WQ0005114_Regional Office Historical File Pre 2018

`4.
'Tatawba
Town ot
k pa
NCDENR- Division of Water Quality
117 Mail Service Center OCT 2 9 2003
Raleigh, NC 27699-1617
SUBJECT, PEpMIT NUMBER i Q00 11 � �r fi z
IE . 0U, 'a1u.. i"5 w,1"ag x s,
Dear Sirs:
Please advised that the Town of Catawba sold its water and sewer utility system o the
City ofHickory� ., on April 1, fl 1 cans ticr rntly, the To has discontinued the
practice of land application oflnio-solids. C lr. Sevin Greer, an engineer with the City o
Hickory, recently forwarded orr spond n to your agency regarding ths matters.
In the event the Town is the y responsible for requesting a rescission, please accept
this letter as our notification to that effect. Thank you for your prompt attention to these
matters.
Sind ly,
E. T dd Clr
Town Manager
Kevin Greer
Ellen Huffman
102 First Street, -NW - ,0 70 Catawba, NC`28609
Phone: -1r1 Fax.- 828-241-9968

NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
INVOICE
Annual Permit Fee
This annual fee is required by the North Carolina Administrative Code. it covers the administrative costs
associated with your permit, It is required of any person holding a permit for any time during the annual fe-e
period, regardless of the facility's operating status. Failure to pay the fee by the due date will subject the
permit to revocation. Operating without a valid permit is a violation and is subject to a $10,000 per day fine.
If the permit is revoked and you later decide a permit is needed, you must reapply, with the understanding the
permit request may be denied due to changes in environmental, regulatory, or modeling conditions,
Permit Number: WQ0005114
MITCHELL SETZER Catawba Town -A Sludge
TOWN OF CATAWBA
PO BOX 70
CATAWBA NC 28609
Annual Fee Period: 911/2003 to 8131112004
Invoice Date: October 22, 2003
Due Date: November 21, 2003
Annual Fee- $675-00
Notes: 1. A $25.00 processing fee will be charged for returned checks in accordance with the No Carolina
General Statute 25-3-512.
2. Non -Payment of this fee by the payment due date will initiate the permit revocation process.
3. Remit payment to*
NCDENR -Division of Water Quality
1,617 Mail Service Center
Raleigh, North Carolina 27699-1617 contact the Annual Administering and
4. Should you have any questions regarding this invoice, please
Compliance Fee Coordinator at 919-733-5083 extension 210.
ANNUAL PERMIT INVOICE
(Return This Portion With Check)
Permit Number: WQ0005i 14 Annual Fee Period:
Catawba Town -A Sludge Invoice Date:
Due Date:
MITCHELL SETZER Annual Fee:
TOWN OF CATAWBA
PO BOX 70
CATAWBA NC 28609 Check Number:
October 22, 2003
November 21, 2003
$675-00

......__- .................
Me of Water anti'S�pwer Utility System
D*ie:'Tue, 22 Apr 23 I.:35 P0
6 ,, a "Town nistrator'' to 1caataa Wh rt r.net`
"Ellen M '" II . net>
Ellen
Its official. The Town Council and Hickory City Council signed a contract last night and the system now
belongs to the City of Hickory. We will be going throug, ka a transition period for several months
transferring permits, etc. My primary contact with the City of Hickory is Mr. Gene Haynes and he can be
rah at $28-323-7427. 'Sorry t didift call to speak NArith yout, person,, but 'm way behind. This
contract has dernanded all of my tinle for the last two weeks.
"I
odd Clark
To,wn Manager
Town of Catawba
u.

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Rio Caf "'ntinf rt"ep 19744 VMT 1101"Nm 14
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Apr^- 7-0 tit P-01
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Town of Catawba
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To: Fax
Company:
Reference:
from:
Number of pages including this raver sheet
102 First Strtet, P.0, 90, 0 Carawba, NC ZR609
Mow -241-221' 9 r SZS-2 1.9968

4
State of North Carolina
Department of Environment,
" Health and Natural Resources
Division of Water Quality
t
James B. Hunt, Jr.,` Governor
Jonathan B. Howes, Secretary
, Preston Howard, Jr., P.., Director
The Honorable Mitchell Setzer, Mayor
i owl) Of Catawba
P.O. Box 70
Catawba, NC 28609
Dear Mawwor et.er:.
Jane 5, 19977
r'
Subject: Permit No. WQ0005114
Town of Catawba
Land application of Wastewater Residuals
Catawba County
In accordance with your application received on March , 1997, 7, we are forwarding herewith
Permit No, WQ00 51 l 4, dated Jane d 1997t to the Town of ataww ba for the continued operation of
wastewater residuals land application program.
This permit shall be effective from the date of issuance until May 31, 2002, shall void Permit No.
WQ0005114 issued September 19, l 2 and shall be subject to the conditions and limitations as specified
therein. Please, pad` particular attention to Condition 1, jf1 allowing,for the land application of residuals 50
feet from the property line and also mite the monitoring and reporting requirements contained in this
permit, Failure- to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.
1`f any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicator), hearing upon written request within thirty ) days following in receipt of
this permit. This request must he in theform f a written petition, conforming to Chapter, 150B of North
Carolina General Statutes, and tiled with the Office of Administrative Hearings, P.O- Drawer 27447,
Raleigh_; NC 27611-7447. Unless such demands are made this permit shall be final and binding.
If you 'need additional information concerning this matter„ please contact Mr. Randy Kepler at
(19) 733-5083 extension 1.
ncerel
Preston Howard, Jr., P.E.
Catawba Counry health Department
gill Rehearsal office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
TTainina and Certification Unit, No change in rating
Facilities Assessment Unit

'A
—7 NORTH CAROLIN
ENVIRONMENTAL MANAGEMENT COMMISSION
"-DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RESIDUALS LAND APPLICATION PERMIT
In accordance with the provisions of Axticle 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Town of Catawba
Catawba County
FOR THE
operation of a wastewater residuals land application prog%ram consisting of the application of 6.42 dry tons
per year of residuals from sources listed in Condition E 5, to approximately 45 acres of land in Catawba
Countv with no discharge, of wastes to the surface waters, pursuant to the application received on Match 3,
1997 and in confortirty with the project plan, specifications, and other supporting data subsequently filed
and approved by the Department of Environment, Health and Natural Resources and considered a part, of
this permit,
This pernut shall be effective from the date of issuance until May 31, 2002, shall void Pe pit No.
WQ0005114 issued September 18, 19�92, and shall be subject to the following specified conditions and
limitations:
I —PERFORMANCE STANDARDS
3.
4,
This permit shall become voidable if the soils fail to adequately assimilate the wastes, and
may be rescinded unless the sites are maintained and operated in a manner which will
protect the assigned water quality standards of the surface waters and ground waters.
The land application program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this
program.
C�
The issuance of this perrnit shall not relieve the Permittee of the responsibility for damages
to surface or aroundwaters resultina from the operation of this program,
In the event that the land application program is not operated satisfactorily, including the
creation of nuisance conditions.. the Permittee shall cease applying residuals to the sites and
take any immediate, corrective actions as may be required by the Division.
I

. Some of the buffers specified below may not have been included in previous permits for
this land application operationHowever, , anysites or fields that are included in this
permit, but were approved with different applicable buffers shall be reflagged to comply
with the below buffers. The following buffer zones shall bemaintained:
a) 400 feet from residences or places of public assembly under separate ownership for
surface application method; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and approval from the:
appropriate DWQ regional office,
feet from residences or places of public assembly tinder separate ownership for
subsurface residual injectionmethod; however, the buffer zone requirement may be
reduced to a minimum of 100 feet upon written consent of the tuner and the
appropriate DWQ regional office,
l 100 feet from y public or private water supply source, waters classified as SA or S .
d any Mass I or Class fI impounded reservoir used as a source of drinking water for
both methods,
dl 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal graters and any outer lake or impoundment for surface application,
ei 50 feet from any streams classified as WS of B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for subsurface application,
f) 50 feet from property lines for both surface and subsurface applicationmethods;
i 50 feet from public right of ways for both application methods,
h ip feet from upslope interceptor drains and surface water diversions for both
application methods,
ii 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both application methods.
6 A copy of this permit shall be maintained at the land application site when residuals are
being applied during the `life of this permit, spill prevention and control plan shall be
maintained in all residuals transport and application vehicles.
Specific residual application area boundaries shall be clearly marked on each site prior to
and during application;
. No residuals at any time shall be stoned at any application site, unless approval has been
requested and obtained from the Division of Water Quality.
q. Maximum slope for residual application shall be 1 for surface application and 1 % for
subsurface applications,
1p. When wastewater residuals are applied., the Class A pathogen requirements and site
restrictions in 40 CFR fart 03.32(a) or the Class B pathogen r qui, e ents and site
restrictions in 40 CFRPart 503.32(b),d one of vector attraction reduction requirements
in 40 CFR Part 503.3-1 shall be met. Additionally, an evaluation must be performed which
demonstrates the residuals ability to comply with this requirement. Upon request, a copy
of this evaluation must be submitted including all test results and calculations.
OPERATION AND MAINTENANCE RVOUIREME
l . The facilities and application sites shall be properly maintained and operated at all tunes.

A suitable vegetative cover, as listed in condition fl 4, shall be maintained in accordance
with the crop management plan outlined by the local Extension Office of the Department;of
riculture, the Natural Resources Conservation Service,, or other a ronotnist, and
approved by this Division.
.
An acceptable ply must be maintainedin
the soil, residual and lime mixture, greater than
.0, on all land application sites to insure
optimum yield for the crop(s) specified below,
The aprono 'st shall provide information
on the pH bent suited for the specified crop and
the soil type.
®
The application rates shall not exceed the following for the specified crops..
Cron
PAN lh.la- I r.
Alfalfa
200
Bermuda xrass (Flay, Pasture)
2220
Blue Grass
120
o ram)
160
Corn (Silage)
200
Cotton
70
Fescue
250
Forest (Hardwood Softwood)
5
100
Small Grain (Wheat, barley, oats)
100
or hum, Sudex Pasture
180
Sorghum, S,udex (Silage)
220
Soybeans
200
Timothy, Orchard, & Rye Grass
200
.
No residuals other than the following
are hereby approved for land application to
accordance with this pe t,
Permit Volume
Source Coumj,-
Number d r tons ear
Town of Catawba WNA,7P Catax0a
NCO025542 6.42
6,
The metal loading_rates shall not exceed the following Cumulative pollutant loading rates.
Kilograms
Pounds
Parameters Per Hectare
r acre
Arsenic 1
36
Cadmium
Copper 1,500
1,338
Lead 300
Mercury 17
15
Molybdenum ----
Nickel
Selenium 100
89
Zinc 2.800
2,498

