NC0068888_Enforcement_20080414

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Civil Penalty Amount • i investigathre Amount ,Legal Cost Interest Amount j Initial Total Amount Due
.., • ,..{*,r ; $141:123,98 $1,789.07 $0.00 $0.00 $142,413.05 l tl
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$95,749,00 $0,00 $95.,749,00 --.' ANNUALLY l ill
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Date Entered !B Paid Date ; Amount Paid Check 0 Payment Category i;Payment Note i Posted By
12131/2014J2:04 PM 12131(2014 $10,00000 072900 CIVIL PENALTY Hudnall,Carolyn M. li
12/31/2018_08;58 AM 12/23/2013 $10,000,00, 70676 CIVIL PENALTY Hudnall,Carolyn M
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ill ' 01/02/2013 01;50 PM 12/31/2012 $10,000,00 068507 CIVIL PENALTY Hudnall,Carolyn M.
Hudnall Carol
4 12/1612011 01:48 PM 12/1612011 $10,000.00 066332PENALTY CIVIL ,Carolyn M.
0j/044011 12:37 PM 12/2E512010 $10,000,00 064400 CIVIL PENALTY Foster,Amanda L
• '. !. 01/04/2011 '1215 PM 06/1412010 $1,289.07 063341 INVESTIGATIVE COST Foster,Amanda L,
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06/14/2010 $4,459,93 063341 CIVIL PENALTY
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Civil Penalty Assessments
(1/2'2 1
, rrr a � 1Penalty Date CI . ateCase Ne
DIVISION OF WATER QUALITY (1)
TOWN OF DALLAS(BY AND 08-002404/14/2008
THROUGH ITS BOARD OF
AL
072900 12231/2014 $10,00D00
Total: $10,000.00
Totals Fos DIV1 1 OF WATERQUALITY' 10
Page 1 of
Pmt t'on 1/212015 7',2 .46 AM

Civil Perialty Assessments
(1 0 )
Grand Total:
Printed on 1/2t2O15 7:29:46 AMw Page 2 of 2

tilichuel F. Easley,Crgvcyncrr
William G, Ross Jr„Secretary
3
. � �M\7 North Carolina Department of Environment and Natural Resources
Q Coleen H.Sullins,Director
Division of'Water Quality
April 14, 2008
CERTIFIED MAIL 7003 0500 0002 6814 4738
RETURN RECEIPT REQUESTED
Mr. Steve Miller, Town Manager
Town of.Dallas
210 North Holland Street '
Dallas, NC 28034
,C D `° ,. R;0
SUBJECT: Assessment of Civil Penalties
NPDES Permit NC0068888
Town of Dallas WWTP
Case Number PC-2008-0024
Gaston County
Dear Mr. Miller:
This letter transmits notice of a civil penalty assessed against the Town of Dallas in the amount of
S141,123.98, including $1,123.98 in enforcement costs.
Attached is a copy of the assessment document explaining this penalty. This action was taken under the
authority vested in me pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources. Any continuing violation(s) may be the subject of a new
enforcement action, including an additional penalty.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural Resources
(do not include waiver forrn). Payment of the penalty will not foreclose further enforcement action for
any continuing or new violation(s). Please submit payment to the attention of:
Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
uM
NcithCarolina
vVaturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1 6 1 7 Phone[phone] Customer Service
Internet, ywxv.ocwateguali _urgg Location' 512 N.Salisbury St. Raleigh,NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer—50%Recycle 1©%Post Consumer Paper

2. Submit a written request for remission including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s)occurred
or the accuracy of any of the factual statements contained in the civil penalty assessment
document. Because a remission request forecloses the option of an administrative hearing, such
a request must be accompanied by a waiver of your right to an administrative hearing and a.
stipulation and agreement that no factual or legal issues are in dispute. Please prepare a detailed
statement that establishes why you believe the civil penalty should be remitted, and submit it to
the Division of Water Quality at the address listed below. in determining whether a remission
request will be approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)
were wrongfully applied to the detriment of the violator;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator has been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all evidence presented in support of yoUr request for remission must be.
submitted in writing. The Director of the Division of the Division of Water Quality will review
your evidence and inform you of his decision in the matter of your remission request. The
response will provide details regarding the case status, directions for payment, and provision for
further appeal of the penalty to the Environmental Management Commission's Committee on
Civil Penalty Remissions (Committee). Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director.
Therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
In order to request remission, you must complete and submit the enclosed "Request for
Remission of Civil Penalties, Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form within thirty (30) days of receipt of this notice. The Division of Water Quality also
requests that you complete and submit the enclosed "Justification for Remission Request." Both
forms should be submitted to the following address:
Point Source Branch
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1.617
OR

3. File a petition for an administrative hearing with the Office of Administrative
Hearings:
If you wish to contest any statement in the attached assessment document you must file.a petition
for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings. You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A petition is considered filed when it is received
in the Office of Administrative Hearings during normal office hours. The Office of
Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m.
and 5:00 p.m., except for official state holidays. The original and one (]) copy of the petition
must be tiled with the Office of Administrative Hearings. The petition may be faxed - provided
the original and one copy of the document is received in the Office of Administrative Hearings
within five (5) business days following the faxed transmission. The mailing address for the
Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Telephone [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Ms. Mary Penny Thompson, Registered Agent
DENR
1601 Mail Service Center
Raleigh, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty(30) days of receipt of this letter, as
evidenced by an internal date/time received stamp (not a postmark), will result in this matter
being referred to the Attorney General's Office for collection of the penalty through a civil
action. Please be advised that additional penalties may be assessed for violations that occur after
the review period of this assessment.
If you have any questions, please contact. Bob Sledge at [phone], extension 547, or via e-
mail at bob.sledge ciAncmail..net.
Sincerely,. .
4„ 751-7
Susan A, Wilson, P.E.
attachments
cc: Mooresville. Regional Office- SWP Section
NPDES Unit- Enforcement File
Central Files

t
STATE OF' RTH CAROLINA DEPARTMENT OFENVIRONMENT
AA NATURAL RESOURCES
S
COUNTY OF GASTON
IN THE MATTER OF ASSFSSNIFTWAIVER OF RIGHT TO AN
OF CIVIC PENALTIES AGAINST I AD: M.INISTRATIVF HEARING AND
TOWN F DALLAS ) STIPULATION OF FACTS
NPDES PERMIT NC0068888
FILE NO. PC-2 C -002
Having been assessed civil penalties totaling I i,I2S. forviolation(s) as set forth in the
assessment document of the Division of Water Quality dated April 14,2008 the undersigned,
desiring to seek remission of the civil penalties,does hereby waive the right to an administrative
hearing in the above-stated matter and does stipulate that the facts are as alleged in the assessment
document.. The undersigned further understands that all evidence presented in support of remission
of this civil penalty must be submitted to the Director of the Division of Water Quality within 30
days of receipt of the notice of assessment. Ne new evidence in support of a remission request will
be allowed after 30 days from the receipt of the notice of assessment.
This the day of '00
BY
ADDRESS
TELEPHONE

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: PC-2008-0024 County: Gaston
Assessed Party: Town of Dallas
Permit Number: NC0068888 Amount Assessed: 5141 ,123.98
Please use this form when requesting remission of this civil penalty. You must also complete the
Request For Remission, Waiver of Right to an Administrative Hearing, and Stipulation of
Facts" form to request remission of this civil penalty. You should attach any documents that
you believe support your request and are necessary for the Director to consider in evaluating
your request for remission. Please be aware that a request for remission is limited to
consideration of the live factors listed below as they may relate to the reasonableness of the
amount of the civil penalty assessed. Requesting remission is not the proper procedure for
contesting whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Pursuant to N.C,G.S. § 143B-282.1(c),
remission of a civil penalty may be granted only when one or more of the following five factors
applies. Please check each factor that you believe applies to your case and provide a detailed
explanation, including copies of supporting documents, as to why the factor applies (attach
additional pages as needed).
(a) one or more of the civil penalty assessment factors in 1\LC,G.S. 143B-282,1(b)
were wrongfully applied to the detriment of the petitioner (the assessment factors are listed in
the civil penalty assessment document);
(b) the violator prom tiv abated continuinc, environmental damacre resultin -from the
violation (i.e., explain the steps that you took to correct the violation and prevent fUture
occurrences):
(c) the violation was inadvertent or a result of an accident (i.e., explain why the
violation was unavoidable or something you could not prevent or prepare for):
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain how payment of the civil penalty will prevent you from performing
the activities necessary to achieve compliance)
EXPLANATION:

STATE OF NORTH CAROLINA NORTH CAROLINA.
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF GASTON File No. PC-2008-0024
IN THE MAHER OF )
THE TOWN OF DALLAS )
) FINDINGS AND DECISIONS
FOR VIOLATIONS OF: ) AND ASSESSMENT OF
NPDES PERMIT NC0068888, ) CIVIL PENALTIES
I5A NCAC 2B .0211(1), AND )
1.5A NCAC 28 .021I(3)(b) )
Acting pursuant to delegation provided by the Secretary of the Department of Environment and,
Natural Resources and the Director of the Division of Water Quality, I, Susan A. Wilson, P.E.,
Supervisor of the NPDES Western Unit of the Division of Water Quality(DWQ) make the.
following:
I. FINDINGS OF FACT:
A. The Town of Dallas is a municipality organized and existing under the laws of the
State of North Carolina.
B. The Town of Dallas operates the 0..6 MGD Dallas Wastewater Treatment Plant
located in the Town of Dallas, in Gaston County, North Carolina.
C. The Town of Dallas was issued NPDES Permit NC0068888 on August 23, 2005
(effective October I, 2005, with an expiration date of January 31, 2010) for the
treatment of wastewater and the discharge of treated wastewater to Dallas Branch,
class C waters of the State in the Catawba River Basin.
D. Part II, Section C. (2.) of the NPDES Permit states, in part, that "The permittee
shall at all times properly operate and maintain all facilities and systems of
•
treatment and control (and related appurtenances) which are installed or used by
the permittee to achieve compliance with the conditions of this,permit.
E. Part II, Section C. (6.) of the NPDES Permit states, in part, that "Solids, sludges
filter backwash or other pollutants removed in the course of treatment or control
of wastewaters shall be'utilized/disposed of in accordance with NCGS 143-215.1
and in a manner such as to prevent any pollutant from such materials from
entering the waters of the State."
F. ! Part II, Section D. of the NPDES permit states, in part, that "Samples
collected and measurements taken, as required herein, shall be characteristic of the
volume and nature of the permitted discharge."

. Town of
PC-200870024, p. 2
G. Part II, Section E. (9.) of the NPDES permit states, in part, that "The Permittee
shall report to the Director or the appropriate Regional Office . „ any of the
following:
a. Any occurrence at the water pollution control facility which results in the
discharge of si'glificant amounts of wastes which are abnormal in quantity or
characteristic .
b. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate wastewater treatment —
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a
by-pass to receiving waters without treatment of all or any portion of the
influent to such station or facility."
H. Part II, Section B. (2.) of the NPDES permit states "The Permittee shall take all
reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human.
health or the environment."
15A NCAC 2B .0211(3)(h) establishes the water quality standard for Dissolved
Oxygen in Class C waters, stating that for non-trout waters, that dissolved oxygen
shall not be less than a daily average of 5.0 .ing/L with a minimum instantaneous
value of not less than 40 mg/L.
J. 15A NCAC 2B .0211(1.) states that best usage for Class C Waters are"aquatic life
propagation and maintenance of biological integrity (including fishing, and fish),
wildlife, secondary recreation, agriculture and any other usage except for primary
recreation or as a source of water supply for drinking, culinary or food processing
purposes."
K. 15A NCAC 2B .0211(2) states that Class C waters "will be suitable for aquatic
life propagation and maintenance of biological integrity (including fishing, and
fish), wildlife, secondary recreation, agrieulture; sources of water pollution which
preclude any of these uses on either a short-term or a long-term basis will be
considered a violation of a water quality standard."
L. On November 8, 2007, Mr. Jim Fisher of the DWQ's 'Intensive Survey Unit
observed scum and sludge in Dallas Branch downstream of the Dallas WWTP. A
report of the observations (including photographs) was forwarded to Surface
Water Protection Section staff of the Mooresville Regional Office on November
20, 2007.

Town of Dallas
PC-2008-0024, p. 3 t
M.. On November 27 and November 28, 2007, staff from DWQ's Mooresville
Regional Office performed an inspection of the Town of Dallas WWTP. The
WWTP was found to be in a serious state of noncompliance due to town
personnel's neglect of operations and maintenance. One half of the WWTP's
treatment capacity had been out of service since August 9, 2007. The remaining
train was overloaded with solids, and solids were being discharged in the effluent.
The effluent was not being disinfected and had not been disinfected for almost
two months. Effluent samples were being manipulated to make the discharge
appear to be in compliance with permit effluent limitations. Photographs were
taken of the observed conditions. A complete description of the conditions
observed at the Dallas WWTP is contained in Attachment A.
N, During the inspection, Dallas Branch was observed to be heavily impacted by the
deposition (4-- 8 inches in depth) of wastewater residual solids for a distance of
approximately 0.5 miles downstream from the discharge point.
O. The dissolved was oxygen concentration in Dallas
yg Branch reduced from 8,96 mg/L
at the WWTP's upstream sampling site to 3.81 mg/L at the downstream sampling
location on November 27,. 2007, On November 28, 2007, the dissolved oxygen
concentration dropped from 11.52 mg/L to 3.51 mg/L between these same two
locations,
P. During the November 27, 2007 inspection, DWQ staff observed evidence of one
overflow of raw sewage from the influent pump station (occurred November 23,
2007) and another overflow of wastewater from the aeration basin, Both spills
reached surface waters (Dallas Branch). Neither spill was reported to DWQ as
required by the terms of the permit.
Q. Since March 2003, the Town of Dallas has been assessed penalties totaling
b
$42,974.00, in the matters of twenty-seven enforcement actions associated with
the performance of the Town of Dallas WWTP and its compliance with the teens
of the NPDES permit.
R. The costs to the State for the investigation and enforcement procedures in this
matter totaled $1,123.98..
Based upon the above Findings of Fact, I make the following:
LI. CONCLUSIONS OF LAW:
A. The Town of Dallas is a "person" within the meaning of G.S. 143-215.6A
pursuant to G.S. 143-212(4).
B. NPDES Permit NC0068888 is required by NCGS 143-215.1.

Town of Dallas
PC-2008-0024,p. 4
C. The conditions within the subject permit regarding the proper operation of the
wastewater treatment plant, removal of solids and sludges, reporting of
noncompliance, representative sampling, and the duty to mitigate are terms,
conditions, or requirements of said pen-nit.
D. Dallas Branch constitutes waters of the State within the meaning of G.S. 143-
215.1(a)(1) pursuant G.S. 143-212(6),
E. 15A NCAC 28 .021 1(1), 15A NCAC 2B .0211(2), and 15A 'NCAC 2B
.0211(3)(b) are water quality standards established pursuant to G.S. 143-214.1.
F. The conditions observed at the Town of Dallas wastewater plant on November 27,
2007 and November 28, 2007 constituted a failure to properly operate and
maintain systems of control, in violation of Part II, Section C. (2,) of NPDES
Permit NC0068888.
G. The Town of Dallas violated Part II, Section C. (6.) of NPDES Permit
NC0068888 for an undetermined period of time before and including November
27, 2007 and November 28, 2007 by failing to properly dispose of solids and by
discharging residual solids into waters of the State.
1 I. The Town of Dallas violated Part II, Section D. (1)of NPDES permit
NC0068888 by manipulating the samples it submitted for analyses to be reported
to demonstrate compliance with permit effluent limitations, thereby not providing
samples representative of the discharge.
I. The Town of Dallas violated Part II, Section E. (9.) of NPDES permit NC0068888
on two occasions by failing to report overflows/spills of wastewater that occurred
on or about November 23,2007 and November 27,, 2007.
J. The Town of Dallas violated Part II, Section B. (2.) of NPDES permit
NC0068888 by failing to take prompt action to correct conditions that allowed the
continuing discharge of under-treated (if not untreated) wastewater to be
discharged to waters of the state,
K. General Statute 143-215.6A (a)(2) provides that a civil penalty of not more than
twenty-five thousand dollars per violation may be assessed against a person who
violates or fails to act in accordance with the terms, conditions, or requirements of
a permit required by G.S. 143-215.1.
L. The Town of Dallas violated 15A NCAC 2B .021 1(1) by discharging undertreated
(if not untreated) wastewater containing high concentrations of residual solids,
creating conditions that removed the best usage from Dallas Branch.

Town of Dallas
PC-2008-0024,p.. 5
The Town of Dallas violated I 5A 'NCAC 2B .0211(3)(0 on two occasions by
creating conditions that caused the dissolved oxygen in Dallas Branch to drop
below 5.0 mgf.L, the dissolved oxygen water quality standard for class C waters.
on November 27. 2007 and November 28, 2007.
N. General Statute 143-21.5.6A(a)(1) provides that a civil penalty of not more than
twenty-five thousand dollars per violation may be assessed against a person who
violates any classification, standard, limitation, or management practice
established pursuant to G.S. 143-214.1.
O. The State's enforcement costs in this matter may be assessed against The Town of
Dallas pursuant to G.S.143-215.3 (a)(9) and G.S. 143.B-282.1(b)(8).
P. Susan A. Wilson, P.E., supervisor of the Western NPDES program, pursuant to
delegation provided by the Secretary of the Department of Environment and
Natural Resources and Director of the Division of Water Quality, has the authority
to assess civil penalties in this matter.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
HI. DECISION:
The Town of Dallas is hereby assessed a civil penalty of:
S coo For violation of Part II, Section C. (2.) of NPDES Permit
NC0068888, by failing to properly operate and maintain the
wastewater treatment plant during an undetermined period
of time before and including November 27 and 28, 2007.
S 2-5- 006 For violation of Part II, Section C. (6.) of NPDES Permit
NC0068888, by permitting residual solids to enter waters of
the State during an undetermined period of time before and
including November 27 and 28, 2007.
S cc For violation of Part II, Section D (1.) of NPDES Permit
NC0068888„ by failing to provide representative sampling
of the discharge from the Town of Dallas WWTP during an
undetermined period of time before November 27, 2007.
S tpoo For violation of Part II, Section B. (2.) of NPDES Permit
NC0068888, by failing to mitigate the conditions that
existed at the Town of Dallas WWTP during an
undetermined period of time before and including
November 27 and 28, 2007.

Town of Dallas
PC-2008-0024,p. 6
S 500 f9 For L of 2 violations of Part 11, Section E. (9.) of
NPDES Permit NC0068888, by fading to report spills of
wastewater that occurred on or about November 23 and 27,
2007.
$ Z.5 coo For violation of 15A 2B .0211(1), the water quality
standard for best usage of Class C waters during an
undetermined period of time before and including
November 27 and 28, 2007.
S /0 000 - For 4 of 2 violations of 15A 2B .021 l(3)(b), the
water quality standard for dissolved oxygen, on November
27 and 28, 2007.
S 4-0, 000 TOTAL CIVIL PENALTY
S 1,123.98 Enforcement Costs
$ 141 I 21 9e. TOTAL AMOUNT DUE
As required by G.S. 143-215.6A(c), in determining the amount of the penalty I have
considered the factors listed in G.S.143B-282.I(b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
(8) The cost to the State of the enforcement procedures.
•
4
(Date) "§i.isart A. Wilson, P.E.
Supervisor,NPDES Western Unit
Division of Water Quality

ATTACHMENT A
Case PC-200E-0024
Town of Dallas WWTP
NPDES Number NCOO69175
Conditions Observed During Inspection Conducted oh November 27 Si. 28, 2007
• One train of the WWTP remained out of service. It had been taken down on August 9, 2007
• The bar screen was inadequately screening debris. Screenings were present throughout the
treatment process.
• Heavy foam was observed throughout the facility and in the receiving stream.
• The aeration basin had a low dissolved oxygen concentration and was covered with thick
foam.
• The secondary clarifier was covered with scum. The depth of the sludge blanket in the
clarifier was 11 feet, almost the depth of the clarifier..
• 2 feet of sludge solids were measured on top of the liquid in the chlorine contact chamber.
• The effluent was receiving no disinfection. The operator reported the chlorine dosing system
had not been used for over two months.
• Digesters for both trains were full, not allowing for the wasting of sludge from the WWTP.
• The last wasting of sludge occurred on September 27, 2007, according to the operator's log.
• Effluent was turbid and exhibited excessive foaming.
• DWQ testing of the effluent yielded the following results:
11127/2007
Fecal conform: >2,000 cfu/100mL (grab sample)
1.1/28/2007
TSS: 1050 mg/L (composite sample)
NH3-N: 28 mg/L(composite sample)
BOD: 430mg1L (composite sample)
Fecal conform: >2,000 chill00mL (grab sample)
• DWQ testing of the receiving stream yielded the following results:
11/2 7/2007 Upstream Downstream.
Dissolved Oxygen 8.96 moll 100 mg/L
11/28/2007 Upstream Downstream
Dissolved Oxygen 11.52 mg/L 3.51 mg/L
Fecal Coliform 290 efu/100 ml >20,000 cfu/100 ml
• Approximately one half mile of stream was impacted on both days of the inspections, with
sludge depths of varying from 4 -8,"

t
ATTACHMENT A (p. 2)
Case PC-2008-0024
Town of Dallas WWTP
NPDES Number NC0069175
Conditions Observed;During Inspection Conducted on November 27 &28, 2007
• An unreported overflow from the aeration basin that reached the facility's storm drain system
was observed.
• Evidence of a second unreported spill of raw wastewater from the influent pump station to
surface waters was observed. The spill occurred on November 23, 2007.
• Neither the Operator in Responsible Charge (ORC), nor the back up ORC visited the WWTP
with the frequency proscribed by state regulations.
• The ORC's visits to the facility from.August 31, 2007 through November 28, 2007 consisted
only of looking at laboratory data. No walk throughs of the WWTP or observations of the
receiving stream occurred.
• The operator log book contained no entries from October 5, 2007 until November 26, 2007
• The facility operator on site told inspectors effluent reporting data had been falsified:
Total Residual Chlorine values were completely fabricated.
Fecal Coliform samples actually contained tap water.
Effluent samples for ammonia were mixed with tap water.
Toxicity samples for August and September actually contained bottled spring water.
NOV-2007-PC-0819 was issued on December 12, 2007, citing the Town of Dallas for violations
observed during the inspection.

