NC0062278_Enforcement_20180418

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NORTH CAROLINA
WHAEL S..REGAN
LI
October 3, 2018
Berkley Oaks, LLC Berkley Oaks, LLB
Sam Misuraca - Manager Deborah Faron - Registered agent
Bl West Eleven Mile Road 3714 Walkers Cove Trail
Royal tali, ME 46Charlotte, NC 28214-3441
SUBJECT. Acknowledgment of Receipt of Payment
Berkley teaks, LLL
Berkley Oaks Mobile florae Park, Gastonia, i
Gaston County
ase;l o. SS- 8 1
Clear .Sir and Madam:
This letter is to acknowledge receipt of check 8561 dated S 1B from Berkley Oaks in the amount of
,BB .BS received on 9/ 18, The balance of the penalty is 2.
This payment satisfies in full the civil penalty assessment for case number SS-2018-0001 and upon check
clearance; this enforcement case will be closed,
Payment of this penalty in no way precludes further action by this Department for continuing or future
violations. you are encouraged to contact Carey Basinger ort ri Tuvla with the Mooresville Regional Office
e
at (704) 6 3-1699 if you creed assistance in achieving compliance at the site.
If you have any questions, please call wren Higgins at 1) -3 30 or me a (91.9) 707-3636,
Sincerely
Shelton Sullivan
401 & Buffer Permitting Branch
cc Corey Basinger ri Tuvia ffi- DWR Mooresville Regional Office
401 & Buffer Permitting Branch— file Copy
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BERKLEY OAKS, L.L.C.
21 West Irevera \tile R mci
af� ,r...t _, ,�,, t .v� ,..ax..
}
A. 0t°"e 4•r.
Karen Higgins
DW - 401 & Buffer Permitting Branch
;12 N. Salisbury Street
l aalci-h, North Raarolinaa 27604
RE: Assessment of Civil Penalties
Berk -ley Oaks.
Berkley Oaks Mobile home lark. Gastonia. NC
Gaston Counts
Case No, SS-20 18-0001
Dear Ms. lliu ins
We are requesting remission of the civil penalties outlined in your Corr°cspondence oty April
1 8> 201 , received in this office. on April 26. 2018. a copy ol'ww=hic:h is aattaached, based on the
I,- % e k,werc advised by our ORC that the dischargoe was the result ofleakage fl'oaaa a pipe
which cracked due to extremely frigid weather, an event wwc consider the equ'waalent
ol`aan accident and inadvertent on our part.
2. As soon as we becarne aware of the problem. we promptly tly: engaged as contractor tr-akctor to
take all action necessary to remove the sewage sludge. imposing no Iinartaation on the
contractor whatsoever.
3, When it became apparent that the first contractor could not der the: work as quicklw as
we, required, we engaged an additional contractor to work side Iby side �vith flee lirsi
contractor, Ultimately the sewage sludge wwaas removed as noted in the attached
Findings of Fact
4, In all wa=e incurred Dills to remove the sludge in the total amount ol'S537,522, wwlaich
amounts s were immediately paid, an enormous financial burden for as cornp anN, ofour
size.
In addition. we have engaged a contractor to make upgrades to our plant ctlstin�� rare
aaddit onaal 16, trtl. In order to make these payments exceeding $50.000._wa.e wwere
required to borrow outside funds,
6 We acknowledge that this damage is taltitnaatCIV Our r sponsihilitw, but we rwoarld hope
that avatar° actions in dealing with this incident Would incline vou towward remission of
flee civil penalties

tray . 201
Page two
-----------
'rhank you flor your consideration.
Very tru Y(All's.
�atikuc
ccCorey Basinger and Cori Tuvi
Enclosures
Sm

STATE OF NORTH CAitEiLlNA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF A�aTO
IN THE MATTER OF ASSESSMENT WCAI E E RIGHT TO AN
OF CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING AND
Berkley Oaks, LLB STIPULATION OF FACTS
CASE NO.— SS-2018-0001
Having been assessed civil penalties totaling; . forviolation(s) as set forth in the
assessment document of the Director of the Division of Water Resources dated Argil 18. 2018, 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 most he submitted to the Director of the Division of Water Resources within thirty (30
calendar days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allowed after thirty ( calendar days from the recent of the civil penalty assessment:
r` day of 4z.
Thisthe 20
SIGNATURE
ADDRESS
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TELEPHONE
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7008 11W 0000 1125134
ROY ( 00111,k
MKIIJAEVS RJ'6AN
I INDA
Berkley Oaks, LLB Berkley Oaks, LLC
Sam Misuraca - Manager Deborah Faron - Registered Agent
821 West Eleven Mile Road 3714 Walkers Cove Trail
Royal Oak, MI 48067 Charlotte, NC 28214-3441
SUBJECT: its SeSSment of it Penalties
Berkley Oaks, LLB
Berkley Oaks Mobile Home Park, Gastonia, NC
Gaston County
Case No. SS-2018-0001
. at
A
Within thirty (30) Calendar days of receipt of this notice, you must do one of the following three options:
1e Submit payment of the penalty, OR
2. File a request for remission of civil penalties, OR
3, File a written petition with the Office of Administrative Hearings.
Failure to exercise one of the above three options within thirty (30) calendar days; of your receipt of
these documents will result In this matter being referred to the Attorney General's Offloe with a request
to In Itlate a civil action to collect the penafty.
Payment should be made to thie order of the D ft e nwrdotneOtal aliiyjgm�
Please include the 1��e NO. � on your Check Or morre* order, Payment of the
kW91rrRcmjrcr,,40 I &
419 $07.6,100 WWW nmattroughty.org
. . .. .. .. .

penalty will not foreclose further enforcement action for any continuing or new violation(s).
Payment must be sent within 30 calendar days of receipt of this notice to the following:
If sending via US Postof Service If sending via delivery service (UPS, FedEx, etc.)
Karen Higgins Karen Higgins
DWR — 401 & Buffer Permitting Branch DWR —Cif. & Buffer Permitting Branch
1617 Mail Service Center 512 N. Salisbury Street
Raleigh, NC 27699-1617 Raleigh, NC 27604
- -1
l earir and ti elation of Each and the ached cation for Remission Re uest" which
should describe whrou helierre.
(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 not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
For this option you must file your request for remission of civil penalties within thirty (30)
calendar days of receipt of this notice. Submit this information to the following:
Jf sending via U.S Postal Service If sending via delivery service (UPS, FedEx, etc,
Karen Higgins Karen Higgins
DWR — 401 & Buffer Permitting Branch DWR — 401 & Buffer Permitting Branch
1617 Mail Service Center 512 N. Salisbury Street
Raleigh, NC 27699-1617 Raleigh, NC 27604
This decision can be contested as provided in General Statute 1508 by filing a written petition for
an administrative hearing to the Office of Administrative Hearings (OAH) within thirty (30)
calendar days of your receipt of this notice.