7. The pollutant concentrations in the residuals which will be applied to the land shall not
exceed the following Ceiling Concentrations (Dry Weight Basis):
parameterc.
Arsenic 75
Cadmium 85
Copper 4,300
Lead 940
Mercury 57
Molybdenum 7-5
Nickel 420
Selenium 100
Zinc 7,500
8Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified land appli cation/residuals operator to be in responsible charge (ORC) of
the land application program, The operator must hold a certificate of the type classification
assigned to the land application program by the Certification Commission. The Pemnuee
must also employ a certified back-up operator of the apprOpriate type to comply with the
conditions of Title 15A NCAC 8A, .0201
9Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
10: Surface applied residuals will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
I I For areas that are prone to flooding or within the 100-year flood elevation, residuals may
be applied only during periods of dry weather. The residuals must be incorporated into the
soil within twenty-four (24) hours after application,
11 Appropriate measures must betaken to control public access to the land application sites
during active site use and for the 12-month period following the last residual application
event. Such controls may include the posting of signs indicating the activities being
conducted at each site.
13Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residual,; application area onto the adjacent property or into
any surface waters.
14, Residuals shall not be applied in inclement weather or until 24 hours following a rainfall
event of 1/2-inch or greater in 24 hours. Any emergency residuals disposal measures must
first be approved by the, Division of Water Quality.
15. Residuals shall not be applied to any land application site that is flooded, frozen or snow-
covered.
16, Residuals shall not be applied at rates greater than agronomic rates, unless authorized by
the Division,
17. Animals shall not be grazed on an application site for 30 days after residuals application.
Application sites that are to be used for grazing shall have fencing that will be used to
C-1
prevent access after each application.
4

Food crops, feed crops and fiber crops that do not come in contact with the residuals shall
not be harvested for 30 days after residuals application.
19.Food crops with harvested parts that touch the residuaLlsoil mixture and are totally above
the land surface (ex, tobacco, melons., cucumbers, squash, etc.) shall not be harvested for
14 months after residuals application.
20, Food crops with harvested parts below the surface of the land (root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after application of residuals
when the residuals remain on the land surface for four (4) months or longer prior to
incorporation into the soil.
11. Food crops with harvested parts belo,,v the surface of the land shall not be harvested for 38
months after application of residuals when the residuals remain on the land surface for less
than four (4) months prior to incorporation into the soil.
22. Turf shall not be harvested for I year after residuals application if the turf is to be placed on
land with a high potential for public exposure.
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue t" ck
analyses,) deemed necessary by the Division of Water Quality, to insur
e protection of the
environment will be established and an acceptable sampling and reporting schedule shall be
followed,
2, Proper records shall be maintained by the Permittee tracking all application activities.
Thesc records shall include, but are not necessarily limited to the following information. -
a, source of residuals
b, date of residual application
c. location of residual application (site, field, or zone
dmethod of application
e. weather conditions (sunny, cloudy, raining., etc.)
f, soil conditions
type of crop or crops to be grown on field
fit. volume of residuals applied in gallons/acre, dry tons/acre or kilogram, s1hectare
i, annual and cumulative totals of dry tons/acre of residuals, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be limited to arsenic,
cadmium, copper, lead, meTcury, molybdenum, nickel, selenium and zinc), annual
pounds/acre of plant available nitrogen (PAN), and annual pounds/acre of phosphorus
applied to each field.
3 A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted
on each site receiving residuals in the respective calendar year and the results maintained on
t!
file by the Permittee fora minimum of five years.
The Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the
following parameters:
tl
Acidity
Calcium
Copper
Magnesium
Base Saturation (by calculation)
Cation Exchange, rapacity
Manganese Potassium
Percent Hurnic Matter Sodium
pH Zinc
Phosphorus
5

0
The Standard Soil Fertility analysis (see above) and an analysis for the following
pollutants shall be conducted once prior to permit renewal on soils from each site which has
received residuals during the permit cycle.
Ars,eul'c Mercuryto el
Cadmium Molybdenum eleniurrt
Lead
residuals analysis will be conducted Annually from the date of permit issuance by the
Permittee and the results maintained on file by the Pernnttee fora minimum of five years.
If land application occurs at a frequency less than, annually', a residuals analysis will be
required for each instance of land application. The residuals analysis shall include but is
not necessarily limited to the following parameters:
Arsenic ci
Cadmium Nitrate -Nitrite Nitrogen
Copper Magnesium
% Total Solids
Mercury PH
Molybdenum Phosphorus
Mickel Plant .available Nitrogen y calculations
Selenium Potassium
Zinc Sodium
Aluminum TKIN
`Ammonia -Nitrogen
All residuals included in this permit must be monitored annually, from the date of permit
issuance, for compliance with condition 110 of this permit. Data to verify stabilization and
vector attraction reduction of the residuals must be maintained by the. Permittee. The
required data is specific to the stabilization process utilized, but should be sufficient to
clearly demonstrate compliance the Class A pathogen requirements in 40 CFR Dart
03.3 iai or with the Class B pathogen requirements and site restrictions in 40 CFR Part
03.32(b), and one of vector attraction redaction requirements in 40 CFRPart 503.33. In
addition, the EPA certification statements conceming compliance with pathogen
requirements, vector attraction reduction requirements and management practices must be
completed annually by the proper authority or authorities if more. than one is involved,
either the person who prepares the residuals, the person who derives the material, or the
person who applies the residuals.
Three copies of all required monitoring and reporting requirements as specified in
conditions 1111, III; , 1113, III 4, and 1115 shall be submitted annually on or before March
I of the following year to the following address,
NC Division of eater Quality
Water Quality� Section
Facility Assessment Plait
PO fox 29535
Raleigh, NC 2-053

7. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number 704-663-1699, as, soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following.
a, Any occurrence with the land application program which results in the land application
of significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the land application program resulting in a release of material to receiving
waters,
c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this perrin't or the parameters on
which the system was designed.
d, Any process unit failure, due to knowri or unknown reasons, that render the facility
incapable of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
application site.
Persons reporting such occurrences by telephone shall also file a written report in letter•
form within five (5) days following first knowledge of the occurrence. This report must
outline the actions taken or proposed to be taken to ensure that the problem does not recur.
IV.
2, Any groundwater quality monitoring, as deerned necessary by the Division, shall be
provided,
3. No land an , plication of waste activities shall be undertaken when the seasonal high water
table, is less than three feet below land surface,
4. Existing monitoring well MW-2 shall be abandoned in accordance with the procedures
outlined in 15A NCAC 2C .0 113 .
7

V. INSPECTIDN'S
I The Pemittee or his designee shall inspect the residuals storage, transport, and application
facilities to prevent malfunctions and deterioration, operator errors and discharges which
rnav cause or lead to the release of wastes to the environment, a threat to human health. or a
nuisance, The Pe tree shall maintain an inspection log or summary including at least the
date and time of inspection, observations made, and any maintenance, repairs, or corrective
actions taken by the Permatee. This log of inspections shall be, maintained by the Permittee
for a period of five years from the date of the inspection and shall be made available to the
Division of Water Ouality or other permitting authority, upon request:
2. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises or place on
or related to the application site or facility at any reasonable time for the purpose of
determining compliance with this permit, ay inspect or copy any records that must be kept
under the terms and conditions of this permit; and may obtain samples of groundwater,
surface water, or leachate.
VlGENERAL—CONDITJQMS
This permit shall become voidable unless the land application activities are carried out in
accordance with the conditions of this permit. the supporting materials, and in the manner
approved by this Division,
2, This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3. This permit is not automatically transferable. In the event that there is a desire for the
facilities to change ownership or a name change of the Permittee, a formal permit request
must be submitted to the Division of Water Quality accompanied by an application fee,
documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.
4 The, following are approved sites for residuals application (see attached map[s]),
Application Area [acres]
17itp NA Owni-,r/Tf-,vqt-c- (excluding buffers)
Catawba County
Troy Dale Kom 45.0
TOTAL AVAILABLE ACRES 45:0
5 Failure to abide by the conditions and limitations contained in this permit may'subject the
Pernintee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215.6(a) to 143-21,5.6(c).
6 The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15 NCAC 2H .0205
(c)(4).
7. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
sliencies (local. state, and federal) which have jurisdiction.
8

. The Permittee, at least six ) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.,
This pen -it -may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division of eater Quality deerns necessary ir
order to adequately protect the environment and public health.
Permit issued this the Fifth day of June; 1997
NORTH CAROLINA ENVIRONMENTAL l ANAGE . %7 f` COMINUSSION
. Preston Howard, Jr., P.., Director
Division of Water Quality
y Authority of the Environmental Management o. fission
Permit Number WQ0005114

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I' ` FIGURE1
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SLUDGE LAND APPLICATION
CATAWa
Bad COUNTY
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SITE LOCATION MAP

7Rv Compost Facility Update
Subject: r Compost Facility ate
Date.- Wed, 14 Aug 2002 1 . 4:4' -070
From:"Town ini trator°" <townofcatawbaoacharter, nev-
To "Ellen Hu an" <Ell n_ a angry rinul, n t
Yes, we would want to secure the lead app. permit as only a backup for emergency purposes!
---- Original Message ----
From.- Ellen Huffman
To: Town Administrator
Subject: - Compost Facility Update
that is great news! I assume that you still ;want to renew the Land App. permit just in case, es
Ellen
Town Administrator of
Ellen, e have signed a contract °th Catawba County to utilize a portion oftheir dedicated
capacity in the composting consortium here in Catawba County, Our attorney is in the
process ofdraTtirrg a contract with the City, of Hickory to haul the bi ulid . -Additionally,
our engineer is completing the application to renew the permit for land application. Just
wanted to keep you abreast of these matters' Todd dark
Town Manager
Ellen Huffman - Ellen.Huffman@ncmail,n t
Environmental Specialist I
NorthCarolina Dept. of Environment & Natural resources
Div. of Water Quality
919 N, Main S.
Mooresville, NC 28115
h- 704.663.1699 Fay: 704,663.6040
t of 1 I142002 2: 3 P

4
State of North Carolina
Department of Environment 1AAR 12 2002
and Natural Resources
Division of Water Quality
0 lam 1, WA
Michael F. Easley, Governor "CDENR
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director NoRTH CARouoA DEPARTmF-NT or
ENVIR014MENT ANo NAxuRAL RE5ouRCES
March 7, 2002
Mr. E. Todd Clark CERTIFIED MAIL
Town of Catawba RETURN RECEIPT KLQLLESTED,
PO Box 70
Catawba, NC 28609
RE. Request for Remission of Civil Penalty
Permit No. WQ0005114
Catawba County
File No. PC 01-018
Dear Mr. Clark. -
In accordance with North Carolina General Statute 143-215.6A(f), I considered the
information you submitted in support of your request for remission and did not find grounds to
modify the civil penalty assessment of S2,233.59.
There are two options available to you, You may pay the civil penalty assessment or you may
present your request for remission to the Cormnittee on Civil Penalty Remissions of the
Environmental Management Commission. If you choose to pay the penalty, please make _yourcheck
rural Resources and reference the case number,
Send pay ment within 30 days of your receipt of this letter to the attention rife
Mr. Steve Lewis
DWQ
,1617 Mail Service Center
Ralei-li, North Carolina 27699-1617
Mailing Address: Telephone [phone] Location:
1617 Mail Service Center Fax [phone] N. Salisbury St,
Raleigh, North Carolina 27699-1617 State Courier #5 2-01 -01 Ralei�h, NC 27699-1617
Air Equal Opporruniti-lAffinnative Action Enjplt.,ayer
% recycled l 10% post-consunrer paper
hrtp,-11h2o. enrstate, nc. its