,
April 27, 2012
401
Honorable Mayor John Bridgeman & City Council
City of Gastonia
Mayor P.O. Box 1748
Rick Coleman Gastonia, NC 28052
Aldermen
John Beaty
Allen Huggins Re: Town of Dallas Wastewater Treatment Proposal
Scott Martin
Darlene Morrow
Hoyle Withers
Dear Mayor Bridgeman & City Councilors:
Town Manager
Jim Palenick As you all are keenly aware, the challenges facing each of us, as elected officials, are
seemingly becoming more daunting each day. We are collectively charged with the
Town Clerk stewardship of scarce public resources in the most efficient and effective manner possible
Maria Stroupe
and often, in fulfilling our duties, we are left with choices that are both limited and
Town Attorney unpopular. That is why it is truly refreshing when we encounter an opportunity that
Rennie M.Thrower genuinely represents a "win/win"outcome for each prospective party involved—
particularly when the prospective parties are each municipal governments looking to use
Public Works Bill Trudnak citizen-generated revenues to provide and sustain the most basic of public services.
Electrical So, you ask, what "win/win"opportunity and what basic-service provision, (involving
J. Doug Huffman which two municipal governments), am I referring to? Specifically, to the opportunity for
the City of Gastonia to provide/sell ongoing, bulk treatment of wastewater flows
Police Chief generated by the Town of Dallas collection system, via a negotiated, long-term agreement
Gary Buckner whereby the Town of Dallas, in turn, relinquishes its NPDES permit; abandons its
Planning wastewater treatment plant; and becomes a "wholesale" customer to the City of
David Kehler Gastonia/Two Rivers Utility on a guaranteed, pay-for-service, "cost-plus"basis,
Fire Chief More to the point, our proposal is as follows:
Steve Lambert
•Recreation That, the Town of Dallas and City of Gastonia/Two Rivers Utility enter into a
Anne Martin negotiated, long-term (not-less-than Forty (40) years) inter-local Agreement which
incorporates:
Town of Dallas
210 N. Holland St,
Dallas NC 28034 • That, the two municipalities jointly complete the re-opening, re-connection, and
,
re-establishment of the sanitary sewer interconnect line connecting the Dallas
Phone: ,
, collection system to the Long Creek WWTP in Gastonia; with each municipality
704-922-3176 assuming financial responsibility for (whether through its own finances, grants, or
Fax:
704-922-4701 a combination) that portion of the line on its respective side of the metering
Web Page: station; Dallas assuming financial responsibility for purchase of the meter; and,
www,daliasne,net Gastonia/Two Rivers funding the meter pit/station rehabilitation costs..
• That, upon completion of the interconnect line and following execution of the
Inter-local Agreement, Dallas submits a formal request to the NCDENR to
terminate its NPDES Permit No. NC0068888; to thereafter send all untreated,
-4111111.-7. -.
Public nW,S;',7' sanitary sewer flows to the Long Creek WWTP for treatment; and to permanently
OR HO WC WN POW r MOM
abandon and/or remove its wastewater treatment plant.

0
• That, the City of Gastonia/Two Rivers agrees to take and treat all Dallas Town flows, up
to a maximum daily average flow (measured as the average of any 60-consecutive-day
period) of .75 mgd; and a wet-weather(peak) flow (measured as that sustained over any
48-consecutive hour period) of 1.75 mgd; at a "contractual bulk rate" charged to the
Town of Dallas and calculated as:
1.) A rate per 1,000 gallons of flow received and treated, as measured by a properly-
calibrated meter read and recorded daily; and,
2.) Including a component"Base"rate which shall be calculated as the complete, all-
inclusive costs incurred by the City of Gastonia/Two Rivers (including provision for
depreciation and capital reinvestment and replacement per industry standard) to fully
treat the sanitary sewer flow received to then-current Federal and State permitted
standards; plus an additional, component "Return-on-Investment" (ROI) rate which
shall equal fifteen percent (15%) of the then-established "Base" rate—with the
"Base" rate calculated yearly and based upon audited expenditures of the previous
fiscal-year's operational costs; and,
3.) Including a monthly, "readiness-to-serve" charge equal to the then-current
"availability charge" established by Gastonia/Two Rivers for sanitary sewer service
to"outside city" customers based on a ten-inch (10") water line; and,
4.) Including a monthly "customer charge" equal to the then-current "customer charge"
established by Gastonia/Two Rivers for sanitary sewer service to "outside city"
customers.
5.) Such rate shall be contractually established and guaranteed to Dallas and have no
connection to, nor be impacted by, any other established or amended"wholesale"or
contracted rates charged by Gastonia/Two Rivers to any other existing or future
municipal wastewater treatment customer(s).
Now, for the sake of discussion and to serve as illustration, given the terms offered herein, let's
assume the Gastoniarfwo Rivers "all-in" treatment cost is determined to be $2.25/1000 gallons;
and, let's use Dallas' most recent completed year's total treated wastewater flow of 120,404,000
gallons. Under such a scenario, the Town of Dallas would pay Gastonia/Two Rivers:

$270,909.00/year Base Rate Fees ($2.25/1000 @ 120,404)
$40,636.35/year ROI Rate Fees ($r3375/1000 @ 120,404)
$33,487.20/year Readiness-To-Serve Charge ($2,790.60/month @ 12)
$35.52/year Customer Charge ($2.96/month @ 12)
TOTAL: $345,068.07/year
• $345,O68.07 divided by 120,404,000 gallons= $2.87 per 1,000 gallons (net)
Under such scenario, Gastonia/Two Rivers would gain a guaranteed, long-term customer
exceeding$345,000 in new revenues ($40,600 or more of which represents quantifiable, pure
profit); while Dallas would be out of the treatment business permanently and gain equally-
quantifiable cost-effectiveness in comparison to the continued operation of its current, inefficient
WWTP.
Conversely, for each passing day, month, and year that the two governments operate
independently, neither gains the very clear advantages described herein.
The decision will rest with the City of Gastonia. The Town of Dallas, with the support,from the
NCDENR (see attached correspondence) is committed to the proposal and terms provided
herewith. Please note, however, that our individual staff representatives have engaged in
informal discussions regarding these approximate terms and City of Gastonia personnel have
indicated little interest in, or support for any agreement which might be based on an established
cost-plus-return-on-investment basis. Instead, it has been stated to us that.Gastonia would only
entertain a wholesale treatment agreement based on the $3.80 per-1,000 gallon municipal.
wholesale charge that Gastonia is currently assessing against existing contracted customers.
Understand that such a rate, both currently and well into the future, would represent costs to the
Town of Dallas well-in-excess-of current, all-in treatment costs and hence provide nothing,.
either short or long-term, that would be in the Town's interest. From our understanding, when
viewed on a "cost-plus" basis, the current "wholesale rate" maintains an exorbitant and untenable
profit margin—certainly not one that we as stewards of Town resources could willingly accept or
agree to.
In summary, we need to know if Gastonia is interested in entertaining the proposal terms we
have detailed herein and thereby gaining a substantial new profit center for your water/sewer
enterprise fund; or, is the desire to maintain a consistency of rates among all wholesale
customers, as indicated by your staff, the driving force behind your motivations, and therefore an.
immovable obstacle to our further negotiations and partnering. You may wish to keep in mind
that your negotiations today with the Town of Dallas may be a great deal different than past
negotiations with other potential municipal customers facing very different circumstances.

Gastonia has a great deal of excess capacity at Long Creek; the marginal cost of treatment is
relatively low and any substantial increase in new demand is unlikely. This situation is not unlike
the airline industry where airfares are established and the vast majority of passengers on a given
flight have paid the going rate. But since your fixed costs don't change a bit whether the plane
leaves full or with a few empty seats, it's better to get a smaller airfare from those last few
passengers before the plane leaves, than to maintain your pricing structure and"fairness" to the
full-paying passengers, and take off with empty seats and unfulfilled revenues.
To that end, Dallas will remain an "empty seat" under any full fare pricing approach.
We look forward to your prompt reply, and we thank you for your gracious consideration.
Sincerely,
Rick Coleman, Mayor
Town of Dallas
Cc : Board of Aldermen
Jim Palenick, Interim Town Manager
Bill Trudnak, Public Works Director
Pennie Thrower, Town Attorney
Robert Krebs, NCDENR DWQ MRG
Attachments: Feb. 17, 2012 Palenick Letter to Ass't Atty General
April 13, 2012 Response Letter from NCDENR

AVA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild Dee Freeman
Governor Director Secretary
April 13, 2012
Town of Dallas
210 North Holland Street
Dallas, North Carolina 28034
Attention: Jim Palenick
Subject: Town of Dallas
Response to February 17, 2012 Letter
Gaston.County
Dear Mr. Palenick:
The Division of Water Quality(hereafter"the Division") is in receipt of your letter dated
February 17, 2012. In your letter, you requested that the Division consider the recent compliance
history of the Town of Dallas and modify the May 10, 2010 Settlement Agreement. Specifically, your
letter requested foregoing any additional settlement payment installments so that the installments could
be put toward "re-opening and rehabilitation"of the interconnect line to Two Rivers Utilities,
On March 1, 2012, Robert Krebs, with the Division's Mooresville Regional Office, discussed
with you additional details surrounding your February 17, 2012 letter. Mr. Krebs has elevated the topics
of your conversation and I have determined that there is an opportunity to enter into negotiations to meet
a mutually beneficial settlement modification.
The Division is willing to discuss holding the stipulated penalty repayment plan for one year to
allow the Town of Dallas to finalize negotiations with Two Rivers Utilities, complete the sewer
interconnection, and rescind the Town's NPDES wastewater permit. If these conditions are acceptable,
we believe we can move forward to quickly draft a settlement modification.
If you have any questions about our findings, please feel free to call Mr. Krebs at 704-235-2176.
Sincerely,
;‘,,‘2/
Charles Wakild, P.E.
cc: Don Laton, Attorney General's Office
Matt Matthews, DWQ
Robert Krebs, DWQ MRO
1617 Mail Service Center,Raleigh,North Carolina 27699.1617 One
Location:512 N.Salisbury St Raleigh,North Carolina 27604 Nnrt Carolna 1
Phone,919�07#s3©e t FAX:[phone] Naturally
Internet:wv+w newater uali o It `
Ago Equal Opportunity 1 Affirmative Action Employer

ntrl
February 17, 2012
Mayor Mr. Donald W. Laton
Rick Coleman Assistant Attorney General
Aldermen N.C. Department of Justice
John Beaty Environmental Division
Darlene Morrow P.O. Box 629
Allen Huggins Raleigh, NC 27602
Scott Martin
Hoyle Withers
Re: Town of Dallas Settlement Agreement under NPDES Permit# NC0068888
Town Manager
Jim Palenick Dear Mr. Laton:
Town Clerk As you know, the Town of Dallas entered into a Settlement Agreement with your Agency
Maria Stroupe and the Division of Water Quality, in May, 2010, in which it agreed to pay The NCDENR
Town Attorney a total of$101,289.07 in civil fines, penalties, and enforcement costs, over a ten-year
ennie M. Thrower time-period, in satisfaction of certain NPDES Permit violations in 2008 at the Town's
WWTP and involving then-employed Town personnel.
Public Works
Bill Trudnak As further background, and since the time of the last-recorded, WWTP NPDES Permit
Electrical violation in June, 2008, The Town of Dallas has complied with and/or achieved the
1. Doug Huffman following:
Police Chief • Over 40 months of violation-free Plant operations, under the supervision of a
3ary Buckner skilled Operator who is also employed by The City of Gastonia(Two Rivers)
Utility System.
Planning
)avid Kehler
• The "contracting-out" of all Lab services to the City of Gastonia(Two Rivers)
:ire Chief Utility System„
Steve Lambert
recreation
\rine Martin • The timely payment of the first two installments ($21,289.07) of the agreed-upon
"Settlement Amount", leaving $80,000 remaining in (8) further installments.
Fawn of Dallas
ri0 N. Holland St.
• The pursuit of detailed financial and engineering studies to determine the best
Jailas, NC 28034
method for, costs of, and infrastructure improvements associated with the
Phone: Consolidation of the Dallas Sanitary Sewer collection system to the City of
'04-922-3176 Gastonia' (Two Rivers) Long Creek WWTP.
-ax:
'04-922-4701
Web Page: With the aforementioned in mind, it is the considered position of the Town of Dallas that
vwmciallasnc,net we have made, and continue to make every possible good faith effort to fulfill our
Settlement obligations while also pro-actively moving forward with initiatives to assure
the long-term operational quality and success of our Town's Wastewater collection and
treatment system. To that end, the next critical step in the Town's evolution along this
continuum is for the Town of Dallas and City of Gastonia (Two Rivers Utility) to jointly
iblk complete the re-opening, re-connection, and rehabilitation of a sanitary sewer interconnect
HOMITM EMOV PRIMER line connecting the Dallas collection system to the Long Creek WWTP in Gastonia,
---44 ,4111"

In Section "4." Of the Settlement Agreement,the parties agreed that, "The unpaid balance
remaining of the Settlement Amount shall be forgiven by Respondent if prior to January 15,
2019 Petitioner(Town of Dallas) irrevocably conveys ownership and operation of the
WWTP to an unrelated third party,or submits a request to terminate NPDES Permit No.
NC0068888". It would seem that such language clearly contemplated a desire, on behalf of the
Respondent(Attorney General's Office and NCDENR Division of Water Quality) to see the Town of
Dallas, in effect, "get out of the Treatment business"and turn over same to the only likely and
feasible alternative provider-that being the City of Gastonia (Two Rivers Utility).
However, if such action were to ever occur, the first essential step to achievement of same would
be to complete the re-opening and rehabilitation of the interconnect line,which carries with it an
approximate$180,000-$200,000 cost; with approximately$120,000 being the responsibility of
the Town of Dallas.This brings us to the point of this correspondence.
Specifically,The Town of Dallas would like to propose that,rather than making the remaining
S80,000 in Settlement obligation payments in installments over the next(8)years,we instead be
allowed to spend an equal total of$80,000 in productive,real infrastructure improvements toward
the re-opening and rehabilitation of the Wastewater Interconnect line between the Town of Dallas
collection system and the Long Creek wastewater Treatment Plant in the City of Gastonia. We think
an Amendment to the Settlement agreement in this regard would be appropriate and in the interest
of all concerned.
In the alternative,the Town of Dallas will be using its otherwise scarce financial resources in
punitive payments to the NCDENR rather than toward the sustainable upgrade of the infrastructure
systems which might better assure continuing compliance over the long-term.
I thank you for your gracious attention to this matter, and I await your prompt reply.
Sincerely,
James M. (Jim) Palenick
Interim Town Manager, Dallas, NC
Cc: Mayor&Board of Aldermen
Pennie Thrower,Town Attorney
Coleen Sullins, NCDENR Director of Water Quality Division
Dee Freeman, Secretary NCDENR

correspondence Profile Cover Sheet Page 1 of 1
Alcirdies, fer„ (
NCDEHR
Colicspundatce Tracking System
09305200802536
Summary
Petition for a Contested Case Hearing: Town of Dallas(by and through its Board of Aldermen)v.DWQ
Received 05/20/2008 via Letter
Legal issue for Mary Penny Thompson
Issued 05/15/2008 by Wiliam W. Took of Robinson,Bradshaw& Hinson,P.A.
** For Recipient Use Only **
To:
Date: / /
Respond By:
Please: a replyforsigPreparenaturemy and return to me.
Reply, noting the letter was referred to you by me, *
Prepare a reply for the Governor's signature and return to me.
Reply, noting the letter was referred to you by the Governor. *
For your information,
Take appropriate action
Note and file.
Note and return to me.
Note and see me about this.
Your comments and/or recommendations.
'Copy to Secretary's Office
Remarks
http://iibeam.enr,state.nc,us/os/dts/print.do?dispatch=crsdProfile&id=2536i 5/20/2008

� �tx
MAY
STATE OF NORTH CAROLINA IN TIlE OFFICE-OF ADMINISTRATIVE p* ENT a.
COUNTY OF GAsToN crsiL ACTION NO:
TONS\ OF DALL. S
by and through its Boaar®d or Aldermen
Petitioner;
VERIFIED IED PETITION OF 1 hhlt N OF
DNORTH+C: RI.I"`y itT I' ITT °TE" T OF ALL S FORA CONTESTED CASE
HEARING
ENVIRONMENT AND NATURAL,
L
RESOURCES, DIVISION OF 'INATER
QUALITY
Respondent,
Petitioner Tossn of Dallas (friallas' 1 . by and through its Board of,- l erniei
acting on behalf ofthe citizens of Dallas, timels petitions for a contested case hearing to
set aside the April 11. .t0t18 Findings and Decisions and Assessment of Ci tl Penalties of,
the North Carolina Department of Environment ent and Natural Resources 1"DEX,R. File
Ni , P( -"2tnnii-oo2 ("Civil it Penalty Assessment-1,pursuant to NCGS l 50B- . . In
support.; Dallas states as folios;s.
NATURE OF_THE ACTION
1: The citizens of Dallas have been victimized by two men in whom they,
reasonably placed their trust to properly operate the town wastewater treatment plant and
who were the sole persons qualified to operate the plant, One, Kirby Case, is now wider
federal indictment for(»a)knowingly discharging untreated Wastewater and(b} '.knowingly
tampering with regtaired monitoring reports: T E R found the other, George Hughes,hes, to

have so utterly failed to use his speciahred knowledge of the t<<aste_water treatment
system as un be "derelict in his duties:.
Dallas relied entirely upon the expertise of these two state certified wastewater
rrenttneat Operators. and it had no reason not to do so_ Dallas paid these two men well.
and it assured ample funds wwere available to implement all necessary repairs and meet all
operational needs. Hughes held the highest certification issued by DLNR, and.Case also
held a stare certification to operate a wastewater treatment plum, Each man had bears of
experience operating ww^astewater treatment plants. For unexplained reasons_shortly after
Case became a full-time operator of the wastewater treatment plant onJuly 16,2007, he
knowingly discharged untreated vastewate.r into the receiving creek for an unknown
period of time and tampered with samples in reports sent to DFNR. For equally
unexplained reasons. during this same period.Hughes failed to request and install the
$2,000 worth of repairs necessary'to keep the wastewater treatment plant in good repair
even 'though. the Board of Aldermen had budgeted more than enough for such repairs.. and
he subsequently failed to report the criminal discharges of untreated wastewater,
3. Dallas has now spent S22 000t to clean up the creek these two men
contaminated: has lost its on-site laboratory certification because Case fraudulently
tampered with samples: has been subject to weekly state inspections; suffered substantial
disruption to its operations as a result; and has already paid over$30,000 in civil
assessments that were avoidable had the operators performed in accordance with law and
their obligations as state certified wastewater treatment operators, and not acted
fraudulently or been derelict in their duties. After becoming aware of the behavior of
Case and Hughes. Dallas irnmediatelw conducted an internal investigation, fired.and
7

replaced Case and 'Hug lees, and has hilly craeiaerat; d worth state and federal investigators,
inc funnily" the State Bureau of Investigation and the(tnnnaaal Investigation t an of the
Termed States Ens ir0ramciatail Protection Attend,.. Dallas has now installed or is preparing
to instill ovei iii60O6)ii north of upgrades and new equipment as a demonstration tt
DENR of its good fang cooperation and intention to assure future caainpliaance
4 Dallas. its Board of"Aldermen. and its citizens non find themselves a Nictina of
Case and Hughes. vet again, thus time sshen DEER assessed da record-breaking penally°of
l4I.l2. .O.s based upon criminal and derelict activity by rogue employees about which
Dallas had no knowledge,wartime,or notice, and user which it had no control. Dallas
respectfully requests that the Office ofAdministrative Hearne s Court enter a decision
craraclatdin? than DENR exceeded us authority acted erroneously,ously, arbitrarily and
capriciously: without support of the facts;contrary to the United States and North
( airrriuw Constitutions, a. plrcablc statutes, regulations and common law,outside its
authority, and or contrary to established policy when it assessed the record-breaking
l`II.I2 .t9E civil penalty.
ALLEGATIONS IOl O I.MMl. \ TO ALL CLAIMS
Dallas, Gaston County, is a a unicipaltts organized and existing tinder the law
of the State of North Carolina. Dallas has a 2006 estimated population of; 400 men,
women,and children.
6. Dallas has a CouncitiManager form of Government. The Board of Aldermen
consists of a Mayor and five elected part-time officials. The Mayor and Board
of
Aldermen include several retirees, a machinist,and real estate developer, No member of
i.ti 849 A 5 xj fiats
3

the Board of Aldermen has technical expertise re, aardat e the operation of a-wastewater
tradurre at plant
;a Dallas conducts its das d i operations through its Town manager r :` t \
°Idler NIE Miller r became the Tow is Manager ter on December 1m 2004, MI M filler's
training, t firs',naming and ion*, He has no technical expertise regarding the operation
of wastewater treatment plant
8, Dallas owns a trade`-III hiologtical wastewater treatment plant that is permitted
to Itschar e up to 600g000 gallons per daft of treated wastewater,ater, The plant Baas
established in 1989 and is a dual train system, with each rated for 300,000 gallons per
day The arastewater treatment plant actually processes bet ,eon 250,000 and 3S0(tot"i
allaans per day of astt ater. The curt era outside Operator in Responsible Charge has
concluded after tour months that the wastewater treatment plant rail operate most
effectively using. a single train of the system, rids conclusion is consistent with
documents dating to 1995, All discharges front the wastewater ater treatment plant are
subject NPDES Pert iit No NC 0068888,which expires January 1, 2010
. Between July 2005 and June 2uuit the Board of Aldermen annually budgeted
between $151,800 and Si 8 .4.6 to operate the wastewater treatment plant,exclusive of
salaries and benefits, The budgets included incl items for equipment maintenance,
chemical supplies, and contract services for sludge disposal that totaled between $6 , 00
and $ . 4p9 a tally t 1p in Information and Iaehef, the annual budget amounts are
consistent with the budgeted operating costs of other similar sized municipal wastewater
treatment systems in the area.