AffkleY Oak�, UC
Gaston County
Caso No. SS 2018 0001
PagP3 of 3
m;a be obtained
pi
If sending via U.S. PostolService: If sending via delivery service (UPS, FedEx, etc,)
Office o 't Administrative hearings Office of Administrative Hearings
6714 Mail Service Center 1711 New Hope Church Road
Raleigh, NC 27699-6714 Raleigh, NC 27609-6285
One (1) copy of the petition must also be served to the Department of Environmental Quality.,
William F, Lane, General Counsel
Department of Environmental Quality (DEQ)
1601 Mail Service Center
Raleigh, NC 27699-1601
If you have any questions, please see the folio wing,website: hqp' �401-b�uffer- �ermitti�n-jpqVBarn e.
assistance -pro s�e- ngnfanm or contact Shelton Sullivan at [phone] or Karen Higgins at [phone],
Sincerely,
Jeffrey 0. Poupart
Division of Water Resources
ATTACHMENTS
cc: Corey Basinger / Andrew Pitner / Ori Tuvia - DWR Mooresville Regional, ffice — email copy
401 & Buffer Permitting Branch- File Copy

CASE NO. w 0..':
FINDINGS AND DECISION
AND ASSESSMENT OF
CIVIL PENALTIES
Iw FINDING F FACT
A. Berkley Oaks, LLC is responsible for operating a wastewater treatment plant (W (,
which treats the wastewater from Berkley Oaks Mobile le Home e park located off NC
State Road 1112, near Gastonia, in Gaston County, North Carolina,
n January S, 2018, DWR Mooresville Regional Office staff conducted a site inspection
after receiving a complaint call on January 4, 2018. During the inspection, DWR
observed that sewage sludge from the Berkley Oaks WWTP had impacted
approximately 200 linear feet of stream. On January 5, 2018, t7WR notified the
Operator in Responsible Charge (CIRC) and environmental contractor and instructed
them to immediately begin efforts to remove the sewage sludge from the stream.
Cw On January 10, 2018DWR Mooresville Regional Office staff conducted a follow-up
site inspection at the request of the environmental contractor for Berkley Oaks, LLC
and noted that while the cleanup had commenced, the sewage sludge in the stream
had extended to approximately 3,500 linear feet downstream
IJ_ Title 15A north Carolina Administrative Code (hereby known as NCA ( 02B ,0211 (2(
requires that "The waters shall be suitable for aquatic life propagation and
maintenance of biological integrity, wildlife, secondary recreation, and agriculture;
sources of water pollution which preclude any of these uses on either a short-term or
long-term basis shall be considered to be violating a water quality standard."
F. Title 15A INCAC 028.0211 211 (B) states that: "Floating solids, settleable solids, or sludge
deposits: only such amounts attributed to sewage, industrial wastes, or other wastes
as shall not make the water unsafe or unsuitable for aquatic life and wildlife or impair
the waters for any designated uses:

Berkley Oaks, LLC
Gaston County
Page 2 of
F to January 29, 2018,Mooresville Regional Office staff conducted a follow-up site
inspection and observed that the sewage sludge removal had been completed.
n February 2, 2018, the DWR Mooresville Regional Office issued a Notice of Violation
and Recommendation for Enforcement to Berkley Oaks, I.I.C. DWR records indicate
that this Notice of Violation was delivered on February 15, 2018. I_?WR received a
response dated March 15, 2018 from Berkley Oaks LLC.
K The Impacts occurred to an unnamed tributary to McGill Branch, Class C waters,
within the Catawba River Basin.
1, The cost to the State of the enforcementprocedures in this matter totaled 82.85.
Based upon the above Finding of Fact,1 make the following:
11. CONCLUSION OF LAW
A. Berkley teaks, LLC is a "person" within the meaning of G.S. 143-215,6A pursuant to
GS. 143-212: (4),
The unnamed tributary located at the site constitutes waters of the State within the
meaning of G,S. 14 - 2 (6).
C. Berkley Oaks, LLC violated Title 15A NCAC 02B .0211 2 for loss of use of
approximately 200 linear feet of stream.
D1 rkley Oaks LLC violated Title ISA NCAC 028 .0211 (8) by impacting approximately
200 linear feet of stream with sewage sludge deposits:
F. Berkley Oaks, LLC may be assessed civil penalties in this matter pursuant to .5. 143
215.A (a)(1, which provides that a civil penalty of not more than twenty-five
thousand dollars (25, ) per violation per day may be assessed against a person
who violates any classification standard, limitation, or management practice
established pursuant to G,Sw 143-2 .4.1, 14 -214. , or 14 -215w
F. Berkley Oaks LLC may be assessed civil penalties pursuant to �S. 43-215. A (a
which provides that a civil penalty of not more than twenty-five thousand dollars
($25,000,001 per violation per day' may be assessed against a person who violates a
rule of the Commission implementing this Part: Part 2 , of this Article, or G.S. 14
55(k).
C, The State's enforcement cost in this matter may be assessed against Berkley Oaks,
t.CC pursuant to G.S. 48-213 {a}() and G.S. 14B-282..1 lb1(8

H
Jeffrey 0,, Poupart of the Division of Water ®• pursuant to delegation
provided by the Secretary of the Department of Environmental CtuallItV and the
Director oftf* Division Of Water Resdurc6s; has the authority to assets civil penalties
in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the follow ing,-
11L DECISION
Accordingly, Berkley Oaks, LLC is hereby assessed a civil penalty of,
for violation of Title 15A NCA(: 028 =0211 (2) for loss of use of
approximately 200 linear feet of stream
iY 000 for violation of Title 15A NCAC 028 .0211 (8) by impacting
approximately 200 linear feet of stream with sewage sludge deposits
0 -0 TOTAL CIVIL PENALTY, authorized by G.S. 143-215,6A
1�982.85< Enforcement Cost
TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of penalty, I considered the factors
set out in G.S. 1438-282,1(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 Jeffrey 0, Poupart
Division of Water Resources