You also have the option of presenting your request to the Committee on Civil Penalty
Remissions, which is comprised of members of the Environmental Management Commission. You
or your representative will be allowed approximately five minutes for your presentation.
representative from the Division of Water Quality will present the ease against remission, The
Committee on Civil Penalty Remissions will render a final atid binding decision in accordance with
If you choose to present your request to the committee, please notify meat the address above
within 30 days of receipt of this later. Your request will he scheduled on the agenda of the next
scheduled committee meeting and you will be :notified of the date and time. If a response is not
received by the Division regarding this notice, your request will be automatically scheduled on the
agenda for an upcoming committee meeting.
Thank you for your attention to this matter. If you would like a receipt that your cheek was
received, plesend it via certified mail. Please contact Steve Lewis at (19) 733-5083, east. 539
if you have any questions.
incerely,
Grey orpe, PI .lax.
cc: D. Rex Gleason. P".E., Mooresville Regional Supervisor
ten Huffman, MRO
Pile # PC 0 w 1
Central Piles

3
<< State of NorthCarolina
Department of Environment AAM
Ak
z and Natural ResourcesA Abe
Division of Water Quality
Michael F.`Easley, Govemor
William G. RossJr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
April 19, 2002
APR 2
MR E TODD CLARK
TOWN OF CATAWBA
PO BOX 70
SUBJECT: Acknowledgment Receipt litter
File No. PC 0 1 -0 1
permit it #t WQ000 11
Catawba County
Dear Mr. Clark. -
This letter is to acknowledge receipt of your check #k 6452 in the amount
$2,233.59, received from the Town of Catawba.
This ;payment satisfies in frill the civil assessment in the amount of $2,23159
levied against the Town of Catawba, and this enforcement case. has been closed. Payment
meat
of these penalties iir no way precludes further action by this Division for future violations.
If you have any questions please call Steve Lewis at (°) 733-5083 Girt. 539.
Sincerely,
0
Steve Lewis
Non -Discharge Compliance & Enforcement
cc; Mooresville Regional Office
Enforcement/Compliance Files ## PC 01- 1:
Central Files
1617 Mail Service Center, Raleigh, Merril Carolina 27699-1617 Telephone [phone]'
FAX 91971 - 049
An Equal Opportunity Affirmative Action Employer % recycled/ 10°r` post -consumer paper

Subject: info for WQ0005114
Date- Fri, 12 Jan 2001 11:06:29 -0500
From- Ellen Huffman <Ellen. Huffinan@,ncrera il.net>
Organization: NC DENR - Mooresville Regional Office
To: Todd Clark - twnCatawba <townofcatawba(a-)twave,net>
BCC- Brian Wrenn <Brian.W'renn@ncmaiLnet,>
Hi Todd,
Here are some good web sites for biosolids.
*DENR, home web page- 11tt J,L_ _ __ _ __
go to water quality section 'then non -discharge for mosolids
info. I
*EPA region 4-biosolids web page
*National Biosolids Partnership web page
*'fraining and Certification web page
application forms for certification can be found here.
NC DENR e-mail addresses you may want to keep handy.
*mine is at the bottom
*Brian Wrenn is the new non -discharge enforcement person is
Raleigh. Any annual report qs can be sent to him or me.
His e-mail is [e-mail]
*for info on land application school schedule you can e-mail Tony floneyetat at
tony.honcycutt@nctnail, net
I -odd, let me know if Kerry (I hope that this is the correct spelling) discovers any other 2000 sludge data
the tab may have on file. He may want to see if he has plant operational data showing MCRT in the
digesters (> 40 days detention at 20 Q to show pathogen reduction for 2000 and option 5 for VAR (table
5-8),
What to do now.
I suggest Kerry check with the lab on any holding/preservation requirement for the tests below (don't
forget Chain of custody for each sample ) and
I- pull a sludge sample for fecal (pathogen reduction)
2- a SOUR test (vector attraction) can be done gUl if the lab is close by. Otherwise you may want to see
if the, lab can do a 30 day bench scale aerobic digestion test - option 3 table 5-8 or see if plant data can be
documented -option 5,
3- pull a sample for 503 metals AND NUTRIFNTS
*you need nutrients to calculate loading rates on the field report.
4- pull a saniple for TCLP for 2001
You also need to get, trucking records for 2000 from Signion.
As you probably already know, , you will be getting a Notice of Violation -with recur on for
enforcement letter from the Mooresville Regional Office for the sludge record keeping and compliance
deficiencies for permit WQ0005114. I will be taking all the mitigating circumstances (we discussed) into
consideration.
I of 2 1/17/200 18:40 AM

IpV
P e mate that Si non Environmental may not know all of the 503 sludge requirements you may
`want to contract with a company who is more familiar with this type of land application recycling. I will
be, contacting Siginon to see if they have anyone who has taken the land aplic tion L classes r i
LA certified..
know 2001 will be a much better year for you at Town ofCatawba!
Ellen Huffman - Ellen. [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. . of Water Quality
919 N. plain Stu
Mooresville, ville, 11
Pli: 704�6611699 Fax: [phone]
NC DENR - Mooresville
Div, of Water Quality
E

Mar— 1 t I
TO
wn of Catawba

NEW-
ppppw- 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 404-56-1-9305.
Sincerely,
Brian L. Wrenn,
Environmental Specialist III
cc: Vince Miller, EPA Region IV
MRO Regional Supervisor
Non Discharge Compliance / Enforcement File
Central Files

� s .. 0
Water Tech tore
pinewood Plaza] Office Box 105
Granite Falls, North Carolina 28630-0040
(7 4) 396-4444
city,..... -Catawba Received—: 1/1 /01 Time: 1 :
45
state. —:NC Zip. . .28609
F i l i .:'f air) of Catawba -Sludge rt ..; 03/05/01
A LA,1 � 1
ys]
:A r i
tr1 i =(-p on
r all Is 1 __s
r
01ltl See Attached //R
REPORTED BY: NC CERTIFIED LA9 60
V6�A L?
r
3> A. Gregg,

0!
Water Tech Laboratories, Inc,
1*5 dlid Plaza, Post Office Box 1056
rani Fat °l a North Carolina28630-0040
'7
Client ;Town of Catawba Collected 01 1 1 'F o Ii * 0
d r..: - 0. Box -10 Sampler Card' Brua0well
Ci,ty.. m ..:Catawba € ec i ed .: 1 ?' 1 / 1 rime: 1 :4
Busts.».,; Zip.-!28609
Facilityw:Town of Catawba- SlUdge Reported,,: t
it ». .,.;
REPORTED BY: NC CERTIFIED LAB # 60
0 6 r'o t? ev C, 4&

P t4
t tt "tatiou;
M s, C, % p
Date Received-
l2 #V l
Report Date:
2-Feb-0I
sample Date.
17-Jui-O I
13RL
-20 1-0077
Lab Sarnple IM.
t_ I -` 001-003
Client Sample 3 :
Catawba gludge
rtttr eResult
NIOL
Unit
Method
Time
Pato
Analyst
,89
1e3.5
dra tt ti •it
s - 4("Ott3
15+ 28
21-1-1101
'M1 s
1.. si
0.470
674
dry m"" &g
`,a �r�e�-84 -6010
1528
112110
—s
d
3 77
1,31
ratl'
; -84 -€010
1519
M.4101
NS
r
283
3,37
dky jjjt�tVg
SNIV- 46-60io
1312LA
2123/01
MIIIS
1
_ 50
07,4
dfN tart"
SW- -wr,-t=010
]?: Zq,
2V21A)l
NES
4.1
17,09tl
67.-1
dry t,}gi.'t:g
SNV- `1tt-s 0 10
1 .2
,"7 t)
AS S
a"bit
. .
t t'�t' t}► :'%.!.f
W-846-6010
1 V-12
713101
a a�4IR1..,,Ni .
9t3,"P.
6.t1t
11}y.„;riY
6K+-i•3°�i�FM}1.
dlrp"
vr�a: "ljtt
;`r`l;j
Pb
107
674
dry- angAg,
%V-84 - o
15,2
23M
6 6
a1 tttt_tt g
SW- 40- 010
13, 2
2/5)t11
r IRL
sc
Mt
,7
a{. V•1
drµµ,\
- - 6-t+'IIyl°{tlW
1
212 ,101
TLygSy
py
't`••
pt9Pyrirlpp�
qq��'qq;
M]b'4'°ai46-A,Y�ILy
a'?1
A10101
Allki,
RRaF
a�
....tyy
Reported e
C'cat ct ntII �IIt'irttxs
,ts ter*1 ''linjintinj tt.lttti nation L im t ��
li;t 8� here noted.
�;' laaIIStta�•:tfiatr�
t"III°II1tit�tc4t''�t),
�"'
3 r

E
ReceivedDate / /
Lab p t 110518, note sampled1)17/2001
Date t
status ASAP
Blue Ridge Labs P 728-0149 . stew Johnson Q 8- t 1
P.O.
box 7940
cnvi ,
Sludge:
Lai Rgert IL 8M011 Method
216101 13112 Jj
t hereby certify that the ti procedures played are those approved by the
t r to t� a ette r other O H ab M th t` rth anal

WATER TECH LABORATORIES
ppp 5 Pinaw**4
«
Plaza r 4066
Cranito
P.O.CHAIN OF CUSTODY
CLIENT: Town of Catawba PHONE: [phone]
Bim 70 TYPE SAMPLE: Wastewater
Catawba, N 6LOCATIONS:
SAMPLER NAME.
SAMPLE TYPE
SAMPLE COLLECTION CONTAINERS
SAMPLE LOCATION DATE 111 °T T lw i 1 TIC/
ACILtI*Y NAME O GLASS ANALYSIS 011 E
t AR
NC002155421 influent CO'NIPOSUE GLASS
Town of Catawba 1101),T ap °i4,
N"025542 COIMPOSITE GLASS PHENOL, CYANIDE,
ZINC COPPED
RAS1LlTT
` t ITE , c
a A.TF
C OSITE
GRAB PLASTIC �
t= N P i T
GRAB PLASTIC
; r LA
GRAB _ PLASTIC
CONIPOSITE, GLASS
GRAB PLASTIC
V17P TT C LA s �a
tip 7Q_
TINIE. WEIVER DVrE« �
VATS
oo o — B6D,TSS, Conductivity, NfSAS, Color, Alkalinity, CLVI'Turbid'ity
Cool 40C -, pH<2 w/ f QS04- N113, i -1 1 j'KID, Oil & Grease, TOC, COD, hardness,
Pbenalics, T. Phosphorus
Cool 4T — PH<2 w! - Metals except Cr, V
Nme-Chloridc, pH, fluoride
I`i ` t
l -C — Na2S2033 oli f Bacteria: l
? Coo]VC tam, Ascorbic, Acid Cyanide
11
LNIC C- ` II'LT ) LAB 9 50

