoted a staff person to

Mr. Kevin Barnett
Response to May 17, 1999 NOV
Page 2
June 14, 1999
solids management coordinator. His responsibilities will include all solids management at the plant including
land application. This should help us by giving additional accountability to our solids management program.
Since the November 1998 N.O.V. we have made additional staff changes. We now have a Wastewater
Treatment Plant Superintendent that oversees all management aspects of the plant. This has fostered better
communication between plant personnel and other city management staff.
I hope that you will agree that we have taken all possible measures to ensure that this problem does not occur
in the future. We have operated the program with no additional violations since November 1998. We
anticipate this trend continuing far into the future. If you have any questions related to this issue, please feel
free to contact me at [phone].
Very Truly Yo s,
ay C. Stowe, P.E.
City Engineer/Director of Public Works and Utilities
Enclosures (2)
cc: Mr. Ed Burchins, City Manager
Mr. Danny Sigmon, WWTP Superintendent
Mr. Eric Jones, Solids Management Coordinator
Mr. James Richards, WWTP O.R.C.
Mr. Chuck Willis, P.E., Willis Engineers

C�'I CITY OF
t(a
THE HEART OF CATAWBA COUNTY
P.O. Box 550 • Newton, NC 28658 • [phone] e Fax [phone]
PUBLIC WORKS AND UTILITIES DEPARTMENT
December 9, 1998
Mr. D. Rex Gleason, PE
Water Quality Supervisor
NC Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Subject: Permit No. WQ0003902
City of Newton
Land Application of Wastewater Residuals
Dear Mr. Gleason:
On Thursday, December 3, 1998 I received a faxed copy of the results of our residuals
analysis for the sample collected on November 19, 1998. Upon review of these results I
discovered that we had exceeded the ceiling limit of 420 mg/kg for nickel. Plant staff contacted
Burlington Research and verified the results of this analysis. At 0945 on December 4, 1998 I
called the Mooresville regional office and reported this violation.
I immediately stopped the application of residuals. We recirculated our 91 Thickener and
collected another composite sample and hand delivered it to Burlington Research, for nickel and
total percent solids analyses. We stopped transferring from our #2 Thickener to our 91 Thickener,
and in effect began a batch operation. We received the results of t uF s sample December 8, 1998.
The result of this sample for nickel was -below the ceiling limit. We began land applying again on
Thursday, December 10, 1998.
There are several things we plan to do to insure that no residuals are applied in the future
that exceed the ceiling concentration for nickel. We have changed the way we operate our
thickening process. We have always operated our two thickeners in series to obtain the thickest
residuals possible for application. Beginning immediately we have changed this to a batch process.
We will now fill one thickener, adjust the pH, and collect a composite sample. We will not haul
from this thickener or add any additional residuals to it until we have the results of this sample.
Only after we are sure the nickel concentration is below the ceiling limit and the pH requirements
have been met will the contents of this thickener be land applied.

Changing to a batch process will cause the percent solids of our residuals to decrease and
increase our application costs. We have two holding tanks on site that are identical to our
thickeners except that they have no rake mechanisms to aid in the removal of thickened residuals.
I will request that we install rakes in these holding tanks so we can once again obtain the thickest
residuals possible and continue to use the batch process.
We have collected a soil sample from the field where residuals have been applied since
October 27, 1998. This sample will be analyzed for nickel content by the North Carolina
Department of Agriculture. I will include the results of this analysis in my annual report.
In addition to these items we will have Willis Engineers look at our land application
program. After we review their findings, we may make additional changes.
I believe the steps we are taking will insure that no residuals are applied in the future that
have a nickel concentration that exceeds the ceiling limit.
Sincerely,
James Richards
Supervisor/ORC
Clark Creek POTW
cc: Mr. Chuck Willis, PE

I= MEART OF CATACVHA COUMT
h6wh 25,19W
PUBLIC WORKSANDUTILITIES DEPARTMENT.'
ni.
__-
Y-. P. O. Box 2935 ' ..
'-,Raleigh, North Caroh27626-0535' ...
• ►« nl ,•!1! v_' ?I - "I AV I fro -9 , t: 'e.'1 I t
• 1•:i
•1: - •:.: • 1I11
Dew SiM
I would like to include. the following information as an amendment to My 1998 regort. 'I.". '
did not receive the results of these tests in time to inch& them in the anmial mart. These are the
results of the soil saw we had analyzed for nickel contcait in reiadon to tba nickel viola#w that
occurred in November 199& The concenhstioe' of nicker in the sod was very low, when compare&
to other samples we have had analyzed m the past I do not believe that the bigh nicker '
n of the biosolids applied in November had aay a&cm effect on the land. where we
were applying.
If there are my quesdons, ply call me at (828)-465-7480.
Sincerely;- -�
ames Richards
SupervisorlORC
Clark Creek POTW

1
NCDA Agronomic Division 4300 Reedy Creek Rd Raleigh, NC 27607-6465 [phone]
k ~ ' U de ding the soil Test
r
����s7111 C�:O:A��•'
i
s si:
ST RE �RQPS (Crop Coaes 040 , 060)
Soil pH end the amount of lime required for optimum yields are crucial parts of the soil test
report.' Low, soil pH and low phosphorus cause more yield losses than any other factors in
forage production. Excessive soil acidity (low pH) reduces the capacity of forage crops to
utilize applied fertilizer nutrients. Lime recommendations are based on pH, amount of acidity,
and desired pH for the designated crop. Establishment and maintenance of legumes depend
very heavily. on maintaining the proper pH.
For best results, recommended lime and fertilizer should be mixed into the top 6 to 8
inches of the soil before establishment. Although most forage crops show no response to
phosphorus and potassium above an index of 50, some fertilization will be recommended for
certain crops.
Recommendations for nitrogen, phosphorus and potassium are for annual application.
Depending on the crop, climate and soils, split applications of nitrogen and potassium may be
required. Past experience, management level and economics will influence rates and time of
application. For additional information, see Note 12 "Forage and Pasture Crops" that
accompanies your soil test report. The table below shows the relationship between soil test
level and response to applied nutrients.
Soil Test Index
Crop Response to Nutrient Application
Range
Rating
Phosphorus
Potassium
manganese
Zinc
Copper
0-10
Very Low
Very High
Very High
Very High
Very high
Very High
11-25
Low
High
High
Higll
High
High
26-50
Medium
Medium *
Medium *
None
None
None
51-100
High '`"
"' None
Low -None
None
None
None
100+
Very High
None '""
None
None
None
None
* Response decreases as soil test index increases.
Abbreviations
MIN '::
mineral soil
M-0
mineral -organic soil
0
organic soil
IIM%
percent lulmic matter
NV/V .
weight/volume. of soil
CEC
cation exchange capacity
BS%
percent of CEC occupied by bases
Ac
acidity(decreases as p11 increases)
P I
phosploius index `
K-I
potassium index''
Ca
calcium``
Mg
magnesium
Mn-I :
manganese index
Mn-AI
manganese availability index
Zn I
i •nine index
ZnAI
zinc availability index
CtI
copper index
S-I
sulfur index
SS -I
soluble salt index
NO3 N`'
` nitrate nitrogen _(plinl)
N114 N
anunoniunl nitrogen (ppnl)
Na
sodium
KLO
potash ,
P2O5
phosphate
B
boron '
A
copi4s of this pudic document were printed it a cost of $431 r'22 or $0.02 per copy.

q!
6h micVvisli 276 ee 'Cieek:Ro.ad"'Raleigh NC1 07-64 5"'1"(919);733-2655 23374 XN 0 on-11 3 0 Report No
Grower- Ardrey, Tye Copies lo: Richards, James A.
4260 Herter Rd.
Maiden, NC 28650
.0d Test RePort Fann:
2/2 19 SERVING N.C. CITIZENS FOR OVER 50 YEARS Catawba CounjZ
;Agronomist Comments:
C 12
�The heavy metal concentration is well within the limits of normal background levels and should pose no threat to crops grown on this land. Follow soil test recommendations for lime and
fertilizer application. T.'Kent Yarborough
"Reid 4 WO MeO ,06hu �,R
Sample No. Last Crop Ho Yr r/A Crop or Year Lime N R05 K70 Mg Cli Z1, B M1, See Note
098 Fes/QG/TirnM 1st Crop: Fes/OG/Tim,M 0 120-200 120-140 60-80 0 0 0 0 12
2nd Crop:
Test Results
Soil Class HM% WIV CEC BS106 Ac pH P-1 K-I Ca% M9% M?1-1N11-A1(1)Mn-A1(2) Zn-I Zn-Al Cu-1 S-I SS-1 NC3-NN]h-N Na
MIN 0.41 1.19 4.9 78.0 1.1 5.9 6 35 52.0 22.0 475 ' 304 37 37 70 51 0.1

Heavy -Metal Soil Test Report
Ardrey, T?e A
4260 NerteRd!
MEHLICH-,.EXTRACTION
maiden, NC 28650
f� 4
F `14
n
Catawba County
Questions
concerning these
analyses should be referred to the Agronomic Division, Soil Testing Section
I,
Cd, Ni Pb
Se Cr.
Sample ; ', t; t =;;.:
:..., Cadmium Nickel Lead
Selenium Chromium
ID::: ,..i, ..., _
mg/dm3 (ppm)
098 0.10 0.30 0.00 0.00
i
i crt �, jlr it I
sf �
I
I � I
i�•
0.10
Report #: 23374
Al As
Aluminum Arsenic
5.00

T
�I
CITY OF
THE HEART OF CATAWBA COUNTY
December 9, 1998
Mr. D. Rex Gleason, PE
Water Quality Supervisor
NC Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
P.O. Box 550 • Newton, NC 28658 • [phone] • Fax [phone]
Subject: Permit No. WQ0003902
City of Newton
Land Application of Wastewater Residuals
Dear Mr. Gleason:
PUBLIC WORKS AND UTILITIES DEPARTMENT
EI�FVi p,Ln, -; TIA ,
f.
MiwusvllI� �u �„ l of
On Thursday, December 3, 1998 I received a faxed copy of the results of our residuals
analysis for the sample collected on November 19, 1998. Upon review of these results I
discovered that we had exceeded the ceiling limit of 420 mg/kg for nickel. Plant staff contacted
Burlington Research and verified the results of this analysis. At 0945 on December 4, 1998 I
called the Mooresville regional office and reported this violation.
I immediately stopped the application of residuals. We recirculated our #1 Thickener and
collected another composite sample and hand delivered it to Burlington Research, for nickel and
total percent solids analyses. We stopped transferring from our #2 Thickener to our #1 Thickener,
and in effect began a batch operation. We received the results of this sample December 8, 1998.
The result of this sample for nickel was below the ceiling limit. We began land applying again on
Thursday, December 10, 1998.
There are several things we plan to do to, insure that no residuals are applied in the future
that exceed the ceiling concentration for nickel. We have changed the way we operate our
thickening process. We have always operated our two thickeners in series to obtain the thickest
residuals possible for application. Beginning immediately we have changed this to a batch process.
We will now fill one thickener, adjust the pH, and collect a composite sample. We will not haul
from this thickener or add any additional residuals to it until we have the results of this sample.
Only after we are sure the nickel concentration is below the ceiling limit and the pH requirements
have been met will the contents of this thickener be land applied.