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August 21, 2018
ERT"IFIEII MAIL E—RTIFIED MAIL
RETURN RECEIPT REQUESTED RETURN RECEIPT REQUESTED
7003 2260 0005 5380 5541 d 2260 0005 5380 5558
Berkley Oaks, LLB Berkley Oaks, LLB
Sam Misuraca - Manager Deborah Earon - Registered Agent
82 est Eleven'Mile Road 3714 Walkers Cove Trail
Royal Oak, MI48067 Charlotte, NC 28214- 44
Subject: Request for.. emission of Civil Penalty
Berkley Oaks, LLB
Case No. SS-2018-0001
Gaston County
Dear Sir andMadam:
in accordance with North Carolina General Statute 14 -21 .6A (f) and delegation provided by the
.Secretary of the Department of Environmental Quality (DE and the Director of the Division of Water
Resources D R , 1, Jeffrey 0, P upart, have considered the information you .submitted in support of
your request for remission and hereby remit $2,000.00 of the $4,982.85 civil penalty assessment, The
revised civil penalty Is therefore a total amount of $2,982.85, which includes $982.85-in investigative
costs.
There are two options available to you;
1) you may pay the penalty:.
If you decide to pay the penalty at this stage of the remission process, please make your check
a able to the Department of Environmental Quality (DEQ). Send the payment within hin thirty ( 8
calendar days of your receipt of this letter to the following:
If sending via US Postal Service If sending via delivery service (UPS, FedFedEx, etc.)
Karen Higgins Karen Higgins
R — 401 & Buffer Permitting Branch DWR — 401 & Buffer Permitting Branch
1617 Mail Service Center 512 N. .Salisbury Street
Raleigh, NC 276 5-1617 Raleigh, NC 27604
North CarOrra Department of EnvirDninerital full � Division of eater Resources
12 Nonh Salisbulry Street 11617 Mail Service center I Raleigh, North Carolina 276 -16 7
91 _707, 000

2 of 2
OR
2) You may decide to have the Environmental Management Commission's Committee on Civil Penalty
Remissions make the final decision on your remission request.
if payment is not received within 30 calendar days from your receipt of this letter, your request for
remission with supporting documents and the recommendation of the Director of the North
Carolina Division of Water Quality will be delivered to the Committee on Civil Penalty Remissions for
final agency decision.
If you or your representative would like to speak before the Committee, you _roust cony pjgjLand
return the attached form within thirt calertdar da s of recei t of this later, Send the
completed form to,
if sending via US Postal Service if sending vio delivery service (UPS, FedEx, etc.)
Karen Higgins Karen Higgins
DWR — 401 & Buffer Permitting Branch DWR — 401 & Buffer Permitting Branch
1617 Mail Service Center 512 N. Salisbury Street
Raleigh, NC 27699-1617 Raleigh, NC 27604
The Environmental Management Commission (EMC) Chairman will review the supporting
documents and your request for an oral presentation (if you make the request). if the Chairman
determines that there is a compelling reason to require a presentation, you will be notified of when
and where you should appear, if a presentation is not required, the final decision will be based
upon the written record,
Please be advised that the Environmental Management Commission's (EIVIC) Committee on civil
Penalty Remissions will make Its remission decision based on the original assessment amount.
Therefore, the EIVIC may choose to uphold the original penalty amount and offer no remissions,
they may agree with the remission recommendation detailed above, or the penalty amount may
be further remitted.
Thank you for your cooperation in this matter. If you have any questions, please contact Shelton
Sullivan at [phone] or Karen Higgins at [phone],
Sinc rely,
Jeffrey 0
0, Poupart
, Poupart
Division of Water Resources
cc: Corey Basinger/ Ori Tuvia — DWR Mooresville Regional Office
DWR — 401 & Buffer Permitting Branch - File Copy

DIVISION WATER RESOURCES
CIVIL PENALTY E I I FACTORS
Cast Number: - 01 Region: Mooresville County: Gastonia
Assessed Entity: Berkley Oaks, LLC
Whether one or more of the civil penalty assessment factors were wrongly;applied to the
detriment of the petitioner:
OWR contends that the lassessrrment factors were correctly applied,
Whether the violator promptly abated continuing environmental age resulting from the
violation:
d lr R agrees that the sewage sludge was rerrmediated, however, the slow response of the initial
contractor ollowed the initial impact of 200linear et of stream to eartend to approximately 3,500
linear feet of stream.
dWhether the violation was inadvertent or a result of an accident:
DWR agrees that the incident was the result of an accident.
{ ) Whether the violator had been assessed civil penalties for any previous violations:
Berkley Oaks tt C was assessed a penalty on 912212015 forra wastewater limit violation, DWR case
number !. V-2015-0219for $396,: :
e) Whether payment of the civil penalty will prevent payment for the remaining a esse
remedialactions:
DWR understands that that some reduction may encourage Berkley Oaks tLC to complete the
necessary upgrades to achieve compliance.
DECISION (CheckOne)
Request Denied El
Full Remission Retain Enforcement Costs? Yes El No
Partial Remission 2 (Enter Amount Remitted) Retain Enforcement Costs? Yes N
Jeffrey 0. Potmprt Curate
Division of Water Resource

Pr STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF GASTON DWR CASE E® SS-2018-0001
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTIES AGAINST- REQUEST FOR ORAL PRFSENTATION
BERKLEY OAKS, LLC
I hereby request to make an oral presentation before the Environmental Management Commission's Committee On Civil Penalty
Remissions in the matter of the case noted above, In making this request, I assert that I understand all of the following statements:
This request will be reviewed by the Chairman of the Environmental Management Commission and may be either granted
or denied.
Making a presentation will require the presence of myself an&or my representative during a Committee ineeting field in
Raleigh, North Carolina.
resetttation will beitnited to discrtssian of issues d ' arntatioit sub 'tree in rrt on anal remission re uewt, and
because no factual issues are. in dispute, my presentation will be limited to five (5) minutes in length.
etnity Ifyou or ymw representative ivould like to speak befift the Committee, you raost complete and return this fiam within
thirty (30) days of receipt of this letter. I
Depending on your status as an individual, corporation, partnership or municipality, the State Bar's Opinion affects how you may
proceed with your oral presentation. See wNvw,ncbar.com/etbirQ, Authorized Practice, Advisory Opinion 2006-1 and 2007 Formal
Ethics Opinion 3.
If you arc aq-j�n individual �urbusmess o�Aaier and are granted an opportunity to make an oral presentation before the
Committee., then you do not need legal representation before the Committee; however, if you intend on having another
individual speak on your behalf regarding the factual situations, such as an expert, engineer or consultant, then you must
also be present at the meeting in order to avoid violating the State Bar's Opinion on the unauthorized practice of law.
If you are a o a Lion artnershto ar rnuraie l.it and are granted an opportunity to make an oral presentation before
the Committee, then your representative must consider the recent State Bars Opinion and could be considered practicing
law without a license if he or she is not a licensed attorney. Presentation of facts by non -lawyers, is pentrissible.
If you choose to request an oral presentation, please make sure that signatures on the previously submitted Re -mission Request
fornt and this Oral Presentation Request form are: 1) for individuals and business owners, your own signature and 2) for
corporations, partnerships and municipalities, signed by individuals who would not violate the State liar's Opinion on the
unauthorized practice of law,
This the day of —,20—,, SIGNATURE ­
`TITLE (President, Owner, etc;,)
ADDRESS_________
TELEPHONE