0
State North r olin
andtt
epartment of Environment
Natural Resources
Division of WaterQuality
Michael F. Easley, Governor
Sherri Evans -Stanton, Acting Secretary
Derr T. Stevens, Director
COMPLIANCE INSPECTION
GENE IM L INFOR AI1 TION
City/Town/Owner: Town of Catawba aunty: Catawba
permit No.: Issuance Date: Dime 5,1997
Last Amended Lute: N/A Expiration Date May l 2002
If applicable SOS` Issuance Date: —N/A Expiration Date: /
Perrnittec Contact: Todd Clark Town M, , Telephone No_ 828-241-2215
ORC Name: .e r x l road °ell "Telephone o.: same
Reason for Inspection
ROUTIN OMPL IT FOLLOW -Hip OTHER
—Collection System _ Spray Irrigation X Sludge —Other
"I"hFi own of Catawba has one wastewater treatment plaint. A plant and field site visit was
performed on January 11, 200 1. Residuals from the plant are lard applied once per year: Sigmon
Environmental is the current hauler, The Town has contracted with Water "tech Labs to by the
C.. The Town will be sending The WWTP ORC to the next Land Application certification
school, The Town Nvas not actively applying at the time of inspection, The site is slightly rolling
d very remote. The 1999 annual report did not include plant monitoring data to confirm;
pathogen reduction requirements.
Is afillow-up inspection necessary __yes X no
Inspectors I amels /Title(s)Ellen Hutitrr / Eny, Technician
Telephone No, 704/663-1699 Fax No. 704/663-6040
Date of Inspection ,Tamar 11 2 1

Presiduals Insaction Check List Pg I
WQ0005114-Town of CataWba
Type, of Residual
X Land Application (class B) __ Distribution and Marketing (class A)
Record Ktt "in
YIN
Copy of current permit available at residual generating site
Current metals and nutrient analysis (see permit for frequency)
TCLP analysis Y SSFA (Standard Soil Fertility Analysis)
Nutrient and metals loading calculations (to determine most limiting parameter) YTD
Hauling records (# gaUton hauled during calendar year to date)
Field loading records Y Field site maps and information
Records of lime purchased
Pathogen & Vector Attraction Reduction
Comrnems:
Pathoeen & Vector Attraction Reduction Records (check which methods apply)
Fecal coliforrn
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)
(6_eornetric mean of 7 saniples/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 n/a Class A lime stabilization n/a,
Volatile solids calculations —
Bench -top aerobic/anaerobic digestion results
PH records for lime stabilization (Class A or B
Treatment (check treatment ty � pe(s) used
X Aerobic digestion n/a Amothermal Thermophilic Aerobic Digestion
tria Anaerobic. digestion Drying beds (may not meet 503's)
n/a Alkaline Stabilization Lime other
Compost (check treatment type used
Windrow n/a Aerated Static Pile n/a In vessel n/a Other n1a

Residuals Inspection Rts. pg 2
WQ0005114-Town of Catawba
IrIpsport No and application activity at time o inspection.
permit in transport vehicle? n/a Spill control plan in transport vehicle? n/a
Does transport vehicle appear robe maintained? n/a
Overation & Maintenance records No land application activity at time Qfins pection,
Calibration records of land application equipment n/a
Condition of land application equipment on site n/a
Storage
Number of days/month storageda, s y
Describe storage
(if more than 2 yrs, does facility have Surface Disposal Permit'?) n/a
Spill control plan on storage site?
]Za Lagoon - Is lagoon lined_
Above ground tank--n/a In ground tank —n/a
Aerated — Mixed — Aerated— Mixed
_nZa Dry � in beds __Concrete storage pads
Samnling
Describe Sampling
Fecal Coliform, metals, and nutrient sampling are taken as grab samples prior to land application in
accordance with the pem-iit and EPA standards. review of the plant monitoring data All lab data
was in order at time of inspection.
Is sampling adequate Y Is sampling representative —Y
Field Site (end, useforclass B bi2j2jjN Field identification
Na land application activity at time of inspection.
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 (if no, improvements recommended)
Rain Gauge on site during application
Comments -
Are there any limiting slopes on fields? Y/N N
—10 % for surface application _I 8% for subsurface application

pppr
Residuals Insptction Res. pg 3.
Q0005 -Town of Catawba
Monitoring ii in pe it; n
gat` rcii it` , location s
Odors/vectors
Odors present no
Vectors present n
Describe any nuisance conditions and any corrective actions needed

Water Tech Laboratories,
Pinewood Plaza, Post Office Box 1056
Granite Falls, North Carolina ¢- 4
(4) -4444
Client :Town of Catawba
Collected 07/1 7/01 Time: 08*00
Address.. : P. 0. Box 70 Sampler Cary Broadwell
i .... s $ Catawba Received. a : 1/1 1 Time: 1 :4
F i l i t .® Tow f Catawba -Sludge Reported..: 0/01
lei ..... : NCO 4
A-1-4
REPORTED BY: NC CERTIFIED LAB # 50
. . t r gg, SUPERVISOR

Water Tech Laboratories, Inc.
6 Pinewood Plaza, Post i Box 1056
Granite Falls, North Carolina 2 6 6-664
704396-4444
Client :Town of Catawba Collected / 18/ 1 Time: 09:0
Address..: P. 0. Box 70 Sampler Crary 6roa w el l
f . , ... , : ataw ba Received..: 01 /18/01 Time: 1 : 4
State....:NC Zip..:28609
Facility:Town of Catawba -Sludge Reported..: 6E 1
ID#__:NC0025542
Analysis =Sample,kraal iAnalY i Resin €1ni�t Date
Fecal Coliform 21,000 /166 ml 61 /18/ 1 JRG
REPORTED BY: NCB CERTIFIED LAB # 50
V&�& q qgq&.
L . A. Gragg, SUPERVISOR

Client
Water Tech Laboratories. Inc.
P. 0. Box 1056
Granite Falls, N. C. 25630
Attention:
s. C, Gragg
bate'. Received:
124/01
Report rate:
27a b-O
Sample after
1 W , -01
1L2001-007
Lab Sample :
L.Sli-2001-OOaS
Client Sample
Catawba Sludgy
Analysis
Analysis
m.
P arar eter
Result t L
UnitMethod
d
Time
Date
Analyst
Ag
8,89 1.35
dry ni /kg
Sid`-946-6010
1528
2/23/01
MLS
Al
10,900 6,74
dry m&'fig
SW-846-601
1 ;25
2/23101
Nus
As
153 6.74
4- m&lg
SW- 46-6[110
i s
2/23/01
ta,
6.470 67.4
dry in&tk
Sty- - 01
1 :2
2/23/01
NIL
d
3,77 1.33
drY nigikg
SW- 46-6010
1 :2
2/23/01
1V11..S
r
28-7 3,37
° aaa
S "- 46-6010
13:28
2/23/01
S
u
200 3.37
d . m
S - 46-601
1518
2/23/01
NILS
%»
5.530 67.E
dry- to
SW-846 010
1518
2/23/0
S
Mg
1090 67.4
dry' tra "kg
SW- 6-6010
1 :25
2/23/01
Cv11..S
3r
L584
drew trt .l1 g
SL'-846-6010
1332
2/ 101
AIRL
Na
22,500 6.74
dry dngg
SW-846-6010
1 -2
2/23/01
MLS
Ni
9: 85 6.74
dry nt , -
S -8 6-6010
13:28
2/,23/61
NILS
Pb
107 6,7
dn' ni&I
SW- 46.6010
15:29
2/23/01
ULS
Se
6,6
dry ttt '
Sty-846-6610
13:32
2/5/01
AIRL
n
377 6,74 74
dry m
SW- 46-6010
1 :2
2/23/01
NILS
tt
112
dr2, mg,k-g
SW-840-7.170
12. +1
2/6/01'
A[R:1
Reported -.
K.S.
heson. S.J.
Johnson
Concentrations aas e laelrao !"I niounnQuantification
Limit except where noted.
ter'
NC Laboratory Certificate No. 27

ANALYTICAL INDUSTRLAL RESEARCH LABORATORIESt INC.
CLEVEIANDt 12
42 4- 6 Fax: 4 4` -7 1
Lab Report 118518 Date Received 2 2
/2001
"ate 1117/2001
Dale Requested 2/9/2001
4 h Status
Blue Ridge s .phone [phone]
Attention: Mi. Steve Johnson s' 2 728- 1 1
Box 2940
Lenoir, NC 28645
Dry i" t' 413,2 13.2000 7470 V 6101 7 e 1 JJD
thy Ott S 46,6 nVfiK9 O 10 V SMI 1132 JJ
1 hereby certify, t the analytical procedures employed are those approved bar the
Environmental t to rn Agency or other applicable methods for these
Siped

WATER TECH LABORATORIES INC.
5 Pinewood Plaza Drive, P.O. Box 10S6
Granite Falls, NC 28630
(828) 3964444
CHAIN OF CUSTODY
CLIENT: Town of Catawba PHONE.- [phone]
P.O. Box 70 TYPE SAMPLE** Wastewater
Catawba, NC 28630 NO. LOCATIONS: I
SAMPLER NAME:
SAMPLE COLLECTIOP
SAMPLE LOCATION __iiA_TE __jEqjE TEIV
FACILITY NAME 0C
Town of Catawba
NCO025542 Influent
Town of Catawba
NC0025542 Effluent
3 ov
COMPOSITE
p
BOD,TSS, N143j FECAL,
GLASS
PHENOL, CYANIDE,
J ZINC COPPER
PRESERVATION:
iry Cool 40C — BOD,TSS, Conductivity, MBAS, Color, Alkalinity, Cr, VIjurbidity
Cool 4'C — pH<2 w/ H.' .1 SO4 - NH3, NO2-NO3, TKN, Oil & Grease, TOC, COD, Hardness,
Phenolics, T. Phosphor -us
Cool 4'C — pH <2 Nv,/ HNO3- Metals except Cr, VI
None -Chloride, pH, Fluoride
OTHER:
VC — 1 2S203 oliform Bacteri NH3
ol
'm
gin. Aso — Cyanide
Cool 4'C — pH >12,,v/Na L Ascorbic Acid
Cool 4*C — PH >9 w/ NaOH, ZnOAc-Sulfide
Per Analyzing Lab — Organic's
Sample —a emperature at Lab ('C)
NC CERTIFIED LAB 41 50