lit- I hiss. toe ono anon o[the\vas/ow Ater rr annettt plain aaouSI be ovelSeell by an
Operator in Respoiasibtc Charge w i'th Grade III or higher.state certification Pursuant to
l;t.A ( L tl+'G 0201, Dallas designated bientge lughes the CIperaat r it Resnoitbibl
e
ti°aar-gc' both Istlards 1. 002 until Ins di rtaissaal on .11ercinber 26, 20021. During that nor
Besse. Hughes anttaatatned a Grade IV state certification the highest certification awarded
b . DL\R and one grade higher than that required to operate the Wastewater treatment
platrt,
11. 11tt hes reported directly to the Director of Public [..tilitie , John Ferguson.
1"ereuso.Ea s training is electrical power distribution Dallas owing an electrical utility that
distribtat s power to in citizens and other customers. Ferguson has no technical expertise
regarding the Operation of a rsasteaa°aatet°treatment plant. and therefore relied upon
Hughes asa state certified operator and the designated Operator um Responsible Charge,
12, As a holder of a Grade IV certification, ptirsn t to 15 i NiCAC(ISO.tt fi?
Paa�uhe
was required to have at least two years of actual experience as an operator of a Ciradc ITI
biological wastewater treatment plant before refighting his Grade 1\ certification. Upon
it ftaataaa€iota and bench Hughes had such experience prior to earning his Grade IV
certification.
13. 3s the Operator aaa Responsible Charge,Hughes was required by 15A xN ';A '
Ot(i.(L0af to visit the TasteWatea treatment plant at least five times a week excluding
hrilidays.,and ieaote irerltientls,as necessary to ensure the proper operation of the system.
III/pries was also required by 15A NCAC p 0.0204 to certify', by signature,to the
validity glad momionng and reporting information: to docraiaeerat the operation
maintenance and visitation of tlae system,in a daily log: to notify Dallas in writing of"any
,
( "%o;lq 0 ut

o%erflows_ bypasses, permit violations or the need for any system repairs or
modifications: and to be a%ailable to respond to emergency situations. Until November
2007, Dallas reasonably belie‘ed that Hughes was 111 hill compliance with his legal
obligations as an Operator in Responsible Charge,
4 Until he was assigned in July 2007 to operate the water treatment plant, Mike
Hurt had conducted day to day operations at the wastewater treatment plant, overseen by
Hughes, Upon the recommendation of Hughes and concurrence of Public Utilities
Director John Ferguson, on July 1.6, 2007 Town Manager Miller hired part-time
employee Kirby Case full-time to conduct day to day operations at the wastewater
treatment plant under the charge of Hughes,
15. Case had maintained a Grade I state certification since September 1 1997.
Approximately ten years ago Case had worked at the wastewater treatment plant as an
employee of an outside contractor, and he worked off and on at the wastewater treatment
plant until he started his own porta-john business in 2003, In September 2006 Case
returned to work for Dallas as a pan-time employee working at the wastewater treatment
plant on weekends and during times that Hurt was not available, Case worked full-time
at the wastewater treatment plant from July 16, 2007 until his dismissal on December 26,
2007. Until November 27, 2007, Dallas reasonably believed that Case was qualified for
employment at the wastewater treatment plant under the supervision of the Operator in
Responsible Charge, Cieoree Hughes, DENR,has imposed the Civil Penalty Assessment
based solely upon events that occurred entirely after Case became a full-time operator at
the wastewater treatment plant on July :16, 2008 and before November 27, 2008,
(.-i.08195[Yv 20339,0w I
6

fit.. Rule IRA NCr (i" ri a 01 o I requires every certified operator to have a minimum
of six contact hours of D R-approt ed Limning annually Pursuant to IRA A \C ('
(t a(7 na tal. DENR may revoke an operator's certification if the operator is found to be
practicing fraud or deception in the performance of duties, fails to use reasonable care or
id txaent in the performance rra ance ofa duties, falls to amity knowledge or a flare in the
performance of duties or its aateoinpeient. Lami November 22. 2002. Dallas reasonably
believed that Case and Hughes were acting In In caatnplianee With the requirements of
their respective certifications issued and overseen by DENR. Dallas had no reason to
suspect. nor did it suspect, that Case and Hughes were engaged in practices that would
support the revocation of their state certifications.
17. On April id.2008. DENR revoked the(trade I certification of Kirby Case. Case
admitted to l fa K..that for approximately'eight to twelve weeks prior to November 22
20t,t*he;had filled sample bottles with tap water before conducting the laboratory
analysts required by the Permit and applicable fins: DENR concluded Case had practiced
fraud in the performance e of his duties. Until November 27,20 , Dallas had no reason to
suspect Case was tampering With required sample results.
18. On April He 008, DIN .. revoked the(tirade IV certification of George Hughes.
Hughes told DENR on November 28, 2007 that he never determined whether repairs to
the chlorine feed system had been made, he had not inspected the outfall for over three
moan€hst he visited the plant site for only minutes utes at a tnne and had not physically
Inspected the treatment system since hiring 'ase,and that he had no knowledge of how
much conditions had deteriorated at the plant, DENR R concluded that Hughes had been
°derelict in his duties as [Operator in Responsible f bar to fi Though Hughes had

adequate knowledge of'sy°stern operations, his failure to property oversee the wastewater
treatment plant had allowed conditions to deteriorate sienitica:ntly and result in
-egregious- conditions, Until ,November 28, 2007. Dallas had no reason to suspect that
HIughes VS as derelict in his duties as Operator in Responsible Charge.
19, Upon information and belief, before the revocation hearings conducted by DENR
on April 9. 2008, neither Case not Hurdles had been the subject of any disciplinary action
b DENR,
20_ Dallas had every reasonable expectation that Hughes would comply with his legal
obligations as the Operator in Responsible Charge and a Grade IV operator. Dallas had
even reasonable expectation that Case would comply with his legal obligations as a
Grade I operator. Dallas provided Hughes and Case with all resources necessary to keep
the wastewater treatment plant in compliance with the Permit and applicable law. Dallas
did not have an stall'other personnel with technical expertise sufficient to provide
meaningful oversight of thew: two certified wastewater treatment system operators, Upon
information and belief, tnunicipalities that own wastewater treatment plants permitted to
discharge less than 1 million gallons per day do not rely upon personnel other than
certified wastewater treatment system operators to assure wastewater treatment plant
compliance with permit and other legal conditions.
21- On August 30. 2007, DENR discovered untreated wastewater and sludge was
being discharged from the wastewater treatment plant into the receiving creek, This
upper initted discharge caused decreased levels of dissolved oxygen downstream of the
wastewater treatment plant. The DENR inspectors discussed the unpermitted discharge
directly with Case and Hughes. The DENR inspectors were told that the unpermitted
C.ao:{495,o 03;9;)um

discharge was the result of pumping sludge fin III One treat lent basin at the plant that had
lost biological activity se\era! a eeks earlier into the other treatment bitsin that remained
bic lcrµ!aca lls aetm\e.
22. Despite his clear obligation to do so as the Operator in
1 ' Responsible Charge,
Hughes never mtorrned Dallas In an . !'barn or fashion that: tat one oldie treatment bashes
at the plant had lost biological activity prior to the August ust 30,7l)(7 Inspection: ih) that
there had been an os erflosr, bypass, and permit violation on Attiguist 30, 200 , or(e)of"
the need for any system repairs or modifications. Town Manager Steve Miller.Public
litilaties Director John Ferguson and Dallas first learned of the. trust at)unpermitted
discharge(luring 1.) NRIs November 27328, 200" inspection
23. Between June 2003 and prior to the August 30, 2007 un errrt.itred discharge,
DF P had assessed ` 10,,r55.t'l4 in mil it penalties and enforcement costs The
assessments were for thirteen permit parameter violations that involved intermittent
c .ceedances principally olmammonia nitrogen parameters, to a lesser extent fecal.
confomi, and serf' occasionally pH. biological oxygen demand, and total suspended
sr lids, Upon information and belief, there as no particular pattern to the exceedances and
the dequ ncya type and scale of such exceedataces tipon informatirm and belief, the
frequency, type and scale of these exceedanges am common to biological wasteivater
treatment plants that process similar small volumes of wastewater.
24. Between June 2003and prior to the August 30_2007 undermined discharge,
DENR sent all assessments for civil penalties and enforcement costs to Town Manager
Steve Miler or his predecessor, Town Manager Nicholas `ns sa/len, Dallas paid in Rill
esers assessment for emit penalties and enforcement'costs in (call, a'ithotlt petitioning for
9

a contested ease hennae,requesting a remission o penalties. or otherwise negronatirrau a
reduction. 3 he historw,of permits iolations prior TO the August 30, 200' tuipeimilted
discharge provided Dallas Vs nh no reasonable mdicarion that us Operator in Responsible
Char Ve might he derelict in his duties.
25. On September O. 2t107Y Hughes sent DENR a letter describmg events leading up
to the August 30, 2007anpennitted discharge and response act dies he allegedly took in
response no the unpermitted discharge. Contrary to the direction ofDallas that all town
correspondence should be on Dallas letterhead and material correspondence first
reviewed by the Town Manager or his designee prior to sending, Hughes prepared and
sent this letter in violation of these policies and without advising Dallas of his
correspondence to DENR or the august 30, 2007 unpermitted discharge ContrarY to
Dallas direction that all mater inmatet Lir correspondence be copied to the "'own Manager or
Pudic Utilities Director,Hughes never provided Town Manager Steve Miller or Public
Utilities Director John Ferguson with a copy of his September 6, 2007 letter. Dallas first
discovered this letter when it searched the hard drive;of Hughes' computer on December
I 7.,;2007 as part of its internal investigation of Hughes stemming from DI'NR's
November 2' 2 , 2007 inspection. Dallas has no records to confirm that Hughes annually
implemented the responses he describes in the September 6,2007 letter:
2[_. For reasons that are not clear, on November 5, 2007 DENR sent a Notice of
Violation and Recommendation for Enforcement regarding the August 30=permitted
discharge directly to Hughes. This was a significant departure from the past practice of
having all such correspondence sent directly to the Town Manager. Dallas can only
surmise that on or shortly after August 30 Hughes directed DENT.to send such
rwrusTi s 5i05, 0001:
1t

correspondence solely to him as part of a cover-up effort. By having the DENR.
correspondence sent directly to him. Hughes was able to hide from the Town Manager
and Dallas problems at the astewater treatment plant and that he was.failine_his duties
as Operator in Responsible Charge. Town Manager Steve Miller and Dallas first learned
2007E ,
of the November , Noirce of Violation and Recommendat ion for Enforcement and
rile August 30 unpemoiued discharge during DENR's November 2 28, 2007 inspection.
27. On November 27 and 28, 2007, DENR inspected the wastewater treatment plant
and discovered Case was dischargiq untreated tivastewater and sludge directly into the
receiving creek. Case also admitted to having falsified laboratory data for perhaps nearly
the entire time since he had been engaged July 16 to work full time at the wastewater
treatment plant. DENR determined that both Case and Hughes were aware of needed
repairs but had not implemented them. Hughes admitted that despite his obligations as an
Operator in Responsible Charge_ he had not visited the wastewater treatment plant since
the August 30 unpennitred discharge or overseen operations there in a meaninglitl way
for some time,
28, Subsequent to the November 27-28, 2007 inspection, Dallas undertook an internal
investigation of the activities of Case and Hughes. Dallas suspended Case and Hughes
on December 14. 2007, and on that day hired temporary replacements, including an.
Operator in Responsible Charge, to maintain and operate the wastewater treatment plant_
On December 26, 2007, Dallas terminated the employment.of Case and Hughes and hired
replacements on a contract basis, including an Operator in Responsible Charge, to
maintain and operate the wastewater treatment plant. These replacements have since
informed Dallas that it appears either Case or Hughes,or both. for some unknown reason
try 495 o,_2tO S(rile 1 E I I

ry
and period of time substituted ww atea ttar®the liquid chlorine that Dallas paid to hiir e put
into the chit-vine teed barrels used to disinfect and treat the wwaastewwatea-.
20 on December 7, lit and 11. after the No ember 27-2N. 200 inspect t n, DENR
suet Iowa Nlanager Steve Miller taw e. letters assessing a total of 09. 1.0t1 ur civil
p aaalties and enforcement.costs fOr permit parameter violations occurring during each
month from March through A ueust 2007.other than May Biological oxygen demand and
rtr unorara nitrogen were the primary reported exceedances that resulted in the
assessments. Upon information and belief the type and scale of these exceedances are
common to biological wastewater treatment plants that process similar volumes of
wastewvater, The frequency of these violations would have merited an inquiry= into
operating conthootas by Dallas had Dallas received notice of these violations before the
November 27-2 , 2007 inspection. Dallas promptly paid the assessed civil penalties in
bail. t NR`s delivers of the civil assessments in December did not provide Dallas s or
I o n Manager Steve Miller with any indication prior to the November 27-2 , 2007
inspection that there might be problems with the management and operation of the
swrastewa atet-treatment plant
0: On February , 2008, DENR assessed S260 .20 in civil penalties and enforcement
costs for ammonia nitrogen and nitrogen permit parameter violations occurring in
September 2007. On February 12, 2008, DENR assessed $10,448.74 in civil penalties
and enforcement costs for the August 30 unpermstted discharge On April 8, 2008,
DENR assessed 8706.2t for a variety of permit exceedances occurring in December
2007 when the wastewater treatment plant was the subject of intensive investigation by
12

federal and state law enforcement authorities: and operations were ph inly in disarray.
Dallas promptly paid the assessed total orS21:761.41 in hill
Allier the November 27-28.2007 inspection and before issuing the S141.123,98
il Penalty Assessment that is the subject of this verified petition, DENR first assessed
and Dallas paid the $31,692.41 described in paragraphs 29 and 30 In operator activities
that were either fraud lent derelict or both, and that were certainly outside the scope of
their employment, These underlying violations were hidden from Dallas and Town
Manager Steve Miller until after the November 27-28 inspection, DENR delivered its
assessment of these penalties well alter the problems at the wastewater treatment plant
fast came to light during the November 27-f:18, 2007 inspection, The assessments
delivered after the Novembet 27-28. 2007 inspection gave Dallas and Town Manager
Steve Miller no reason to inquire into management problems at the wastewater treatment
plant prior the November 27-28, 2007 Inspection.
32, By correspondence dated April 14,2008, and received by Dallas on the following
day, DENR conveyed die Civil Penalty Assessment and assessed Dallas$141.123.98 in
penalties and enforcement costs. The Civil Penalty Assessment asserted violations
based solely upon the fraudulent and derelict activities of Case and Hughes that DElNR
first discovered during the November 27-28,2007 inspection.
3.3. DENR assessed the fa llowmg penalties in the Civil Penalty Assessment,all of
which result directly front the criminal and derelict activities of Case and:Hughes:
(al S25,000 on the grounds that Dallas failed to at all times properly operate and
maintain the wastewater treatment plant.
1.bi $25.000 on the grounds that Dallas pemaitted residual solids to entei the
receiving creek:
cubsigsnts 2)339 OW I
13

tct S25.000 on the grounds that Dallas failed to provide representative samples of
the wastewater treatment plant discharge:
Id) $25,000 on the grounds that Dallas failed to take all reasonable steps
necessary to minimize or prevent a discharge with the reasonable likelihood of
adversely affecting the receiving creek:
(et S5,00o on the grounds Dallas failed to report two wastewater spills,
tf) S25,000 on the,grounds Dallas discharged wastewater that violated applicable
water quality standards ibr best usage:
{g p S10,000 on the grounds Dallas discharged wastewater that violated applicable
water quality standards for dissolved oxygen; and
(}t} S I,1.?3,98 in enforcement costs,
BASES FOR PETITION
34_ Among the factors DENR considered was its conclusion that "the violations [by
Dallas] were willful and intentional" and the `intentionally[sic] lack of operation and
maintenance [by Dallas] was egregious,- DENR made these conclusions even though
Dallas had no knowledge of this criminal and derelict activity, Case and Hughes
undertook this activity without regard to the requirements of their employment and the
law, Dallas had no reason to suspect such criminal and derelict activity, and despite a
fully funded budget established by the Board of Aldermen to assure the proper
maintenance and operation of the wastewater treatment plant. DENR's conclusion that
Dallas willfully and intentionally violated the law,and intentionally failed to operate and
maintain the wastewater treatment plant is arbitrary and capricious and not supported by
the facts,
35. In assessing the civil penalties against Dallas, DENR also considered as a factor
its conclusion that "likely considerable money was saved by the town by not properly
operating the plant. These include but may not be limited to: energy costs, chlorine
GM:095( 5 20319.0401i 14

chemical costs,facility repair costs, and solids/sludge disposal costs " Dallas has saved
no money through the criminal and;derelict activities of Case and Hughes For the fiscal
sear that is chided November 2007, Dallas established a [ulIs It nded Sr 51.000 budget
l xclus i e of salaries and benefits) that Was comparable to that of other municipalities
operating similar sized wastewater treatment plants and which was fulls adequate to pay
for all costs of operating and maintaining the wastewater treatment plant Dallas saved
r
no money on energy costs. Dallas estimates that S2,00(0 would have been sufficient to
make the necessary repairs that Hughes failed to request and implement. Dallas deferred
no more than S2,000 in chlorine chemical costs by the criminal and derelict behavior of
Case and Hughes. Dallas may have deferred at most another$2,000 to $. .000 when Case
and Hughes failed to arrange for sludge disposal. Dallas spent over S22,000 to clean up
the creek that Case and Hughes contaminated; it has spent$60,000 over its maintenance
budget of 5,12,000 to upgrade and install new equipment in an effort to rebuild the
confidence of D NR and to demonstrate cooperation and good faith. In order to make
these new installations,Dallas had to take each of the basins offtline twice, which has
required it to spend an additional S26,000 over the chemical budget of t . 00 to bring the
basins back into balance. Hughes and Case have cost the citizens of Dallas over
1 5,00ti in direct costs, and substantially damaged the image of the town. Dallas saved
no money thanks to the criminal and derelict activities of Case and Hughes. DE 's
assessment of civil penalties based upon the conclusion that Dallas saved "considerable
money¢,from the criminal and derelict activity of Case and Hughes is arbitrary and
capricious and not supported by the facts.
C-108491}ti52(3Ir100 11
1