En viron mental
Quality
ROY COOPER
MICHAEL S, REGAN
Se tat;
LINDA CULPEPPER
Inter m Director
February 2, 2018
CERTIFIED ANIL # 70151370 0000 2595 7450
RETURN RECEIPT REQIJETED
Mr, Sam Mismaca
Berkley Oaks, LLC
821 West Eleven Mile Road
Royal Jabs, ,Nell 48067
Subject: Notice of ViolationlNotice of Recommendation for Enforcement Action
NOV-2018-SS-000 I
Berkley Oaks WWTP
NPDES Permit No. NCO062278
Gaston County
Dear Mr. Misuraca:
Chapter 143, Article 21 of the North Carolina General Statutes (G.S.) authorizes and directs
the Environmental Management Corrunfission of the Department of Environmental Quality to
protect and preserve the water resources of the State, Ili e Division of Water Resources (DWR)
has the delegated authority to enforce adopted water pollution control rules and regulations.
On January 4, 2018, a complaint was reported to this Office that approximately 200 linear
feet of an unnamed tributary to McGill Branch was impacted due to sewage sludge from the
Berkley Oaks wastewater treatment facility. Mooresville Regional Office (MRO) staff conducted
an initial investigation at the subject site on, January 5, 20t8 and confirmed that the unnamed
tributary to McGill Branch (Class C waters in the Catawba River Basin) had been impacted by
sewage sludge from the Berkley Oaks waste grater treatment facility. Accordingly, the following
violations were note&
1) Sewage sludge (settleable solids) was observed in the unnamed tributary to McGill
Branch (Class C waters in the Catawba River Basin). This cons itit utes a settleable solids
violation. The deposition of sewage sludge (settleable solids) observed in the stream is
a violation of 15A NCAC 211.0211 (8) which states "..floating solids; settleable solids;
sludge deposits: only in such amounts attributable to sewage, industrial wastes or other
wastes as will not make the water unsafe or unsuitablefor aquatic life and wildWe or
imp a ir the j+,a te rs fo r any des ig n a te d uses.
"
Mooresvifie Regional Office
Lmfion: 610 East Center Ave, Suite 301 Mooresville, NC 28116
Phone [phone] k Fax: (704) 663a4O ? Customer Servim 1-877-673-6748
Intemet" WWW,nCWater7Uafi'[y&9

The photographs below, taken on January 5, 2018, document the above noted violations:
NIR0 staff immediately contacted the Operator in Responsible Chiwge (ORC), Mr. Dusty
Metreyeon and the contract operations firm Kace Environmental. MRO staff instructed Mr.
Metreyeon and Kace Environmental staff to make the necessary arrangements to immediately
begin efforts to remove the sewage sludge from the unnamed tributary to McGill Branch,
However, the sexage sludge removal effort did not commence until January 10, 2018. On
January 10, 2018, MRO staff were requested to visit the site by cleanup contractor Stanley
Environmental to provide guidance and direction for the removal efforts, Upon arrival on site,
MRO staff inspected the stream with the Stanley Environmental staff and determined that due to
the delay in commencing the removal efforts, the affected area had increased to a total of nearly
3500 linear feet of strearn. A final follow-up inspection was conducted on Januajfir 29, 2018 by
MR O staff to verify that the sewage sludge removal had been completed,

W" IMMOW "RMNRMMF— -
L-:',�lvironrnt�rt i%zl"'
QUallt',y­
ROY COOPER
Governar
MICHAEL S, REGAN
Secre"a7y
JANDA CULPEPPER
IW0,07 'DO-F, C rop,
The photographs below, taken on Januar-y 10, 2018, document the additional impacted
stream segment,
Please be advised that this letter is a Notice of Violation with a Recommendation for
Enforcement Action, You are requested to respond to dais Notice, in writing, regarding the above
noted violations, within fifteen (15) days of receipt. The response should inclUde all remedial
actions including the specific activities to prevent the recurrence of these violations as well as
detailing the sewage sludge removal efforts that have been completed to date, Failure to respond
and/or failure to resolve the violations could subject you to further action by the Division of Water
Resources. Please be advised that pursuant to G.S. 143-215,6A, a civil penalty of not more than
twenty-five thousand dollars (S"415,000.00) per day, per violation and may be assessed against axw
person who violates or fails to act in accordance with the terms, conditions, or requirements of any
permit issued pursuant to G.S. 143-215, 1,
Should you have arry questions concerningthis Notice, please do not hesitate to
contact Ori Tuvia at (704) or me at (704) _235-2194
Sincerely,
W. Corey Basinger
Regional Supendsor
Mooresville Regional, Office
Division of AX"ater Resources
Cc: NPDES
MIZO Files
Adam Coe (E-copy)
Mooresville Regional Office
Locafion: 610 East Center Ate., Suite 301 Mooresvifle, N C 28115
Phow (7,N) 663-16S9 i Fax: [phone] Customer Servim 1977-6216748
Internet: wwwnwaferquafty,org

BERKLEY OAKS, L.L.C.
ELEVEN MILE MANAGEMENT COMPANY
821 West Eleven Mile Road
Royal Oak, M1 48067
Phone: [phone] * Fax: [phone]
E-Mail; scini@oal,,,,ridgemgt.com
March 15,2018
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
6 10 East Center Avenue, Suite ite 301
Mooresville, NC 28115
RE: Notice of Violation/Notice of Recommendation for Enforcement Action
NOV-2018-SS-0001
Berkley Oaks WWTP
NPDES Permit No. NCO062278
Gaston County
Dear Mr. Basinger:
W
,d e are writing in response to the Nw otice of Violation that as seaon t February 2 . Here at
Eleven Mile Management Company we strive to be stewards of the local environment.
Maintaining compliance with local authorities and regulatory agencies is of the utmost
importance to us and our employees.
We were alerted to the initial sludge spill by Kace Environmental on the evening of January 51.
Knee Environmental, at this time, inspected the plant. The inspection showed clear effluent
exiting the plant and no mechanical problems could be detected at the time of the initial
inspection.
Our contractor, Stanley Environmental, arrived at the spill on the morning of January 8th and
began removal efforts, Removal of sludge from the tributary continued through January 911. Upon
arriving at the site on January I 01h it was noted by lace Environmental that a large pipe had
become frozen, ruptured during the night and determined this to be the source of the spill. lace
Environmental immediately replaced the affected pipe. When the plant was inspected by Gary
Hudson on March 7, he, observed that the detective pipe had been very recently replaced.
Nonetheless, Stanley Environmental continued removal efforts and concluded that longer hoses
and larger capacity trucks would be needed to expedite the clean-up process. We gave immediate
approval to employ whatever resources were necessary to expedite the clean-up. Stanley
procured the necessary equipment, but the speed of clean-up did, not meet our expectation. In
order to expedite the removal process further and ensure that the removal process occurred in a
timely manner, we contacted Bio-Noinic to assist Stanley Environmental,
By,,'Iies,iii,*sewer,'ek,tnm,2018,'wioL,itioiis,'NOV-2018,SS-(1001