Water Pollution ControlDesignation r
Nvpcsocc
. CAC 1 .k. .
0201
GencrulInformation:
pem,IjEjee OwnerlOfficer Name, j f ata ba l ctd Clark
mailingAddress: o 70, Catawba, N 9
City.Catawba State: Zip:
09
Date: 11/9/00
��r Priority Si :' More ':
toed vita
rmae tw
attach a FacilityInformation:
ge to cc
a Pee wa
Mali r of Catawba P
atllst:
addrear
apiece
t Number". �i �} County.
resent *I .„e .
rya , e EpkRATE M FOR EACHtI
an inj I
e of alit 1a 14
Spray Irrigation
Wastewater Plant Lard Application
it hysla Cite c
ees � "al Sane
1e Collection System
operator in Responsible Clar e:
Printsocial security #
es
certificate Type and Grade. �
Signature:
rk T leplt rye:
��M®tar®w�NMsttaei�ssr�Y�s�rM���s��#s®smw���>.�srf�r•���i�M
Back -UP Operator in Responsible Char :
t l t rrte' t Social Security
y
prin.. Certificate
Certificate Type and Grade:
or% 'eleph ea
Mail qxr fax to: _ WPCSOCC
1618 Mail Service Center
ter
Raleigh, N.C.'fi t- 15
Fax- 991' Y1�

22A
ro
Town oj,- Catawba
June
N, C DFNR
Division of Water Qua-',4
Jkttentiotv IMr. Kevm 11-41. Banctt
1617 NUB Service CMU-7
lWejo, NC Z7699-16!"t
St,TBjL pFRINji,r N L: MRF-R WQOM 5 114
19" *tIINUAL REPORT
Dear Mr. Bamem
As directed, the 'l-Own Of CAtxwba is quinnitting our 1999 -annual r,, for the application
of \vastewater tTeatmen't cesiduak. Please in this report enclosed v,-* .h this letter.
I wuuld like thank you for your coop(,nriots and prAtience as I ha, - rMently assumed the
I � >
position of Town Adininistrator and have had to gather the r vssary infarmidtiQft t,L
complete this repom :rye pkAse fecl free to contact me 241-:1,1215 should
you have -any qucstions.
Oncc again, thank you rur patience.
Sincerely,
Todd Quk
Town Administrator
Xc: Town Administrai ar -
102 F. 3tifhwt, NW P.O. 11" 70 CAthwbs- 286"
Moe: a2g-241-2215 Fax: M241-9W,

WA $$F (14*4)

OEM rem fw OM)

wA
W"4X Techto
p{
i J&C,':,yay
IS' jkI�d"`a'jAi
P.Q.
avosate v 1l R VC 114-16
Oats SaMle
0/ 9
ai/0 / 0
ttwt the Gran
Vate Of UPDXt
Lgh Samplea
60
Parameter
f
ad�1 V' T40.042
1
Chromium, TCLP
-to, 0,10 aag
MezCUZY, T; ,
0
q p6p
O.1
Silver, TCLV
40.010 l
cacimium, Tot
t 07
1. 1 f kg
Co f c
(Cif. )
98.1 "/kg
Rocks m' t
i 3 Y
43. k
stlenium'Tot
1011,417)
.8 rgjkq
.Tot
to I Im
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
APRIL 18, 2000
CERTIFIED MAIL
RETURN RECEIPT REQUSTED
Mitchell Setzer, Mayor
Town of Catawba
P.O. Box 70
Catawba, NC 28609
Dear Mr. 5etzer.-
14y
MOO
oft(
Subject: Notice of Violation and Recommendation for Enforcement
Failure to Submit 1999 Annual Report
Permit No. WQ0005114
Town of Catawba
Land Application of Wastewater Treatment Residuals
Catawba County
The Division of Water Quality is issuing you a Notice of Violation and Recommendation for Enforcement h)T failure
to submit an annual report of Distribution and Marketing activities for the 1999 calendar year. The Division of Water
Quality mailed yc)u a reminder letter, complete with instructions and forms, in December 1999.
The issued permit requires that anannual report of activities be Submitted to the Division of Water Quality on, or before,
March 1, of the following year. The Non -Discharge Compliance / Enforcement Unit has not received your 1999 annual
report.
You must submit tine original and two copies to the letterhead address within 10 days of receipt of this letter, The
tirneliness,and completeness of the response: will be considered in the potential enforcement action, It should be noted
that at violation of the state issued permit for reporting can result in the assessment of civil penalties of tip to $10,000.00
per day for each violation.
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,
If you have any questions regarding this Notice of Violation and Recommendation for Enforcement, please do not
hesitate to call me at 919-733-5083 ext, 529
cc: MTsJWftHuffWtstm Mooresvi1Ie,kegibtWff11c4
Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Technical Assistance and Certification Unit
Central Files
Sincerely,
Pe, It ? 1 o
k�z i/01
Kevin H. Barnett,
Environmental Specialist III
Alaffing Address. Telephone [phone]
1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01,
An Equal Opportunity /A trinarive Action Einployer
50% recycled / 10% post-consuiner paper
hrtp.-IM20, enr.sunenc.us
Location:
-512 N. Salisbury St.
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment
and NaturalResources
Division of Water Quality
Aim amok.,
Michael F. Easley, Governor N%00
William G. Ross Jr., Secretary NORTH CAROLI"'C)XE
Gregory oryC . Thorpe, Ph.D., Acting Director ENVIRONMENT
t
rw..
November 15, 2001
Mr. E. Todd Clary, Town Administrator
Tram of Catawba
PO Box 70
Catawba, NC 28609 WATER QUA, LITY SEC Tiv4-qv;
RE Remission on Request
Town of Catawba
Permit No. WQ0005114
Catawba County
'file PC 01-01
Dear Mr. Clark
This letter is to acknowledge receipt of your request for remission of the civil penalty levied
against the subje-et facility. This request will be reviewed at the net scheduled conference i
January, and you will be notified about the Division's decision concerning remission. if you Have
any questions. please call rase at (91 ) 733- 1 3, ext. 529.
incerel ,
d
BrianL. Wrenn
Non -Discharge Compliance & Enforcement
cc;; Rex Gleason, MRO RegionalSupervisor 7attacbmen
Central Files
File # PC 01-01 i 3 attachments
Mailing Address: Telephone (91,%o 733-5083 Location;
1617 Mail Service Center Fax [phone] N. Salisbury St
Ralciah, North Carolina 27699-1617 State Coarier ##52-01-01 Raleigh, NC 76 -1617'
0% recycled / 10 post -consumer paper
lards;11h o.enr.sgate.tie.as

w�
Joll
*.Town of Catawba
November 8, 2001
Mr. Brian Wrenn
CDENR
,.
DWQ
1617 Mail Service Center � 1 >
Raleigh, I"-11 `
SUBJECT:: f NO. WQ0005114
MITIGATION OF CIVIL PENALTY
Dear _ Wrenn-
1 am writing this letter in reference to the correspondence we recently received frta
Jeffrey 0, Pdtrpart dated October 30, 2001. In response ns to his letter and the civil penalty
of $2,233,59, we hereby submit this letter requesting mitigation ofthe fines levied against
the
The Town ofCatawba acknowledges non-compliance wth Section I-G of the Findings of
Tact as set forth in the "Findings And Decisions And Assessments of Civil Penalties"
statement included with Mr, oupart's letter. The following information is pry, -voided,
however, as you consider our request for mitigation,
1 Immediate fiction V* as Taken To Correct the Violation
Following Ms. Ellen f ff's inspection of January 11, 2001, the Town took
immediate sups to rectify the violations and achieve compliance. Ms. Huffman
was kind enough to provide assistance to ensure we had t en the appropriate
action to avoid further vriolations
f die iolatiaans ere l+til1u11 al In win 1 o iced
The Town employed a part-time Town Administrator, as well as an Operator
Responsible in Charge, when the original permit was issued in 1997. Shorty
thereafter, however, bath persons voluntarily separated their e' ploy ent with the
Town of Catawba andnew personnel were hired. Unfortunately, subsequent
Administrations were unaware of the existence of the permit and operations
*bon "Sw-? 1- 21 Fax.[phone]

pppppp-
continued in a manner believed to ensure the health, safety and welfare of the
public and surrounding environment.
3, The,To t s never As seed lvil penal dr
loltions of the Permit
e State of North Carolinadid not perform u .l inspections following the
issuance of our Permit in 1997. Had these inspections beeh performed and the
problems recognized earlier, the appropriate Administration would have taken
immediate "orgy to gain compliance with the " . Obviously never
happened d penalties have not been imposed.
4Pavment of the Pen ill Not Correct -TheViolation- But Burden Our Aijility
To Comnlv
e violations have been corrected and the payment of a civil penalty will simply
delay our plans to expend ney in the immediate future to ensure continued
milli
Once again, we acknowledge the violations and are making everyeffort to maintain
compliance. Enforcement of this penalty will not "right 7, but hinder our efforts
to achieve a - mutualo we have with DENR to protect the health, safety and welfare o
the people of North Carolina and it's natural resources.
Thank- you for your ons d ation of our request, Please feel Tree to contact me at 828-
241-2215 should you have any questions.
Sincerely,
E. T6dd Clark
Town Administrator
Cc- Tom Jones,Mayor
Town Board ofCommissioners
Torn'Warlick, Town Attorney
Mitchell Setter, NC House of Representatives
town files

STATE OF NORTH CAROLENA ENVIRONMENTAL AGES '' T
COMMISSION
COUNTYOF CATAWBA,
INTHE MATTER OF ASSESS T-R OF RIGHT TO ?`
OF CIVIL E d TIES AGAINST ADNHNISTRATIVE HEARING AND
PERMIT NO. WQ0005114 STIPULATION OF FACTS
FILE NO. PC 01-018
Having been assessed civil penalties totaling '-), for
violations set forth; in the assessment document of the Supervisor of the Non -Discharge
Compliance and Enforcement xtent Unit of the Division of Water Quality dated, _ etober 30. 2001,
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.
This the 8th day of November 2001,
A��
—je
SIGNATURE
DRESS
PO Box 70
Catawba, NC 28609
TELEPHO