36. DENR further considered as a factor its assertion that Dallas had a -poor
complianCe lusm jnassess ma the cien penalties. DENR based this conclusion hirgeiY
upon the S31.09241 in assessments DENR made after the November 27-28 inspection.
Those assessments were for operator activities that were either fraudulent derelict or
both, .ind that %Vero certainly outside, the scope of their employment_ Dallas admits that
pi or to engaging Case and the August 30 Inspection, it had a modest history of non-
compliance, The pre-August 30 history of non-compliance reflects the periodic technical
difficulties of keeping a small wastewater treatment plant in complete equilibrium, and
upon information and belief reflects a history that is not uncommon among most
municipal wastewater treatment plants of this we. Dallas admits that its pre-Augum 30
history of non-compliance is a factor DENR may reasonably consider in assessing
penalties: however, consideration of the civil penalty assessments DENR made alter the
November 27-28 inspection is arbitrary and capricious and not supported by the facts,
37 North Carolina lass is clear that civil penalties may be assessed solel as
punishment to deter unlawful behavior, and as such have no remedial purpose. _Vorth
Coroirme„School&arch Ass n r. Moore, 359 N,C, 474, 524-526, 614 S.E.2d 504. 507-
10(2005p Pursuant to Article R, § 7 of the North Carolina Constitution N.C. Gen,
Slat. § 143-215.6A(111)and N.C. Gen, Stat. $1 I5C-457,3, all civil penalties must go to
the local school technology fond, and no civil penalty may be used to restore the
enviromnent. In this case, DENR has imposed a record fine for criminal and derelict
behavior that Dallas had no reason to suspect,could not have reasonably predicted or
prevented, and that it certainly did not encourage or in any way knowingly participate in
or derive any benefit from. Dallas undertook no activity that DENR could reasonably
5 2i'63900021
16

hope to deter through the imposition of the Assessed Civil Penalty, nor is there a rational
basis to punish Dallas tor the eritninal and derelict actbities of highis specialized 3tale
certified Wastewatel treatment operator SWho acted outside the scope or their
employment.
„Dii, Dallas took ail reasonable steps necessarily to priiperly operate and maintain tile
wastewater treatment plant: provide representative samples of the wastewater treatment
plant discharge; minimize or prevent a discharge with the reasonable likelihood of
adversely affecting the teceiding creek:and prevent the discharge or wastewater that
violated applicable water quality standards scar best usage and dissolved oxygen Dallas
did nor permit residual solids to enter the receiving creek, The criminin and derelict
activities of Case and Hughes that resulted in residual solids entering the receiving creek
were contrary to the express requirements of Dallas and applicable law. Dallas was
unable to report the wastewater spills because Case and Hughes failed to pros:ide Dallas
with notice of the spills stemming from their criminal and derelict behatimi as required
by the terms of their employment and applicable law,
39, ihe criininal and derelict activities of Case and Hughes tvere intervening actions
about which Dallas had no notice,over which Dallas had no control and which Dallas
or not have reasonably anticipated,
40, DENR's Civil Penalty Assessment is based upon criminal and derelict activity
that Dallas neither supported, condoned,nor could Dallas have reasonably anticipated or
presented the behavior of Case and Hughes 'The Civil Penalty Assessment therefore is
arbitrary and capricious, not supplied by the facts:contrary to the United States and
(ol 084 oI Ov, °MI]
I 7

North f.arohna Constitutions, applicable statutes. repaint iODS and ctattstttt rr lens: and
outside its authority an di established policy.,
I he Civil Penalty Assessment des not properly reflect the nature i t the alleged
violations and the degree and extent of hattt .caused by.. Dallas_I:8al1as` Cates itaais record of
compliance, or mitigatory factors. all 01'Which require a penalty substantially lly less than
that assessed by DENR.
42, DENR has deprived Dallas ofproperts. ordered it to pay an administrative
penalty. and or substantially prejudiced Dallas' rights.
41 DENR R assessed the Civil Penalty Assessrrtem after haying adopted erroneous
cortclumolb of fact and arbitrarily.and capriciously applied those factors required bsix
statute at N.C. Gen. Staat. jj 14313-218.6A. Imposing the C n it Penalty Assessment
exceeded DENR"s authority tinder N.C. (ten. Slat 'l f 3-3, s iodated Article 1. a:s 1`J, 21.
and 3 and Article I ', § 3 ofihe North Carolina Constitutions and violates the 14 t
s ere exit of the United States Constitution,
Whet for the reasons stated above Dallas petitions that:
A. The Civil Penalty . ssessinerat be set aside; and
II, The Administrative Hearings Court order such other and further relief as it
deems hest and proper.
This _ ,ay of May, 2008.
Willia W. Took
N.C. Bar to 16862
ROBINSON, BRADSHAW & HINSON, P.A.
101 !mirth Tryon Street, Suite I )U(}
Charlotte"North Carolina 28246

05 "14/2e 47 19:33, 7 4..1322-47 1
14N DAL4_.. = r",46': oak ;
futtot\...,
Pantie NI,Thrower
` * , R No 2 6
'. Second Ave
Gastonia, C:28053.-0279
Direct Dial: (70 ) 869-610.1
Direct Facsimile. (7,a4) - 1
rl.Pe true;i c m;c h >er1aww corn
Attorneys for Tpwn of Dallas
19

PAGE` 03/03
STA'rE OF NORTH CAROLINA
coti.Nrie OF GASTON
VE—
� TI "r
Stevan Van i ,being Bist duly sworn.deposes and says that he is.the
Triven M w rger for the/oven of Dahas in the foregoing a tidn,and that he has read the
foregoirig Petition and knows the contents thereof,and rise same is true of his own
knowledge,except as to those matters therein stated upon information tion and belief;and as t
those matters he behaves them to be true.
Steven Van wen l!sr ler
Subscribed worn to
before nte'dins/5-,day
ofMay,2008.
No tray Public
MY CommissionExpires _ -2(7
SEAL:
m _ .
C
-a 4a 2Qa39 !i

CERTIFICATE OF SERVICE
1 hereby certify that the fbreeouig,PETITION OF TOWN N F DALLAS FORA
CONTESTED CASE HEARING has been served upon Respondent aondent t • deposition same
in the United States mail, powtaae prepaid, in an cm elope addressed as follows
Mary Penny Thompson_ Registered . gent
North Carolina Department nt of Environment and Natural.Resources
1 601 Mail Service Center
Raleigh. NC 27690-1601
This day of May. 2008,
er)
illaant it'. Toole
21

DIVISION OF WATER Qt.:TALI-1N
MEMOI I3 1 T C Bob Sledge
FROM: Robert crt B. rc s
February 11 200 � mrr
PIP BYm Donna Hood
I iB IF ('T Enforcement
Violations ul'U. a 113-21. .1, 1A N :"A " 2 .0211
and NPDES Permit No, NC0068888
'The Town of Dallas
Dallas \V‘VTP
iastota, NC
Attached is an enforcement report, which details a violation of 14 - 1 .1(a)(4), 15A
CAC 213..0 11(2), NC AC 2B .0211 (3)(h) and NP1 1 S Permit number NC068888.. Also
enclosed is 1VIl t 's NOV II .I inspection, the sampling results, associated pictures, and the
Dallas NOV/NRE inspection response. Based upon on our review of the pertinent information and
Dallas response. .tc., an enforcement action is still recommended.
If"you have questions or require additional information, please contact Donna or me.
Attachments
I3I1

STATE OF NORTH. CAROLINA NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL
RESOURCES
COUNTY OF GAS ION
File No.
IN THE MATTER OF THE, TOWN OF )
DALLAS )
FOR N./IOLATIONS OF: ) FINDINGS AND DECISIONS
) AND
NORTH CAROL NA GENERAL, ) ASSESSMENT OF CIVIL PENALTIES
STATEIFE G.S. )
1.5A. NCAC 2B .0211 AND )
NPDES Number NC0068888 )
Acting pursuant to delegation provided by the Secretary of the Department of
Environment and Natural Resources and the Director of the Division of Water Quality, I, Matt
Matthews, Division of Water Quality Point Source Branch Manager, make the following:
.L FINDING OF FACT:
A. The Town of Dallas (hereinafter Town) is a municipality organized and existing under the
laws of the State of North Carolina.
B. The Town of Dallas operates the Dallas Wastewater'Treatment Plant(WWIP) in Gaston
County, Th.e Dallas WWI P discharges treated wastewater through Outfall 001 to Dallas
Branch (1-129-1.6-7), class C waters of the State in the Catawba River Basin. The
permitted -flow is 0.6 MGD.
C. The Town of Dallas was reissued NPDLS Permit No. NC0068888 on August 23, 2005,
effective October 1.„ 2005, with an expiration date of January. 31., 2010..
D. Said permit contains the following relevant monitoring requirements for Outfall 001/with
monthly averages in hold and weekly averages in italics:
Monitoring Sample Efilu.ent
Parameter Requirement Location Limitation
NH3-N 2/week E 4.0, 12,0 mg11
BOD(Nov 1-Mar 31) 3/week F 26.0, 39.0 mg/L
T/SS(Nov 1-Mar 31) 3/week F 30.0, 45.0 mg,//,
Fecal Coliform 3/week L 200/100 m1,400/1 00m1
F. Part II. Section C (2) of the NPDES Permit states, in part, that "The Permittee shall at all
times properly operate and maintain all facilities and systems of treatment and control (and
related appurtenances) which are installed or used by the Permittee to achieve compliance

T Town of Dallas—Dallas WWFP
Page 2
with the conditions of this permit. Proper operation and maintenance also includes
adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the Permittee to install and operate backup or auxiliary facilities only when
necessary to achieve compliance with the conditions of the permit. [40 CFR 122.41 (e)1
F. Part II, Section C (1) of the NPDES permit states the ORC of a Class III facility must visit
the plant at least daily excluding weekends and holidays, properly manage and document
daily operation and maintenance of the facility
G, Part II, Section F (6)(a) of the 'NPDES permit states that "The Permittee shall report to the.
Director or the appropriate Regional Office any non compliance that potentially threatens
public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written
submission shall also he provided within 5 days of the time the Permittee becomes aware
of the circumstances, l'he written submission shall contain a description of the
noncompliance, and its cause; the period of noncompliance, including exact dates and
times, and if the noncompliance has not been corrected, the anticipated time it is expected
to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of
the noncompliance [40CER 122AI (1)(6)].
H. Part II, Section D (5) "provides that any person who falsities, tampers with, or knowingly
renders inaccurate, any monitoring device or method required to be maintained under this
permit shall, upon conviction, be punished by a fine of not more than $1.0,000 per
violation, or by imprisomnent for not more than two years per violation, or by both..."
I, North Carolina General Statutes 1.43-21.5,1(a)(4) prohibits any"Increase the quantity of
waste discharged through any outlet or processed in any treatment works or disposal
system to any extent that Would result in any violation of the effluent standards or
limitations established for any point source or that would adversely affect the condition of
the receiving. waters to the extent.of violating any applicable standard.
,J, Title 15A North Carolina Administrative Code 213 .0211. (2) requires that Class C Waters
maintain conditions related to best usage including "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 basis shall be considered to he violating a water quality standard".
K. Title 1.5A. North Carolina Administrative Code 2B .0211 (3)(b) requires "dissolved
oxygen; not less than 6,0 In OIL for trout waters; for non-trout Waters, not less than a daily
average of 5.0 mg/I., with a minimum instantaneous value of not less than 4.0 mg/L,
swamp waters, lake coves or backwaters, and lake bottom waters may have lower Values if
caused by natural conditions".
L. MRO/DWQ staff performed a compliance sampling inspection (CSI) at the subject
facility, on November 27 & 28, 2007.. \IRO D\VQ issued a Notice of Violation.
(NOV)Notice of Recommendation for Enforcement (NRE) on December 12, 2007 for
violations of the subject NPDES permit, North Carolina General Statute 143-215.1.,, 15A
NCAC 2B ,0211 3(b), and 15A NCAC 0211 ,021. 1 (2),
M. The Town's prior record of compliance for the last 3 years with programs 0 er which the
Environmental Management Commission has regulatory authority is as follows:
A civil penalty (Case No. TV-2005-0042) of$1,085,04 was assessed on January

r^"7
Fowri or Dallas —Dallas WWTP
Page 3
24, 2005, for one effluent Biological Oxygen Demand limit violation (hereinafter
BOD) and one effluent ,ammonia-nitrot2en limit violation in October 2004. The
penalty was paid in full on February 14, 2005.
A civil penalty (Case No. IN-2005-0061) of$335.04 was assessed on February 1,
2005., for one effluent fecal conform limit violation in November 2004. The
penalty was paid in full on February 14, 2005.
A civil penalty (Case No. LV-2005-0365) of$335.04 was assessed on September
19, 2005, for one effluent fecal coliform limit violation in May 2005.. The penalty
was paid in full on September 28, 2005.
A civil penalty (Case No. LV-2006-0282) of$580.15 was assessed on August 8,
2006, for one effluent BOD limit violation and one effluent fecal coliform limit
violation in May 2006. The penalty was paid in full on August 30, 2006.
A civil penalty (Case No. LV-2006-0372) of$1,080.15 vas assessed on October
3. 2006, for one effluent HOD limit violation, one effluent fecal coliform limit
violation, one effluent ammonia-nitrogen limit violation, and one effluent Total
Suspended Solids (hereinafter 'FSS) limit violation in June 2006. The penalty was
paid in full on October 18, 2006.
A civil penalty (Case No. LA/-2006-0470) of$2,580.1.5 was assessed on.
December 5, 2006, for one effluent BOD limit violation, four effluent fecal.
conform limit violations, and two effluent ammonia-nitrogen limit violations in
April 2006. 'Ihe penalty was paid in full on January 5, 2007.
A civil penalty (Case No. LV-2007-0053) of$831.50 was assessed on February 2,
2007, for one effluent ammonia-nitrogen limit violation in September 2007, The
penalty was paid in full on March 7, 2007.,
A civil penalty (Case No. TV-2007-0076) of$1,331.50 was assessed on February
13, 2007, for two effluent ammonia-nitrogen limit violations and one effluent 'TSS
Omit violation in October 2006. The penalty has not been paid and the case is still
open.
A civil penalty (Case No. LAT-2007-0121) of$1,331.50 was assessed on March
26, 2007, for three effluent ammonia-nitrogen limit'violations in October 2006.
The penalty was paid in full on April 10„ 2007.
A civil penalty (Case No. LV-2007-0208) of$394.00 was assessed on June 6,
2007, for one 'ESS limit violation and three pH limit violations in January 2007.
The penalty was paid in full on July 5, 2007,
A civil penalty (Case No. .LV-2007-0472) of$1,581.20 was assessed on

Town of Dallas—Dallas W WTP
Page 4
December 7, 2007, for two effluent ammonia-nitrogen limit violations in March
2007. The case is within the 30-day response window.
A civil. penalty (Case No, LV-2007-0474) of$581.20 was assessed on December
10„ 2007, for twenty effluent total residual chlorine limit violations in April 2007.
The case is within the 30-day response window.
A civil penalty (Case No. LV-2007-0475) of$2„33,1..20 was assessed on
December 11, 2007, for three effluent ammonia-nitrogen limit violations and one
effluent HOD limit violation in June 2007. The case is within the 30-day response
window,
A civil penalty(Case No. 1...,M-2007-0050) of$1.,981.20 was assessed on
December 11, 20.07, for two effluent ammonia-nitrogen limit violations, one
effluent BOD limit violation, and one temperature monitoring violation in July
2007. The case is within the 30-day response window.
A civil penalty (Case No. LV-2007-0477) of$3,456.20 was assessed on
December 11, 2007, :for two effluent ammonia-nitrogen limit violations and four
effluent BOD limit violations in August 2007. The case is within the 30-day
response window.
M. Dallas Branch is classified as C waters in the Catawba River Basin.
N. The costs to the State for enforcement procedures in this matter totaled $11.23.98.
Based upon the above Findings of Fact, 1 make the following:
11. CONCLUSIONS OF LAW:
A. The Town of Dallas is a "person" within the meaning of G.S. 1.43-21.5.6A pursuant to
G.S. 1.43-.21.2 (4).
B. NPDES Permit No. NC0037371. is required by G.S. 143-2151
C. The monitoring requirements and the conditions within the subject permit regarding
proper operation and maintenance and test procedures of said permit are terms,
conditions, or requirements of said permit.
D, The Town of Dallas violated NPDES0068888 effluent limitations as detailed in the
effluent sampling results attachment.
E. The Town of Dallas violated NPDE50068888 Part II Section C (2) by failing to repair
the chlorine feed system and one side of the .Vs/WTP so as to maintain compliance
with effluent limits set forth by said permit,
F. The 'Town of Dallas failed to have an OR,C on site for of the required visitation days
in October 2007 and November 2007. By allowing sludge discharge to Dallas
Branch, said ORE' also failed to properly manage the WWTP.

Town of Dallas—Dallas WWTP
Page 5
G. The 'Fawn of Dallas violated Part II, Section E (6)(a) of the NPDES permit
NC0068888 by failure to report two spills at the WWTP,
H. The Town of Dallas violated Part II, Section D (5) by :falsifying chlorine data from
July 2007-November 2007 and tampering with ammonia nitrogen, fecal coliform, and
toxicity samples of the same time period.
I. The Town of Dallas violated North Carolina General Statutes 143-215.1(a)(4) by
allowing the discharge of sludge to Dallas Branch, in excess of effluent limitations
and causing downstream. violations of fecal coliform and dissolved. oxygen. (see
downstream sampling results).
J. The Town of Dallas violated. Title 15A North Carolina Administrative Code 2B .0211
(2) by allowing the discharge of wastewater that had not been disinfected to discharge
Dallas Branch making it unsuitable .for secondary recreation.
K. The Town of Dallas violated Title 1.5A North Carolina Administrative Code 2B .0211
(3)(b) by impacting dissolved oxygen downstream as recorded on the stream sampling
data on both days of the inspection.
L. A civil penalty may be assessed in accordance with the maximums established by
G.S. 143-215.6A(a)(2).
Ni. The State's enforcement costs in this matter may be assessed against the Town of
Dallas pursuant to G.S. 143-215.3(a)(9) and G.S. 143B-282.1(b)(8).
N. 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.
Based upon the above Findings of Fact and Conclusions of Law, I make the following:
III. DECISION:
Accordingly, The TO WIA of Dallas is hereby assessed a civil penalty of:
for violation of NC0068888 by discharging effluent in violation of the
limits set forth by the .NPDES permit.
for violation of NC0068888 for failure to properly operate and maintain
the Dallas WWTP, so as to achieve compliance with the effluent limits.
$ for violation of NC0068888 for failure to achieve required visitation by
the ORC.
$ for violation of 'NC0068888 for failure to report two spills at the Dallas
WWTP
for violation of NC0068888 for falsification of data and sample tampering
for violation of North Carolina General Statutes I43-215.1(a)(4) by

osyn of Dallas -:Dallas WWTP
Page
allorring sludge to discharge and causing stream standard violations on
both days of the inspection
for a violation of`flTifle 15A North Carolina Administrative Node 2B .0211
11
(2) rr-ith the removal of best use (secondar) recreation);
for a violation of Title 15A North Carolina Administrative istrative 'od .0211
( )(h) by causing a stream standard violation in dissolved oxygen through
the discharge of sludge to Dallas Branch on both days of the inspection,
f 1,s CIVIL PENAI:l\, authcoriied by G.S, 143-215,6A
1 2 . 8 Enforcement Cost
l.AO"I"AL a£ 1 `fo v7 I
As required by t.). . f 4 -` I,6A(c), in determining the amount nt f penalty, I considered
the factors set out in C.S. 14 B-2 ...1(h), Nshic:h are:
(1) `1'he degree and extent of harm to the natural resources of the State, to the public
health, or to Irrigate property resulting from the violation(s)
(2) The duration and gravity of the violation(s);
:3) Fite effect on ground or surface cater quantity or quality or on air quality
(4) 'File cost of rectifying the damage
(5) `1"he amount of atone ,,saved by noncom littnce
(6) Whether the x°iolation(s) was committed willfully or intentionally;
(7) 1 hre prior record of the violator in coinlr[y irrg or failing to comply with programs
over r=hich the I:nvironmental Management Commission has regulatory authority;
and
(8) 'the cost to the State of the enforcement procedures.
Gate Matt Nlatthesys, Point Source Branch
Division of \later Quality

DIVISION OF WATER QUALITY
ENFORCEMENT CASE ASSESSMENT FACTORS
Type: Permit Condition Violation (NOV-2007-PC-08 19)
Violator: The Town of Dallas
Responsible. Official: Steve Miller, Town Manager
Address: 210 North Holland Street
Dallas,North Carolina 28034
Dallas WWTP
NPDES Permit.NC0068888
Regional Office: Mooresville
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:
On November 27 and 28, 2007, Ms. Donna Hood and Mr. Wes Bell of the Division of
Water Quality inspected Dallas WWTP after a second complaint was received from Mr.
Jim Fisher of DWQ Environmental Sciences Branch'. The.Dallas WWTP was found to be
improperly maintained and operated as per-NPDES requirements on both days of the
inspection. Resultant harm to the natural resources of the State included but was not limited
to the following:
1.. The downstream dissolved oxygen was 3.00 mg/L on 1127.2007 compared with an
upstream dissolved oxygen of 8.96mg/L.2
2. The downstream dissolved oxygen was 3.51 mg/L on 11/2812007 compared with an
upstream dissolved oxygen of 11.52 mg/L.2
3. Downstream fecal coliform was greater then 20,000 eful100m1 on 11/28/2007
compared with an upstream fecal coliform of 2.90 cfu/100m1s.2
4. Approximately one half mile of Dallas Branch(Class C, 303d impaired) was
impacted with activated sludge solids from the wastewater treatment plant
(WWTP).
The same type of violations were first documented by Mr. Fisher on August 30, 2007.3 A
Notice of Violation/Recommendation for Enforcement (NOV-2007-DV-0272) was sent by
the Mooresville Regional Office on November 5, 2007 in response to Mr. Fisher's initial
documented complaint.
Danger to public health included a lack of disinfection (chlorine addition) to the WWTP
effluent on both days of the inspection.' A house with a child's swing set was adjacent to
the downstre.am sampling site.1
See enclosed pictures
2. See enclosed sample results
3. See enclosed report