On January u 1 " Bio-Nomic arrived on site and began assisting Stanley Environmental in
removing sludge from the tributary. The evening ofJanuary l ' concluded the final stage of the
clean -gip process and restored the tributary.
We hope our efforts to quickly and thoroughly address this incident show our willingness t
cooperate with all regulations. Going forward we will ensure our efforts rt to be prepared for winter
temperaturesand all exposed piping will be properly insulated.
Very truly yours,
r.
ts-uraca,manager
M/
i
}Iperzn'�a•�r,`c+arru"?�1t81viaal�rivas,'NC9�'-2�Pli� �:�at��

BERKLEY OAKS, L.L.C.
1 West F'IScotn Mile Road
RovarlOak, N11 49W,7
E-M ail, Barra €a? g al rr� � rrat t.a part
aw . 201 24; ;.:.2 r
Kaaren Hipg'InS
Dkk'F - 401 & l uffii r Permitting Branch
51 `? N. Salisbury Street
alciuh. P^~ico;tila Carolina 27604
RE: Assessment of Civil Penalties
Berkley Oaks, Lt.(.'
Berkley Oaks Mobile Home Park. Gastonia. NC
Gaston (,ountw
Case No. i -` o I tl-000 1,,'
hear Nis Higgins
We are requesting remission o the civil penalties outlined in your correspondence €:nc ot' Aril
l t3b 201 S. r'c ;ciw ed in this office on April 26, 2018. a copy of wwhic,h is attached, based cwra the
icwlloxw inn
I . We werc advised by our ORC that the discharge was the result of Ie, k ltearrr ra taip
which cracked due to extremely frigid weather. an event we consider the: CgUiwalent
of an accident and inadvertent on our part,
s soon as we hec:arne aware ofthe problern.;cwe promptly engaged ra contractor re)
take all action necessary to remove the serve sludge, irnposine no Brain anion on the
contractor what;€crever. M
*, % "hen it became apparent that the first 'contractor could not do the: work as qrrickl�, rrs
wc. required. we engaged an additional' contractor to wvor•k side h side with the first
contractor. (...litirnately the sewage sludge was removed a,; noted in tine attached
I- indings of Fact,
4In all wVc inCUrred hills to remove the sludge in the total amount ot'$37.522, ww hiclt
amounts ws«'re imincdia rely paid; an e$ ori-n ,ucs' financial harden l'or' a company a+t o'ur
size
In addition. we have engaged aa; contractor to snake upgrades, to our plant costing an
additional $16.700. In order to snake these payments exceeding $50.000, we weer°c
required to bor° cm OUtSi e funds.
6 We ack.noNkled e that this damage is ul intate'y our responsibility. but We wA(Alld hope
that our actions in dealing with this incident would incline YOU tcwwwar-d remission of
the civil penalties,

May 1-4, 2018
Page meo
----------------------
Thank you for your consideration.
Very truJy,vours.
Mm i'suraca
cc: Corey Basinger and Sri Tuvia
sm
Enclosures

STATE OF NORTH C RO INA ENVIRONMENTAL MANAGEMENT
COMMISSION
COUNTY OF GASTON
IN THE MATTER OF ASSESSMENT WAIVER Of RIGHT TO AN
F CIVIL PENALTIES AGAINST ADMINISTRATIVE HEARING AND
Berkley Oaks, LLC STIPULATION OF FACTS
CASE O., SS-2018-0001
Having been assessed civil penalties tctalin for violation(s) as set forth In the
assessment document of the Director of the Division of Water Resources datedApd_j&jQj& the
undersigned, desiring to seep 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 oust be submitted to the Director of the Division of Water Resources within thirty
calendar days of receipt of the civil penalty assessment. No new evidence in support of a remission
request will be allayed after thirty ( calendar days from the receipt of the civil penalty assessment,
a r
This the %2- Y"Ilkl day of 20f
ri
w
NAME (printed)
{
SIGNATURE
DRESS
&X_/
TELEPHONE

Roy c Valli'VR
MKIIAI-IS RI `G A
#3''cPt�'Cax� i #di1:a'#.#I.I'I:i'#I'iFt
Apri# 19, 201
E 1 # # #t ERTIFIEi1 MAIL
REi"LIRI REE'l�`�' RELIES"fEl1 REi 'Rid REEIF'i' R LiES°fEll
Berkley Oaks, LLC Berkley Oaks, LLB
Sawa l lisuraca m Manager Deborah Faron - Registered Agent
$21 West Eleven Mile Road 3714 Walkers Cove Trail
Royal Oak, MI BS Charlotte, NC 2821_4
SUBJECT: Assessment of I penalties
Berkley Oaks„ LLE
Berkley Oaks Mobile Home Park, Gastonia, NC
Gaston County
Case No, SS-2018-
Dear Sir and Madam.
This letter transmits notice of a civil penalty assessed against Berkley Oaks LLC in the amount of
13 m which includes $282.85 in investigative costs. Attached is a copy of the assessment document
explaining this penalty.
This action was taken tender the authority vested in me by delegation provided by the Secretary of the
Department of Environmental Quality (DEQ) and the Director of the Division of Water Resources (DWR).
Any continuing violation(s) may be the subject of a new enforcement action, including an additional
penalty:
Within thirty 0 calendar days of receipt of this notice, you mast do one of the following three options
1. Submit payment of the penalty, OR
. File a request for remission of civil penalties, OR
File a written petition with the Office of Administrative hearings.
Failure to exercise one of the above three options within thirty ( calendar days of your receipt of
these documents 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.
These options are detailed below:
EI tlon t � ScrlFrnt ant rat oft nal
Payment should be made to the order of the artment of nvironr ental uallt ICE
Please include the Vase No. _SS- 018 1 on your check or money order. Payment of the