M
a,
Changing to a batch process will cause the percent solids of our residuals to decrease and
increase our application costs. We have two holding tanks on site that are identical to our
thickeners except that they have no rake mechanisms to aid in the removal of thickened residuals.
I will request that we install rakes in these holding tanks so we can once again obtain the thickest
residuals possible and continue to use the batch process.
We have collected a soil sample from the field where residuals have been applied since
October 27, 1998. This sample will be analyzed for nickel content by the North Carolina
Department of Agriculture. I will include the results of this analysis in my annual report.
In addition to these items we will have Willis Engineers look at our land application
program. After we review their findings, we may make additional changes.
I believe the steps we are taking will insure that no residuals are applied in the future that
have a nickel concentration that exceeds the ceiling limit.
Sincerely,
James Richards
Supervisor/ORC
Clark Creek POTW
cc: M&.Chuck Willis, PE

n
20
CITY OF I �
P.O. Box 550 Newton, NC 28658 [phone] Fax [phone]
WHERE THE HEART IS!
December 7, 1998
Mr. Kevin Barnett
State of North Carolina Department of
Environment and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, N.C. 27626-0535
RE: Response to Notice of Violation Dated November 16, 1998
City of Newton - Biosolids
Permit Number: WQ0003962
Land Application of Biosolids
Catawba County
Dear Mr. Barnett:
PUBLIC WORKS AND UTILITIES DEPARTMENT
t,.
DEC L' 5 1998
Elul i ' F' „ " ,' I J'Jj
I am writing this letter in response to the notice of violation you sent the City of Newton November 16, 1998.
There appear to be four distinct issues addressed in your letter:
1. Nickel concentration of 724.171 mg/kg, February 10, 1997;
2. Nickel concentration of 901.786 mg/kg, October 21, 1997;
3. Supporting data for lime stabilization as the process to significantly reduce pathogens;
4. Calculations for annual and cumulative loading of nutrients and metals in the annual report.
I will try to respond to each of these items in this letter.
Issue Number One
Nickel Concentration of 724.171 mg/kg, February 10, 1997
The nickel concentration for the biosolids tested February 10, 1997 was addressed in the annual report that
we submitted in February 1998. Please find a copy of this portion of the annual report in Attachment
Number One. I believe the problem related to this issue revolves around bad data that we did not detect in
time to resample.
The sample we reported in the annual report of 724.171mg/kg was a composite sample taken February 10,
1997. This figure was calculated based on 2.11% solids. I believe the 2.11% solids reported by our
contract lab for this sample was in error.
We routinely take grab samples of our biosolids before hauling them to the field. Four grab samples made up
the composite sample for that date. Of the four grab samples, we analyzed only one individually. The results
of this sample indicated it was 13.16% solids. Even if the other four samples were 0% solids, the composite
would be greater than 2.11% as indicated by the lab results. I do not have any reason to believe the other
three grab samples were 0% solids.

Mr. Keven Barnett, NCDENR
Response to November 16, 1998NOV
December 7, 1998
Page 2
I believe this problem will not occur in the future because we have changed our process of analyzing figures
for the annual land application permit. In the past we received the samples and did not always calculate the
loading rates until it was time to complete the annual report. Our process now involves calculating loading
rates when we have received sample results from the laboratory. By using this method we will notice
problems sooner and if there is an error in the samples we will still have an opportunity to resample to verify
loading rates.
Issue Number Two
Nickel Concentration of 901.786 mg/kg, October 21, 1997
The Notice of Violation referred to a violation dated July 21, 1997. There was no violation of nickel
concentration on July 21, 1997, however, the nickel concentration for the biosolids tested October 21, 1997
was unusually high. James Richards, O.R.C. addressed this briefly in the annual report submitted in February
1998 (Attachment Number One), and in more detail in the amendment to the annual report submitted in May
1998 (Attachment Number Two).
As noted in the amendment to the annual report, a local industry had problems with their pretreatment plant
prior to this sample. I believe these problems contributed significantly to the high concentration of nickel in
this sample.
The nickel concentration in this sample apparently exceeded the ceiling concentration of 420 mg/kg. When
James Richards, the treatment plant O.R.C., became aware of the high concentration of nickel in this sample
he contacted the Atlanta Regional E.P.A. office and Mr. Mike Parker of the Mooresville Regional Office.
The Atlanta Regional E.P.A. office advised to do soil samples for nickel. The NCDA analyzed these samples
and we included them as the amendment to the annual report. We also include the results as Attachment
Number Three of this letter. Mr. Parker informed Mr. Richards to report the high concentrations of Nickel on
the annual report.
I believe the key issue is that apparently no environmental damage was associated with this occurrence. The
results of the samples from NCDA show a low amount of nickel on all of the fields sampled. The samples
that indicated the highest concentrations of nickel were on fields that we had not applied to during 1997.
Issue Number Three
Supporting data for lime stabilization as the process to significantly reduce pathogens
You requested supporting data for lime stabilization as the process to significantly reduce pathogens. We
send this verification to the E.P.A. each year but we were not aware that the NCDENR wanted it included in
the annual report. Please find a copy of the information that we sent to E.P.A. in the annual report explaining
our entire solids process. I include this as Attachment Number Four. Please include this as an addendum to
our NCDENR Land Application Annual Report.
Issue Number Four
Calculations for annual and cumulative loading of nutrients and metals in the annual report
The final item addressed in your letter dated November 16, 1998 related to several fields on the annual land
application summary form not having calculations for annual and cumulative loadings of nutrients and
metals. I would refer you to the final page of the forms for each field. We include the totals only on these
pages.

Mr. Keven Barnett, NCDENR
Response to November 16, 1998NOV
December 7, 1998
Page 3
We continually try to improve our operation to make it as efficient and effective as possible. As we strive to
do this, some changes in our solids process have been put into place. We currently batch our biosolids and all
samples will be received from the laboratory before any biosolids are placed on the field. I expect this will
help eliminate the possibility of environmental damage to the fields on our land application program.
I would like to reiterate key issue is that apparently no environmental damage was associated with any of
these issues. The results of the samples we ran at the suggestion of the US EPA show a low amount of
nickel on all of the fields sampled.
Once you have a chance to review this information, please call me at [phone] if you have any
questions.
ry Truly Y s,
ay . Sto e, E.
Director of Public Works and Utilities
City of Newton
cc: Mr. Ed Burchins, City Manager
Mr. James Richards, O.R.C., Clark Creek Wastewater Treatment Facility
Mr. Danny Sigmon, Laboratory Supervisor/Pretreatment Cordinator
Mr. Chuck Willis, P.E., Willis Engineers

Attachment Number One
Portion of Annual Report Submitted
February 1998

City of Newton
P.O. Drawer 550
Newton, N.C. 28658
February 25, 1998
DENRlDEMlWater Quality Section
Non -Discharge Compliance Unit
P.O. Box 2935
Raleigh, North Carolina 27626-0535
Subject: Annual Monitoring and Reporting Requirements
Treatment and Land Application of Residuals
Permit No: WQ0003902
City of Newton
Catawba County
Dear Sirs,
Enclosed is our annuat report for 1997. Included in the report is the certification form, the annual
residual sampling summary form, the residual laboratory analysis for the six times we sampled in
1997, the field summary forms, the pathogen and vector attraction reduction forms, and copies of
the analysis of our ground water sampling. Not included in the report are the TCLP laboratory
analysis and the standard soil analysis for each location.
We schedule the TCLP analysis, along with our well samples, our industry samples, and our
NPDES samples annually with Burlington Research. When Burlington Research sends the
containers we collect the sample and return it for analysis. Our TCLP was scheduled for the first
week of September. Burlington Research 'failed to' send us containers for the sample, and I did not
realize that a sample was not collected until I tried to find it to include in this report. The Raleigh _
office said I should collect a sample as soon as possible and send the results as an ammendment to
this report. I have developed a schedule that will track each required analysis to insure this does not —
reoccur. This schedule is included as Appendix A — - -
The standard soil analysis was collected in December, 1997, and mailed to the N.C. Dept. Of
Agriculture in January, 1998. I have not yet received the results. I will include these results along
with the above mentioned ammendment.
According to the results we received from Par Labs, we violated the ceiling concentration for
nickel the first and the fifth report periods. Historical data leads me to believe some of the results I
received were in error. I contacted Par Labs about this in mid February, 1998,- and they said their
results were accurate. Appendix B shows the results I question along with our historical data. I
have circled eight results during the last seven sampling periods that I question the acccuracy of. In
addition to these eight cases, I have found five additional cases in the last five years where I have
contacted Par Labs about their results, they have been in error, and they have ammended their

reports. I have included these reports along with their ammended reports.
I did not question the 2.11% solids on.the first sample for 1997 until mid February of 1998. By
this time no sample existed to reanalyze. We do, however, analyze a grab sample several times
weekly for % solids in our lab. The results of our grab samples for the week of 2/10/97,were
13.16, 10.75, 12.35, and 8.40. I compared the results from Par Labs for the remainder of the
1997 samples with our grab sample results. The results were (their result first, our result last)
4/9/97: 3.31, 5.24; 6/9/97: 7.45, 7.80; 8/4/97: 11.2, 9.82; 10/21/97: 5.377, 5.50; and 12115/97:
11.67,.9.74. These results were mush closer than the 2/10/97 results. If the actual % solids of our
_composite sample was greater than 3.7% we did not violate the ceiling concentration for nickel. I
believe the % solids of our 2/10/97 sample were much higher than 3.7% and therefore do not
believe we actually violated the ceiling concentration for nickel for this sampling period
I had noticed that several results reported for the fifth sampling period were unusual in November,
1997. I did not follow up on these results until February, 1998, when I started compiling data for
my annual reports. At this time we still had a portion of the sample collected 10/21/97. We
normally save sludge samples in cas& we want to reanalyze them. I sent this sample to Burlington
Research Labs for analysis of nickel, potassium, and ammonia -nitrogen (although it was out of
hold time). I will forward these results as part of the ammendment as soon as possible.
I have also included in this report two modified forms that will enable us to better track our land
application activities (Appendix C). I have just received the results of a February 10, 1998 sludge
sample from Paz Labs. I question the results of three tests on this report. I will forward a sample to
Burlington Research for reanalysis. I have also decided to allow Burlington Research to- analyze all
of our sludge samples in the future, and will no longer do business with Par Labs.
I regret that these events occured during 1997. As partial explanation, my wife had a liver
transplant in July, 1997, and contacted another illness in late October that caused partial paralysis.
Because of this I was out of work a lot from July, 1997, through January, 1998. For several years
I have tracked all sampling activities and ensured that our land application program met our.permit
requirements. I have installed safe guards thavwill�ake it easier for my back up to track these
activites in the future. should I not be available. If you have any questions, if I may be of further assistance, or if there is any additional sampling I
need to do, please call me at 704465-7480.
Sincerely,
lea
J es A. Richards
Supervisor / ORC
City of Newton
Clark Creek POTW

Attachment Number Two
Portion of Amendment to Annual Deport Submitted
May 1998

May 14, 1998
DENR/DEM/Water Quality Section
Non -Discharge Compliance Unit
P.O. Box 2935
Raleigh, North Carolina 27626-0535
City of Newton
P. O. Box 550
Newton, N. C. 28658
Subject: Annual Monitoring and Reportin_'Requirements
Treatment and Land Application -of Residuals
Permit No: WQ0003902 _
City of Newton
Catawba County
Dear Sirs,
Enclosed is the TCLP laboratory analysis that was omitted from our original report. The sample
_ was collected March 3, 1998. We will collect another sample for TCLP analysis this fall for 1998.
Also enclosed is the standard soil analysis for each land application site. These samples were
collected in December 1997. I had not received the results in time to include them in the original
report.
I have also enclosed the results of the October 1997 sludge sample I had Burlington Research Lab
reanalyze in February 1998. The nickel results compare to the results obtained by Par Lab when
-- they analyzed the sample in October 1997. These results indicate that we exceeded the ceiling
Concentration of 420 mg/kg. I have --also enclosed the results of additional soil samples collected
from several sites for nickel analyses.
I believe the high nickel concentration in our October 1997 sludge sample was o e
result of a local
industry's discharge. In early September 1997 their pretreatment plant was no operational. They
may have had another discharge in. October that we were not aware of. I have enclosed a copy of
the compliance judgement sheet for this industry.
If there is any additional testing that needs to be done, or if I can be of fiirther assistance, call me
at [phone].
Sincerely,
es A. Richards
Supervisor / O.R.C.
Clark Creek POTW

Compliance Judgement Worksheet For SNC With Limits Page a Use setuuate sheets for each lndusw SNC dote-minadon for F1oo, oodanai, see Section 7-E Use seaam a shectfor each Poilcaas
SIU Name: T
IUP Number.
--- -
Pipe Number. I
Parameter
Six Month SNC
Determination Period= =
See next page for defmitions
-
]Daily Max. and IUP Limit • TRC criteria = TRC Limit - "" Circle which units oa r f
Ave. Limits Cacle 1.4 For TRC for BOD, TSS, oil. fat, grease-, Cuole 1-2 for all other pollutants >n Limits .
from IUP TRC compliance iudtement not reouire'd for pH: _
Daily Maximum Limit: 2. n 1, i • ( 17 or 1.4 = TRC Daily Limit: z mg/l or Ibs/day :
Average Limit: ' 12 or 1.4 = TRC Avg. Limit: or Ibs/day
Column 1: I - Industry self P-POTW A - Average
Colut_mt S: Use only if IUP has monthly. or other?) average Limit. Average values of all sampling events collected .wt$tin the
"average" period (for example, for a monthly average limit, use all values collected within a calendar month) and enter
this average in column S. Treat this average as another OP. Compare this average to the appropriate average IUP limit
or TRC limit.
Column 6 - Use only if IUP has daily limits is Ibs/day. Formula to use is ( mgd' mgll' 834 = lbs/day ).
Column 7: Use only if IUP has (monthly?) average limits in UWday. Use (mgd • m&d 0 834 = Rs/day ).
CoIunm 8: Put "1" for each daily maximum or average value, tally up at bottom as "A."
Colurtm 9: Compare daily and average values to IUP limits above, put "0" if at or below limit. "1" if above, tally at bottom as 'B."
Column 10: Compare daily and average values w TRC limits above; put "0" if at or below limir. "1" if above, tally at bottom as "C."
Col. 1: From From From Col.5: Col 6: Col7: Col8: Col9: Col lo-,
IDMRs. IDMRs IDMRs
Sample or Sample Daily Daily Avg Conc. Davy Load Avg. Load CJP Regular TRC
CJP Types Flow, mgd Conc. mg/1 mgn lbs/day Ibs/day Count Violation Violation
1
ii/.27/ 7
7_
�. 2 Iq
4 /9
-7
.1. P.3 4
12/.2/97
-
4
T
U.la lq7
,1,3
T
Iz .5'l97
.27`1
I
12 / c, /q7
a R.2
12 97
275
r
Iz /97
I.c5
�£
Q Ith /97
77�
List these Totals on next page => I A - IA I Ii = .2 I C _�_
Title: SNC With Limits Compliance judgement Worksheet
F.le name-. COMP:COMPIUDCArp 7-C
Revision data: August 1,1994