2. The duration and gravity of the violations:
Sludge as initially reported in Dallas Branch on August 30. 2007, and was found at
11:30 am by Mr. Fisher of the Division of Water Quality. The 5-day report submitted on
September 6, 2007, by the Operator in Responsible Charge stated that
the sludge discharge did not end until 4:30 pm. No estimate of the volume of sludge
released from the Dallas WWTP was made in the 5-day report. The operator on site
during the November 27-28 inspection stated no sludge clean up was ever pursued after
the initial complaint.
Sludge in Dallas Branch Was reported the second time to the Mooresville Regional Office
on November 20, 2007 via email. Approximately one half mile of stream was impacted
on both days of the inspections. 11./27/2,007 & 11/28/2007 with sludge depths of varying
from 4"-8".
3. The effect on ground or surface water quantity or on air quality:
The dissolved oxygen concentration in Dallas Branch was decreased from 8.96 mg/I at
the upstream sampling location (as specified in NPDES permit NC0068888) to 3.81. nig/1
at the.downstrea:m sampling location (as specified in NPDES permit N('0068888) on
November 27, 2007 and from 11,52 mg/L to 3.51 mg/L OD November 28, 2007. Fecal
coliform concentrations Were increased from 290 cfullOOmi upstream to greater than
20,000 cfull00m1 downstream by discharging wastewater that was not disinfected.
Composite effluent samples collected on 11/28/2007 in violation of NPDES permit limits
are as folio ws':
TSS: 1050 mg,11,
Nit-N: 28 mg/L
BOD: 430mg/L
Fecal coliform: >2,000 cfn,1100mL (grab sample)
Samples in violation from .11/27/2007 are as follows:
Fecal coliform: >2,000 cfn1100mL
,Be.nthic and or fish damage .was not documented,
4. The cost of rectifying the damage:
The Town of Dallas Was required to pump the solids out of approximately 0.5 miles of
stream.
5. The amount of money saved by noncompliance:
The Town of Dallas saved money by improperly operating and maintaining the ViAVTP
equivalent to the cost of pumping and removing the sludge from the treatment process,
repairing the inoperable side of the plant and failure to add chlorine to disinfect the
effluent.
2. .See CI1CIOSCii sample resuk

6. Whether the violations were committed willfully or intentionally:
Violations on site were willful. The sludge in Dallas Branch was a result of ongoing
improper operation and maintenance. Lack of sludge wasting and disposal resulted in a.
very turbid effluent. The continual discharge of the. turbid effluent coated Dallas Branch
with heavy sludge deposition (4"-8" deep) for approximately 0.5 miles. The Town was
first informed of this on 8/30/2007. No plant operational changes or stream clean up
occurred after 8/30/2007, 'Fhis Office was informed again of the same problem on
11/20/2007, which resulted in an NPDES sampling inspection of the facility on 11/27-
28/2007. During the inspection, the operator admitted to falsifying reportable effluent
samples as well as sample data. 'f he ORC did not properly visit the facility even after the
original complaint was made on 8/30/2007. /lhe ORC and operator on site had
knowledge of a raw sewage spill on site at the influent pump station and an overflow
from the aeration basin„ Both spills reached surface waters but neither spill was reported.
to the Division.. Both spills were discovered by DWQ on the first day of the inspection .
Effluent was found to be discharging without disinfection on both days of the inspection.,
The operator on site stated the disinfection system had not worked for two months. Both,
operator and ORC were aware of the needed repairs but had not addressed the issues.
The operator on site admitted to falsifying chlorine values that were reported on DMRs
from July 2007-November 2007. He also admitted to using potable water fir effluent
toxicity samples and effluent fecal samples. In addition he admitted to putting 2 effluent
and 2 potable water in effluent ammonia samples. The ORC missed 1.3 days of required
visitation during October 2007-November 2007,
7„ 'f he Town of Dallas' prior record of compliance for the last 3 years with programs over
which the Environmental Management Commission has regulatory authority is as
follows:
A civil penalty (Case No. .LV-2005-0042) of$1,085.04 was assessed on January 24,
2005, for one effluent Biological Oxygen Demand limit violation (hereinafter BOD) and
one effluent ammonia-nitrogen limit violation in October 2004. The penalty was paid in
full on February 1.4, 2005.
A civil penalty (Case No. LV-2005-0061) of$335,04 was assessed on February 1, 2005,
for one effluent fecal coliform limit violation in November 2004. The penalty was paid
in full on February 14, 2005.
A civil penalty (Case No. LV-2005-0365) of$335.04 was assessed on September 1.9,
2005, for one effluent fecal conform limit violation in May 2005. The penalty., was paid
in full on September 28, 2005.
A civil penalty' (Case No. LV-2006-0282) of$580.15 was assessed on August 8, 2006, for
one effluent BOD limit violation and one effluent fecal coliform limit violation in May
2006. The penalty was paid in full on August 30, 2006.
A civil penalty (Case No. LV-2006-0372) of$1.,080.15 was assessed on October 3, 2006,
for one effluent BOD limit violation, one effluent fecal colifortn limit violation, one
effluent ammonia-nitrogen limit violation, and one effluent Total Suspended Solids
(hereinafter FSS) limit violation in June 2006. The penalty was paid in full on October

18. 2006.
A civil penalty (Case No. I...V-2006-0470) of$2„580.15 was assessed on December 5,
2006, for one effluent ROD limit violation, four effluent fecal, eolifOrm limit violations,
and two effluent ammonia-nitrogen limit violations in April 2006. The penalty was paid
in full on January 5, 2007.
A civil penalty (Case No. LV-2007-0053) of$831.50 was assessed on February 2, 2007,
for one effluent ammonia-nitrogen limit violation in September 2007. The penalty was
paid in full on March 7„ 2007.
A civil penalty (Case No. LV-2007-0076) of$1,331,50 vas assessed on February 1.3,
2007, for two effluent ammonia-nitroge,n limit violations and one effluent TSS limit
violation in October 2006. The penalty has not been paid and the case is still open.
A civil penalty (Case No. LV-2007-0.1 21) of$1,331.50 was assessed on March 26, 2007,
for three effluent ammonia-nitrogen limit violatio.ns in October 2006. The penalty was
paid in full on April 10, 2007,
A civil penalty (Case No. LV-2007-0208) of$3 94.00 was assessed on June 6, 2007, for
One TSS limit violation and three pH limit violations in January 2007. The penalty Was
paid in full on July 5, 2007.
A civil penalty (Case No. LV-2007-0472) of$1,581.20 was assessed on December 7.
2007, for two effluent ammonia-nitrogen limit violations in March 2007.. The case is
Within the 30-day response window.
A civil penalty (Case No. LV-2007-0474) of$581.20 was assessed on December 10,
2007, for twenty effluent total residual chlorine limit violations in April 2007. The case
is ‘vithin the 30-day response wind.ow..
A civil penalty (Case No. EV-2007-0475) of$2,331.,20 was assessed on December 11,
2007, for three effluent ammonia-nitrogen limn violations and one effluent ROD limit
violation in June 2007,. The case is within the 30-day response ‘vindow..
A civil penalty (Case No, LM-2007-0050) of$1„981.20 was assessed on December 11,
2007, for two effluent ammonia-nitrogen limit violations, one effluent BOD limit
violation, and one temperature monitoring violation. in July 2007.. The case is within the
30-day response window.
A civil penalty(Case No. LV-2007-0477) of$3,456.20 was assessed on December 11 I,
2007, for tvvo effluent ammonia-nitrogen limit. violations and four effluent BOD limit
violations in August 2007. The case is within the .30-d.ay response window.
8. The cost to the State of the enforcement procedures:
Central Office Review and Processing — $100,00
41 hours by investigator for investigating and
drafting the Notice of Violation and the enforcement

package ,(4? $23,721hour = $972,52
1,0 hour for Supervisory review(it) $36.46/hour = $ 36,46
1.0 hour for clerical support i $15.00/hour $ 15.00
TOTAL = 81123.98
9. "Type of violator and general nature of business (i.e. individual vs. large corporation):
"Fhe TONVI1 of Dallas is a municipality that operates a water treatment plant and a.
wastewater treatment plant. Both facilities have discharge permits with the Division of
Water Quality,
10, Violator's degree of cooperation (including efforts to prevent or restore) or recalcitrance:
"l'he Ton of Dallas was cooperative in addressing the violations at the Dallas WWTP
after the inspection.
11, Mitigating Circumstances:
The Dallas WWII' is classified as a Grade III plant. Recently, the Mooresville Regional
Office of the Division of Water Quality discovered that the Back-up ORC (Nir. M. Hurt)
for the Dallas WWTP had been reassigned to the Dallas WTP. In addition, the WWTP
()RC (Mr, (3. Hughes) was, spending minimal time at the WWTP due to work obligations
at the WTP„ The ORC missed 13 required visitations after the initial complaint. No
changes were made after the first complaint on 8/30/2007. No clean up occurred after the
first complaint. Necessary repairs to the facility for proper treatment of the wastewater
were not made until after the inspection. Necessary repairs for proper disinfection of the
wastewater effluent were not made until after the inspection. Changes in the frequency of
sludge wasting and disposal, for proper operation of the facilit), did not occur until after
the inspection. Total residual chlorine samples were fabricated between Jul) '2007-
December 2,007, when the disinfection system was repaired. Ammonia nitrogen, fecal
coliform, and toxicity samples were tampered with for the period of July 2007:November
2007. Two unreported spills were discovered at the time of the inspection. Effluent
samples collected on the second day of the inspection were not in compliance with the
NPDI.S permit.
After the inspection, the Town has been cooperative in responding to and fixing problems
at the Dallas WWTP. Prior to the inspection by DWQ-SWP-NIRO the Town did not
respond.
12. Assessment Factors:
a, Receiving Streams: Dallas Branch, Class C 1(1-129-16-7), waters of the State
b. Damage: Dissolved Oxygen concentrations in Dallas Branch below the minimum
required water quality standard of '4.0 mg/I on two different days.
c. Damage: Two unreported spills discharged to Dallas Branch from the WWTP.
d. Damage: Improper operation and maintenance per NPDES requirements
e. Damage: Fecal coliform concentrations in Dallas Branch above the water quality

standard
f. Diunage: Permit violation for ammonia nitrogen, total suspended solids, and
biochemical oxygen demand
g: Cops of Permit Conditions/Limits Pages: Attached
it Copy of Pictures: Attached
E Copy of Sampling results: Attached
Copy of NOVINRE Inspection: Attached

CERTIFICATION PAGE
I c rtit ° that the information in this report is true to the best of m
knowledge. All violations of self-monitoring data lif applicable)bl have h en Verified
by hard copy. review f the monthly reports d)th r ri,t 'permit.
Signature f Principle In sti tors : :" `, , ° \ ..
Donna I-food., Environtnerital Specialist
Date., " V ' ` 'r
A.

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Sample Results

ANALYTICAL RESULTS SHEET
N \MF OF EA( ILIVY: Dallas'WW/TP Grab: X. Composite:
Sample Date(s): 11/27/2007 NPDES Permit No. NC0068888
Sample Location, Effluent . County: Galiton
•
BOD5, Phenols,ugll •
• COD: high, mg 11 Sulfate,mg/1
„ • .
COD: Low,mg/1 Sulfide,ingll
• ,„
Conform:Fecal,#11.00 ml >200061'40 Biornas,s: Dry Weight
Conform:Total,4/900 ml Biomass:Peri Ash Free
• Conform:Tube Fecal, MPN NIL-N, mg/I
Ci iform: I Total, NIPN TK,N,.rng
Residue: 'Total, mgll NO I NO3,mg/1
Volatile, mg11 PU4,mg I
Fixed, mgli P:Total, mg11,
-----
Residue: Suspended, mg/I P: Dissolved,mgli
ing,11 A.g-Silver,up I
------------- -
Fixed, nell Al-Aluminum,ug/I
Settleable Solids, inli Be-for)lliant, up I
p11 s.u. 6,•99, Ca-Calcium,ugll
'TOG., mg/1 Cd-Cadmium,ugll
Turbidity.,NTH Co-Cobalt,ugll
. .
Chloride,mg/1 Cr-Chromium:Total,ti&I
Oil iind Grease,mg/I Cu-Copper, ogll
Cyanide, ugil nigh
Fluoride, me/1 Ph-Lead, up/1
, -
,
Hardness:To•tal, mg/1 Hg-Mercury,ug/1
••------
MBAS,ugil Ni-Niekel,tie]
('onductivity,umhoslcin 568 Semivolanles SEE A/FTACHED STIEETts)
. -
'Dissolved 0Aygen, nip i 6,65 VOC SEE ATTACHED SIIEET(s,)
'Temperature,'/C 19,0
„Alkalinity„mg/L
Chlorine,nip I
*
denotes a violation of a permit limitation,
) denotes that sample ssas collected by grab method,
-

ANALYTICAL RESULTS SHEET
NAME.OE FACILITY, Dallas WW'TP Grab, Composite:, X
Sample Datets): 11127/2007-11/28/2007 NPDES Pennit No. NC0068888
Sample Location: Effluent County: Gaston
BOD5,mg] 430* Phenols.ugil
Ct'ID:High, mg/I Sulfate, up'I
C Ii) I o .me Sulfide,moll
Coliform: Fecal,141100 nil >2000*'6"lii Biomass: I)ry Weight
Coliform:Total,#/100 ml Biomass: Peri Ash Free
ColifOrm:Tube Fecal,MPN NI L-N,mel 28*
Ceiiform:Tube'Fotal, PN 'TKN,mei 87
Residue, Total,inel NI z NO3,ing/1 0,36
Volatile,mel PO ,mel
Fixed, mel P Total,mel 22
Residue: Suspended,ing,1 I(I50 1 Dissolved,nip
Volatile, mg/1 Ag-Silver,up
Fixed, tingil Al-Aiuminum, w211
Settleable Solids,ml I Be-Beryllium, up I
pH,.s.u. 7_ (Grab)
CasCalcium,up
-FOC, mo I Cd-Cadmium, up l
Turbidity,NTH I o-Cobalt, Up l
Chloride,mg i Cr-Chromium:Total, og,,1
Oil and Grease,mgd. Co-Copper,ogil
' Cyanide, up.l Fe Iron, med
Fluoride,mull Pb-Lead, up I
Hardness:Total, nigll Fig-Mercury, ugll
MBAS, ugli up l
Conductivity„ umhos/cm 6,5z1,r0a Sernivolatiles SEE ATIACTIE,D SHEET(s)
Dissolved (),seen,mgd VOC SEE ATTACHED SHEET(s)
,
Temperature,°C.
met., 181
Chlorine, mg/L
* denotes a violation of a permit limitation
)5--lrabi' denotes that sample was collected by grab method.
V V

ANALYTICAL RESULTS SWEET
NAME OF F ,.Cii Fl ': Dal!as kV WT.P Grab: Composite: X
Sample i atets): 1 1:27 2f1()'-I I/2R 2t:N)7 • \PE)E S Permit No. N(:00k68888
Sample Location: Influent I ount): Gaston
RI)1)5,nag;l 320 Phenol;,no I
(,'OF): Bich,rtag,l Sulfate,rngll
C, 01): Lo\v, mg,'1 Sulfide„raglI
Cc+liform:Fecal,#'I00 inI 11 mass Dry 1\eight
Conform:Total,g100 nil Biomass: Peri Ash Prce
Cirlitorm tube Fecal, MPN NI•13-N, rrut;(i 38
I uliforrrr:'Tube Total, \IPN T Kh, mg.11 51
Residue: Total. mg/I NO:•'-NO3,rngx'l (.1.02
Volatile, mg?I PC),,mg I
Fixed, rug P:'Fn ai,mpg 7.q
Residue: Srr,peuded,mg:'I Salt) P; Dissolved,rug
\ni tr ic, utgrl Ag-Silver,
Fixed, engd �1..,+ Irataair7utrt,ug.l
Settleable Solid,„mE'I Be-Bcr-vlliurn,ug'I
p11,,,a- • Ca-Calcium„
'FC.)1 ,,nlg.'I Cd-(w"Qadnrir rn, rug'I
`Furbidit).Ni'F1 Co-Cobalt, ngr'1
Chloride, mg/I Cr-Chromium: Total,ILO
• Oil and t:..irea+c, rng l Cu-Copper,ug'I
1.:)aanide,ugt1 Fe-]rrrn, mg/I
Fluoride, rn,c/I Ph-Lead, ug.°`l
Hardness:Total,rng:'I Fle..-1lercur)',ugr"I
i ILAS, ug'I N`¢-Nickel,ugil
Conductivity,umhos/cm Seam ivolatiles SEE ATI'1"ACFIE'])SHEET(s)
Dissolved()vvgen.,rrag'I \"OC SEE ATTACHED SHHF,:1 s)
• 'Temperature,11C
Al6ea init),mgr`L 20 I
•
Chlorine, rrt.f_
* denotes a violation of a permit limitation.
• IIGII"<) denotes that sample was collected by grab method.

Stream Sampling Results
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I
A
. ,_.. nil . . <,> xm. '�
1-Upstream sampling site: (Per permit requirements)
-Eff`1uent discharge site
3-Downstream site I
4-Downstream site II (per permit requirements)
Sampling Results:
11/ / 007
upstream
`Femp rature: 1I.7°C:
Dissolved oxygen: 8.9 rn I
Conductivity: 92 us/cm
PIT: 6*1.8 su

Downstream Sludge (at downstream location II)
Temperature: 15.72'Ci
Dissolved oxygen: 3:00 mg/L
Conductivity: 489 us/cm
PIT: 714 su
11/28/2007
Upstream
Temperature: 8.82°C
Dissolved oxygen: 11.52, mgili
Conductivity: 78 us/em
PH: 7,02 su
Fecal eoliform: 290 cful100m1
Dowristrearn. II
Temperature: 13,22°C
Dissolved oxygen: 3:51 mg/L
Conductivity: 364 us/cm
PH: 709 su
Fecal Coliform: >20,000 eful100m1

Jim Fisher's Initial Ctilliftlaitit

Thank you for your work on this and for the concise report. I 've passed it on. to Jimmie.
Dianne
Jim Fisher wrote:
••. • DWQ Environmental Sciences Staff, Jim Fisher and Sam Whitaker, while sampling
Dallas Branch in the Catawba Basin for Watershed Stressor Studies, noted a sludge
spill in Dallas Eranh at SR 2275 Gaston Co. ( Robinson - Themes Rd. ) in Dallas NC
on B/30/2007 at 1130 N. Physical data was taken ( Temp. - 26. 5 °C, DO - 0 .3 mg/1,
pH - 7 .0 so, SP. Cond. - 624 umnos)and the chemical samples slated ( Tot . P & metals)
for this stream were taken.
We then went to the Dallas wastewater treatment plant to see what was going on
and found one of the operators, a Mr. Eirby Case and told him there was sludge in
Dallas Branch. at Robinson - Clemer Rd. ) . We then walked. over to one of: the two waste
treatment plants on the site and saw that sludge was going over the weir in, the.
clarifier and then checked a manhole to the outfall pipe and saw sludge in it. I .:
asked Mr. Case if there was anyway to shut the flow of sludge off. lie informed me .•
•
that the ORC, a Mr. George Hews, had, just left, and that they were pumping sludge
.: •
from one plant to another because they had. lost that plant a few weeks earlier. Mr. •••Case said he would call Mr. Hews about tie spill . I told him that they needed to
call the Field Office in Mooresville and report a. spill and that I would call the
Mooresville Office also. 1 called the Field Office and talked to Barbara Sifford and
reported the spill , We then went to the upstream sampling site for the treatment
plant on Dallas Branch and saw that it was clear and took physical measurements (
Time 1240, Temp - 23.0 'C., DO - 7 .5 mg/i, pH - 6,9 su. , Sp. Cond. - 105 umhos. ) . I
walkeI down to where the effluent pipe went into the stream and saw that sludge and
wastewater were coming out of the pipe.
In subsequent phone calls to Barbara. Sifford she said that Mr. Hews had called
her and they decided to divert the wastewater flow to the plant off line, stop
pumping sludge, and let the plant with the hydraulic overload settle down. Barbara.
Sifford asked how far the sludge had traveled, so we went down to the next larger
creek which. was Long Creek at NC Hwy. 279 and found. the sludge in the stream and ,•
• took physical measurements (Time 1315, Temp. - 27.0 °C, DO - 0.0 mg/1, pH - 7.0 so. , ,I•
:•
• • Sr . Cond. - 240 umhos) ,
We went back to. the Dallas wastewater treatment plant and Mr. Hews was there and
. .
.•
we talked about his conversations with Barbara Sifford and the solutions to the
problem they had discussed_ We looked. at the clarifier and saw that the effluent was
clearing up and the sludge blanket in the clarifier was going down. Mr. Hews asked •
about pumping the sludge out of the stream and. I told him I didn't see that much •
.1, access to the stream only a small section at the road crossing, don't know how that
was resolved. We talked. to Barbara Sifford again and told her what was going on and
that we would go check the next downstream bridge: on. Long Creek and call her. On the
way to Long reek we stopped by Dallas Branch at tobinson - Clemer Rd. and saw
that the stream was still dark with sludge and that the flow was down and that a thin
layer of sludge had coated the sand in the stream where the flow had receded. We
checked Long Creek. at Dallas- Spencer Mountain Rd. and determined that the sludge
hadn' t gotten that far and took physical measurements ( Temp. - 25.2 °C, DO. - 6. 3
mg/1, pH - 7 . 1 su, Sp. Cond. - 199 umhos) . Called Barbara Sifford again and reported
our findings and told her that we were going on to Stanly MC to sample two streams
near there.
Dianne Reid
Supervisor - Intensive Surveys Unit
NC DENR/Division of Water Quality
p (919) 733-6510
f (919) 733-9959
1621 Mail Service Center
Raleigh, NC 27699-1621
"We never know the worth of water till the well is dry. " Thomas Fuller (1608-1661)
[Fivd: Inv& Re: Sludge Spill - Dallas Branch - Dallas NC]I.ern1 Content-Type: messa.gelife822
.•
.•
2 of 3 Il 1/200.8 12:16 PM