State of North Carolina�M
` Department of Environment
and Natural Resources
Division of Water Quality�
Michael . Easley, Governor
William G. Ross Jr., Secretary
Gregory I Thorpe, Ph.D., Acting Director,
{
4%
Mr. E. Todd Clark, Town Administrator : °
Town of Catawba �� � � � F d 2001`
PO Box70 `
Catawba, NC 28609
WATEREMA
ia1 T Ytf
RF Remission Request
Town of Catawba
Ferns t No. WQ0005114
Catawba County
File PC 01-018
Dear Mr. Clark:
This letter is to acknowledge receipt of your rearrest for remission of the civil penalty levied
against the subject facility. This request will be reviewed at the next scheduled conference in
January, and you will be notified about theDivision's decision cone in remission. if you have
any questions. please call rne at t919t 7- CD 3,;ext. 529.
Sincerely.
Brian L. Wrenn
Neon -Discharge Compliance & Enforcement
cc
Ellen Huffman, MRO Regional Office watt ch en1 _
Central Files
File # PC 0 1 -0 18 attachments
Mailing Address Telephone (9,19) 7334083 Location.
1617 Mail Bernice Center Fax [phone] N. Salisbury St..
Raleizh. North Carolina 27699.1617 state COUrieT #52-01-01 Raleigh. NC 276 9-1 17"
An Equal Opportunity lA irtnativ Action t player
50% recYc°ted / 10% post -consumer paper
http://l`12o.enr.state.eic.us

a
0" Town of Catawba
November 8, 2001
. Brian W�renrq
1)V "
117 MaH Service Center r" , ' `i
Raleigh, NC 27699-1617
x
SUWECTPERMIT NO. WQ0005114
MfTIGATIO�4 OF C�IVIL PENALTY
Dear . Vre
I am writing this letter in reference to the correspondence we recently received from Mr.
Jeffrey 0. Poupart dated October 30, 2001. In response to his letter and the civil penalty
of $2,23.3 . 4;9, we hereby submit this letter requesting mitigation of the fines levied against
the Town.
The Town of Catawba acknowledges non-compliance with Section T-G of the Findings of
Fact as set forth in the " indin-s And Decisions And Assessments of Civil Penalties"
statement included with Mr. Poupart's letter. The following information is provided,
however, as you consider our request for mitigation.
I Immediate fiction Was Taken To Correct the Violation
ollo ing Ms. Alen Huff" an's inspection of January 11, 2001, the Town took
immediate steps to rectify the violations and achieve compliance. Ms. Huffirnan
was bind enough to provide assistance to ensure we, had taken the appropriate
action to avoid further violations.
. The Violations Were Not Willfully and Knowinelv Committed
The Town employed a part-time Town Administrator, as well as an Operator
.esponsible, in Charge, when the original permit was issued in 1997. Shortly
thereafter, however, both persons voluntarily separated their employment with the
Torn of Catawba: and new personnel were mired. Unfortunately, subsequent -
Administrations were unaware of the existence of the permit and operations
102 First Street, ?N - P.O. Box 7 - Catawba. NC 28609
Phone: 1- 21 Fax: ? -2 1-

continued in a manner believed to ensure the health, safety and welfare of the
public and surrounding environment.
3. The Town of Catawba Has Never Been Assessed A Civil Pe
Yiolations of -the Permit
The State of North Carolina did not perform annual inspections following the
issuance of our permit in 1997. Had these inspections been performed and the
problems recognized earlier, the appropriate Administration would have taken
immediate action to gain compliance with the permit. Obviously this new
happened and penalties have not been imposed.
4. Pavment of the Penal tv W-U]Not Correct The Violation. But Burden Our Abilfty
jo- Qg-mgply In -The Future
The violations have been corrected and the payment of a civil penalty will simply
delay our plans to expend money in the immediate future to ensure continued
compliance.
Once again, we acknowledge the violations and are making every effort to maintain
compliance. Enforcement of this penalty will not "right a wrong7, but hinder our efforts
to achieve a mutual goal we have with DENR to protect the health, safety and welfare of
the people of North Carolina and it's natural resources.
Thank you for your consideration of our request. Please feel free to contact me at 828-
241-2215 should you have any questions.
Sincerely,
E Clark
To Administrator
Cc: Tom Jones, 'Mayor
Town Board of Commissioners
Tom Warlick, Town Attorney
Mitchell Set ter, NC House of Representatives
town files

T
STATE OF NORTH CAROLLN-A ENVIRONMENTAL MANAGEMENT
SST
COMMISSION
COUNTY OF CATAWBA
IN THE MATTER OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES TIES C ST ADNHNISTRATIVF, HEARING AND
PERMIT NO. WQ0005114 STIPULATION OF FACTS
FILE NO. TIC 1- I S
Having been assessed civil penalties totaling $ for
violations set forth In the assessment document of the Supervisor of the Non -Discharge
Compliance and Enforcement Unit of the Division of Water unity dated, ----__October 30, 200 t
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.
This the 8th day of November 2001.
y
SIGNATURE
U
ADDRESS
PCs Boss. 70
Catawba, NC 28609
TELEPHONE
828- 41- 1

,
a,
State of North Carolina
Department of Environment R 12 2002 4�►
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor SmL6-12100'
William Jr.,Secretary
Gregory J. Thorpe, Ph.D., Acting Director NoRTH CAPOLINA DEPARTMENT OF
March 7, 2002
Mr. E. Todd Clark CERTIFIED MAIL
Town of Catawba RETURN RECEIPT REQUESTED
PO Box 70
Catawba, NC 28609
RE Request for Remission of Civil Penalty
Permit No. WQ0005114
Catawba County
ile No. PC 01-018
Dear Mr. Clary
In accordance with north Carolina General Statute 1 3- 1S. A fj 1 considered the
information n you submitted in support of your request for renussion and did not tired grounds to
modify the civil, penalty assessment of 2,233b q.
There are two options available to you. You may pay the e€veil penalty assessment or you may
present your request for remission to the Committee on Civil penalty Remissions of the
Environmental Management, Commission. If you choose to pay the penalty, please make your check
a ble t ties lie trrrent f draw iroanr r trt a ?wlarural Resources and reference the case number,
Send payment within 30 clads of your receipt of this letter to the attention f:
Mr. Steve Lewis
DWQ
1617 flail Service Center
Raleigh, North Carolina 27699-161
Mailing Address: Telephone (91 ) 733-5083 Location
1617 1wlail Servi e:. Center Fax (91 ) 733.0059 512 N. Salisbury Si,
Raleigh, Nona Carolina 27699-1617 State Courier 52-01-01 Raleigh, NC 276 9-161
An Equal Opportunity 1.4ifirinative Acton Employer
http://lt2o.etrr. tat .ti .cis
I

PPPPP"
You also have the option of presenting your request to the Cormnittee on Civil Penalty
Remissions, which is comprised of hers of the Environmental Management Commission. You
or your representative will be allowed approximately five minutes for your presentation. A
representative from the Division of Water Quality will present the case against remission. The
Committee on Civil Penalty Remissions will render a final and binding decision in accordance with
NCGS 143B-282. I (c).
If you choose to present your request to the committee, please notify me at the address above
within 30 days of receipt of this letter. Your request will be scheduled on the agenda of the next
scheduled co Witte meeting and you will be notified of the date and time. If a response is not
received by the Division regarding this notice, your request will be automatically scheduled on the
agenda for an upcoming committee meeting.
Thank- you for your attention to this matter. If you would like a receipt that your check was
received, please send, it via certified mail. Please contact Steve Lewis at [phone], ext, 539
if you have any questions,
Sincerely,
Greg jg I FOIrTpe, PWD.
cc:,k . Rex Gleason, P.E., Mooresville Regional Supervisor
Ellen Huffman, MRO
File # PC 01-018
Central Files

State of North Cart) n
Department of Envi�,'ronment
and Natxiral Resourres
Division f Water Qun!' ! "y
Nfichael F. Easley, ,-,-,, .
William Jr, r
GregoryActing Director
Octobel'30,2001
Mr. Todd Clark
Town of Catawba
PO Box 70
i`
Catawba, North Caroliti,,+
: Assessment of Civil Penalties for
Violationg of Permit No,,
ii
CatAwbq Coitnty
File No 1- 1
Dear Mr. Clark
This letter ice of a civil Penalty assessed against Town of Catawba in the
amountof $2,213.59 which includes $233.59in investigative costs. Attached is a copy of the
assessment document exi4aming this penalty,
This action was t i'zen under the authority vested in me by delegation provided by the
Secretary ofthe e w t of Environment and NaturalResources and the Director of the
Division f Water Quality. Any continuing violation(s) may be tbc subject of a new edorcement
action, including ddit ion penalty.
Within thirty &s.r,; of receipt of this notice, you must (to one of thefollowing:
I subinit paymento ,
Payment t,l1 ould be made directly to the order of the Department of
PaymentEnviromucut and Nattual Resources (do not Include waiverform).
vkf the, ty will not foreclose furdwr enforcement action for
tly continuing or n w vi l tiou s .
1617 dear Strvitr Cent 1919) 733-0059 512 N_ SaUsbury St,
RAIrigh, North Cwohnx 27609_1 17 State 1 1 Rakigh. NC 27699-1617
An l Opportunity/ rive Aetion Employer
a
ttp.o. en r.,note, ac.s
dWOO 396VHOSI(I-NON GGN- -6M 10:91 10OZILOICO

F. Permit OP11 tiara 11 ': 5, requires that the pormittm maintaindala to verify stabilization and vector
attraction irdacrion of the residual$. The required data is specific to the stabilization process
utili d, Lat should be sufficicnt to clearly demonsTTare compliancewith the Class s A pathogen
requiremepts,in 40 CFk P s 21'a1 of with the Class la pathogen a uirc site
etion.�, in 40 CPR Part 50132tbi, and tarts* of the vector attraction requimnonts in
Pan 0133 GOn �
Januaty 11, 2001 DWQ staff from the Mooresville Regional Office performed a routine
inspection of the land application program. The following observed ;tt the inspection:
l . 7,c,,svn of Catawba did not have a certified ORC for the land application system,
. Town of Catawba could not provide tabs for the land application activities that
&z,,,xorod during a calendar 2000.
3. Tc,,vvn of Catawba could not provide Any records p n drat the pathogen reductiara And
°tor attraction reduction requirements had been met.
The t tabs the SWe of the enforcement procedures in this matter to$23159
aced upon the aboveo,pindi:tgs of ract, t aakt� the following-
H. CONCLUSIONS t.ao
A. Town of ;� to a is a "person" within the meaning of , .1 -21 . A pursuant to G.. 1 -
2121.
permit f ! a land application of wastewater residuals systems is required by 1 . 14 -211_ 1.
C. Town of ntawvha violated Permit Condition 1. 9. of the issued pormit by failing to employ An
ORC for fiat: land application prosararn.
D. Town of Catawba violated Permit Condition M. 2. of the issued Permit by failing to aihtain
proper r (,ails tracking all applicationvibes.
. Town of Calawba Yiolalcd Permit Condition M. 5, of theissued permit by flailingto maintain data
to demonsv-ate compliance with, Part 503 pathogen reduction and vector auraction
reduction r-quirements.
F. Town of Cat.,iwtur may be assessed civil penalties its this matter pursunt to G.S, 143,
21 .6 ai(2), which provides that a civil PenalrY Of not more, than thousand do 1 , )
per Violati�n may be assessed.
® The t ctiformtoent costs in is inatier may be messed against Town of Catawba pursuant to
G.S. 14 -21 , laifpl and G.S. 1 .13-282.1(b),i.
H. o yap i,�or,of the - , Compliance. nfo dt Unit of Division ofWater
Quality, mu to delegation provided by the Secretary of the Department of 'Environment and
Natural Re5coirccs and the Director of the Division of Water Quality, has the authority to assess civil
penalties its this matter.
H - tat 0 0 -C -1 10t T' 10OZ/ 0/ t