Attachment Number Three
NCDA Sample Results

NOVA _Agronomic Division 1jUU Recay urea: Icalei
n 1% L /o /-UYo7 9170a-40»
im ,ul t nu. P-111 V
Grower: S gnion, Ja ce A.
Copies to:
Richards, James A.
2955 Signnon Dalry Rd
Sol
tRep®rt
Nemion,NC 25658
Richards,, James A.
es
Dann:
PO Box
550
Nnion,
NC 28658
4/13 8 SERVING N.C. CITIZENS FOR bVER 50 YEARS Catawba County
Agronomist Comments:
�
F
Field Information�`�j�5. ,a;
lied I,in1e
Recomtliendat�oQis �. , u.,; x..t. 1.
Sample No. Last Crop
o Yr T/A
Crop or Year
Lime N A05 KO
Afg Cut
Zn B
A1n See Alote
014 Alfalfa, M
1st Crop: Alfalfa, M
0 0.0 0 80-100
0 0
0 2.0
0 12
2nd Crop:
Test Results
Soil Class HA1% W/V CEC BS%
Ac plf P-I
K-I Ca% Mg% Mn-I Mn-AI (1)Afn-AI (2) Zn-1
Zn-AI
Cu-I S-1
SS-1 NO3-N Nih-N
Na
MIN 0.13 0.95 61.1 100.0
0.0 7.2 824
43 94.0 6.0 221 131 ' 1058
1058
1472 181
0.2
Field Inforntation4,=: �, ° . ,
A lied Lime
Recommendations' ..>.
Sample No. Last Crop
Alo Yr TIA
Crop or Year
Lime N PROS ICO
Afg Cu
Zu B
Ain See Note
015 Berm llay/Pas,M
1st Crop: Berm Hay/Pas,M 0 180-220 0 100-120
0 0
0
0 12
2nd Crop:
Test Results
Soil Class 11,41% W/V CEC BS%
Ac pll P-I
K-I Ca% Mg% h1n-! Hn-AI (1)Mn-Al (2) Zn-1
Zn-Al
Cu-1 S-I
SS -I Na-N NIL-N
Na
MIN 0.36 0.84 62.6 100.0
0.0 7.5 629
52 94.0 5.0 559 330 743
743
838 214
0.2
Held Ia><formation rj ' 'sH��
lied Lime
Recommendat�onsF T
Sample No. Last Crop
Jfo Yr T/A
Crop or Year
Lime N R05 KO
Mg Cu
Zn B
Ain See Note
019 Alfalfa, M
Isl Crop: Alfalfa, M
0 0.0 01 0
0 0
0 2.0
0 12
2nd Crop:
Test Results
Soil Class M1% 1V/V CEC BS%
Ac pH P-I
K1 Ca% Mg% A1n-I Mn-AI (1)Mn-A!(2) Zu-I
Zu-Al
Cu-I S-I
SS -I NC3-N-N&N•
Na
MIN 0.25 0.99 60.4 100.0
0.0 7.7 668
128 93.0 6.0 837 493 896
896
1128 203
0.2

Heavy Metal Soil Test Report Sigmon, Jake A. Report #: 34110
t
2955 Sigmon Dairy Rd.
MEHLICH-3. EXTRACTION Newton, NC 28658
Catawba County
Questions concerning these analyses should be referred to the Agronomic Division, Soil Testing Section
Cd Ni Pb Se Cr Al As
Sample Cadmium Nickel Lead Selenium Chromium Aluminum Arsenic
!D nig/dm3 (hpm) -
014 0.20 15.3b 0.00 1.20 1.00 5.80
015 0.20 13. ' 0.00 1.40 0.20 5.70
j 019 0.20. 5.40 0.70 0.50 0.80 7.10
i
I

'11CPAW0110MIC DIVIII01U."J.'WU ROMIY UNCK H0110 IWIC1911,
INU A70WAA05';A7 1 13-40))
111131111111 nil; .111u7 I
5-0701.
Smith, Kermit
Copies to: -Richards, J,,to i.,s A.
joh
Dal
2955 LS1gmon D I Rd.
NC 28618
,� - oil
T1
est
eort
Rp
eMon,
Twim:
Ricliards, James A.
PO Box 550
Nemon, NC 28658
4/13/98 SERVING N.C. CITIZENS FOR OVER 50 YEARS
Catawba County
Agronomist Comments:
Field InformatioiNVAM
Appjie4,,Mflie
ActdifiIn' efidAoAs 1411.1"
Sample No. Last Crop
Alo Yr TIA
Crop or Year
Lime N
h05 F,20
Mg Cu Zu. B Afn See A'ole
005 Fes/0G/1'1m,M
1st Crop: Fes/OG/Tim,M
0 120-200
0 I P-20
0 0 0 0 12
2nd Crop:
Test Results
Soil Class HM% WIV CEC BS106
Ac pH P-1
K-I Ca% Mg% Mn-1 Afti-Al (1)Mn-AI (2) Zn-1
&-Al Cu-I S-1 SS-1 A103-Al AIIA-N Na
MIN 0.22 1.09 44.9 100.0
0.0 7.4 535
80 93.0 6.0 478
283 713
713 662 115 0.1

Heavy Metal Soil Test Report smith, Kermit ; Report #: 34057
C/O Jake Sigmon
MEHLICH-3 EXTRACTION 2955 Sigmon Dairy Rd.
Newton, NC 28658
Catawba County
Questions concerning these analyses should be referred to the Agronomic Division, Soil Testing Section
Cd Nil Pb Se Cr Al As
Sample Cadmium Nickel I Lead Selenium Chromium Aluminum Arsenic
ID I mg/dm3 (ppnt)
005 0.20 2.20 0.40 0.20 0.60 5.50
j
i
V

N'CDAAgronomic Division',!�`4300 Reed Creek 1 )ad Raleigh,
NC 27607=6465. (919) 733-Z055
xe Cori No:
Grower:
Maiden Amuses cht Co.
ColVea la• Richards, Janes A.
I
7045 Startown Rd.
Maiden NC 28650
z}„
c
'Test
ReportS
Richards, James A.
o
1 nrnt:
I10 Box 550
Ne%%Ion, NC 28658
4/13 8 SERVING N.C. CITIZENS FOR OVER 50 YEARS
Catawba Coun[
Agronomist Comments:
Field Informaiion3 =.._
liedLime
Recommendatiops.
Sample No. Last Crop
J1o, Yr T/A
Crop or Year
Lime
R05 KO h1g Cu
Zu B hin See A`ote
006 Fes/OG/Tim,M
1st Crop: Fes/OG/Tim,M 0 120-200
0 30-50 0 0
0 0 12
2nd Crop:
Test Results
Soil Class KA1% W/V CEC BS%
Ac p1l P-1
K-I Ca% Mg% Afn-I hfn-AI (1)Ain-AI (2) Zn-I Zn-AI
Cu-1 S-I SS-1 NQt-N Nlh-N Na
MIN 0.46 0.96 11.1 97.0
0.3 7.0 81
52 86.0 9.0 829
499 ' 1115' 115
162 57 0.1

I' ... :1\�..1J 11 :C1 �1 VllV lll�.:."L■t �Jlvu dr � .:- _..:-ravv;.i.a.�.uJ a..a.o• a.v.... �.. -- - -- - - - --- - - -
ii..
Maiden Amusement Co. Report #: 34107
Heavy Metal Soil st Report p
7045 Startown Rd.
MEHLICH-3 EXTRACTION Maiden, NC 28650
Catawba County
Questions concerning these analyses should be referred to the Agronomic Division, Soil Testing Section
Cd Ni I Pb Se Cr Al As
Sample' �° Cadmium Nickel Lead Selenium Chromium Aluminum Arsenic
ID nig/dni3 (ppm)
006 0.10 0.60 0.00 0.40 0.20 6.30

AgranamicAi�isian 4i00 Reedy Creek Road.:":Rideigh.NG 27607-G4155 '
Report No: 34109NCA
drover: Seaford, David
Coples lo: RIcliurds, f ames A.
462911ortcc• Wad
l,incolnton, NC 28092
T
;.;„ ® oil
T st Report I
Richards, James A.
PO Box 550
Nnion, NC 28658
4/13/98 SERVING N.C. CITIZENS FOR OVER 50 ITARS Catawba County
Agronomist Conunents:
i
Field Inforlmation�W
Iied Aific
.Rkbiiimendations� .. ,.e :� ..
Sample No. Last Crop
Mo Yr. T/A
Crop or Year Lime N h05 ICO i Afg Cu
Zu B 11fu See Note
008 Fes/OG/fim,M
lsl Crop: Fes/OG/fim,M 0 120-200 50-70 50-70 0 0
0 0 12
2nd Crop:
Test Results
Soil Class HM% W/V CEC BS%
Ac pHI
6.6 14
I K-I Ca% Mg% Mn-1 Mn-AI (1)Mu-AI (2) Zu-1 Z11-AI
82.0 14.0 353 220 122 122
Cu-1 S-1 SS-1 N[$-N NIA-N Na
117 51 0.1
MIN 0.41 1.02 9.4 98.0
0.2
37

Heavy Metal Soil Test Report Seaford, David Report #: 34109
4629 Herter Road
MEHLICH-3,EXTRACTION Lincolnton, NC 28092
j Catawba County
Questions concerning these analyses should be referred to the Agronomic Division, Soil Testing Section
Cd Ni Pb Se Cr Al As
Sample Cadmium Nickel Lead Selenium- Chromium Aluminum Arsenic
ID mg/dmi3 (ppni)
i
008 0.10. 1.40 0.00 0.20 0.40 7.10

a'l\Id�St1 ru11u111IG 11IMiIm .7;1uu.11CUUy IUicUn,wnu nniaigul nu JAIuuI -u-nij ��;, i,,,,-���,
••� , ,, ..��
(,rower: Smyrejeffrey
Coples to: Rich-iials, James k
2435 Smyre Farm Rd.
Nnion, NC 28658
3K
o Z
est e o rt farm:
Richards, James A.
FO Box 550
Nnion, NC 28658
4/13 8 SERVING N.C. CITIZENS FOR OVER 50 YEARS Catawba County
Agronomist Comments:
Field:Informalion .. „ _'
lied, Lime
:Recommendationsa
Sample No. Last Crop
Alo Yr T/A
Crop or Year Lune N h05 ICO Mg Cu
Zn B 41n See Note
007 Fes/OG/rim,M
1st Crop: Pies/0?/rim,M 0 120-200 80-100 50-70 0 0
0 0 12
2nd Crop.
Test Results
Soil Class HAf% 1®/V CBC BS%
Ac pH P-I KI Ca% Mg% Mn-I Mn-AI (1)Mn-AI (2) 1 Zu-Zn-AI
Cu-1 S-I SS -I A`B-N NHE-N Na
MIN o.46 1.00 6.2 87.0
0.8 6.6 20 41 65.0 19.0 516 317 1 60" 60
56 40 0.1

1 -1.3uu 1-.rVzU.Y;%-1r-VzM imuou A,! VU! 7%J-2%J-P., I 1✓✓7----
Heavy Metal Soil Test Report Smyre, Jeffrey Report #: 34108
2435 Smyre Farm Rd.
MEHLICH-3 EXTRACTION Newton, NC 28658
Catawba County -
Questions concerning these analyses should be referred to the Agronomic Division, Soil Testing Section
Cd- Ni Pb Se Cr Al As
Sample Cadmium Nickel Lead Selenium Chromium Aluminum Arsenic
ID ingldnO (ppin)
0.10
0.70 0.00 0.20 0.20 7.30
I