Attac ment
Inspections and responses

February 27, 2007
Mrs. Marcia Allocco
Division of Water QualityI , .•
610 East Center Ave.
Mooresville N.C.28115
7 ::73
Subject. Response to NOVof Follow-up Compliance Inspection
Dated February 14,200,7
NPDES Permit No NC0 S
t ee,& tR ; e
Dear Mrs. Allocco,
This letter is to address the violation listed in the Compliance Inspection Letter dated February
14, 2007. In response to the deficiencies in the Effluent Pipe section of the Inspection report;we have
addressed the foam by skimming it off the surface and depositing it on the drying beds.We are also
checking it daily and removirng the foam on a as needed bases to keep the accumulation down to a minimum.
Hopefully this is a short lived problem,that will soon clear up,
Should you or Mrs. Basinger have any questions pleas contact me at 704-91 -4 1 or 04-g -1 0g
Sincerely,
George Hughes
CRC

North Carolina Department of Environment and Natural Resources
> 7.1
Drccoor
E,19,15tou jr Quality
December 12, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7007 0710 0005 2882 1912
Mr, Steve Miller, Town Manager
TOWrI of Dallas
210 N. Holland Street
Dallas, NC 28034
Subject: NOTICE OF VIOLATION/
NOTICE OF RECOMMENDATION
FOR ENFORCEMENT
Compliance Sampling Inspection
Dallas WWTP
NPDES Permit NC0068888
NOV-2007-PC-0819
Gaston County, North Carolina
Dear Mr. Miller:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility On Nov-ember 27 and 28, 2007, by Ms. Donna Hood and Mr, Wes
Bell of this Office. Please inform the facility's Operator-in-Responsible Charge of our findings by
forwarding a copy of the enclosed report,
Compliance sampling as performed both days of the inspection, On November 27, 2007 an
effluent fecal coliform sample as well as upstream and downstream sampling was performed.
Stream samples showed a stream standard violation of dissolved OXygell caused by the Dallas
WWTP discharge, On November 28, 2007, compliance sampling was performed on the effluent by
splitting the composite sample with the facility. These results indicate a permit limit violation for
BOD, NI13-N, and TSS, To report these numbers on the November 2007 D\IR, average them with
the results reported by the facility's contracted lab, Deleterious stream impact from the undisinfected
effluent discharge is evident the >204000 cfu downstream fecal count,
This report is being issued as a Notice of Violation (NOV) because of the violations of the
subject NPDES permit, North Carolina General Statute (U.S.) 143-215.1, 15A NCAC 2B .0211
and 15A NCAC 02B ,0211 (2) as detailed in the Operation and Maintenance, Record Keeping,
Laboratory-, Influent Sampling, Influent Pump Station, Bar Screens, Aeration Basin,
Secondary Clarifier, Disinfection, Aerobic Digester, Dechlorination, Effluent Flow
47A
NCDENR
N G.DiViMon of Vv'zticr Clualit77,;loorcsvtlic.Rtgtonal Officr,%610 East Ceater Avenuc,SuIN 30.1,Ntoorellt NC 2$115 (701)663-16)9 Cumomer Scrvicc,
1-877-623-6743

NOV-2007-PC-0819
Nleasurement, Effluent Sampling, Effluent Pipe and Additional ("nutmeat Sections of the
attached report, Ptirstiant to (:),S 143-215„6A, a civil peniilty of not more than taventy tive-thousand
dollars ($25,000,0)) per violation per day may be assessed (against any person aaho iolates or nits to
act in accordance aaith the ter , conditions, or requirements of am permit issued pursuant to Ci S.
143-215.1,
it is requested that a Ai ritten response he submitted to this Office by December 27, 2007,
addressing the ahoac-noted iiolations art the attached report, including stream clean up procedures
and conipletion dates. In respt nding. please address your comments to the attention of Ms. Marcia
Alloeco.
This purpose of this letter is also to 110tify you that this Office is ciansidering sending a
Recommendation for Enforeenient to the Director of the Fitt\ision for the \notations of G.S,
143,215.1, 15A NCAC 213 .0211 3(1)), 15A NCAC 0213 ,O211 (2), and the NPDFS Portant
NC0068888, If yon have an explanation for the violation that you wish to present, please
include it in the requested response. Your explanation 'IA 1 he reViCIA ed and if an enforcement
action. is still teenier appropriatei your explantation .1aS,ill he forwarded to the Director, along with
the enforcement package for his consideration
Tins report should be self-explimatoryi hots even should you bat e any questions concertina)! the;
report, please do not hesitate to contact Ms. 'flood or me at ("7(14) 663-169 )
Sincerely,
1412
Robert 13. Krebs
Regional Supervisor
Surface IiVater Protection Section
Enclosure
cc: Gaston County Health Department
DH
Ase.A
NCDENR
N I n mISS stet'11,11,1a1 MooresslIk Resesonal Office,610 1.:a;t 'enter Ass.nue,Susie.301 Slu.rrssyllIc sIC 28115 (7011 o61-IssISs Custormr Senl‘s
I-S Is-621-61141

ve otC4J JCateS c fovIIom7ert{a! -'rnrea"r n,.k;ency
© Form Approved
E©
t ! l Washington,.0.�0 20450 OMB No 2043 005
Water Compliance Inspection„Report Approval expires 8-31-9g
Section A' Nat Data System Coding (i.e , PCS)
Transaction Code NPDES yr'mofday Inspection Type Inspector Fac Type
' 1 1 °I 2 1 5 1 <fe Ei�`?-:?y 111 121 r t.rr 1,1 2 1 12 81 c l 19 s 1 <]l J
Remarks
sa
•
Inspection Work Days Facility Self-Monitoring Evaluation Rating 81 QA
6 16 0 169 70111 711 I 72I n1 "1 I 17
3 751 1 I I , l I I I
Section B. Facility'Data
Name and Location of Facility Inspected(For Industrial Users discharging to PCRiI,also include Entry Tome/Date Permit Effective Date
PCTW name and NPDES permit Number)
•Ca11 &. S�FvTF° 12:15 ?1 x. 1/ 05/1C.. 01
.,T4 0 :-N 1 l r St. Exrt Tirne Date Permit Expiration Date
1.as N . :8314
03;3G ._, 0 1 1,2. 10 O'1/31
11 Name(s)of iDnsrle Repre3orvtatwe(s)aTilIes(s)-;'Phone. and Fax Number(s) Other Facility Data
30.2c.g= to Hu9I e.5/t: ..3 .';a-tv,2-.11s?,,
'Name, Address of Responsible Official/Title/Phone and Fax Number
• Contacted
Steve Mill`e..1 ;fir ? ._I St +Thars.sc. n+_ 02,4 e5,':"otan
:t] 'a't:.'2'. l i ,w _ 4`2v 7 ;:.0 No
Section C: Areas Evaluated Duringinsect +
p on (Check only those areas eb al�tated}
Permit . Flow Measurement N'Operations & Maintenance RecordsiRepOrts
Self-Monitoring Program •Sludge Handling Disposal II Facility Site Rea.iew II Ef tiuent`Rec-eiving Waters
h. Laboratory
Secton D Summary of FindingiComments(Attach additional sheets of narrative and checklists as necessary)
(Se
e attachment summary)
/�
Nanre(s.) and Signalume s) otinxpector(s) ifs/,Agency?Cfficei'Phone and Fax Numbers //// 7Dal'
/)/////(/1 7
::,: N iea.l MR0. w„ t 6,.b-. 9; Cxt. .;l.
Signature rat Maryapdrrzex;Q A Revievice.r Agency=rCffice:Phone and Fax Numbers Date
Rob x
.„„ /211/7.../A
mom
EPA Form 05h0.3 (Rev9-94)Prr';vious editions are obsolete.
R
a4e, 4 1

Permit NO0068888 Owner-Facility: Dai siweirg
Inspection Date: 1E2762001 inspection Type: Can Sampling
Permit VespiNosNA _NE
erds_or.
(if the present permit expires in 6 months or less) Has the berrnittee submitted a new application? 0 0 0
Is the facility as described in tee permit? NOnn
#Are there any special conditions foT the permit? 0 n
is access to the plant site restricted to the general public? N000
is the inspector granted access to ail areas for inspection? m0 n n
Comment See attached comments
Operations &!Maintenance Yes No NA NE
ros....spornsiciamon.
is the plant generally clean with acceptable housekeeping? nann
Does the facility analyze process control parameters, for ex: rILSS, MORT, Settleable Solids. cH DO, Sludge 00. 00
Judge, and other that are applicable?
Comment: See attached comments,
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? 01800
is all required inforrinailon readily available commiete and current? 0 a 0 n
Are all records maintained for 3 years(lab rail required 5 years)? annn
Are analytical results consistent with data reported on DIVIRs? ri
ls the chainnotrouStedy complete? N000
Dates, times and location of sampling
Ni I individual godormind the sambaing •
Results at analysis and caildnation
Dates of analysis
Name of person performing analyses
Transported COSs
Are DfARs complete' do they include all bemet parameters? 0 N 0 0
Has the facility submitted its annual'compliance report te users and. DWO? no 0 m
n
(if the facility is z or> 5 MOD pernutted flow) Do they operate 42 /7 with a certified operator on each shift? nn a
the ORE visitation log available and current? 0
Is the CRC certified at grade equal to or higher Mae the facility (Dassificatien? annn
Is the backup operator certified at one grade less or oreater than the facility classification? annn
I a copy cf the current NPDES permit available on site? annn
PaoP# 3

Permit; NE0068888 Owner-Facility: Dallas r \°r rP
Inspection Date: r l i2 22 ,7 Inspection Type: Cott/plasma Samsfing
Record Kee Yes No NA NE
F'amley has copy of pretends year's Annual Report on file for reveess. 0
Comment: See attached comments.
Laboratory Yes No NA NE
Are field parameters pert =rmed by ce#ified personnel or laboratory? MIODO
Are all other par ameters`e.aclurffrtg field parameters)performed by a certified tab2 WOOD
#Is the fac.ilrty using a contract labs MODO
is proper temperature set for sample storage(kept at I 0 to 4_4 degrees Celsius)? NO00
Incubator(Fetal Colitorm)set to 44 5-degreesCelsius-se 0 2 degrees"
Incubator(BCD)set to 2�:t.r2 depress elalus Tit t degrees 0 0
Comment: See attached comments,
Influent Sampling Yes No NA NE
is ceraaposlt sampling flow proport�c nal I I 11'
Is sample collected abds'a side streams?
Is proper volume collected? 1 I 1
is the tubing clean? 0
Is proper temperature;set for sample storage(kept at't 0 to 4 4 degrees Celsius)? IN 0 0
Is lam piing performed`accardiraj to the perrnit" ■ I ) 1 4 I
Comment: See attached ccnlm nt <
Pumptation -influ nt Yes No NA NE
Is the pump wet well free of bypass Dries or structures
Is the wet well tree of excessive greasennOIN
Are all pumps present 1
Are all pumps operableT l t l�l
,re float controls operable? C
Is S A to telemetry available and operational 00a 0
Is audible and visual alarm avallal le and operational?
Comment: See attached comments:
Bar Screensoccou
Yes No NA NE
Type of bar screed
a Mengel
Page JO 4

Permit: N00068888 Owner-Facility: Dallas VAIPIP
inspection Date: 11127.20OP inspection Type: Comp fiance Sarnplpig
Bar Screens Yes No NA NE
b Mechanical
Are the bars adequately screening debris'''. nann
Is the screen free of excessive debuts? n n
Is disposal of screening in complian n 0 nce?
Is the unit in good condition? in000
Comment: See attached comments,
o
Aeration Basins Yes N NA NE
Ext
Mode Of operation
Osed
Type of aeratio m ffun system
Is the basm free of dead spots? Dann
Are Surface aerators and mixers operational? 0 0 ni
Are the diffusers operatamai? 0 n n
Is the foam the proper color for the treatment process', 0 fl n
Does the foam cover less than 25%or the basin's surface? nann
Is the DO level acceptatle'? n 0 n
Is the DO lea&acceptabieDel 0 to 3 0 m nanngrI)
Con ment: See attached commEints,
Secondary Clarifier
Yes No NA NE
ppp,
Is the clarifier free of black and odorous wastewater n
nann
is the site free of excessive buildup of solids in center wed'of circular clanger?
Are weds level? snnn
Is the site free of weir biockage? ri ri n
Is the sam free of evidence of shorrocircutog? a 0 0 n
sx:ern removal adequate? norm
Is the site free of excessive floating sludge? 0 Mi 0 0
Is the drive Lt riot operational? scinn
is the return rate acceptable(low turbuiedine3C n n 0
n El
Is the overnow clear of excessive solids/pin floc?
fl
norm
is the'sludge blanket level acceptable?(Approxinriately la of the sided depth)
Page# 5

Permit: NC€a aar Owner-Facility: Deltas `ITP
Inspection Date: t 1t ,,,:.a.t.y Inspection Type: Compliance aampiing
SeconbaryClarifier Yes No NA NE
Comment: See attached comments;
Aerobic_Digester Yes_..No NA NE
is era capacity adequale't
Is the tru.x ng adequate?
Is the s,te free of excessive foaming in the tank? nann
#Is the odor acceptable, an 0 0
#Is tankage available for properly waste sludge Ii
Comment: See attached comments,
Di infe tion-G Yes No NA NE
Are cylinders secured adequately? n000
Are cylinders protected from direct sunioght f 1
Is there adequate reserve supply of da. infectar t I01
fs the Ie'vei of chlorin ressdui acoeptab(e O1
Is the contact chamber free of growth,or slradg buildup
Is there chlorine residual prior to de-chlorination"y
Does the Stationary Scu rce have more than 2500 Ins of Chlorine (CAS No r r g-gu- 1
It yes then is there a Risk Management Plan on site7 0 0 ■
If yes,then what is the EPA twelve digit ID Ns:r ber'(I tn"_ _ )
If yes, then when was the RAP last updated
Con m nt. See attached comments;
De-chlorination Yes, No NA NE
_coor
Tykre of system
Is the feed ratio proportional to chlorine amount t 1 to 1 f y OnE.10
Is storage appropriate for n ors 1 1'
#Is de-chlorination substance stored away from chlorine containers? 0E00
Are the tablets the proper size and type? n 0 ri
Comment: See attached comments,
Are tablet de-chlorinators operational', 00110
Number of tubes in uses
Comment. See attached comments
Page#

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After the initial findings, a second day for further inspection was deemed necessary. On
Wednesday, 1 1 ,8 2007, the inspection was completed. y.lr, Chet Whiting, of this Office, performed
a laboratory inspection concurrent with the continuing NPI)1 S inspection. Due to admission of
falsification of data. the field lali }rators° certification was relinquished onsite. Compliance,
upstream, and downstream samples were collected the second day**. Mr. George Hughes, ORC
was present on the I 1 28rr2007, The ORC has not visited the WWTP 5 days a week as required per
NCAC 1 :08(i.02042)(h) The ORC did not visit the 1 `\VTP 6 of the required days in 10 2007
and 7 of the required days in 1 1`2007. The ORC. did not properly document his Visitation at the
facility. The back up ORC did not visit the \ W"I"P in the absence of the ORC as required per
NCAC 1 5A .08G .0205(2). The ORC stated he only looked at the process control numbers when he
visited the plant and did not walk through the facility. He stated that he had not visited the creek
since 8,'30'2007, The ORC stated he NV as on site after the influent pump station overflowed on
11 '2 3`2007, and was apprised of the situation. However, the spill was never reported to this Office.
The ORC had not checked the chlorine feed system since its reported failure. Please be advised that
it is the ORC's responsibility to provide proper over-site to all operators providing operation and
maintenance to his respective \V\IP. Please be aware all spills to surface eaters must be report to
within 24 hours of first knowledge. The °RC described the problem, With getting the east train
pumped empty to complete the necessary repairs. It is recommended that the facility obtain a better
bar screening system to prevent the carry over of trash into the basins, which prevented the east train
from being pumped empty in a timely fashion.
*Please see enclosed pictures
**Please see enclosed sample. results

Additional Observations:
. The Dallas WWIT was inspected on 11/27/2007 in response to a second complaint made to
this Office by Jim Fisher, DWQ Environmental Sciences Branch. Mr. Fisher submitted pictures via
email to show the gravity of the situation*. Mr. Fisher submitted his 'first complaint on 8/30/2007.
Subsequently, this Office issued a Notice of Violation (NOV-2007-DV-0272) to address the initial
solids release and, documented stream standard violations, Mr, Fisher submitted the second
complaint on November 20, 2007.
Ms, Donna Hood and Mr, Wes Bell, of this Office, arrived at the facility at 12 15 pm on
1. 1/27/2007 for the inspection: Mr. Kirby Case, operator, arrived on site for the inspection briefly
after the inspectors. Mr. George ffi .:ihes, ORC, was off on 1E2712007. The initial visual inspection
of the plant revealed an unreported bypass of treatment units that reached the storm drain system*.
One train of the plant, essential for proper treatment of the wastewater, was taken out of service on
August 9, 2007 for repairs, Repairs had not been completed as of 11/27/2007 and the only train left
in service was inadequately treating the Wastewater flow it was receiving,. Excessive foaming was
seen throughout the aeration basin, secondary clarifier, chlorine contact chamber, and effluent
trough. A sludge judge taken in the secondary clarifier was 1. 1 ',. The sludge blanket in the chlorine
contact chamber was 2.0'. '[he settleonicter result from the aeration basin was 1000m1 out of
1.000m1. The dissolved oxygen concentration in the aeration basin was 0.25 mg/L. No chlorine was
being used for disinfection on the day of the inspection*. The operator stated the chlorine dosing
system was broken and had not been used for over two months, Sodium bisulfite continued to be
used for dechlorination, although the effluent was not chlorinated. Further visual inspection.
revealed a second unreported spill to surface waters at the influent pump station*. This spill
occurred on 1. 1/23/2007 with first knowledge by plant staff on the same day. -file receiving stream
was heavily impacted by solids present in the effluent discharge for approximately 0.6 miles
downstream*,
During the record keeping and lab review several violations were observed.. Review of the
operations log revealed the following; .
I. No entries had been made from 10/4./2007-11/26'2007*
2. No wasting had occurred since 9/27/2007*
3. No Back-up ORC had visited he plant in the C.„)R.C's absence since 7/13/2007
When asked about hoW the facility maintained compliance with most permit limits when the plant
appeared neglected the following was stated:
1. No chlorine had been used for disinfection so the chlorine values used for DMR compliance
reporting were completely fabricated.
2. Fecal samples were collected with tap water, not effluent
3: NH3-N samples were collected by. cuttinglmixing the effluent with. tap WateL
4. Toxicity. samples in August and September were collected with bottled spring water..
An effluent fecal sample was collected on 1E27/20074*. Stream samples were also taken**
*Please see enclosed pictures
**Please see enclosed sample results

The facility description should be updated at permit renewal to include the dechlorination facilities.
Operations and Maintenance:
The facility was poorly maintained and operated at the time of the inspection due to inadequate ORC
over-site. No wasting had occurred since ()27'2007. Bar screen trash was seen throughout the
facility. Heavy foam was seen throughout the facility including the receiving stream. Solids carry
over to the stream has been previously cited back in inspections dating back to 2005.
Record Keeping:
DN'tRs for 9/2006-10 2007 were reviewed for the inspection. The following violations were
reported during the review period or discovered through conversations with. Mr. f lughes and Mr_
Case.
1. October 2007-Falsified CL, data/tampered. sarrrpleslate DNIR reporting
2. September 2007-Falsified C.l.2 data/tampered samples
3. August 2007-Falsified CL2''tampered samples, failed toxicity, 1::30f) monthly average, 3
seekly average BOD, monthly average NH -N, 1 weekly average NI--N
4, July 2007- One weekly average B()I), one weekly average NIL;-N, monthly average N1-1 -N
5. June 2007-2 Weekly N113-N, 1 weekly B01); monthly average NI-I,-N
6. 1vtay 2007-5 12007-TRC limit, one temperature monitoring
7, April 2007- TIC limit every day sampled
8. March 2007- One weekly NH3-N, Monthly Average Nf--13-N
9. January 2007-One 1SS weekly average, 3 daily p1f
November ot T . �b<r Zi,}()?- Two weekly average NI1 -\, monthly average. Nf-I:3-N, failed toxicity,
failed TSS removal rate
All limit and monitoring violations will be handled under separate cover.
Laboratory:
A laboratory inspection was-performed concurrently with the NP.1.)L,S inspection by Mr, Chet
Whiting, of this Office. Laboratory certification 451110 was relinquished at the time of the
inspection. Please refer to Mr. Whiting's report for any other findings,
Influent Sampling:
Influent sampler tubing was dirty at the time of the inspection,
Influent Pump Station:
The influent pump station had an overflow to surface waters that had not been cleaned up or
properly reported*.
Bar Screens:
Bar Screens are inadequately screening debris. Screenings were present throughout the treatment
process. Screening., caught by the bar screens are disposed of at the counts' landfill.
*Please see enclosed pictures