iierldey Oaks, LLC
Gaston County
Case No. SS-2018-0001
Page 2 013
penalty will not foreclose further enforcement action for any continuing or new violation(s),
Payment must be sent within 30 calendar days of receipt of this notice to the following:
If sending via US Pas tot Service If sending via delivery service (UPS, FedEx, etc.)
Karen Higgins Karen Higgins
DWR — 401 & Buffer Permitting Branch DWR — 401 & Buffer Permitting Branch
1617 Mail Service Center 512 N. Salisbury Street
Raleigh, NC 27699-1617 Raleigh, NC 27604
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 art administrative hearing, such a request
will not be processed wfthout a waWer of your right to an administrative hearing and a
stipulation that there are no factual or legal issues in dispute.
:you west execute and retorts t hip office #h t ; ced '"1�laiv of i ht to art drrriistrative
should describe wwhy,„you live:
(a) one or more of the civil penalty assessment factors in G.S. 143B-2821(bp 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 not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
For this option you must file your request (or remission of civil penalties within thirty (30)
calendar days of receipt of this notice. Submit this information to the following:
If sending via US Postal Service il sending via delivery service (UPS, tedEx, etc,)
Karen Higgins Karen Higgins
DWR — 401 & Buffer Permitting Branch DWR — 401 & Buffer Permitting Branch
1617 Mail Service Center St N. Salisbury Street
Raleigh, NC 27699-1617 Raleigh, NC 27604
1 file WrIIIIiiii I ''IlAitionvulth—
This decision can be contested as provided in General Statute 1508 by filing a written petition for
an administrative hearing to the Office of Administrative Hearings (OAH) within thirty (30)
calendar days of your receipt of this notice.

AP(kWy Oak&, LLC
Gaston County
Case No, SS ZOIS OWI
Page 3 of3
A petition form may be obtained from the OAH at ncoah era or by calling the € «4 d
Clerk's Office at (i 431-3000 for information, A petition is considered filed when the original
and one (1) copy along with any applicable OAFI filing fee is received in the CfAH during normal
office hours (Monday through Friday between 8:00am and 5.'OOPM, excluding official state
holidays). The petition may be faxed to the OAH at 1 31-31 provided the original and one
copy of the petition along with any applicable OAff filing fee is received by the OAH within five l
business clays following the taxed transmission,
Mailing address for the Office of Administrative Hearings;,
If sending via U.S, Postal Service: If sending Brio delivery se ire (UPS, FedIx, etc.. )
Office of Administrative Hearings Office of Administrative Hearings
6714 Mail Service Center 1711 New Hope Church (toad
Raleigh„ NC 6 -6714 Raleigh, IBC27609-6285
One (1) copy of the petition must also be served to the Department of Environmental Cluality
William F. Lane, General Counsel
Department of Environmental Quality (DE )
1 Mail Service Center
Raleigh, NC 76 -1601
The violations addressed by this assessment and any impacts to waters roust be abated and properly
resolved, you are encouraged to contact Ctrl Tuvia with the DWR Mooresville Regional Office at (04)
663-1699 if you need assistance in achieving compliance at the site. Please be advised that additional
assessments may be levied for future, continuing, or other violations beyond the scopeof this specific
assessment.
If you have any questions, please see the following e site: httos` ntlt-buffer rrv�ittin wtpi lie ce.
assistance rp rare or contact Shelton Sullivan at (919( 807-6361 o Karen Higgins at (1) RD -6 D, ��
Sincerely,
Jeffrey Ci, Poupart
Division of Water Resources
ATTACHMENTS
cc; Corey Basinger / Andrew Pitner / E ri Tuvia - DWR; Mooresville Regional Office - email copy
401 & Buffer; Permitting Branch- File Copy

STATE OF NORTH CAROLINA
COUNTY OF GASTON
IN THE MATTER F':
BERK EY OAKS, LLC
FOR VIOLATIONS OF
15A NCAC 028.0211(2) and
15A NCAC 028 .0211(8ll
ActingActIng pursuant to Nort
unart, of the Division
te_ FINDING OF FACT
NORTHAROLINA DEPARTmENT
SE NO. SS-2018-0001
FINDINGS AND DECISION
ARID, ASSESSMENT OF
CIVIL PENALTIES
A. Berkley Oaks, LLC is responsible for operating a wastewater treatment plant ( ),
which treats the wastewater fro
m Berkley ticks Mobile Home lark' locat
ed off NC
State Road 1112, near Gastonia, in Gaston County, [forth Carolina"
B On January 5, 2018, DWR Mooresville Regional Office staff conducted a site inspection
after receiving a complaint call on January 4, 2018. During the inspection, DWR
observed that sewage sludge from the Berkley Oaks WWTP had impacted
approximately 200 linear feet of stream. On January 5, 2018, DWR notified the
Operator in Responsible Charge (IRC) and environmental contractor and instructed
them to immediately begin efforts to rernoe the sewage sludge from the stream,
C. On January 10, 2018, DWR Mooresville Regional Office staff conducted a follow-up
site inspection at the request of the environmental contractor for Berkley Oaks, LLC
and noted that while the cleanup had commenced, the sewage sludge in the stream
had extended to approximately 3,500 linear feet downstream,
D. Title 1 A Forth Carolina Administrative Cade (hereby known as l C) 028 ,0211 (2)
requires that he craters shall be suitable for aquatic life propagation and
maintenance of biological integrity, wildlife, secondary recreation, and agriculture;
sources of water pollution which preclude any of these uses on either a short-term or
long -terra basis shall be considered to be violating a water quality standard,'
E.Title 15A t CAC 028. 211(8l states that: "Floating solids, settleable solids, or sludge
deposits: only such amounts attributed to sewage, industrial wastes, or other wastes
as shall not make the water unsafe or unsuitable for aquatic life and wildlife or Impair
the graters for any designated uses."