Attachment Number Four
Portion of Annual US EPA Report Submitted 1998
Related to Solids Process

Newton Waste Water Fax: N4-4UD-(481 NOV .su "38 11:5o r. Ui
Facility Name; Clark Creek Wastewater Treatment Page of
Address: P. O. Drawer 550
Newton, N.C. 28659
NPDES Permit No. NQ&jU9b
Sludge Permit No, WQM3902
PATHOGEN REDUCTION DESCRIPTION
We use lime stabilization as our means of pathogen reduction. We have two gravity thickeners,
with take mechanisms, that we operate in series. Each of the thickeners has a capacity of
approximately 219,000 gallons.
We pump the settled sludge from each of our two reactor clarifiers into our #2 thickener every two
hours. In 1997 we pumped approximately 35,100 gallons per day. The pH of the rector sludge
ranged from 8.4-11.1 in 1997, and was mostly between 8.9 and 9.9. The percent solids of the
reactor sludge ranged from 0.13V9,73% and averaged 3.2% in 1997. The pH of the reactor sludge
was monitored daily (grab sample), Monday through. Friday, by our lab personnel, and the percent
solids twice a week (grab sample). The samples axe collected from the pipe between the reactor
clarifiers and #2 Thickener.
We pump the settled sludge from a recycle boat, where the sludge from our three secondary
clarifiers is combined. In 1997 we pumped approximately 14,300 gallons per day. The percent
solids of the secondary sludge ranged from 0,18%4.40% and averaged 0.73% in 1997. The
percent solids were monitored once a week (grab sample) by our lab personnel. The samples are
collected from the discharge line of our recycle pump.
We pump lime slurry to #2 Thickener as needed, to raise the pH of the settled sludge to greater
than 12.0. The detention time of #2 Thickener is greater than 105 hours (218,000 gal .ors capacity /
49,400 gallons pumped daily = 4.4 x 24 hours/day -105 hours). The actual detention time may be
mom than 15 days since the supetnate from the thickeners flows to the head of the plant, where it
is combined with the influent The pH of 42 Thickener was monitored daily (grab sample),
Monday through Saturday, by our lab personnel. The percent solids of 42 Thickener was
monitored daily (gam maple), May through Thursday, by our lab. personnel. The percent
solids ranged from 1.60/.P-15.6% and averaged 5.3% in 1997.
The sludge that smics in #2 Thickener is pumped to #1 Thickener. Tanker trucks haul the sludge
that settles in #i 1 Thickener to our land application sites. since the tankers haul regularly the
detention time of # 1 Thickener varies. When the tanker s are hauling daily the detention time is a
n u mum of 24 hours. When the tankers are unable to bawl, dine to the weather or on weekends,
the detention time may be more than 1$ days (219,000 gallons capacity/16,200 gallons transferred
daily = 13.5 days).
The pH of # 1 Thickener was monitored. daily (grab sample), Monday through Saturday, by our lab

Newton Waste Water Fax:[phone] Nov 30 '98 12:56 P.02
Facility Name: Clark Creek Wastewater Treatment Page of
Address: P. O. Drawer 550
Newton, N.C. 29658
NPDES P=Mit No. NCOI t 96
Sludge Permit No.
personnel. The samples were collected from the pipe tbat is used to load the tanker trucks. In 1995
our operators began monitoring the pH of # 1 Thickener every► two hours When the tankers were
hauling. They also measured the pH of #2 thickener every two ho= when transferring sludge to
# 1 thickener, The pH values on the enclosed sheets ere from grab samples collected each morning
before the.tankeYs haul and before we transfer from 02 thickener to # 1 thickener. When the pH of
#2 thickener is below 12.0 lime is added before we transfer and another sample is collected by our
operators to verify that the pH was raised above 12.0. We than wait a minimum of two hours,
check the pH again, and begin transferring if the pH is still above 12.0.
T-he percent solids of the sludge in #1 Thickener was monitored daily (gMb sample), -Monday
through Thursday, by our lab personnel. The percent solids of #1 Thickener ranged from 3.20/9-
16.7% and averaged 6.2% in 1997.
In 1997 we collected a composite sample of our sludge that was being loaded onto the tanker
wicks six times. We band delivered these samples to Par Labs in Charlotte for analysis. We used
the results of these tests to figure our loadings. Par Labs informed me that Arsenic and Selenium
were analyzed usmg a graphite furnace, Mercury was analyzed using cold vapor, and Cadmaimn,
Copper, Molybdenum, Nickel, Lead, Chromium, and Zinc were analyzed -using ICP 200.7 EPA I
have included a copy of the data received for each sample in 1997. 1 have also included a copy of
the results of the tests our lab did in 1997.
We have two Sludge Holding Tanks that can be used to store sludge when we are unable to land
apply it They each have a capacity of 218,000 gallons. The detention time of each is more than 15
days.
We have two centzifages at our plant that were originally used to dewater our sludge. They could
be resod again m an emergency situation.
There is a regional composting plant in Catawba County. The City of Newton owns capacity in
this plant_ It resumed operation in January' 1995, and we began hauling part of our reactor waste
there. This gives us an option other than land application and storage of sludge during inclimate
weather. We did not haul to the compost facility in 1997.

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Sludge Land Application/Disposal Report Form
Annual Sludge Analysis-1997
page ZO of�07
Permittee: City of Newton, Clark Creek Wastewater Treatment Plant
Address: P.O. Drawer 550
Newton, N.C. 28658
Sludge Permit No.: WQ0003902-
NPDES Permit No.: NC0036196
Type. of Sludge: Gravity Thickener w/Lime
S#=site number,F#=field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
WEATHER
TEMP
RAIN
01 /07/97
40,448
5
SS
cloudy
43
0
01 /08/97
41,400
5
SS
cloudy
32
0
01/13/97
32,715
5
SS
dear
25
0
01 /14/97
24,269
5
SS
dear
25
0
01 /15/97
35,808
5
SS
dear
45
0
01 /20/97
33,429
5
SS
dear
48
.0
01/21/97
39,734
5
SS
dear
43
0
01 /22197
40,924
5
SS
Ptly_ cloudy
51
0
01 /27/97
38,069
5
SS
cloudy
36
0
Total Gals.
326,795
02/03/97
36,641
5
SS
dear
40
0
02/10/97
21,533
5
SS
cloudy
36
0
02/97
21,414
5
SS
dear
47
0
02/13/97
27,838
5
SS
snow
30
0
02/17/97
26,172
5
SS
dear
56
0
02/18/97
33,548
5
SS.
dear
59
0
02/19/97
36,165
5
SS
dear
60
0 --
02/20/97
40,686
5
SS
Gear
68
0
02121 /97
.40,448
5
SS
cloudy
65
0
02/24/97
42,113
5
SS
dear
34
-0
02/25/97
43,422
5
SS
cloudy
43
0
02/26/97
35,213
5
.SS
cloudy
44
0
Total Gals.
405,192

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Sludge Land Application/Disposal Report Form
Annual Sludge Analysis-1997
page 37 of �0'7
Permittee: City of Newton, Clark Creek Wastewater Treatment Plant
Address: P.O. Drawer 550
Newton, N.C. 28658
Sludge Permit No.: WQ0003902 - - -
NPDES Permit No.: NC0036196
Type of Sludge: Gravity Thickener w/Lime
S#=site number,F#=field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
WEATHER
TEMP
RAIN
03/05/97
45,920
1
16
SS
cloudy
41
0
03/07/97
38,306
1
16
1 SS
Gear
43
0
03/10/971
43,779
1
1 16
SS
cloudy
71
0
03/11 /97
37,950
1
16
SS
dear
56
0
03/12/97
38,069
6
1
S
dear
50
0
03/13/97
29,734
6
1
S
cloudy
46
.0
03/17/97
40,805
6
1
S
dear
38
0
03/18/97
36,879
6
1 1
S
Clear
52
0
03/21 /97
34,143
5
S
Clear
47
0
03/24/97
35,451
6
1
S
Clear
60
0
03/25/97
14,038
6
1
S
cloudy
46
0
03/27/971
26,886
6
1
S
Clear
50
trace
03/28/971
31,407
6
1 1
S
cloudy
50
0
/31/97
32,834
6
1-
S
Clear
52
0.1
otal Gals.
486,200
04/01 /97
34,50
1
S
Clear
61
0
04/02/97
42,351
6
1
S
Clear
67
0
04/03/97
39,258
6
1
S
Clear
44
0
04/04/97
33,072
6
1
S
clear
48
0
04/08/97
- 34,143
6
1
S
Clear
47
'0
04/09/97
27,362
6
1
S.
Ptty. Cloudy
50
0
04/10/97
30,455
8
S
Clear
30
0
04/11 /97
30,455
8
S
Ptty. cloudy
44
0
04/14/97
37,355
8
S
clear
55
0
04/.15/97
34,024
8
S
Clear
53
0
04/16/971
25,934
8
S
Clear
53
0
04/17/971
20,462
8
S
cloudy
52
0
04/18/971
35,213
8
I
S
trace
04/21 /97
34,975
5
SS
clear
50
0
04/25/97
38,069
5
SS
Ptly. cloudy
43
0
Total Gals.
497,627

Facility Name: Clark Creek Wastewater Treatment
Address: P. O. Drawer 550
Newton, N. C. 28658
NPDES Permit No. NCO036196
Sludge Permit No. WQ0003902
AAav 1 QC17
June1997
Page 5-3 of j 0 7
Thickeners
Reactors
Secondaries
IThickeners
Reactors
_
Secondaries__
#1 H
#2pH
#1 % S
#2 % S
pH
% Solids
pH
% Solids
_
# 1 pH
#2pH
#1 % S
#2 % S
- pH
% Solids
pH
_ % Solids
_
1
12.1
11.7
7.80
15.60
9.4
7.7
1
2
12.1
12.2
9.4
7.7
2
12.2
12.1
6.72
6.35
9.5
1.48
7.4
_ _
2
3
7.6
_3
12.3
12.3
5.88
6.56
_ 9.2
_
_7.4
3
4
4
12.4
12.3
_ 6.15
11.62
9.5
1.86
_ 7.4
_
0.75.
_4
5
12.0
12.1
8.60
8.30
9.3
_
7.3
5
12.3
12.2
_ 7.41
11.20
_9.4
7.4
--_
_ 5
6
12.212.3
8.60
5.90
9.4
7.4
612.3
12.1
9.3
7.4
6
7
12.1
12.2
7.97
4.20
9.5
2.22
7.4
0.79
7
7.4
_
7
8
12.3
12.4
7.10
4.25
9.6
7.4
8
8
911.912.0
9.4
7.3
911.7
_
11.8
- --
- 7.80
6.20
---
9.2
1.00
7.3
----
-
9
--
10
-
-
7.2
,
1012.1
11
-2. 1-
12.1
12.1
12.1
6,55
7.84
8.49
5.57
9.4
9.2
4.57
7.4
7.4
0.7811
10
12
12.1
11.9
8.10
6.00
9.5
1.40
7.3
12
12.2
12.1
6.90
4.65
_9.8
_ 7.4
1_2
13
12.3
12.3
5.49
6.60
9.6
7.2
13
12.1
12.0
8.8
7.4
-_
13
14
12.1
12.2
6.20
6.10
10.0
5.80
7.2
0.80
14
_ 7.5
_
14
15
12.2
11.9
6.00•
- 5.10
9.11
7.3
15
_
15
16
12.212.2
9.5
7.3
1611.8
11.8
9.22
8.36
9.8
0.57
7.3
16
17
7.4
17
12.1
11.9
7.94
7.81
9.2
7.3
_
17
18
1812.011.9
6.69
6.82
9.7
4.61
7.3
0.78
18
19
11.9
11.9
5.60
5.40
9.3
2.70
19
12.2
12.1
7.13
7.28
10.1
20
12.0
11.7
5.60
4.50
9.3
7.3
20
12.3
12.1
9.4
7.4
21
12.1
12.0
5.20
4.90
2.90
7.4
0.80
21
7.3
21
2212.3
12.4
5.51
5.08
9.5
7.5
22
_
_
2_2
23
12.0
12.1
9.6
7.4
23
11.6
11.5
7.72
-�5.98
9.7
0.66
7.3
23
24
7.3
24
11.9
11.7
9.83
.16
9.5.
.7.3
_
24
25
_
25
12.0
12.2
10.17
5.16
9.7
_ 5.02
7.4
_ 0.80
25
2612.3
12.3
5.98
4.62
9.2
0.63
7.3
2612.1
11.6
6.38
4.85
9.4
5.13
7.4
26
27
12.2
12.3
5.50
5.20
9.4
7.4
27
12.1
11.9
9.4
7.4
27
28
12.2
12.1
5.60
5.90
9.5
3.50
7.3
0.80
28
7.4
28
29
12.3
12.3
5.37
- 5.38
9.8
7.4
29
'
_
_29
30
30
11.9
12.2
' 9.8
7.4
30
11.9
12.0
8.93
6.19
-
9.1
3.57
7.3
31
7.3
31
_--
31