The aeration basin had a low dissolved oxygen concentration and \vas covered kVith very thick foami
N 0 Was t ing has lead to a ver:y high solhds inventory Foam from the aeration hiisin has spilled out of
the basin and the effluent discharge line*.
Secondativ Clarifier:
The secondary clarifier was covered iivith scum. The sludge blanket was I I feet, almost the depth of
the clarifier.
Disinfection-Gas:
No chlorine was being added tom disinfection on either day of the inspection*. The chlorine contact
chamber Was covered with eseessii„e amounts of solids
iAterobie Digester:
Digesters for both trains siere full on both days of the inspection. There \vas no room to adequately
waste the W,IWTP,
Dechlorinatitm:
Sodium bisulfite is used for dechloriniatiota, Deehlorinatiori was being used even though chlorine
as not being fed on the first day of the inspection.
Effluent Finn Nleasurement:
'The flow chart wus off by several hours at the time of the inspection, The effluent filmy meter had
not been calibrated during the last calendar year, Please have it fin immediately
Effluent Sampling:
Sampler tubing was dirty on the day of the inspection,
Effluent Pipe:
The reechoing stic ii Nits heavip. impacted In the P discharge, hoiiiin had spilled mit of the
effluent line leading to the receiving stream*,
*Please see enclosed pictures

The aeration basin had a low dissolved oxygen concentration and was covered with very thick foam..
No wasting has lead to a very high solids inventory, Foam from the aeration basin has spilled out of
the basin and the effluent discharge line*.
Secondary Clarifier:
The secondary clarifier was covered with scum. The sludge blanket was 11 feet, almost the depth of
the clarifier.
Disinfection-Gas:
No chlorine was being added for disinfection on either day of the inspection*. The chlorine contact
chamber was covered with excessive amounts of solids,
Aerobic Digester:
Digesters for both trains were full on both days of the inspection. There was no room to adequately
waste the WWTr
Dechlonation:
Sodium bisulfite is used for &chlorination, Dechlorination was being used even though chlorine
was not being fed on the first day of the inspection.
Effluent Flow Measurement:
The flow chart as off by several hours at the time of the inspection, The effluent flow meter had
not been calibrated during the last calendar year. Please have it calibrated immediately,
Effluent Sampling:
Sampler tithing ,xas dirty on the day of the inspection.
Effluent Pipe:
The receiving stream was heavily impacted by the WWTP discharge, The stream must be cleaned
up immediately. Foaru had spilled out of the effluent line leading to the receiving stream*.
*Please see enclosed pictures

t.t_,,4,,,... .„:.,...,,,,z:(,r,,-,,,,,,, ,,-.„:,,,,,,,. ,42-4— ,, te:ti'll4«, 44,,C1 "«,,,.4«.,t- '4'.1tir'
ts' . .: *-4.'s V 4,'' - "i 4' c; 4 - .1A-0.'" , ,,,-„. te-rti;,.7, ...,4,..,.1,,,.. '. . - 4k..1-
,, 4,,,...-, . ,, ,,.,74 ,ff'. .... ,,,r• ..'r—„,.„,---f,..#4; ... ;.,"$,;: -- --,V A.-r--
, ,,,,‘,„.%0.* 1,,"&t. ..?,,,'', ., - .r,,,,,,Or* , ,.,t fi;,*v = '-, /4' t ,X,iiif ..e-;.-;,. ,' , , Itirsoi,z
;,......,,Aa—c:-,.'vr; .., lkit .;, -...,,-*:-?,,:;1,c`Vir,„_ --,01 - q i-4,H1,-r - - . „v-4,,,,i.
,6,
.i.‘"AL1.' ` 11-'i V .1.. .4.,.'',0, lit' N iz,'T'oe' «;;°'***r ., .,
.. 1( ,w ei„ --..-,-.,. ., .i,t
,
,t'
At
',"`rl,
..• ...; 11, .. t ., ," 74,-'$.4 ,Igttil„ ., .//tvvk, ;" , .....51., `,.„.„..,.-425,1,. 4t_z 4t
t f, ° ".;"'P.: ".".-4-4,* 1 ;'7, zr----. , , 4. -
.±.144,÷1
' A rr,,,,,
4 rit "Tot' v'l
-„ „ i r: ,,....
, \ *• V'; i* -e,Ovit'Af' = ';;;Itl"* 'it•;,%.' 7, 44*;, ' . *,,
i'v'..4 4-`444,,t,,,4A44i,,4,-„- t N, . - 47,1 4-.4'..
— ,
-..'-"‘.1,
\,,,,,c,,, ,;,‘,,,,,% k4.'r,,, ,,- ,..,, ., - -;,:,--7..- ,tal%iik,Zar,,,, „„ siv;.."1—
‘,, /
- , ^.Ak:. , X44 " *"..''''4 ..74,-i"- ,,...., .., *N4., /
._.., . :11' : - :::*':*:-, : 1:* -.4-'‘ , -''2,4-';''*:':A,- ' ':.-- -- '
'-. :.-• .-- ,..„...,- .F..,,...is:,1,'1,,'4'4•11,44..40*. '',' ....," — '\e------*
• 41 `"4•4 r''' .7i. ",-*k,** ' NV:,,..,,#,,, .. --- - ----- ';
..,-,,:zirk,:k
1,
''.,. ,,s,. .
),,,,,,,..• .7, . - 1 ,,,,, , .,,,,,,...4„,4*.,, , ,,t,,,;',"4-',1,1„,',"*"t't ,,* ' ' •
,
i' Nt''''', ' ,...1
- '. 1 ,
' .. ,. .
.
, . ,... ,
.. . 4 . , ,
4 -
. .,
'Second Dallas Branch complaint by Jim Fisher
.—. —
..m
„
• - --„,v'.-1
d ,.
,„..,
,.....,.'4,4.
"
'j
i ow
• *
1 l
, ,,,
.
•
• A. MA •
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' V , A•
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The first storm dram shovdrug the unreported spill inside the \VV-Fli

NANE OF FACILITY: Dal \-kiWITP Grab; X Composite:
• Sample Datefsfy 1 NEDES Permit No. NC0068888
Sample'Location: Effluent County: Gaston
, .
•
13OD5,mi-lrf I Phen.ols. ugfl
• COD! T-Hgh,rngll Sulfate, ingll
COD,L.,ow„ mg,1 Sulfide, mg/1
_. . .. ... .
- '
Co I ifo nu: Fecal,#1100'ml ,,-,2000*//'-;4'fl Biomass:Dry'Weight
Conforini Total, 4/100 all ' Biormis,s: Peri Ash Free
__ . .Conform!Tolne Fecal, NIPN NH,-N, mg/I
' )
Coliflorm: Tube Total, N1PN IKN, ing,11
......„
R.esidue: foil, mg I Ni + NO), ing'ill
. ' . . . ,........._ _ .........
Volatile, rug i I-101, ingrl
Fixed:, ing,I1 F.Total, mgil
Rtsidue: Suspended, mgr,11 P.Dissolved,mgll
'Volatile, ingil ' AgsSilvcr,
— -
Fixed, ingid .A[-Aluminum., ugll
Settleable,Solids, mil Be-Berillium,ugd.
pH,ssu. 6:9 , i Ca-Calcium,ugil
. ,
IOC, ing'l Cd-Cadrni um, ugll
Turbidity,NTH i
Co-Cubalt.ug/I
— _
Chloricie.II Cr Cr-Chromium: Total, ugsl
. ... i
Oil and Grease ritgli Cu-Copper, ugl
i... . ,
Cyanide, ugll F•e-Iren,mgil
i
Fluoride,ingsd Ftsdstra.-1, ugll
. ... -..
1 Hardness-Tot ill. moll fig-Mercury, ugli
. MBAS, ugil • NI-Nickel, 'ugll
Conductivity u mhos/cm 568 Semivolatiles SEE,AlTiACHED SHE,ET(s)
Dissolved tOxygen, rug/1 6,65 , VOC SEE ATTA(.".HED SHEET(s)
-1.
Temperature.°C, 1')
Alk.ilinity,mgiE
Chlorine,mg,•'1,
.. .. _... _ .... ... ..„-. .
* denotes a violation of a permit limitation,
(`-''''biI denotes that sample was collected by grab method,
- - . . ...

...--------. ..--- ,
. ... .
NAME OF FACILTFY: Dallas WWII° ' Cir,ab: Composite: X
,
Sample Patc(s): 1 R2712007-1 1/28.-"2007 , ,
. NPDES Permit No. NCbl068888
,
.
Sample-0 oca6ons Effluent County: Gaston.
. .... .. — . ...--.
BOD5, ringil 430 Phenols,urtS1
COD: Hlgh, mi 1 Sulfate,-ing/I
COD: Loco,imell Suit-Ries m
• ...
Colifontr.. Fecal, :4100 ml s-2000,0:Clotit
• Bicma.ss. Drtit Wel,41-ti
- - •,,
Corn Total..4/100 rid ! aiomass, Pori Asti Free
_. .
- ---- !!
Cohform.Tube Fecal,.MPN N1E-N.ingil. ' 25*
Coliform! 'Tube Total,MPN 1 TKN,inc-'
- , .. •, 5"
_ , —
Psesidue. T,iital, mgll NO,. st-NO), ing/I 0.36
._
Volatile, turtil PO4, mg/1
Fixed, in gill P.Total, mei 22
Residue: SUSpe.nded, initil 1050' Ps Dissolved, rugl
Volatile, ingll A.g-Silsver,-tig/I
_ --•
Fixed, mcji AlsAlumirttim, ugfl
Settleiitilsii Solids, trail .Be-Berylliurn,ugll
— .
pli,s.u. 7, 2.i..u,,to Ca-Ctrictufn. 60
12C, nicsl Cd-Cadmitatt,ugil
— .
. .
Turbidity,yru CmCobalt,ugfl
..... „.. .
Chloilde, mutil Cr-Eirorninnil Total,ug/1
_ . . .
...... .. ....._.. ........ ..
Oil -and Grease, mcll Cu-Copper,00
_ •
. .._ .
Cyanl,de, tig,./1 Fesiron,ingil
---—
Fluoride, mg1 Ph-Lcad, up/1
... .
Hardness: Total,nigll Hg-Mercury, upli
!!
:MBAS, UPI Nis„Si'lek.el, ug,Il
CondUCZAVIty, UTIlhOS/cm 6,5,,G,..ia Semivefatiles S.EE ATTACHED SHEET(s).
. .... . „ ,
Dlssolved 0)xygen, mg/I 7,13(6...Lc VOC SETii AT FACEIED SH.F.E.T(s).
. _.
. .... . ....._
Temperature,QC -1 s,28,asa.ta
Alkalinity.rnEtsl_. 181 _ . . .
Chlorine, Ingit _
..--.
* denotes a violation of ia permit limitation.
denotes that sample was collected by grab method. —
— „

N-V\tE'OF FACILITY: Dallas.\l'i1"I.P Grab: Composite: X
Sample'Date%sl. 112712007-t I/28/2007 NPDf'S Permit No. NC006$5183
Sample Location! Influent Country: Gaston
POD , mg:'l 32) ` Phenols,uQll
COD: High, mg'I Sulfate., me
• COP) Low,ingll Sulfide,moil
Ct,6it'ttrm:Fecal,4:`I J0 tni Biomass: Dry' eight
Col,it(urin,Total,0,100 rrtil Biomass: Peri.,Ash.Free
•
Conform:Tube 3S Fecal,MPN till.-_`ti„nig°`1
Coli'crm:.Tube Total, MPN "6'ltiN; iug.tI 52
Residue: "Focal,mg/I NO2+:NO3,tng(I 0.02
Volatile,nig1 • PO, tog l
Foxed,mg"I P:Total, mgll
Residue: Suspended, tng l 3S0 F: Dissolved, mg`I
Volatile, mgl .=fig-Silver,ug'I
Fixed,m;g1I aa51-5lumin.urn,
iettleaible Solids,mill ' Be-Beryllium, ugll
ce.
P Il,s_u. Ca-Calcium,ug'`l
'roc, mg/I Cil-Cadmium,ug;/l
' Turbidity,NIT ' Co-Cobalt, uc,,'I
• Chloride,t1r:,I CI-Chromium. Total,ui?s"I
Oil and (rru ti e,nt,g`I Cu Clapper, ugr'I
Cyanide, ug l F: Ir,=r;.mgfl
Fluoride, met`I I'la-Lead, ug`I
"Herb Tot:IL mm'I }i `l resin, ttgrl
he1Ft\S, ug l Ni-Nickel,
•
Conductivity, umliosrc.trt Sernivolatiles SIZE ATTACHED Si1I-E°Ii"s'o
Dissolved Ox,iiigen, mg;`l V(IC SEE AT I`.;Af HE.G) 51011 I°i's`t
`I'eni.peratttrt_,°C
51k<tlirtiEm, ruti<1_. not
Chlorine, 'n5.'C
* der�o[e l'S a violation of a rrnit limo Sti.m
i i,�'!`yt 5
denotes that sample was collected by grab method.

r* . ; NI , „II
Y111411--- iii743.41
1
, ::,..4•,, 4'4 mor,444-,P. iiiit 5 - - = , “.,= A;c-!" 0' :l'.::•= "'",t14‘-3" dtti4" iLltg,k1 *I a
Iwo ill
)_, -,,;iirg.....tit.ou.,.,„0. ,i'ilaN ;0 -1' " " '
, ' ' ,
.1, , -,,
.44\ .IV'
-1-,,,-"N
-1f.:44,111,10:',,,,7'
''', - -.,`-f-, f-4;1743 , 4 ,- —- - • ,,,, ,-• • r . ... , t r.4„. ,. _ -4,, ...7.,,,,p,i I Wt ,
. .N • ,t/ • . ., Ntzt...- . ••••••-.4i4-•.A"'it;o4ii- it
,e . .,, 4;i1,„,,,,,,t,, ,,,,,,:i±ii,x,„„...,.,
D II WWTP /
- ' ' e
a - ' ' ,, " ..-
,.. ...,-: , -------1---
“ i -
41w,l,
.., . ' 'k i- , ,I"„ -mu-,,,l- , • ,,,•' : . . ... =- - .. .
4- ',...° °"'" . -...-;. t -.•• ""°°°--77.--tt,t,_1. r.7°- ' itillytt,„- • °' ••1
111°•°'•t '; ,,••,• . '-"t, *ar''',,,,,P ,,,:•,/,,, • •••,•;°•••' '•-•°"..".°4"; '''?".t.74•" '4'*...,.1.0!°1r7.`",.N..*:,:-'' '' -"''''''''''';'-'•--4..„ /iii N't '.,' `4°''''••:,'..t° „. • -` .'1,-4,-.„. 'I •.- ••:-.7.:-"°". °I
* • ' ' \ • •1'°•°..* ' •(' • -'-'- V"...--",-••X°11 -... • 1,7••1•11.*.•!, .1
'„,,,..,"••L",,°t. 'r .. " ° ''''.°°:, ,,,,,‘'''''°°°1.4. ',..!•T''.'4' L, „'',.*,:kc„-:-',:H.4,--,-,°,t,',:°;-.. 4::.'.' ,---,,,,:,.0..' 1,q"4---.1,- -.,--111!„1,'. . . - :. ;.'„,:-.7 ' it--,, :1-----,-- - ' ,'II/
.J,,-: ,4,,,,„,-. 11,,. , .. ,',„,,,: ,, c-,,,tis-,o(.. 44rit. ---‘o '- ' •:',g,':),„--1,-As:q411:- '' '''' '':'-'7' ''' '''"' ' ';r' ' : 16*,.....„. d" 1'
' ,;t:',.„::'- n-1,..-:L'-'• ,''' ',,'X'va:ir VY?,.1 ' '.""'"''''''''''1'.44''' ' IS,,,,,, ,,, '-,:':-. 1101(1-E t4cE, '"1: „, . - ) -*-:MI .. -...'''-'7*.° ,'
--,a
4"194141:,... . • ,,.,,, , ', - ,,, .,-4,16-,,,,-1,--i: :-, ,,t,--,,,V4- ,,,c) 'i ,:, - -'r '.\,,,,,0''':1' ''t''' . P.'..,0 (S' 1* ' ......'.....M. ' 'r'''
ill Ikt ' '1'4'i .7"41 " V r ,:'''''i'''''i ''''''' 'ill::.7. :,,..i:'7,',, i'l, 4 r; I '' ' ' ' .:".' , A.'''''', : 1,:.';n ty:': 1 71t't, ' '''•':44. '10: .............7 ' .... I. ,
1 it : 1 'VW '' 'L.11.. ' '4r;4.'''''' r'"5'.''.: ''.44,4A r '4, L, /i. n''?'', ' ' ,. '1 ' " 714% *'4''': "'''i71'.:t"'':.§C**-:• ••:0-4/404-",,,,:,,, 5' •,•:: . - , '' - , is ', V_-4:;,-..•,- ‘,.--T.:-;,,,-,ct,-4,40o00:s4114-C,'S ..•,c0, licc„,2"1111--if ..',,,, . ' ''' ' - - -, --'- '' - n'i -N'''',*Cc ' -'') ,•:,-iii.' - --, 1t(t' "-"-.•• ,'.4•, ,,, ' c--c Iti
-..-"':'-':',•.::"•1/4i4,, '-.",1•5 tif'-.Po? .-\\:A.,.11,7i. 4:- .,4t,.'`k.4)•' '%t,4,' ,t„, , , _ :'4 ',:;:V.,,e', ..-''1.:. itlf,.L'i it k.',_., 4 “,
\Is
-•' -•.,:(a.••:,),,, (-:',v/),,,,„ "z"",.... - :401, •»4 ::::••%1:---.)',. , .,,,,,,---''-i" .-_- 1.:, ,,„..,-;,, 4,,,,t- n-z..„ rt .. ';'!,-:,,.--,:1,‘-%:_,, ,„c---4' ,,!: ,.--(i :-!,-,f6,cgo•-y-, , •,. ':7,4 '• ', ;.*r,4 1 en% SAW tclikliti 0,4,7,-.0;it.; ....i,,' ,--7,:“Le4t, :.t ' ,744 r. : ''.,.,,,,...)',,,,r', ' R,7,'1, ) '.4,.-'k4'1,Q.:.'*-nr-::, ',",1,':',",;:,,,:r„
t ,\
i -j., ,.. -':‘,:.. r,, ,,..::!,r;
,,,-:-"-J.-;'4-110-11-14,10'!"'Ef.11, :.f-dir,r, -,-"--4,,,, ',..:. '-*.',,- ,,;.- '-'1,,, - ,,,,,\ ,.. ,,r 5.4.,,, , . 1.. ?,,,r.',,,,.ii.,,,, • ,.., '. . 4.',...1.., ',,,.',,' ,..,,,,,,-„..---r. ,
,........,,,,,, \ .._.,,,,?f,,,,,,i'*-,,,,.
\
„-,.4,\ ..:,..7,-...,,,,I, 1 H. .4..,,,,,...!. .44t7.,.:.,:::
)
;„),,„ ';0; .;.,„;0 :;: .' ,': , matt t, ,'-,7'4'.:','.',.!'';'.!Fr'','.:. ';''':.'
'k, -')\- ',,, ,---c-'" r,„,,,, .., . .,.. „.,a.%,., y:., w. ,. .....',.,.:A. .4,..,,.. - ,.,. ,,..........--,
,\....
V0*-7 , ', .,1- T.---''' , '""*,‘ ,,,44-"°,'-;,";7,11"1.:::,..,:•.'„;'''.• 1C ., r"„ - . ..--1.;-.._:'.•("--'9 ':',- 1. :-
-(7'>•-,:c. ( - •?"'"-','".0. '-44' ' '' •.• (,',: ,, '1/4--•;,'--,.§..•.(- , :'-7. '' ',, ':,1. -••,,,,,,t-',,:',-,:i..,.:•- tc 777, ':°:..-- 6.--::.t.-;';:' '-',.-;'.'
( ..,,, ,,..i,
....
1-Iipstream sampling site (Pet permit requirement )
2-Ef fluent discharge site
34)ownstreant site 1
4-Downstreant site in (per permit requirements)
Santpli lig ReStlitS:
11/27/2007
Upstream
Ternperature; 1 1 .7°C,
Dissolved oxygen: 8,96 rug;''1
Conductivity: 92 uslcui
PIT 6,1S sli

7-ttoNeristream .1„
Temperature: 16,84GC
Dissolved oxygen: 6.50 ingle
onductivity: 498 usecm
PH: 7.00 su
1)iftvristreatri H. (in stream bend)
'temperature: 15.38de.
Dissolved oxygen.: 0711 rriglt
Conductivity: 388 ussem
PII: 6,84 su
PONITnstrearilH (tbalivag. of stream)
'temperature: 15.60°C
Dissolved oxygen: 3.81 ingil
PH: 7.19 su
.1)aNvristream Sludge at dolvtistream location If)
-
Terriperattire. 15.72°C
Dissolved oxygen: 3.00 nage",
Conductiinty: 489 LIS/cm
Plin 7.14 su
11/28/2007
upstremil
Teinnerature: 8.82°C
Dissolved oxygen: 11.52 iing/L,
Conductivity: 78 usfcm
PH: 7.02 su
Fecal conform: 290 cifull 00nd
DCnilliStrearti
ternperature.: 1322°C
Dissolved oxygen: 3.51 !Tiger.,
Conductivity: 364 us cm
PH: 7,09 stl
Fecal Coli form: >20,000 cfu/100tal

A_\IAI.NTIC'AL RESULTS SHEET
NAM.P.OE 1.Ai II,]fY: Dallas VirVs'TP grab: X Composite_
• Simple. C:>atei;s.t: 11,127i2007 NPDFS Permit No. lit 0068.888
Sample Location: Ettlucnt County Galion
B( [)j,mg'I Phenols, ugli
COD, 1-iichs,ui l ,Sul fate, trts I
COE) Low, tnt:;,'I Sulfide, rng<f'I
Col tfor :1 cal,4`'100 ml
Biomass,�ttttyi t hr Dry'Weight
Colil'orm:-1 tail,#/100 ml Biomass Pero,,Ash Free
•
Colifo m. Tube:Fecal,, 1PN ,API '. rn,e l
Coliforu,Tube Total,;t1P l hKv, ntu'1
Residue, I utal, amid NO2- tit ti,j
Volatile, rng/I PO4,rn,i;/I
Fixed,rrtg:``l P: Total„ nip;I
Residue: Suspended, tug/I P: Dissolved,rtrgll
Volatile,, me l V.-Sifter,tt*il
Fixed,nue l I-. luntirqutn uptI
Settleable'Solids,ink! Be-Beryllium, ug°F`I
gIl,sr'', 6.99, Cm'a-(u'aIeium., ul;/1
"IOC me I • i d .'<rrintiunt up:`l
Turbidity,NTH C.it Cobalt, u,€ll
Chloride, tng`I Cr-Chromium, Total,
i.tg'I
Oil and Grease,mgil Cu-Copper, up/I.
C°t°eni,de a{'I 1Fe-iron,mg l
Fluoride,migil Pb-Lead,ug l
[I ii lrr-ss:Total,mg I H -.-A%4ereury, up;1
MBAS, uctl Ni-Nickel, upr"I
Condriet'ivir, umhoslerrt 568 miv,o a(ile; SEE,A°I`;1;',C1-1i:I3 SIIIPT(s)
Dissolveed Oxygen,nip I 6.65 VOC SEE ATTACHED Slli°.F`1'(s)
Temperature, C. I9,i;1
Alktrlinitt`,,togiL
Chlorine,nip L
denotes a violation of a permit limitation,
" t denotes that sample Was collected by grab method.