BerMeV Oak$, LLC
Gaston CmAntV
Page 2 of I
O8, Mooresville Regional Office staff conducted a foilow�up site
inspection and observed that the sewage sludge removal had been comploted,
H. The impacts occurred to an unnamed tributary to McGill Branch, Class C waters,
within the Catawba River Basin.
1, The cost to the State of the enforcement procedures in this matter totaled �2�85.
Based upon the above Finding of fact, I make the following-
11. CONCLUSION OF LAW
A. Berkley Oaks, LLC is a 'person" within the meaning of G,S. 143-215,6A pursuant to
G-S. 143-212 (4)„
B. The unnamed tributary located at the site constitutes waters of the State within the
meaning of G.S. 143-212 (6).
C. Berkley Oaks, LLC violated Title 15A NCAC 028 .0211 (2) for loss of use of
approximately 200 linear feet of stream.
D: Berkley Oaks, LLC violated Title 15A NCAC 028 M11 (8) by impacting approximately
200 linear feet of stream with sewage sludge deposits.
E, Berkley Oaks, LLC may be assessed civil penalties in this matter pursuant to G,S. 143-
215.6A (a)(1), which provides that a civil penalty of not more than twenty-five
thousand dollars ($25,000) per violation per day may be assessed against a person
who violates any classification, standard, limitation, or management practice
established pursuant to GFS. 143-214.1, 143-214.2, or 143-215,
F. Berkley Oaks, LLC may be assessed civil penalties pursuant to G-S. 143-215.6A �a)(6)
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 a
rule of the Commission implementing this Part, Part 2A of this Article, or G,S, 143-
355(k),
G. The State's enforcement cost in this matter may be assessed against Berkley Oaks,
LLC pursuant to G.S. 143-2153 (a)(9) and G.S. 1438-282.1 (b)(8),

Berkley 0"" arc
Gaston county
Page 3 Or I
Poupart of the OMSiOn Of Water Resources,
provided by the Secretary of the Department
Directorr of
in this thatter,
Based upon the above Findings of Fact and Conclusions of Law, I make the fo lowvin :
III, DECISION
Accordingly, Berkley Oaks, LL : is hereby assessed a civil penalty of
.ate for violation of "title 15A NCAC o (2) for loss of use of
approximately 200 linear feet of stream
000
for violation of Title 15A NCAC 028 ,021 ( by impacting
approximately 200 linear feet of stream with sewage sludge deposits
0Z9TOTAL CIVIL PENALTY, authorized by G.S. T. - 5, A
9 , 5 .Enforcement Cost
�Z TOTAL AMOUNT DUE
s required by G.S. 1 - 15. A(c), in determining the amount of penalty„ I considered the factors
set out in G.S. laid -7 .1(b), which are;
() 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
() The duration and gravity of the violations;
() The effect on ground or surface water quantity or quality or on air quality,
() The cost of rectifying the damage,,
(5) The amount of money saved by noncompliance,
() 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
() The cost to the State of the enforcement procedures
Date �JeffreyOPoupart
Division of Water Resources

ELEVEN MILE
ry I..;I�.MENT .: A,NY
AN Wed
a u
�a.srrp r�``'87 s'�� , t 2,� * F<sm' 28a aka .175
EVOL a
aaa`c Via: 15. 20
4
'A. Owe, Baainger
F( gir?n,ap C£per ra:rsr
%Wn% Rewonal WW"
IN% srott of I ater Ikeh =urea
610 p x"t Center Avenue,_ ""'suit �'Oi
Know Hk. "tid, 28115
: Nmkt of of Recommendation four Enforcement Actin, n
p ter Is � e,� 0wo k �,, A, k 11
NKRIS Pe§k'odt °gtia' (l)(0 278
Cz;.iti= Catiunty,
" v ar `tia rt&'lt p in a'r.sNmw to be Niotic i 3 � ts`dathin that was sent ask F el r&, ary 2:. 11;"r`t" at
Wen a`o-psaa Nlta%iaagetale9as L tray;.. w1, irr„ gar"rai` rtt he ste'ae:arr1s i'sp flraM pt`+.'LL.d �.`k6'a'Ereigrrtie;ar,
�yu�:ktSsE.r'a!?in is<`c$'a'kp5�y„t.:s_e to h ,a.= as <§..9ipa'prlrtCM„ rriai.p raugula3$t'I�t. flcri."rra:ae, la .'a� th aanntn',
w..,,4a ads and uur
,., "ae Wed w the mina€k Mudge a0H by Wc ON fit`atrYy?"wri"a,,rl on th V':;:€ in tsfl�`d➢zui u-*a
Nucc a ttt rr p§bmerrla L at thr, aria2e hispeaed the p1m. Fhe haprt:rlM Anted clear oftluent
,\Ui[xw the pAnt and no p'#'tari:;rx:n l pB`.tbleni'a au's ulk h .ier'&'Cted at Ox" a-n , i;dyf tlw iniTi ad
Spit ' s&'aai,.
j4fi3'oatad.':9tias;". Stanlew «Prx=6k's`;`"sentaL iwrk A 'rr ihw,;pt , o`n tht `" and",
bv'gankmwrFwahnal of t.ytrd?;.a~ pra, m Hw aa°rpa atw3 cs`tE3 inued thriai gh January IF L jst t
arr"it',ti at aaa " "tr KK s7rx .pwrrr§t3 rr i''` it t=a r'rt. °s, by hr C Enironmentud `Mara a 1,irge, pipe tt.k
p=e.'es`#asa, Swem rtr rrir` dA;r$BtaW a%R"Yi#«:rN and doanAned E3"k§'slat he iat'T.i, ,t urc ,;flh gll,U, Kic
Fn"s grttg}>?ae➢oA ar5'ta "P ars la rupl aved the affected d pipe, e, '' Taear the P`Wnt .rw imp'tevaud Q r,tµx%
lhod i wi '*ap.srdi In tYp+tit't°Lesa OEM the spe ecpivr ,, pipe e had been a rt ,t"w.`a`inly fvp l aecd..
,
�`waaSa�'ypac,`�a�.t�,. Rank, p'3<t#rvxaa"§,re€tk%ap a ttEaaBrr§€a`d rela,c*wl ti"prtm s and Ccw1C1t;dvd that lasa`;''
and a 4C er �xap aca a trru&e , &wtdk `v raeea: c ,tt the c lea-aa'0-uj-,t prx,,%xv1,e u, . innt°dmi ,
a lMra . ta; r , wnp to % pwieve'r" t"" mmir't a;s "am r"„s;'aw3ar"t: """ Qqxaliwrp e :;4va1a-Cip1 `�@irrapc.
prr`,:'ti;(tnd the grey es*rr ry egkp meu parr rpw qved 4vkan-up did Etas! ""ne'€ our expt':txia, m In
,'ldcr aaa L:xpwte ,the reinnal r'3rsnew 10her h i 4larurc that rsTka4 t A pmm "isa;aEP'4"p', rra a
Met, Sa"ssar neL " > astarsra wd W- onlia Yts st aniet p"Sa't ai"itRaRara ila p

{
nS,n ?'a3$nina,i ' ;`O'BEanNisSt'iSn sAlth d un sic and Sgan assisling StxnlvE3'E"«SS'a*nGiSental 13s
rea°aao , sludge Rom iffic, tfibwary, Fhe evening of January 121ainchided the Anal stage of Ah
,:i fian.up and the uibtaat°N.
We "aatpe +.`<Sn' e1t+wts to, kjuicklE and .horoousgdil� rSs. E a"#.s, thk incident A'u,'m our %', Wingl;eS" to
s'csiT:k S"3Sa. Ss ah all S`n'gu ain ow` ,.. 4 ➢t P'm T hYt'wSa d vue "in ends@nt'n: mr effora d to bQ pkcp,,,`3rvd for v4 i3i e
3 _a,
n0. ae,�cC:3`ata!aaa� ,561d ,9H eVowd a''pnn,-� �s Ski be t)ak,spefl� S4}Sndlmsz.
Vmrtrtd
Ski