Sludge Land Application/Disposal Report Form
Annual Sludge Analysis-1997
page �`� ofj7
1Permfliee: City of Newton, Clark Creek Wastewater Treatment Plant
Address: P.O. Drawer-550
Newton, N.C. 28658
Sludge Permit No.: WQ0003902
NPDES Permit No.: NCO036196 -- - - -
Type of Sludge: Gravity Thickener w/Lime
., r
S#--site number,F#=field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
wExnHER
TEMP
RAIN
05101197
38,544
5
SS
clear
58
0
05/02/97
36,403
5
SS
clear
48
0
05/05/97
33,548
5 1
SS
clear
67
0
05/06/97
32,120
5
SS
Cloudy
69
trace
05/07/971
33,072
5 1
SS
Clear
71
0
05108/971
25,9341
8 1
S
Clear
54
0
05/12/971
33,0721.
8
S
Pay. Cloudy
70
0
05/13/971
30,4551
8
S
Cloudy
57
0
05/14/971
38,0691
8
1
S
clear
72
0
05/15/971
31,644
8
S
Clear
60
0
05/16/971
42,113
6
2
S
clear
62
0
05/19/971
48,656
6
2
S
clear
64
0
05/20/971
52,2251
6
2
S
Ry. Cloudy.
67
0
05/21 /97
! 53,6531
6
2
S
Clear
55
0
05/22/971
40, 448
i 6
2
S
Clear
49
0
05123/971
33,429
! 6
2
S -
dear
49
0
05/27/971
31,8821
6
2
S
cloudy
61
trace
- 05/28/971
• . 37,8311
8
1
S
cloudy
—621
0
05129/971
35,213
8
S
Cloudy162
0
Total Gals.
1 7083131
06/02/971
25,458
8 -
-
S
Cloudytrace
06/05/971
52,106
8
S
Clear
0
06/06/971
. 38,0691
8
S
cloudy
0
06/09/97
49, 608
8
1 S
-cloudy
56
0
06/10/97'i
43,541
8
S
Cloudy
57
0
06/11/971
40,4481
6
2
S
cloudy
59
0
06/12/971
25,2201 6
2
S
Cloudy
65
0
06/17/97
54,7241 5
SS
cloudy
84
0
06/18/97
! 39,7341 5
SS
cloudy
77
0
06/19/971
35,6891 5
SS
clear
851
0
06/20/971
32,120 ' 5
SS
Cloudy
88
0
06/23/971
37,5931 1
14
SS
Clear
75
0
06/24/97
! 42,351 ! 1
14
SS
clear
84
0
06/25/971 42,5891 6
1
S
Clear
811
0
06/26/97' 36,522; 6
1 1
1 S
Clear
861
0.2
06/30/97 ; 34,5001 6
2
S
Cloudy
67
0
Total Gals. : 630,273

Facility Name: Clark Creek Wastewater Treatment
Address: P. O. Drawer 550
Newton, N. C. 28658
NPDES Permit No. NCO036196
Sludge Permit No. W00003902
July 1997
Auqust 1997
Page .. 7 0 of / 6-7
Thickeners
Reactors
Secondaries
IThickeners
_
Reactors _
Secondaries--_
#1 pH
#2 H
01 % S
#2 % S
H
% Solids
H
_% Solids
#1 pH
#2pH
#1 % S
#2 % S
�H
% Solids
pH
% Solids
1
12.2
12.3
7.68
6.86
9.6
7.3
1
12.2
12.2
_
9.6
. _
7.3_
212.212.2
8.94
5.48
9.8
2.28
7.3
_
0.72
2
_
7.5
2
3
12.0
12.1
7.34
5.90
10.0
7.3
3
_ _
_
3
41
1
9.4
7.3
412.1
12.1
9.82
9.18
9.6
0.55
7.4
4
51
7.1
512.1
12.1
10.26
8.03
_ 9.1
_
7.4
_
_ 5
6
_
612.1
12.0
9.04
6.58
9.2
4.61
7.3
_0_66
G
712.2
12.3
8.22
4.86
9.0
4.98
_
7.3
712.011.9
9.21
6.70
8.9
5.76
7.4
_7
8
11.9
11.9
7.68
5.55
9.3
7.3
8
12.2
12.1
_
8.9
7.4
_8
9
12.3
12.3
6.33
5.39
9.7
3.66
7.3
0.63
9
_
` _
_
7.4
_ _
_ 9
10
11.9
11.9
6.54
5.89
9.2
7-A
_
10
9.89
4.61
9.1
2_ 47
7.3
10
11
11
12.1
12.1
9.5
7.4
11
11.9
11.6
12
7.2
.12
12.1
12.2
8.72
5.88
9.2
_
_ 7.3
13
13
11.9
11.9
8.75
5.42
9.3
4.84
7.4
0.63
13
1412.0
12.0
7.22
4.90
_
9.6
2.85
7.4
1412.1
12.1
8.36
6.96
9.4
7.4
14
1512.0
12.3
8.37
4.37
9.5
7.4
1512.1
12.3
_
9.3
7.4
15
1612.1
12.0
6.98
4.83
10.2
_
4.46
7.3
0.65
16
7.4
16
17
12.1
12.1
9.36
5.32
9.6
7.4
17
_ _
_
_
_
_ _
17
18
12.1
12.1
9.2
7.3
18
_
12.2
12.0
7.85
8.09
9.2
-_9.2
-- _5.79
7.4
-_7.3
-_
- _
-
18
19
19
7.4
19
12.1
12.2
9.58
G.85
20
8.4
6.92
7.4
20
21
12.2
12.1
12.2
12.2
9.98
16.18
9.5
9.4
4.05
7.3
7.3
_
0.67
20
21
21
12.012.0
7.37
7.80
8.26
6.47
2212.2
12.2
7.64
6.91
9.6
.7.3
2212.2
12.3
9.5
7.3
22
23
12.0
12.0
7.99
6.08
8.8
5.62
7.3
0.68
23
-
_ -
-
7.3
_
23
24
12.1
12.1
7.94
6.42
9.9
7.4
24
_
_-_
__
24
25
12.0
12.1
9.5
7.3
25
12.4
12.4
10.34
5.90
9.1
6.26
7.4
25
26
7.4
26
12.3
12.3
9.14
6.36.34
_ 9.0
_
7.3
26
27
27112.3
12.2
6.82
1 7.72
8.9
5.39
7.3
0.60
_27
28
12.1
12.2
10.97
7.91
9.2
6.32
7.3
28
1?.3
12.3
7.13
5.410
_9.2
7.3
28
29
12.2
12.0
8.15
•- 8.14
9.2
7.3
_
29
12.0
12.0
_
9.3
7.3
29
30
12.1
12.2
11.89
9.30
'` 8.7
6.18
7.2
_
0.75
30
-�
--
_
_
-_„�_®
7.4
___
30
31
12.0
12.1
12.36
11.33
11.1
7.3
�_____ _
31
_-_
-
31

Sludge Land Application/Disposal Report Form
Annual Sludge Analysis-1997
page_Of 7
Permittee: City of Newton, Clark Creek Wastewater Treatment Plant
Address: P.O. Drawer 550
Newton, N.Annual Sludge Analysis-1997
Sludge Permit No.: WO0003902
NPDES Permit No.: NC0036196 -- -
Type of Sludge: Gravity Thickener w/Lime
S#>`site number,F# =field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
WEATHER
TEMP
RAIN
07/01 /97
35,451
6
2
S
Cloudy
70
0
07/03/97
20,462
6
2
S
Clear
70
0
07/07/97
35,689
8
1
S
Clear
81
0
07/08/97
44,017
8
S
Clear
69
0
07109/97
45,206
8.
S
dear
69
0
07110/97
41,637
8
S
Clear
67
trace
07/11 /97
34,500
8 1
S
dear
72
0
07/14/97
6,186
8
S
Gear
71
0
07/15/97
33,905
8
S
Gear
73
' 0
07/16/971
39,734
8 1
S
Clear
72
0
07/18/97
38,663
8
S
dear
84
0
07/22/97
36,879
8
S
Gear
80
0
07/25/97
33,310
8
S
Cloudy
70
0.3
07/28/97
39,496
8
S
clear
92
trace
Total Gals.
429,223
1
08/01/97
37,474
8
S
Gear
82
0
08/04/97
36,165
8
S
Cloudy
86
0
08105/971
36,046
8
S
Pdy. cloudy
70
0.0fTl
08/06/971
38,306
8
S
Gear
74
0
08/07/97
31,526
8
S
Cloudy
64
0
08/08/971
36,760
8
S
Pty. Cloudy
63
0
08/11/97
29,979
8
S
Ry. Cloudy
67
0
08/12197
' 20,224
7.
S
PGy. Cloudy,
70
0
08113/971
32,120
7
S
Pty. cloudy
70
0
08/14/971
32,001
7
S
cloudy
71
trace
08/15/971
-. 31, 407
, 7
S
Pty. Cloudy
68
0
08/18/971
33,310
7
S
dear
81
0
08/ 19/97
, 31,8821
7
S
I Cloudy
67
0
08/20/971
10,1121
7
S
1 cloudy
73
0
08/21 /971
32,1201
7
S
I dear
74
0 1
08/22/971
S
clear
60
0
08/25/971
37,9501
7
1
S
Cloudy
61
0
08/26/971
36,4031
7
S
clear
58
0
08/27/971
32,9531
7
S
Clear
64
0
08/28/971
32,8341 7
1
S
I Pev. Cloudvl
661
0 1
08/29/971
21,6511 7
S
FIty. Cloudy
1 681
0
Total Gals.
1 669,2931
1
I
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Sludge Land Application/Disposal Report Form
Annual Sludge Analysis-1997
page 89of 7
Perm tee:. City of Newton, Clark Creek Wastewater Treatment Plarr
Address: P.O. Drawer 550
Newton, N.C. 28658
Sludge Permit No.: WQ0003902
NPDES'Permit No.: NC0036196-
Type of Sludge: Gravity Thickener w/Lime
S#=site number,F#=field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
WEATHER
TEMP
RAIN
09/01 /97
24,982
7
S
Ptly. Cloudy
69
0
09/02/97
30,931
7
S
Ptly. Cloudy
69
0
09/03/97
38,901
7 1
S
clear
67
0
09/04/97
26,767
7
S
clear
55
0
09/05/97
37,355
7
S
clear
48
0
09/08/97
40,448
7
S
dear
65
0
09/09/97
41,637
7
S
cloudy
71
0
09/12/97
35,689
7
S
cloudy
82
0
09/15/97
31,407
5
SS I
cloudy
651
trace
09/16/97
38,782
5
SS
cloudy
62
0
09/17/97
28,670
6
1
S
cloudy
63
0
09/19/971
24,388
6
1
S
cloudy
69
trace
09122/971
37,236
6
1
S
cloudy
57
0
09/23/97
. 12,253
6
1
S
cloudy
61
0
09/26/971
29,860,
, 6
1
S
Ptly. Cloudy
54
0
09/30/97
45,206
6
1
S
clear
54
0
Total Gals.
1 524,513
10/01/971
36,284
6
1 1
S
dear
1 57
0
10/021971
36,879
6
1
S
0
10/03/971
40,448
6
1
S
dear
45
0
101/06/971
37,3551
6
1
S
dear
54
0
10/07/971
2 8,3 13
6
1
S
dear
56
0
10/08/971
28,5511
8
S
clear
58
0
10/091971
46,1581
8
1 S
dear
58
0
10/10/971
14,0381
8
1 S
y. ciou
61
0
10/13/971
44,017
8
I S
y. cloudy
59
0
10/141971
11, 896
8
! S
cloudy
63
0
10/16/97
41.8751
8
1 S
cloudy
47
0
10/17/97
�-36,99818
1
1 S
cloudy
47
0
10/21/971
42,8271
1
1 14
1 SS
y. cloudy
44
0
10/22/971
27,3621
1
1 15
SS
clear
53
0.1
10/231971
24,9821
1
1 15
! SS
dear
34
0
10/24/97!
29,7411
1
115
1 SS
y.cioudyl
45
0
10/29/971
41,8751
1
1 15
1 SS
y. clou
38
0
10/31/971
33,4291
1
1 15
1 SS
cloudy
1 401
trace
Total Gals.
1 603,0301
11