i'l ice of Administrative
0,14 Mail Service Center
R,tleigh, North Carolina-1
Mail cx &Uid-dcliver a Copy of the tit t
f-
:"
00"ice of General Counsel
11()1 Mail Service Center
Ralcigh, NC 27699-1601
Failure to exerci&,ol,e of the options above within: days, as evidenced by a daft
stamp (not a postmark)dicating when we received your response, will result in this matter
being fern to the t u.e e General's Office with a rNuest to initiate a civil action
e Penalty. Please be adA,i diti n assessments levied for future violations
which occur after the revicw periodf this assessment.
IT you have qnr s , 1 e contact 19) 733-5083, ext. 529 or
Since
Jeffrey 0. Poupart
ATTACHNMNTS
ees Rey Gleason, Wilmington Water Qualityi Supervisor wl attachments
Ellen, MR0 V attachments
Central Fib attach
Ernie Seneca, Publicnfc tt v is
t- -CEO.- t:t TOOV

STATE OF NORTH CAI?,�')LINA ENVIPONNMNTAL MANAGEMENT
COMMISSION
COUNTY OF CATAWBA
IN THE MATItg OF ASSESSMENT WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES Af)AINST ADN911-UTRATIVE HEAPING AND
PERMrr . WQ000511.E STIPULATION OF FACTS
F ~ No. PC 0 t- 1
Having been assess d civil penalties totaling
violation(s) as set foA in 0 ie; assessment document of the Supervisor of the Non-Discharg
Compliance ad Fuf ,)rnt Unit of the Division of Water Quality dated, t a ;M1
the undcrsiped, desixing to s=kmission of the civil penalties, does hereby waive the right to an
administrative, hearing its above -stated matt r and does stipulate the facts am as alleged in the
assessment document.
This the _ day of 2001.
SIGNATURE
ADDRESS
TELEPHONE
39' ROSIN 6 20 - L- t TO: T T � 6

y STATE Of NORTH CAROLINA
NON -DISCHARGE COMP PAGE 04
NORTH
DEPARTMENT OF
AND NIATURAL RESOURCES
IN THE MATTER OF:
TOWNOFCATAWBA
FOR MLATJONS OF FM, 10 IONS
NON -DISCHARGE AND ASSESSMENT OF
N. WQ0005114 CIVILPENALMS
Acting pursuant to delegation provided by the Secretary of the Department t, fBnvjr0maent and Nabird Resources
d r of the Division of Water Quatity� 1, deffrey O—Poupart, SuPcivisor of the, Non -Discharge
Comptiance and Enforcernent thut of the Division of Water Quality (DWQL make the following.,
f FINDING OF FACT:
A. Town of Catawba is municipality i d nlu of the o North
tyro; .z . f
a Town of Catawba owns, and oporaws a Land Application OfW84OW&W 1103iduals system located
in Catawba County in North Carolina.
C. Towm of Catawba was issued Pernut No- WQ0005 114 on Luo ,1997,>effective June , 1997,
with expiration d June 31, or the o` o�e land application of wastewater
residuals s
DPenuit, ConditConditkin IL 8. requires that upon classillcadoo by the Cerdfication CornoussJon,
Permittee employ a certified land applicationlresiduals oli r"116t to bo in responsible charge )
of the, land application p
Permit Condition u" s that proper records be xu*vatmed by the Parnittee uacking
llead*n aclivities. ThewArds Include, but are, not necessarily limited to the
of the residuals;
. date of residuals applicatiow,
u. lmadoaPf rcsidualsi application site, f1eJd, orzoa
d, xnethod of 'application;
weatlier conditions (sunny, cloudy, raining, etc,);
soil o lti
. type of crop or `crops to eld;
volume ofresiduals €�pp . in out torts/act or kiln i
i d cumulative totals of dry tons/acretons/acre of,rosiduals, annual and cumulativo
pounds/Aoxe of each heavy met (which shall'b-'J�Jude, but not be limited to
cadmium. copper, lead, nickel, and zinc), aumd pounds/acre of plant available
nitro , and 11=11al pounds/Acmof ph('.4sphorua apoed to e It field.

1 1 : 9 19® 3- 0059 NON -DISCHARGE COMP PAGE / 0
PPP'P_
Please submit payment to the attention of.,
Brian Wrenn
NCB
DWQ
1617 Mail Service Center
Raleigh, North Carolina-1 1
DR
2. Submit a Written request for remission or mitigation i uding a detailed
justilicatiou for such requese
request for remissioll or mitigation is limited to consideration f the
reasonableness of the amount of the penalty and is not ilie proper procedure for
contesting the accuracy of any of the statements oo 'r)1ed in the assessment
letter. Because a remission request forecloses opt a of an administrative
hewing, such a request must be accompanied by a Wainer of your right to an
administrative hearing a stipulation that there am too factual r legal issues, in
dispute. You roust execute and return to this office the attached waiver d
stipulation form and a detailed statement which you believe establishes h
e or more of the civil penalty assessment factors in G.& 14 -11,1.
were wrongfully applied to the detriment of the petitioner;
the violator promptly abated continuing enviroumental damage resulting
from e violation;
e the violation was Inadvertent result of an accident;
d the °violator° had been assessed civil penalties for y previous violations;
payment of the civil pcnalty will prevent payint at for the remaining
-necessary remedial ctions:
Pleasesubmit this information to the attention of:
Brianre
NICDENR
DWQ
1617 Mal Service Center
, North Carolina 7 -1 1
rSuhndt a vvrittim request for udmiulstrative ht*Evai'g:'
If you Wish to contest any portion of the civil penalty isles cut, you must
request an administrative hearing. This request must in the form of a written
petition to the Office of Administrative Hearings and tiikil t confornr to ChVwr
150B of the North Carolinaa Statutes, You must file your original petition
with the.

.001 1 , d9 919- - 959 NON -DISCHARGE COW ' PAGE B2YO4
PPPV
ALL . I I Iti•
Accordingly. Town of Catawbais hereby assesses a civil penalty of°
for violating Permit Condit . & by failing to employ land
application/residualsoperator to be in resp i3sible charge'( ) of the land
application prod
for violating e t Condition M.
fall�,AS to maintain p r rmords traQkiug;
all application activities.
for violating Permit Condition e by failfaili ug to maintain data to ntt
compliance,with 40 C17R Put 503 pathogeo reduction ad vector attraction
reduction rdgtt ` nt.
S____133.59 Enforvement costs
.TOTAL AMOUNT
As rcquirtd by 03.14 - 1 � (c), in detenxdr&g the amount of the peralty I have considered the factors listed to
(i) The degree and extern of harm to the natural resources of the State, to the public health, or to
private property resulting from the nl
e duration and gravity of the violations-,
() The effect on ground or surface wAter quantity or quality or voo air qualiT,
) The cost of rectifying the damage;
() The amount of money %avcd by noncompliance;
) Iftether the violations were committed ly or in tlow ly*
) , e Prior recordviolator in complying or Whng to comply 'th proStams over which the
Environmental ern t Commission has regulatory authorit , and
)' The cost to the of the enforcement procedures.
.w
(Date) JCffrMeYdirtp p upervisor
Non -Discharge ompii e and EnfOrcement Unit
Division of Water QwWty

F,
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
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Todd Clark, Town Manager
Town of Cataviba
Post Office Box 70
Catawba, to Carolina 28609
Recommendation for Enforcement
Permit No. WQ0005 114
Town of Catawba Land Application
Program
Catawba County
Dear Mr. Clark:
An annual inspection of the Town's land application permit was conducted on January 11, 2001
by Mrs. Ellen Huffman with this Office. The following violations of Permit Num. her
WQ0005114 were observed:
• Permit Condition 1.10 requires 40 CPS Part 503.32 (b) Class B pathogen and vector
attraction requirements to be net:
• Permit Condition 111. 2. requires proper records betaintained by the Permittee, tracking all
application activities. These records shall include, but are not necessarily limited to, the
following information:
a, source of residuals
b, date of residuals application
c, location of residuals application (site, field, or zone #)
d. method of application
e. weather conditions (sunny, cloudy, raining, etc.)
f soil conditions
g. type of crop or crops to be grown on field
h, volume of residuals applied in gallons/acre, dry tons/acre or kilograms/hectare
i. annual and cumulative totals of dry tons/acre of residuals, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be limited to,
cadmium, copper, lead., nickel, and zinc), annual pounds/acre of plant available
nitrogen (PAN), and annual pounds/acre of phosphorus applied to each field.
1 71 -Raw am -N Am 'W-
NdkTH CAROUNA 06�40*MtNt Or
WIRORMtOT AND� NOURN_ RESOURCES
January 17, 2001

ppppp-*
Page
Notice of Violation and
Recommendation for Enforcement
Permit No. WQ0005114
Permit and tion 111.3 requires that a representative sail sample be conducted on each land
application site in the respectivecalendar year.
The Division n of Water Quality is currentlyreviewing the severity of the noted violations. Prior to
our preparation of an enforcement action, the Town of Catawba may respond to this Notice of
Violation. Your response should include mitigating circumstances for the violations include any
new procedures that will be implemented to prevent any recurrence. Please reference the state issued
permit number when providing your response.
As you may know, the Town of Catawba may be assessed civil penalties in this matter pursuant t
G.S. 1 4- 1 r f a ) which provides that a civil penalty of not more than twenty five thousand
doll : ,f1 .d per violation per day may be assessed against a person who violates any permit
condition, sifacation, standard, limitation, or management practice established pursuant to G.S.
1 T 1 .1, 1 3- 1. or 143- 1.
If you have any questions regarding this Notice of Violation and Recommendation for Enforcement,
please do not hesitate to call Mrs. Huffman or me at 704-663-1699.
ncerely,
w
.mom s,
D. Rex Gleason, P.E.
Mooresville Legion Water Quality Supervisor
cc Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit, Shannon Mohr Thornburg
Mooresville regional Office, Ellen Huffinan
Technical Assistance and Certification Knit
Central Piles