BERKLIAMAKS, La ve
AN WO R'a,w''a? issixa. Road
rvovA a as . Nil }=."
Pho. iei , . f aav �, 18',
t�_�,kxat€� ��.�,..x,�a� aatsxsxaaass� a3s3
eghm_tl Saapoa;iw,"
Did isi,,n of Watei as ..aa
a' D Fan ( F acts° Asm uA Ahe Ali
March 6.2
13crkle,. t Lat s W%% I
WIS PenmW U. MUMPS',
fjt'(aaa3 _*saunt'a
Dear W. HaNdigm,
Wc aaw whing in est`m m 1a, 1t " a. ° 4 o-;€ M m s a.x, a a ."xt =`n �'"�W$a'�.� , 0l tS
s" 8 � €ttlaticx >, ?, � a,,
"'tr1a,..t': our ,..:a'"a i is u) he in 101 cc§aa'",12i,xril.a.:e and io tTa,°3aitc saki, and 0A1a`n.,.tl . the Nc.shwe _ l'
iol "A on, iN „t real henefi° ro us it, an odd son of mv. 1 t%Akve = a, 1mve vione T Y,
am a'h m tea; in ;an, a a t nt tom l^ ' r; i t 'a i ` � iiali �" =a 1 a„`tta�`3 1 '-tYi, t.. aa" € � � ,� � �,'Cs� � °€' `t�' t ',£at
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c trtttit I ti?nw and the in ,.a chA a atgta" M 4 mia:1tC"w* t„ a a e � 1g `
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t.:cdh% Sfi per" `mc d izCvt ax°rag'a as ;r'ed a j the acnahm Win ,and c",aa €g3i.a m a3 M
fkhw y Qating .,la,ziald he xw`tst'avrQ MAa."at wen l I—e the ` tt' 1i €aa IJIQ (flRt.
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thw z.t�e,aetti't't'basin and s,,etta'te%':Ctuat`i AH iwo,t a l�� ''Id ..,isit`a`s6; b'n'atl t'c
xeaitx,ta,A Wi't thes~w.was and t"a"p1sSced \vA £ m, 11"a,.Izcn,a, and raiIin w to ,.rc ata'
a We ",'9"1*a: tiaax.<.`xa s,aa a, 4R t Itse€,.lwr IM R haft'
21 1 At'4`kate " a*+xia""atter "a&"TSMW €O he csa9a3ltta.' mt of the uv at°,rem volt due ta, ,l
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hole in dw 1�l;taa" a 'ia tag°a" k6i3, ; la it t "`air Ic hok in To p x m ind enumv As,
4'attltiitt basin 4:1'.t.x a"a a; P' aat aRi PI"^'',Tuala zhtt$8m., least d lay° ,u.v.v$axin a
xs;leml .at the d8iit crs' a Ptx;it $;71a x,°.;3 Hoc g Owsl&o" a d pE +;
1� t ai'a t"a a a'°"

aeratictn, The JH1'usvr,,, are ARamer tI iratrk- irtO-, prorvrh W at H I he makwed c eh,
in the future.
4 i Bar screen %us Rill AdArk. Bat, scr(�en is tuidemized and i,,i �nstfl'11,�,Wnt U) cawh the
dehris 40 influent rloxi, Screening %,,as obscr, ed in &,m n�tream treaunent unit"', -
( 4"Pher t, tilities 11"Is been ctintractcd Ui replace It! ctirrent iindersized bar wren \k ith
a bar went 4 adeqwue We. Ile OW has retiam cot the debris that ;A as nowd
ckjong dw bar scwo,,
scum twugh "aN ndl and appeared k, collid O\CHIOsk, RCQUId(I h PUJ[11410 ,� e C, ufn
tnwgh nint bc dcqw to enmue prywr loci -- 1he sL'uar, tnoug!h, %kill he inonin,in,!d aird
purnped ,-,hen iwcdcd io prtnent an) PikAhHh) (CoWl",
0) 1R,fle w; neomdap WHAer skAwrq ties not prewnokVo "cre not aikare thn,
i, rqudhu . t cire,\ith opo-ations, k\e eertdnQ. W have sme inWA when the
i,ow I r mwk is pcolmned
SwcoWns 0-00 AWnrer eaq wq woi,king pmTeA, ohmung AmWe na. ostreud
in the clanAr Rotan pign ever. Asawad N; \ Wan cmishy whAmc in Me
clahtlev , Gopher L 1HAWN "HI mInq Ow Ncoadmi chnna NUmner to anum iWit
k,tt prop,.:r 1�% 'A ni the clahtler arid eCficientk tlwatirk..
hiadva. (Ispher " M alai inspect the Nitan pwes tl dkignwe'and rv.,oa�e tht: eibrxion
inue.
FOluentconydic winj% The wwnplu winpaaumc nju�,t
be dmunremed Ar enh QnnNobe sampling exenj t,> hiijt tjje s,,-trnT1L:s "ere
hcog PnTC-,H,,, prck!vxed et I "an or L'clua Ho 6, V I A uN A N'IS I
aprnns Lai 1hernionicor ha v been inmalfod in dw �,01UCIH! eilrnrLk4.
VnInent Jig Quirig wa, Wakh1g. Falum mas-h-vr%,xi t,, he ,czfl,in�2 on ;aid.groun,.d,
I Me Wuon pTe Hn&g has bev�n re"pair-ed an�] no k11"a""r
A WOW iu 0h: diueqer 11yeswu nint he Wxed A larze ckhrk,
Co"'Od ih�� J�,111.1,,�wr
ON Won ronoi, ad th"n the dilglea Acr,
�h? Lkek"aq 60" my Agnso run nqn Rum Q a Omni do., WMW 6, we
Aedro Ah in fliicknes,, tiophcr
repiase V-notdh ',\6r

In zicikm Qn m d Ironed, Jild 10%A PtAwmancc acm; med in the
have a AM begun mikk a imaal Am took vN kh A ipher I dhS,
I he )R( u A Q jjjijj-jr,��j �Jmcs and keep llumc ivowd swine T"ard. " c urc
W"mr adheNnce ot "'ulncfar"e xnd h aw or mi mn phn
reAct, Van
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