Facility Name: Clark Creek Wastewater Treatment
Address: P. O. Drawer 550
Newton, N. C. 28658
NPDES Permit No. NCO036196
Sludge Permit No. W00003902
Page 104 of l-q-7 -
November 1997 December 1997
Thickeners Reactors Secondaries Thickeners IReactors Secondaries
#1 H
#2 H
#1 % S
#2 % S
pH
% Solids
p_
% Solids_
_
#1 pH
1t2 H
#1 % S
#2 % S
p_
% Solids
pH-
% Solids
1
7.3
1
12.3
12.3
8.40
6.60
8.7
3.90
7.4
_
1
2
2
12.5
12.5
8.79
7.82
0.94
.7.4--
0.74
2
3
4
12.4
12.3
12.5
7.80
4.60
9.8
0.50
7.5
3
12.6
12.4
G.36
_9.7
9.9
7.3--__3
12.2
7.00
2.86
9.4
4.297.4
0.79
4
12.3
12.3
_8.20
7.90
5.40
9.3
-
_
7.3
_
_ 4
5
12.3
12.3
8.50
4.20
9.4
3.60
7.5
5
12.4
12.3
_
9.7
_
7.3
_
_ 5
6
12.0
12.2
5.96
4.63
9.2
4.24
7.4
6
_
_
7.4_
_
G
712.312.4
9.4
7.4
7
_
_
7
8
7.5
8
12.0
11.8
_
9.20
7.90
9.6
3.20
7.4
__
_ 8
9
12.3
12.4
8.90
7.10
9.4
_ 7.4
9
10
_
12.4
12.6
6.90
5.25
9.6
4.73
7.4
_ -
_9
10
___12.6
12.6
5.80
_
9.3
2.80
_____0.80_
10
11
11
12.5
12.5
5.60
5.30
9.5
7.4
11
12.7
9.7
_
__7.2
12
12.4
12.4
5.40
3.00
9.5
2.10
7.3
_
0.70
12
12.1
12.1
_
_
12
1311.8
11.9
6.40
3.70
9.0
7.4
13
_
_9.6
13
1412.1
11.8
9.8
7.4
14_
_
14
15
15
12.4
12.2
9.24
_
16
1612.1
12.2
8.90
8.10
7.2
0.80
16
17
12.6
12.5
6.24
5.20
10.2
0.72
.7.4
17
12.1
12.1
10.00
5.70
17
18
12.3
12.2
6.10
4.10
9.7
7.8
_
18
-1 .
12.1
9_60
, 5.50
7.3
_
0.80
18
1912.1
20
12.4
12.1
5.20
5.26
4.70
9.6
3.10
7.4
0.80
1912.210.2
----
----
----
_
--------------
-
-
--
-----
- ----- - --
-___ -
19
2i�
-21
12.4
2.39
9.6
2.73_
7.4
---
20
21
21
12.1
12.2
9.2
_
7.4
22
7.4
22
12.1
12.0
_--
22
23
12.1
--
. 11.50
.10 0
7.1
0.80
23
-24
24
12.1
12.1
6.97
7.04
9.7
0.72
7.4
12.4
12.1
7.2____
25
25
12.0
11.8
6.32
5.99
0.99
7.3
L23112.1
12.6
12.7
__
11.10
10.30
7.3
0 80
2612.212.1
6.24
5.94
9.0
4.14
7.3
0.7112.5
12.4
-
26
-27
27
12.2
12.2
9.2
7.3
---
27
---
28
12.6
12.6
9.3
7.5
28
-
--
-
----
_28
-
29
- �
�
7.3
29
_
12.6
12.4
12.6
_
I i
- ------
29
30
-30
--
-
30
12.3
----
- -----
---
_
- 7.3
31
31
12.5
12.3
31

Sludge Land Application/Disposal Report Form
f
Annual Sludge Analysis-1997
page/6S of 0
Permittee: City of Newton, Clark Creek Wastewater Treatment Plant
Address: P.O. Drawer 550
Newton, N.C. 28658
Sludge Permit No.: W00003902 -
NPDES Permit No.: NCO036196
Type of Sludge: Gravity Thickener w/Lime
S#=site number,F#=field number
SS=Injection, S=Surface Application
DATE
GALS.
S #
F #
S or SS
WEATHER
TEMP
RAIN
11/04/97
38,069
6
2
S
clear
39
0
11 /05/97
32,120
6
2 .
S
Pty. cloudy
36
0
11 /06/97
32,358
6
2
S
cloudy
381
0
11/10/97
33,310
6
-2
S
cloudy
39
0
11 /11 /97
27,362
6
2
S
Cloudy
491
0
11 /12197
26,053
6
2
S
cloudy
411
0
11/17/97
22,008
6
2
1 S
Pty. cioudyl
26
0
11/18/971
23,793
6
-2
S
Pty. gaudy
371
0
11/19/971
30,931
6
1 2
S
cloudy
321
0
11 /20/97
33,310
6
2
S
Pty. cloudy
461
0
11/21/971
16,655
6
2
S
cloudy
421
0
11/25/971
34,500
6
.2
S
dear
401
0
11/26/97
28,670
6
1 2
S
dear
311
0
11 /28/97
24,150
5 .
2
S
cloudy
401
0
Total Gals.
403,289
12/03/97
32,358
.6
2
S
cloudy
411
0
12/08/97
26,886
6
2
S
cloudy
331
0
12115/971
29,027
6
2
S
cloudy
221
0
12/16/971
17,131
8
S
clear
261
0
12/17/97
1 14,871
8
1
S
dear
301
0
12118/971
24,507
.8
S
clear
351
0
12/19/971
17,845
8
(
S
dear
321
0
Total Gals.
1 162,625
1
a

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Joseph C. Stowe, Public Works Du.
City of Newton-Biosolids
P.O. Box 550
Newton, NC 28658
Dear Mr. Stowe:
410
• �•/
1
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 16, 1998
Subject: Notice of Violation
City of Newton-Biosolids
Permit Number: WQ0003902
Land Application of Biosolids
Catawba County
NOV P,3 1998
t'lll��ll E.F E~i'•.rrr�rr��99L'?T°.1 1 T
� ..•g{rn ' rru�iiL!'i
The Non Discharge Compliance / Enforcement • Unit has completed a preliminary review of the submitted 1997 Annual
Report of land application activities. The Nickel (Ni) concentration for the biosolids tested on 2/10/97 was 724.171
mg/kg and on 7/21/97 was 901.786 mg/kg. The state issued permit number WQ0003902 requires that the land applied
biosolids not exceed a nickel concentration of 420.0 mg/kg. You are hereby notified that the application of these
biosolids were in violation of state permit number WQ0003902.
Additionally, on the Annual Pathogen and Vector Reduction Form you have checked Lime Stabilization as the
"Process to Significantly Reduce Pathogens." There is however no supporting data included in the 1997 annual report.
Permit condition III. 6. requires that records of stabilization processes utilized should clearly demonstrate compliance
with 40 CFR 503.32(b) and 40 CFR 503.33. Permit condition III. 7. requires that these records be submitted as part of
the annual report.
Lastly, on the Annual Land Application Summary Form, several fields do not have calculations for annual and
cumulative loading of nutrients and metals loading as required by the state issued permit in section 11I. 2. i. Permit
condition I1I.7. requires that these records be submitted as part of the annual report.
You must respond within 15 days as to these non-compliance situations. You must also include all missing data with
your response. Please reference the state issued Permit Number when providing a response. All information should be
signed and submitted in triplicate to the attention of Kevin Barnett at the letterhead address. '
These non -compliant issues have been forwarded to both the Pretreatment Unit and the NPDES Compliance and
Enforcement Unit for further review of the City of Newton's wastewater treatment program.
Nothing in this letter should be taken as removing from you the responsibility or liability for failure to comply with all
applicable state laws and regulations.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

City of Newton-Biosolids Notice of Violation
Permit Number: WQ0003902 Page 2.
If you have any questions, please do not hesitate to call Kevin Barnett of our central office staff at 919-733-5083 ext.
529.
Sincerely,
n s R. Ramsey, P.E.
ssistant Chief of Non Discharge
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Pretreatment Unit
NPDES Compliance / Enforcement Unit
Nlooresvifile-Regianal'Office
Technical Assistance and Certification Unit
Central Files
Sigmon Dairy Farm
Mr. Kermit Wayne Smith
Maiden Amusement Co.
Mr. Jeffrey L. Smyre

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
November 5, 1998
Mr. Jay C. Stowe, P.E., Director
City of Newton Public Works and Utilities
WAYNE MCDEVITT tx
post Office Box 550
SECRETARY -
'`
Newton North Carolina 28658
4 } �
Subject: Notice of Violation and
Recommendation for Enforcement
Permit No. WQ0003902
City of Newton Land Application Program
Catawba County
Dear Mr. Stowe:
Chapter 143, North Carolina General Statutes, authorizes and directs the
Environmental Management Commission of the Department of Environment and
Natural Resources to protect and preserve the water and air resources of the State. The
„
Division of Water Quality (Division) has the delegated authority to enforce adopted
'
pollution control rules.
In two (2) letters received in this Office on November 2, 1998, Mr. Charles A.
Willis, Jr., P.E., with Willis Engineers and Mr.James Richards, Supervisor/ORC, City
of Newton (City) WWTP acknowledged that wastewater residuals from the City's
WWTP were applied to an unpermitted field in the southwest quadrant of the
intersection of SR 2021 (Blackburn Ridge Road) and SR 2022 (Herter Road) in
southern Catawba County. A follow-up inspection of this site was conducted on
November 4, 1998 by Mr. Michael Parker with this Office, which verified that
wastewater residuals had been applied to the site even though the site was not permitted
by Newton for residuals disposal.
Based on information provided by the City and through Mr. Parker's
investigation, we have reason to believe that the City of Newton is responsible for
activities resulting in noncompliance with North Carolina Law. Specifically, North
Carolina General Statute (NCGS) 143-215.1(a) (9) states in essence that no person shall
dispose of sludge resulting from the operation of a treatment works without having first
applied for and obtained the appropriate permit. Based on information contained in the
files of this Office, we have no record of the City applying for or obtaining a permit to
land apply sludges on the aforementioned site.
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 2811S
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER -SO% RECYCLED/i 0% POST -CONSUMER PAPER

Mr. Jay C. Stowe
November 5, 1998
Page Two
Pursuant to NCGS 143-215.6A(a)(2), a civil penalty of not more than $10,000 per
violation may be assessed against any person who violates the terms,- conditions and requirements
of a Permit. Please be advised that this Office will be preparing an enforcement recommendation
for the General Statute violation. If you have any additional justification (outside of the letters
received from you and Mr. Richards on November 2, 1998) concerning this violation, you must
reply in writing to the Mooresville Regional Office within ten (10) days after receipt of this
Notice. Your justification will be reviewed and forwarded to the Director for his consideration.
You will be advised if any enforcement action is taken.
If you have any questions regarding this matter, please contact Mr. Parker or me.
Sincerely,
D. Rea Gleason,( P.E.
Water Quality Regional Supervisor
cc: Compliance/Enforcement Group
�8arbara Christian
mlp
hAenflnewton.enf

Newton Waste Water.
Fax:[phone] Oct 27 '98 16:03 P.02
October 27,1998
NCDIENR
919 North Main Street
Mooresville, N. C. 28115
City of Newton
P.O. Box.550
Newton, N.C. 29659
Subject: Permit No. WQ0003902
City of Newton
Land Application of Wastewater Residuals
Catawba County, NC
Dear Mr_ Gleason:
This is to confirm that Mr. Chuck Willis contacted you today in regards to the violation of
the above mentioned Permit. We will be seudin$ a written report in letter form, as required- N
there are further Questions please contact me at (829)-465-7480.
Sincerely,
.�f
es Richards
RC/ Supervisor
Clark Creek POTW
Way Stowe

OF
May 1, 1995 �'gtla
Ms. Brenda Smith, Regional Supervisor
State of North Carolina IJIViSIU�! Or ���"rv�i'a.z, ;r;� .,,,,•., ,_
DEHNR
Div. of Environmental Management
919 North Main Street
Mooresville, North Carolina 28115
Subject: Permit No. WQ0003902
City of Newton
Land Application
Catawba County
Dear Ms. Smith,
In accordance with the provisions of section I:1. of our permit, issued March 29, 1995, I am
hereby notifying your office that on Monday, May 8, 1995 we will begin applying wastewater
residuals to site number 6-0 (Maiden Amusement Company). This site is located off S.R. 1005
(Startown-Lincolnton Highway) at the Lincoln County line. If you have any questions, or if I may
be of further assistance, call me at 704-465-7480.
Sincerely, q �aaa_"z
es A. Richards
Chief Operator
City of Newton
Clark Creek POTW