May 22, 2001
MEMORANDUM TO: Jeff Pouparl
FROM: D. Rex Gleason
PREPARED Y Ellen Huffrn r
SUBJECT: Recommendation for Enforcement
Violation of Permit No. WQ0005 114
Town of Catawba
Catawba County, N.C.
Attached is the enforcement report/recommendation concerning violations of the subject
permit, The violations resulted from a routine inspection ofth Town of Catawba's Catawba'lard
application program,
The attached material should be self-explanatory; however, if you have any questions,
please contact Firs. Ellen Huffman or rne,
Attachments
ebhi

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTYOF CATAWBA
File No. IBC
IN THE MATTER, OF
TOWN OF CATAWBA
FOR VIOLATIONS OF PERMIT FINDINGS AND DECISION
NO, WQ00I 114 AND AND
NC S 143- 15.I ) ASSESSMENT OF CIVIL PENALTY
FOR FAILING TO REPORT }
AND OPERATE AN
MAINTAIN ITS LAND
APPLICATION 'ION YST M
Acting pursuant to delegation provided by the Secretary of the Department of Environment and
Natural Resources, I, Derr T. Stevens, Director of the Division ofWater Quality ( Q), make
the following:
1. FINDINGS OF FACT.
A; The Town of Catawba (the Town) is an incorporated municipality organized and existing
under the laws of the State of North Carolina,
On June 5, 1997, DWQ issued eater Quality Permit No. WQ0005114 to the Town for the
operation of the Towvn's wastewater residuals land application program. The residuals
source is the Town of Catawba ' "ATTP. The permitted disposal sites are located. in
Catawba County.
On January 11, 2001 l 'i Q Staff from the Mooresville Regional Office performed a
routine inspection of the lard application program.
1 ,, The Toww°n's permit contains the following relevant conditions.
• Permit Condition 1.10 requires 40 CFR Dart 503.32 (b)Class B pathogen and vector
attraction requirements be met
• Permit Condition 11.8 requires that upon classification, the Perinittee employ a oertified
land application/residuals operator in responsible charge �ORC .
• Permit Condition III. 2 requires that proper records be maintained by the Permittee
tracking all application activities. These records include, but are not necessarily
limited to the following-,
a. source of residuals
b, date of residuals application
e, location of residuals application (site, field.., or- zone

d. method of application
e, weather conditions (sunny, cloudy, raining, etc.)
f. soil conditions
& type of crop or crops to be grown on field
h� volume of residuals applied in gallons/acre, dry tonsfacre, or kilograms/hectare
i, annual and cumulative totals of dry tons acre of residuals, annual and
cumulative pounds/acre, of each heavy metal (which shall include, but not be
limited to cadmium, copper, lead, nickel, and zinc), annual pounds/acre of
plant available nitrogen >(PAN), and annual pounds/acre of phosphorus
applied to each field. The To of Catawba could not provide any loading
data or cumulative totals for land application activities for previous events,
E, The Town was in violation of the following:
Permit Condition 1.10. The Town could not provide any records proving vector
attraction requirements were met.
Permit Condition 11.8. The Town does not have a certified ORC for this permit.
Permit Condition 111,2, The Town could not provide any records for application
activity that occurred during the calendar year 2000.
E A Notice of Violation concerning the (above mentioned) violations was sent to the Town
of Catawba by DWQ's Mooresville Regional Office on January 17,2001.
& The cost to the State of the enforcement procedures in this matter totaled $233.59.
Based upon the above Findings of Fact, I make the following:
11. CONCL-USIONSOF LAW:
A. The Town of Catawba is a "person" within the meaning of G.S.143-215.6A pursuant to
G.S143-212(4).
B. The disposal system cited in Findings of Fact B. above falls within the definition of same
at GS. 14' )-213(10) or G.S. 143-213(17),
CThe Town of Catawba violated G.S. 143-215. I(a)(9) and Part VI, Condition No. 4 of
DWQ Permit No. WQ0005114 by failing to properly operate and maintain a non -
discharge land application system program. (See findings of Fact E for specific
violations),
D. The Town of Catawba may be assessed civil penalties in this matter pursuant to && 143-
21 55,6A(a)(2), which provides that a civil penalty of not more than twenty five thousand
dollars ($25,000) per violation may be assessed,

FINDINGS AND DECISIONS
Town of Catawba
Page 3
E. The State's enforcement costs in this matter may be assessed against the Town pursuant to
&S. 143-215.3(a)(9) and G.S. 143B-282. I (b)(8)
F, The Director of the Division of Water Quality, pursuant to delegation provided by the
Secretary of the Department of Environment and Natural Resources has the authority to
assess civil penalties in this matter.
lll. _DECISION:
Accordingly, the Town of Catawba is hereby assessed a civil penalty of.
$ for failing to comply with Pen -nit Condition 1. 10 which requires 40 CFR
Part 503.32 (b) Class B pathogen and vector attraction requirements be met,
$ for failing to comply with Permit Condition 11.8 which requires the
permittee to employ a certified land application/residuals operator to be in
responsible charge (ORC) of the land appliation program.
for failing to comply with Permit Condition 111. 2, which requires specific
records (stated in the permit) be maintained by the Permittee to track all
application activities.
33.59 Enforcement costs
TOTAL AMOUNT DUE
As required by G.S. 14' )-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) Kerr T, Stevens, Director
Division of Water Quality

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSME NT FACTORS
Type: C on Discharge
Violator: Town of Catawba
Address: Post Office Box 70
Catawba, NC 28609
Facility: Town of atawba's `a ' T
Responsible Official. Mr> Todd Clark
Address: Post Office Box 70
Catawba, NC 28609
RegionalOffice: Mooresville
1.. The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violations:
No harm has been measured or quantified. residuals slid not appear to have entered surface
waters.
4 The duration and gravity of the violations:
The violations occurred For all of the calendar year 2000.
3. The effect on ground or surface water quantity or quality or on airquality:
No effects have been measured. It is unknownwhat effects the violations had on either
groundwater quality or quantity or on air quality.
4. The east of rectifying the damage:
No environmental damage has been established.
. The amount of money saved by noncompliance:
Unknown.

Town of Catawba
Case Assessment Factors
Page Two
. Whether the violations were committed willfully or intentionally:
The Town of Catawba is aware of the requirements of its permit, however, we do not
know if the violations were willfull or intentional.
7. The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatoryauthority:
The Mooresville Regional Office has no record of any previous actions against the Town
of Catawba for violations of its non -discharge permit.
., The cost to the State of the enforcement procedures -
Ellen Huffman Enforcement Preparation:
Environmental Specialist 4 hours @ $20.381-52
Clerical ilingl op ing`:
1 hour 12� II/hr
Water Quality review and Edit:
Regional Supervisor 1 hour { 3.6fhr 39.96
Central Office review and Processing. $100.00
TOTALT OF THE ENFORCEMENT PROCEDURE: $233.59
9. Type of violator and general nature of business (i.e., individual vs. large
corporation)
The Town of Catawba is a small incorporated municipality.
0 Violator's degree of cooperation (including efforts to prevent or restore) or
recalcitrance:
The Town has been cooperative regarding this enforcement case..

Tern of Catawba
Case AssessmentFactors
Page Three
1. Mitigating Circumstances:
This Office is concerned with the past history of the Town'Town's understanding of its non -
discharge e activities, In the past, the Town has not had an employee who is trained in land
application or he can oversee sub -contractor performance. Sid rare Environrnental (the
previous contractor) apparently had no understanding of the permit, Mate regulations, or
Federal regulations.

PPFFF,
CERTIFICATION PAGE
I certify that the information in this report is true to the lest of my knowledge.
Signature of Principal lnvesti ator(s):,- - /
Ellen i f art
r
0 bate

tl J
Town of Catawba
januan, 19, 22001 JIV
NCI)I,',',NR A
Division of Water Quality,
Attention- Mr. 1). Rex Cileason, PY.
919 North Main Street
N—fooresville, N. C. 28113
S UT3J 11' C 1 NOTICE OF VIOLATION
LAND APPLICATION mmmiT #\VQ)0()051 14
Dear Mr. Gleason:
I arn Wnitingdais letter in response t.(,,) the notice of violation datedjanliary 17,200L This
matter is of g ,react concern to me and to the: Town of Cata\vba. Therefore, I would like to
assurc you that Nve are taking immediate action to rectify these issues a,.tnd expect, t(,,)
compliance in the future.
,-V I s I explillried to Ms. Huffman during tier inspection tit miry 11, 2001, the'fo-,xvn Board
of Corrit-nissioners; hired its first Administrator in November of 1998, Obviously, this action
wxs taken to improve public services, direct the future growth of the to-,vti and address the
increasing number of State wand 1'ederal regulations. Unfortunately, numerous staff changes
have cre,,,ited at situation in which this matter was overshadowed by equally important, bur
more, aPparent inatters of public interest. Since n-ty employment in Match of 2000, the staff
and I have diligently tried tca reined y these problems. Despite these circurrist,,inces, we
understand that we are still responsible for ensun'tig cornpliance with our permit.
.At this time, we ask you to consider the fact that we have taken the following action to
achieve compliance. I
1, The Town of C,atavvba has riot land applied sludge thistrionth (January 2001), Upon
the advice of Ms. Huffn-ian, we have toensludge samples this; week. 'Ibese samples
are, currently being tested for "Fecal" and(,"5f11. Metalys". The subsecti.,tent results will
be forwarded to you upon my receipt from the laboratory. XWe ask- that, you consider
theseas valid samples firer the 2000 and 2001 calendar year.
1 A hind application journal has been started this week. The Town of Catwwba will
iretintitin the journal to track all land applicationactivities.
1 ik copy of our permit has been fonvarded to Signton Environmental with
instructions to maintain the pern-tit in the truck that hauls sludge to the application
site, and.
4. A "Iand Application" sigjiand melee gauge have been erected at the apptication site.
102 First Street,, NW - P.O. Box'70 - Catawba, NC 28609
Phone: [phone] Fax: $28-241-9968

DENR
jantrary 19, 20,01
Page
Once a��a n, 1 would like to r n rate the fact that �,� �I� r horn�� c� asses a Civil
u consider and are taking actin stc s tta c(w '
penal x, lcasc bear in mind that it war not u 1 ° t toviolatelaa�t will t� valuable
l
the t. Furthermore, act it cTaalt will �a�at: correct tlae tcal�atour la�a�l xa. lic tic��a
dollars out gar our budget that would othcr�vis be stint to improve
I- ank you for consideringthese circa s'ta aces, lalc<as feel to call sat 1� - � 1 1
should you have any questions or comments.
F. Todd Clark -
Town Administrator
cc. NIagror Tom Jones
Board of commissioner-,
Cary Broaad 'Cll, hlic Workg I)ctor
r(,)N n File