`W 3 � �) iON llt+�tyr
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From:
North Carolina Department of Environment
°F Health and Natural Resources TLC
Printed on Recycled Paper
Qu�rs,

-h
1,
w CITY OF
WHERE THE HEART IS!
December 22, 1993
Ms. Carolyn McCaskill
Division of Environmental Management
Permits and Engineering Unit
P.O. Box 27687
Raleigh, N.C. 2 7 611-7687
°Ti�j r'!�'I�� l t
. ._. •!Yi! i_. t_i
P.O. Box 550 • Newton, N.C. 28658 • [phone] • Fax: [phone]
Subject: City of Newton - LA Permit # WQ0003902
Dear Ms. McCaskill:
The City of Newton received a letter September 24, 1992 from the Mooresville Regional Office
stating they had reason to believe that the permitted activities had resulted in exceeding the
groundwater standards found in 15A NCA 2L.
The City responded to the letter with monitoring data that dated back to April, 1991. This data
showed the groundwater level for nitrates exceeded the standards at that time. The property
owner explained that this site has been a dairy farm for over fifty years. Manure storage has
been in this area for a long time and is our feelings that this is directly effecting the nitrate level
in this monitoring well. Since sludge has NOT been applied to this site since March of 1992,
the nitrate levels have changed very little. The nitrate levels are listed below:
#2 Well
_Date
=5
Ri i
4-16-91
12.3
3-3-92
27.6
3-9-93
19.2
7-10-91
20.6
7-30-92
24.9
6-23-93
17.2
11-25-91
27.3
11-19-92
23.1
7-21-93
23.1
12-28-92
29.7
11-9-93
16.4
The City had A.R. Rubin to do a site investigation August 18, 1993. He reviewed the site
loading records and took soil samples at different levels and is to submit a report to your office
concerning this matter.

s`'�f�lt.f;c• Jl.7:T
�Cit1��i:i
S' 7 i c " . Pi ,;: 17
�} Ms. Carolyn McCaskill
Page 2
December 22, 1993
A map of the site showing the location of the bam in relation to the well is included. Please
advise as to what steps the City must take to resume applying solids to the Sigmon Farm Inc.
site. Thank you for your help in this matter.
Sincerely,
Dwight Wilson
Director of Public Utilities
DW/bw
enc. 1
c: Karen Walker - Mooresville Regional Office
A.R. Rubin
Jake Sigmon

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14
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16 �o,r
17
i . . .1 Nw. E
18
20 /. � =�- 4 f,2/ 4 2A.5
a. 50 feet•from public road right-of-way
b. 100 feet from free -flowing stream of surface impoundment
c. 50 feet from wet weather stream
d. 400 feet from the nearest residence !
ply well
e. 100 feet from the nearest potable water sup ;

Ok-
Site Investigation
for
City of Newton
by
A.R. Rubin, Extension Specialist
Associate Professor
North Carolina State University
Biological & Agricultural Engineering Dept.
Raleigh, North Carolina
The City of Newton, North. Carolina operates and publicly owns a wastewater treatment facility
and discharges the treated municipal wastewater to surface water for the state. The residuals
generated at this publicly owned treatment works (POTW) are stabilized with lime to achieve
a pH of 12. This pH of 12 is maintained for at least 12 hours and prior to land treatment the
pH of the stabilized mixture is again measured. pH consistently exceeds 11 after several days
to several weeks of storage. These lime stabilized residuals are stored in two aerobic gravity
thickeners until they are land applied onto permitted agricultural lands.
The largest volume of material is transported to the Sigmon Brothers Dairy Farm and applied
directly to land. . The application equipment is a Terra-Gator. The operator has collected
samples of the soil from the Sigmon Brothers Farm annually. Soil pH has increased gradually
since inception of this project. The soil pH on all segments of the Sigmon Brothers Farm which
receive the lime stabilize residuals is in excess of 6.5 standard pH units.
Samples of the shallow ground water collected under one of the permitted wastewater receiver
sites indicates that the nitrate nitrogen levels in the groundwater in one well has been consistently
high since before this project was initiated. The single well (well no. 2) is located at the lowest
elevation in field number 8. Nitrate nitrogen levels in the shallow ground water underlying this
field were checked prior to inception of this program and at that time, nitrate nitrogen levels
were in excess of 10 milligram per liter. This 10 milligram per liter concentration is above the
drinking water standard and the nitrate levels have been in excess of 10 since this project was
initiated. The field does receive animal waste in addition to municipal wastewater treatment
residuals.
There are two factors which must be considered. These are:
1. Well 2 is located in an area used to store manure and
2. Well 2 is located in an area which channelize or funnels the shallow groundwater
from an upgradient position of the site into betts branch.
In order to examine the potential impact of these land treatment operations on soil nitrogen,
samples of the soil material from fields` 8, 18, and 10 were collected and analyzed. Samples

were collected from several horizons and analyzed to determine nutrient levels, soil pH, micro -
nutrient levels, nitrate levels, and soluble salt levels.
There are two purposes to the ,brief reports which follows. The first is to describe the conditions
encountered on each of the sites evaluated. The second is to make recommendations regarding
the possibilities for continued use of the Sigmon Brothers Farm to serve as the receiver for the
wastewater treatment plant residuals, generated by the City of Newton, North Carolina.
Procedure
Records of the land treatment operations conducted on the Sigmon.Brothers Farm were collected
for examination. The examination of the records indicate that the total nitrogen load applied
onto field no. 8 has been 427.81bs since this program initiated in 1985. The 427.8 lbs over 8
years is approximately 60 lbs of plant available nitrogen per acre per year. In fact, additional
nutrients would be required to obtain an optimum yield. The vegetation on the site consist of
corn and small grain and this load is not excessive for this crop. Anticipated crop yield should
be in bxcess of 100 bushels of corn per acre per year. Consultation with the farmer and
examination of farm records indicate that yields are in excess of 100 bu/ac/yr during those years
with adequate rainfall.
To investigate the potential source of nitrogen in the shallow ground water, samples of the soil
material on the receiver site and on control sites were collected. Soil material was collected
from 3 separate areas on the Sigmon Brothers Farm. The control area supposedly received no
waste. The remaining test or receiver areas have received waste since 1985. Soil samples were
collected from each site at intervals of 0" to 6", 6" to 12", 12" to 24", 24" to 36",
36" to 4811, & 48" to a depth between 60" and 72". Samples were placed in plastic bags and
the bags were placed in a cooler for transport to the Biological and Agricultural Engineering
Department Laboratory at North Carolina State University. The soil material was pulverized
and three separate '10 grams subsamples were prepared from each field sample for subsequent
analysis.
Soil samples were digested and Total Kjeldahl.Nitrogen levels (TKN) and nitrate levels were
measured with a Technicon auto analyzer. The. results of the analysis are summarized in table
1 attached. Standard soil fertility tests were used to determine the levels of other nutrients,
micro -nutrients and selected trace metals in the soil material. The standard soil fertility test
results are also summarized in table 2.
A 1 liter sample of the runoff from a drainage ditch exiting the site was also collected to
determine the levels of nutrient contained in this shallow groundwater discharged to surface
drainage. The runoff sample was cooled and transported to the Biological and Agricultural
Engineering Department Laboratory at North .Carolina State University for analysis. Standard
laboratory procedures were used to determine the levels of nitrogen contained in the drainage
discharge from the Sigmon Brothers Farm and results of this sampling are summarized in the
table attached.
During the field visit, the vegetation growing on both the control site and receiver site was

stunted because of an extended drought. No vegetation samples were collected for analysis
because of the very stunted nature of this vegetation. A vegetation analysis performed on this
stunted vegetation would not represent the true qualities of plants grown during a normal year
and for this reason, no .plant tissue samples were collected for analysis. The nitrogen lost
through vegetation harvest would normally be higher than that encountered with these drought
stressed crops. Because of this potentially misleading removal efficiency the nitrogen losses or
uptakes were not determined. The anticipated yield from the Sigmon Brothers Farm appears to
be no more than 20 bushels per acre while as stated previously, during a normal growing year
the yield would be over 100 bushels per acre. These factors do suggest no need to evaluate the
nitrogen content in vegetation during the periods of drought stress, but during periods of normal
growth, plant tissue sampling should be included as a part of this or any land treatment program.
Results
Nutrients, metals, soluble salt levels, and.particularly the nitrate nitrogen levels contained in the
soil material are generally higher on the receiver sites than in the control area soils. These
results are summarized in tables 1 and 2 attached.
The nitrate nitrogen level in the control soil is lowest at the 24" to 48" and 48" to 60" depths.
The nitrate nitrogen level on receiver site 2 and on receiver site 3 are significantly higher than
the control site nitrate nitrogen levels. The Kjeldahl nitrogen level on the receiver sites are
consistently higher than on the control site. The total Kjeldahl nitrogen levels in the shallow
soils will mineralize slowly with time. Eventually, this organic nitrogen will convert to
ammonia and nitrate. These inorganic forms of nitrogen are utilized by plants. If the nitrate
and ammonia mineralized exceeds plant nutrient requirements, then the soluble nitrate will .
migrate below the root zone and may enter ground water. Nitrate nitrogen in shallow ground
water under site 8 is in excess of nitrate standards, however; TKN levels and nitrate levels in
the soil are not excessive although they are higher on sites 2 and 3 than on the control site.
The total nitrogen (TKN+NO3) levels on the receiver sites are consistently higher than those
on the control sites which received manure, but no sludge. The difference in total nitrogen can
be attributed to the combination of animal manure and municipal wastewater residuals applied
to the receiver sites. The nitrate nitrogen levels are significantly and consistently higher on
receiver sites at shallow depths (to 60") than on control sites, similarly total nitrogen levels
(TKN+NO3) are higher, but the differences are approaching levels encountered on any
agricultural site and nitrogen should not be significantly impacting ground water. With time and
continued harvest of crops, the nitrogen levels will fall. Integrity of wells and well location in
field 8 must be inspected. and possibly moved. Well 8 reflects manure impacts in addition to
residuals.
Results of the standard soil fertility testing indicate that levels of calcium and soil pH are high.
Normally, soil calcium levels range between 50% and 70%. The unusually high calcium levels
encountered on a receiver site reflect the application of the lime stable product to these sites.
The high soil pH will not affect crop production, but soil pH should be monitored to insure that
it does not rise to 80 or higher.

Other nutrient and trace element levels are consistent with well managed agricultural operations.
The levels of both phosphorus and potassium are in the high normal range for clay rich piedmont
soils. These levels should not adversely impact agricultural operations. Trace element levels
are within ranges normally encountered in North Carolina.
Continued application of residuals at slightly reduced levels will benefit both the waste
generator and the Sigmon Brothers Farm. Material should be applied to provide no more than
1 ton of lime per acre per year.

o
Table 2
Soil Fertility Test Results,
Newton, NC
O.M.
pH
CEC
p
(mg/kg)
K
(mg/kg)
Ca
(mg/kg)
Mg
(mg/kg)
Zn
mg/kg)
Cu
(mg/kg)
Site 1
0-6
.3
6.8
22.1
210
1004
62.7
22.5
64.3
8.5
6-12
.4
6.7
21.9
241
992
62.0
22.9
52.2
5.0
12-24
.4
6.6
12.8
110
412
52.2
20.1
16.2
6.2
24-48
.1
5.5
8.8
90
136
50.7
26.5
3.04
3.6
Site 2
0-6
.5
7.0
16.6
213
248
86.1
10.1
14.7
23.0
6-12
.6
7.4
7.9
20.4
44
76.9
16.9
2.2
4.7
12-24
.3
6.8
4.4
20.0
40
69.0
20.2
1.5
2.3
24-48
ND
6.5
4.5
3.3
38
58.0
30.4
1.5
1.4
Site 3
0-6
.4
7.5
27.6
214
160
90.9
7.6
34.8
40.9-
6-12
.4
7.4
8.3
24.5
108
84.2
12.5
5.7
6.9
12-24
.4
7.3
7.5
32.6
100
65.6
31.7
3.8
6.5
24-48
.1
6.8
3.0
20.8
28
64.4
30.3
.9
1.4

State of North Carolina
Department of Environment, Health/ and Natural Resources
Mooresville Regional Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 30, 1991
Mr. Richard French
City of Newton
Post Office Box 550
Newton, North Carolina 28658
Subject: Notice of Violation
City.of Newton Sludge Land
Application
Permit No. 9848R
Catawba County, NC
Dear Mr. French:
This Office has reviewed the annual sludge analysis and
application report for 1990.
PO was reported in violation of permitted loading rates for
the fol�owing fields:
Field
Report Value
Permit Limit
(lbs/ac/yr)
(lbs/ac/yr)
2
ill
100
7
102
100
9
ill
100
12
103
100
13
112
100
1-5
104
100
It is requested that a written response be submitted by
February 15, 1991 explaining the reasons for the violations and
corrective measures taken regarding -the violations.
919 North Main Street, Mooresville, N.C. 28115 • Telephone [phone] • FAX [phone]
An Equal Opporninity Affirmative Action Employer

Mr. Richard French
Page Two
January 30, 1991
If you have any questions concerning this matter, please do
not hesitate to contact Mr. Kim Colson, Mr. Rex Gleason, Water
Quality Regional Supervisor, or me at this Office.
Sincerely,
J `I ki
Brenda J. Smith, P. G.
Regional Supervisor
KHC:se
V/e

i
F O
WHERE THE HEART LS!
December 19, 1990
p�st3fifjrae�o�C 550 Newton, North Carolina 28658 [phone]
�aNb1E%i:Al
DEC 20 1990
Mr. Michael Parker
NC Dept of Environmental, Health and Natural Resources
919 North Main Street
Mooresville NC 28115
Subject: Response to violation of sludge
City of Newton
Land Application Program
Permit No. 9848 R
Catawba County, NC
Dear Mr. Parker:
As you recall during our investigation of the odor complaint, the Sigmon Brothers
were incorporating the sludge that had been applied. The sludge on all of the
sites was incorporated by the afternoon of November 28.
I advised Sigmon Brothers of the Notice of Violation. They are aware of the
incorporation requirement. I also advised the Sigmon Brothers, the City will
have a person checking the fields at the end of each day to assure compliance
of the program. I feel the City of Newton has operated and managed a good land
application program and would invite anyone to inspect the sites. The farm has
been very productive from the land applying. If you need any more information
concerning this matter, please contact me.
Sincerely,
Dwight Wilson, Sr.
Water & Wastewater Superintendent
vj
c: Rick French, City Manager

R1;ECT ''
tjL'� ^�'}fd CIF ENVIFUNMEN AL fRi1CN NW,
WDAESVIL&
b'
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street s Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
December 10, 1990
Mr. J. Thomas Lundy
County Manager
County of Catawba
Post Office Box 389
Newton, NC 28658
George T. Everett, Ph.D
Director
Subject: Permit Application No. WQ0003902
City of Newton
Land Application Sludge
Catawba County
Dear Mr. Lundy:
The Division of Environmental Management has received an application from the City of
Newton for the land application of sludge generated by the treatment of domestic wastewater to
lands in Catawba County.
Should you desire to comment on this application as it relates to your interests, please do
so by January 10, 1991.
If you have any questions, please contact Mr. Dana Bolden at 919/ 733-5083.
Sincerely,
P
1"
Saf ' ,Supervisor
Permits and Engineering Unit
cc: Permit File WQ0003902
Moor - resville_Regional-Office-i
Richard French, City Manager, City of Newton
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT
December 10, 1990
Mr. Richard French, Manager
City of Newton
Post Office Box 550
Newton, North Carolina 28658
Subject: Notice of Violation
City of Newton Sludge
Land Application Program
Permit No. 9848R
Catawba County, NC
Dear Mr. French:
The City of Newton is authorized to land apply sludge
generated at the City's Clark Creek Wastewater Treatment Plant at
designated sites and under specific terms and conditions as
contained in the subject Permit. As a result of a complaint
regarding odors, an investigation of the City's land application
sites located at the Sigmon Dairy Farm was conducted on November
27, 1990 by Mr. Michael L. Parker and Mr. Dwight Wilson,
Wastewater Treatment Plant Superintendent.
The investigation revealed that sludge had been land applied
without incorporation for at least seven (7) days. Condition No.
19 of the subject Permit requires that surface applied sludge be
incorporated immediately after application. Violations of Permit
conditions may subject the violator to the assessment of civil
penalties of up to $10,000 per day per violation.
This letter, therefore, shall serve as a Notice of Violation
for the violation of Condition No. 19 of the subject Permit.
Should future violations of this or any other Permit condition
occur, enforcement action may be recommended.
It is requested that a written response be directed to this
Office detailing action taken in addition to efforts made to
prevent future occurrences. This response should be addressed to
the attention of Mr. Michael L. Parker and should be submitted by
no later than December 21, 1990.
919 North Main Street, Mooresville, N.C. M15 • Telephone [phone] • FAX [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Richard.French
Page Two
December 10, 1990
If you have any questions regarding this matter, please
contact Mr. Parker, Mr. D. Rex Gleason, Water Quality Regional
Supervisor, or me.
Sincerely,
Brenda J. Smith, P.G.
Regional Supervisor
cc: Catawba County Health Department
MLP:se
116P

Water Resources
Environmental Quality
March 7, 2018
Mr. James Wentz, Public Works Director
City of Newton
P.O. Box 550
Newton, North Carolina 28658
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Subject: Acknowledgement of Receipt of the 2016 Annual Report
City on Newton — Permit No.: WQ0003902
Land Application of Residuals
Catawba County
Dear Mr. Wentz:
The Mooresville Regional Office (MRO) received and reviewed the 2017 Annual Report for the
above permit.
The information provided in the annual report appears to be complete and in compliance with the
permit.
Should you have any questions, please contact Edward Watson at [phone] ext. 2198, or by email
at [e-mail].
Sincerely,--
Edward Watson, Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
CC: Eric Jones, WWTP Superintendent (via email)
Eric Bruce, Synagro, LA Backup ORC (via email)
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

Water Resources
Environmental Quality.
ROY COOPER
Governor
MICHAEL S:. REGAN
Secretary
LINDA CULPEPPER
Interim Dii-exior
November 6, 20.17
Mr. Martin D. Wilson,. Public Works Director
City of Newton
P.O. Box 550
Newton,;North Carolina 28658
Dear Mr. Wentz:
Subject: Inspection Report
City on'Newton — Permit No.: WQ0003902'
Land Application of Residuals
Catawaba County
The Mooresville Regional Office (MRO) performed a routine compliance inspection for the.
above mention facility The facility was found to .be' in compliance with permitted activities.
The attached inspection report should be self-explanatory. However, should you have any
questions or concerns regarding the findings of the attached report, please feel' -free to contact
Edward Watson by email at edward watsoh@rin denr.gov, or phone at [phone].
Sincerely,
Edward. Watson, drogeologist:
Mooresville Regional. Office
Water Quality Regional Operations Section
Division of Water. Resources., NCDEQ
Attachments: Inspection Report.
CC- Eric Jones,, WWTP Superintendent (via email) '
Eric Bruce; Synagro, LA Backup ORC (via email).
State of North Carolina I Environmental Quality i Water Resources I, Water Quality -Regional Operations
Mooresville Regional Ot ice.l 610 East Center Avenue, Suite 301 1 Mooresville; N6rih.Carolina,28115
704-6634699

Compliance Inspection Resort
Permit: WQ0003902 Effective: 06/01/15 Expiration: 05/31/20 Owner: City of Newton
SOC: Effective: Expiration: Facility: City of Newton Residuals Land Application Program
County: Catawba PO Box 550
Region: Mooresville
Newton NC 28658
Contact Person: Martin D Wilson Title: Public Works Director Phone: [phone]
Directions to Facility:
System Classifications: LA.
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/26/2017
Primary Inspector: Edward Watson
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 10:OOAM Exit Time: 12:00PM
Phone:
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: E Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Land Application Site Pathogen and Vector Attraction Storage
Transport
(See attachment summary)
Page: 1

Permit: W00003902 Owner - Facility: City of Newton
inspection Date: 10/2612017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary
On October 27, 2017, a review of the RLAP for the City of Newton, INC was performed by MRO staff.
During the site visit the digesters were reviewed prior to traveling to the application fields.
There is significant build up on the side walls of Digester 2 which is reducing the holding capacitiy of the tank. Please
reduce the caked material to maximize tank capacity.
During the site visit fields, 7 & 8 received residual materials. The fields were buffered in accordance with permit directives:
The residual material appeared to be being applied in an even manner and care was taken not to allow residual material to
be tracked onto the road upon traveling to a separate field.
It was requested that an additional sign be placed at the enterance to the field on Hickory - Lincoln Highway
Page: 2

.;_t
Permit: W00003902 Owner - Facility: City of Newton
Inspection Date. 10/26/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Yes No NA NE
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑ ❑ ❑
Are GW samples from all MWs sampled for all required parameters?
❑ ❑ ❑
Are there any GW quality violations?
❑ ❑ 0 ❑.
Is GW-59A certification form completed for facility?
❑ ❑ 0 ❑
Is a copy of current permit on -site?
0 ❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
E ❑ ❑ ❑
a. TCLP analysis?
E ❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
N ❑ ❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑ 0
Has land application equipment been calibrated?
❑ ❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ ❑
Are there pH records for the land application site?
❑ ❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑ 0
Do lab sheets support data reported on Residual Analysis Summary?
E ❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has perrnittee been free of public complaints in last 12 months?
E ❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑ E ❑ ❑
Comment: VAR is by lime stabilization. The lab analytical data was reviewed during the site visit and
appears to be in order. No exceedances were noticed in the laboratory analytical data.
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
❑ ❑ ❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class B<2.0'10E6 CFUIdry gram
❑
Fecal colifonn SM 9222 D (Class B only)
Cl ❑ 0 ❑
Geometric mean of 7 samples per monitoring period for class B<2.0.10E6 CFUIdry gram
❑
b. pH records for alkaline stabilization (Class A)
❑ ❑ ❑
c. pH records for alkaline stabilization (Class B)
N ❑ ❑ ❑
Temperature corrected
Page: 3

/--4
parIng: W00003902 Owner - Facility: City of Newton
Inspection Date: 1012612017 Inspection Type: Compliance Evaluation
Reason for visit: Routine
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑ ❑ ❑
e. Timerremp on:
❑ ❑ 0 ❑
Digester (MCRT)
❑
Compost
❑
Class A lime stabilization
❑
f. Volatile Solids Calculat'
❑ ❑ ❑
g. Bee - op Aerobic/Anaerobic digestion results
❑ ❑ ❑
OMH records were not-i
Treatme
Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic. Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
Compost
❑
Drying Beds j
❑
Other
❑
Comment: Reduction by Lime Stabilizatiod
Transport Yee No NA NE
Is a copy of the permit in the transport vehicle? M ❑ E1.13
Is a copy of the spill control plan in the vehicle? M ❑ ❑ ❑
Is the spill control plan satisfactory? M ❑ ❑ ❑
Does transport vehicle appear to be maintained? El❑ El
Comment: The spill plan was reviewed and found to be in compliance with the permit. The loading area
the head of the plant.
Land Application Site
Yes No NA NE
Is a copy of the permit on -site during application events?
❑ ❑ ❑
Is the application site in overall good condition?
❑ ❑ ❑
Is the site free of runoff/ponding?
0 ❑ ❑ ❑
If present, is the application equipment in good operating condition?
0 ❑ ❑ ❑
Are buffers being maintained?
M ❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
❑ ❑ 0 ❑
18% for subsurface application
❑ ❑ 0 ❑
Are there access restrictions and/or signs?
0 ❑ ❑ ❑
Page: 4

r,
.U.
permit: WQ0003902 owner - Facility: City of Newton
Inspection Date: 10126/2017 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the application site free of odors or vectors? M ❑ ❑ ❑
Have performance requirements for application method been met?.
For injection? ❑ ❑ 0 ❑
For incorporation? ❑ ❑ 0 ❑
Does permit require monitoring wells? ❑ M ❑ ❑
Have required. MWs been installed? ❑ ❑ 0 ❑
Are MWs properly located w/ respect to RB and CB? ❑ ❑ M ❑
Are MWs properly constructed (including screened interval)? ❑ ❑ M ❑
Is the surrounding area served by public water? ❑0 ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ M ❑
Are soil types consistent w/ Soil Scientist report/evaluation? M ❑ ❑ ❑
Is the water table greater than 1'/3' bls. ❑ ❑ ❑
Is application occurring at the time of the inspection? ❑ ❑ ❑
Comment: The soil readily absorbed the applied material. Some flys were noticed durin4 the land
application event. However. they were not present in signifcant numbers. No odor was present
except at immediate application The areas where application had already been performed did
not have any odor. No run-off was observed during the site visit.
Page: 5