ANALYTICAL RESULTS SHEET
. . _. ___ . ..... .
N.,AME,OF FACILITY. Da WWTP (limb: Composite: X
. .
Sample Dater,$): 1E27.'2007-I I:28;2007 NP'{.)IlS Permit No. NC )068888
' Sample Location: Effluent County: Gaston
•
1! BOD5, awl 430 F'Lcnols,ug,ll
High, mg11 Sulfate,mg,ll
1 - - - . - - - --•-------- - ----•-• ----
1
COD.I...o W Mg1 Sulfide,mgll
Coliformr.Fegal,01100 tril >2000«ioota
Biomass-'Dry Weight
_ ... _____ ............. .
Coll form.Total,41100 nil Biomass! .P•tri Ash.Free
Conform.Tube Fecal,MPN NLE-N, ingl 28*
-- • •
Coliform.'Tube Total, MPN "1/1(N mall 8'7
Residue: lhotal,ingil NO-2 1-NO3, mg/I 0.36
-- - -- -- -
Volatile,toe l I _ PO„mgll
Fixed,ing/I P. Total, mg/I 22
Residue: Suspended, mg ill 1050* fl: Dissolved, mg ill
Volatile, dig ill , Ag-"liver, ugil
_ . ......_...
Fixed,mg/I ! Al-Alitininum, ugill
Settleable Solids,inlid ! Be-Beryllium, ugll
.. . .
III,sth .7,j.7(c,,b)
. C.,a-Calcium, ug/I
• 'FOC% 1 ll Cd-Cadinium„ogil !!
Turbidity,NTH CosCobalt,upll !!
1! ,.
Chloride, ing/1 I Cr-Chromiunt Toal, rigil
Oil and Grease„ mg/I Cu-Copper, urill .,
, t
Cyanide, mg/I ,Fle-Iron, ingli
Fluoride, rrigil Pb-Lead, ugll 1!
Hardness: Total, ingil FEdiMercury,ugll
• MLIAS, ogil Ni-Nukel,-ugll.
Conductivity,urnhosicth 6,5oisiis Semivolatiles SEE ATTACHED SHEET(s)
' Dissolved Oxygen, nigll 713(C.a.,AL,) V 0 C SEE ATFACIIED SHEE,Tes.).
Temperature,°C, I:!..,,,,,,28assib).
! Alkalinity,mg/t. 181
Chlorine, misst !!
- - " , I
denotes a violation of a permit limitation,
'.'-•"''''il denotes that sample was golleoied,by grab method,
- , --''—' ' ' — • -- - ' ' ' "

ANALYTICAL RESULTS SHEET
N.\\11.:;of-FACILITY: Dallas ww—rP (irate` Composite: X
Simple Hatters): I 1 /2007 1 I 8 20(Y", r'.'PL:)I S Permit No, Nl 00068888
SampleLocaiion: Intluca'ut County: Gaston
B(,)1[)5,rogll 320 Phenols, a t?I
(.:(tI) Hitch, ing l Sulfate.,me l
(_.:C71):Low,rni .I Sulfide, rn;11
Col form: Fecal,411(a)a:ni Biomass:Hry Wei*:•V.Iat
(`':olifarm:lotti)I,# 1C)iJ ml Biomiss I eri Ash Free
Coltt:arn: T"ulae Fecal, 'sIPti 'Ni-I •N,mg/1 38
Col Tube Total,l=.LPN 'l KN,me%I _5?
1 Residue: 'Total,tog-1 NO2 NO3,mz=`l 0,02
Volatile,tntsl P0 , rn_.'`I
Fixed, rngsl P: Total,mg/1 7.9
Residue-. Suspended,mc/1 :380 P: Dissolved.,tog l
Volatile, rood lc-Silver,trn l
es
Faxed, rug/1 Al-Aluminum, tip
Se'lie tOle Solids,mill. It Her\Ilium, ug I
: p11 stu. Ca-+'a.lcium, ua,'1
"IOC,nrh/I ('ci'F'-,admium,trail
ttrhidity,NI`t.' Co-Cobalt, up:i
Chloride,mil Cr-Chromium:Total,unll
Oil and Grease,togil Cu.—Copper, 110
Cyanide, u.Til i, Fe-Iron,nag l
Fluoride, mopr`1 10-Lcad, u,gti
Hardness:'Total,il,m(!I 1-1g- Icrc:rrrr,ucl'I
.NIB AS,u`p 1 Ni-Nickel, tipfI
- C'ttndul,tir it, unthos`sto Serii\"olatiles SEE,•'ITT 1('1IE;I:) SIIL:l f(.$)
L)is"solved Ox,ecn,mg'I \>O( SEE',ATTACHED S1{FL:4s)
Lcrnl,eratua'e,,i`C
Alkalinity:row 1.., 201
Chorine, tnp='I„,
* denotes a viooration or;t pe-riuit limitation.
b'tF}
denotes that stunple was collected by grab method.

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Michael t Easle. Governor
,.� r tl hash,v €r..ss is., Cecre ar
North Carolina k.:tart,¢°.ern of Environment ronment and Natural R sour-
Csoleen H Sullins,'-2!r^-uty Lesec,rr
Division of 'titer(uahrIr
November 5, 20.07
CERTIFIED MAI1 7007 0710 0005 2882 1516
RETURN RECEIPT RE,Qt ESTER
Mr. George Hughes
Town of Dallas
21.0 North Holland Street
Dallas, North Carolina 28034
Subject: NOTICE OF VIOLATION and
RECOMMENDATION FOR ENFORCEMENT
NOV-2007-DV-0272
DWQ Incident No, 200702691
Violations of C3.S. 14 -215.1(a)(6), 15_A NCAC 2B .0211(2)
and 15A NCAC 28 .0211 ( )(b)
Discharge of wastewater and sludge
'Town of Dallas, Dallas WWFP
Gaston County
Dear Mr. Hughes:
On August 30, 2007, Mr. Jim Fisher and Mr. Sam Whitaker of the Division of Water
Quality discovered a sludge spill in Dallas Branch at SR 2275 while sampling Dallas Branch for a
Watershed Stressor study. Mr. Fisher and Mr. Whitaker then visited the Dallas W WW1', which was
upstream from the sludge spill location and discovered that wastewater and sludge were being
discharged from the facility. Mr. Fisher and Mr. Whitaker conducted an investigation to
determine the extent of the sludge spill and any impacts to waters of the State.
The investigation by Mr. Fisher and Mr. VJutak.er found the following:
I. Sludge was found in Dallas Branch, a class C rater in the Catawba River basin, at SR 2275
downstream of the WWTP, ".,the dissolved oxygen concentration in Dallas Branch was 0,3
mg/L at this location.
2. Sludge was found in Long Creek, a class C v ater in the Catawba River basin, at NC Hwy.
279 downstream of the confluence with Dallas Branch and 0,6 miles from the WW P. The
dissolved oxygen concentration in Long Creek was 0.0 n gil... at this location.
tiorthCaro➢ina
}'atuIal/L'
North Carolina Division 01 Water Orlaliry 610 Estsi Center Ave,Suite 301 Mooresville,NC 28115 Customer Service
[lane (704)!,63 1.699 F&\ 1704 663,6040 1 S77-6i, t74L
;1n Equal i~sppc4duttity`A1`ftrrrr_itl,et`Action Employer Interne' h20 errr state..nc.us
111+o Reo:,,seled,r10%Port Consumer Paper

NOV row-uY-02
your ex lanati rr 'A°ill be forwarded to the Director, along with the enforcement package for her
consideration.
If'uiu have any questions concerning this matter, please d riot hesitate to contact Ms,
„Ally co or me at i4 3m 169 ,
Sincerely,
Robert B. Krebs
Regional SuperviSOI
Surface \ rater Protection Section
cc Bobledoc, NPF)ES Western stern Program
Jim Fisher, L.rry rorunental Sciences Section-lntc si\e Survey Unit
Gaston County Health Department
Central Files

Septemeer tin auui
Wes Bell
NCDENR
610 East Center St
Mooreavitle, N.C. 28115
Subject.Plant Upset, Dallas WWTP
Dear Mr. Bell,
At approx. 12:00 noon on Thur(8-30-07)the operator at the plant was notifyed by Mr.Jim Fisher that we
had soikis running Into the creek In which we dicharge into. The operator was somewhat confused,being he just
concluded his process control approx a hour end half before and everthing appeared ok.When notifyed by Mr. Fisher
he was just returning from checking the lift stations.He checked the unit, solids were coming over the weir.
Mr:Fisher suggested reporting it has a spill.At this time the operator notifyed me, I intumed notified the Mooresville office.
The operator increased the return,started wasting to minimise the solids overflowing the weir.
After talking with Barber and explaining what had taken place,and what was going on she recommend,
opening flow to the unit that was down for repairs.Which was done at approx.13:30,the flow over the weir cleared up
at approx, 16:30, at approx 19:00 flow to the unit that was not in service was dosed off.
I feel this problem was caused by several factors,We had took 1 Unit out of service for repairs to a diffuser
which put all the flow on the unit In service,which didn't pose a problem at this time, since each unit is rated for 300,000
gallons.We also started pumping the unit to be serviced into this unit at approx.63,000 gallons a day over the next 6 days
We had increased wasting to try and offset the increase in solids, but appears that it was not enough,this led to
the sludge blanket to increase,This combined with the flow at that time which was approx. 269,000 led to the blanket
overflowing the weir,
To keep this from occuring again we have took serveral steps,we have increased wasting,also during the high
flow we are opening the flow to the basin out of service which has stopped the hydrulic overload,we have had es of this
letter approx.222,000 gals. Of sludge removed from the clarifer,also approx. 110,000 gals of sludge removed from the
contact chamber where it seems most of the solids overflowing the weir were collected,We etc)have contacted
Southern Soil Builders to remove the solids&water in the unit not in service so that the repairs can be made, samples
were pulled on 9-5-07 just has soon has the results are completed,Southern Soil should start hauling hopefully by the
end of next week.We also checked the stream there seems to be no solids eccumlation, that night of B-30-07 we had
a shower that showed a rainfall reading of approx. 1!2"of rein.
Hopefully this will not occure again. Thank you for your understanding,If I can be of further help
please call,704-913-4315,
Thank You, 1
Vl/
a e Hughes

FACSIMILE COVER SHEET
TOWN OF DALLAS 47P/ WWTP
210 North Holland Street Phone Number 1-704-922-1309
Dallas, North Carolina 28034 Fax Number 1704-922-1309
SEND TO „FROM
e.-
ATTENTION DATE
T .7
FAX NUMBER PHONE NUMBER
Urgent Reply ASAP Please Comment Please Review. FYI
Total pages including cover sheet e—S
_ .
— -
. .
.
. .
- —

December 2, 2007
„. . . v „„ , ...„..„. . ... „........,„ <
2
Mr. Robert B, Krebs DEC 7 007
Regional Supervisor
rviR0
610 East Center St,. NC DER
Mooresville, N.,C, 28115
D‘VS-Surface W...er ProtectTori i .
Subject: Notice of Violation and Recommendation for Enforcement
DWQ incident No< 2007026.91
Dear Mr, Krebs,
The fetter that was faxed to Mr, Wes Bell on 916/07 was the response to your NOV letter dated
November 5„ 2007.. I have nothlng to add to It,
Si cerely, I
c\,,,,,,,
2-- - ' ;8„,
George Hughes

Subject: Re: Sludge Spill - Dallas Branch - Dallas NC
From: Dianne Reid <dianne,[e-mail]>
Date: Fri, 31 Aug 2007 12:21:02 -0400
To: Jim Fisher <jim,fishergncmall,net>, Sam Whitaker <sam„whitaker@hcmail,net>
Thank you for your work on this and for the concise report. I 've passed it on to
Jimmie. Dianne
,n Fisher wrote:
PM) Environmental Sciences Staff, in Fisher and Sam Whitaker, while sampling
Dallas bh in the Catawba Basin for Watershed Stress or Studies, noted a qludge I spill in Dallas French at SR 2275 Casten Co. ( Robinson, - Clemer Rd. ) in Dallas
NC en 8/20/2007 at 1130 AM, Physical data was taken ( Temp. - 26 ,5 0C, DO - 0 .9
mg/I, pH - 7. 0 su, P. Cond. - 624 umhos)and the chemical samples slated ( Tot- P
& metals) for this stream were taken.
; We, then went to the Dallas wastewater treatment plant to see what was going en
and found one of the operators, a Mr. Kirby Case and told him there was sludge in
• Dallas Brenda at Robinson - Clemer Rd. ) . We then walked over to one of the two
waste are plants an the site and saw that sludge was going over the weir in
the clarifier. and then checked a manhole to the, outtall pipe and saw sludge in
it. I asked Mr. Case if there woo anyway to shut the flow cf sludge off_ He
informed me that the ORC. a Mr. George Hews, had just left, and that they were
pumping sludge from one plant to another. because. they had, lost that plant a few
weeks earlier. Mr. Case said he would call Mr. Hews about. the spill . I told him that they needed to call the Field Office in Mooresville and report a spill and
that I would call the Mooresville Office also. I called the Field Office and
talked to Barbara Sifford and reported the spill . We then went to the upstream
sampling site for the treatment plant on, Dallas Branch and saw that it was clear
and took physical measurements ( Time 1240, Temp. - 23. 0 °C. DO - 7 .5 mg/1 , pH -
6 .9 su, , Sp. C at. - 105 umhos. ) . I walked down to where the effluent pipe went,
into the stream and saw that sludge and wastewater were coming out of the pipe,
In subsequent phone calls to. Barbara Sifford she said that Mr, Hews had caled
her and they decided to divert the wastewater flow to the plane off line, stop
pumping sludge and let the plant with the hydraulic dverload settle down.
Barbara :file ,' asked how far the sludge had traveled, so we went down to the next
larger creek which was Long Creek at. NC Hwy. 279 and found the sludge in the
stream and took, physical measurements Slime 1215, Temp. - 27.0 °C, DO
7 . 0 au. . Sc , C:', - 240 umhos) .
We went back to the Dallas wastewater treatment plant and Mr . Hews was there
and we talked about his convez-sations with BaFbera Sifford and the solutions to
the problem they had discussed. We looked at the clarifier and saw that the
' effluent. was clearing' up and the sludge. blanket in the clarifier was going down,
Mr. Hews asked about pumping the sludge out of the stream and I told him I didn't '
se that much access to the stream only a small section at the road crossing,
don't know how that was resolved. We talked to Barbara Sifford again and told her I
what was going on and that we would go check the next downstream bridge Ca Long
Creek and call her, Ca the way to Long. Creek we stopped by Dallas Branch at
oçc - Clemer Rd, and saw thdt the stream was still, dark with sludge and. that
the flow was down and that a thin layer of sludge had coated, the sand in the
stream where the flow had. receded. We checked Long Creek at Dallas- Spencer
Mountain Rd. and determined that the sludge hadn't gotten that far and took
Physical measurements ( Temp. - 25, 2 °C, DO - 6.3 mg/I, pH - 7. 1 su, Sp. Cond.
I 19a umhos) . Called, Barbara Sifford again and. reported (cur findings and fill her
:' that we were gojng on to Stauly NC to sample two streams near there.
Dianne Reid
Supervisor - Intensive Surveys Unit
NC DENR/Division of Water Quality
p (919) 733-6610
f (919) 733-9959
,Cl Mail Beovice Center
lot 2 9/1212007 1.44 Pk •

illiart C.; Ross Jr.,Secretary
yr ' orth Carolina Department of Envtronmerr and Natural Resources
r
-1 Alan Vd'. Klimek,P E Director
C C Divisnin of\artr Qrsalirr
November 27, 2006
CERTIFIED M:AIL..
RETURN RECEIPT REQUESTED
Mr. Steve Miller, Town Manager 7003 2260 0001 3494 8971
Town of Dallas
210 North Holland Street
Dallas, North Carolina 28034
Subject. Notice of Violation
Compliance Evaluation Inspection.
Dallas Wastewater Treatment Plant
NPDFS Permit No, NC0068888
Gaston County, North Carolina
Tracking No. NOV-2006-PC-0529
Dear Mr. Miller,
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection conducted at the subject facility on November 9, 2006, by Mrs. Sonja Basinger of this
Office. Please inform the facility's Operator in Responsible Charge of our findings by forwarding
a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) because of the limit violation
and previously cited documentation and operation./ maintenance violations of the subject NPDES
Permit, North Carolina General Statute (G.S.) 143-215.1, and 15,\ NCAC 214 ,(:)805 (8)(0(1) as
detailed in the Record Keeping, Laboratory, and Effluent Pipe sections of the attached report,
Pursuant to G.S. 143-215.6A., a civil penalty` of not more than twenty-five thousand dollars
( 25,000.00) per violation, per day may he assessed against any person who violates or fails to
act in accordance with the terms, conditions, or requirements of any permit issued pursuant to
G.S. l43-215.1.
It is requested that a written response he submitted to this Office by December 27 2006
addressing the deficiencies noted in the Record Keeping, Bar Screens and Standby Power
sections of the report. In responding, please address your comments to the attention of Mrs,
Marcia Allocco.
FilttENR
N C.Division of Water Quaor'r,'r ottresville Rem+„icttal Office,610 East Center Averno,Suite 301,Mooresville NC 28115 (704)&13-1699 Customer Seir ice
1-377-623-6 as

Mr. Steve Nlilier
Page
Noveniber 27, 2006
The report should be self-explanatory, licallover, shotild you have any questions
concerning the report, please do 'lot hesitate to ct)tatact Mrs, Basinger or me at (704ii 663-1699.
Sincerely
Michael L. Parker
,Acting Surface \ rater.)totectiori 111egional Stiperviscir
Enclosure
cc: Gaston Cotinty Health Department
t
SNVB
f4,11;b*'1"nr.mil
N t":.Di3ist er..33t'Water Quality,I.1coresa=ilte Regional Offices.610 Fast.Center, venue,Suite 301.\ti cres olly NC 28115 670,1)663 16 0) Customer Serving .....

----- ------------------ ------ ' 3 - - , ... ,.
Umted States Erivironme6ta FrOtedlc,n,A.1;eriCy
Form Approved,
9 t EPA Wa stling Ion,[71 C,20460
OMB No. 2040-0057
Water Com.Nance instection Resort Approval expires 8-31-98
Section A. National Data System Coding (tie., PCS)
Transaction Code NPDES yrifr,c,"ja!I trispection Type inspector Fac.Type
1 I NI 2 Li 3 I NC.il 0 6 8 f.3 8 a 1 1 1 121 0612/09 I 17 181 ci 191 :5 I 20 I I
,,..--, 3.1
Remarks
"2111111111111111111, 1111111111111 ( 1111111111111i1�e
inspection Work Days Facility Self-Monitcring Evaluation Rating B1 QA -Reserved-
67 I 2 i 0 I 6.9 70L1 71 Li71 721 Ni I 73[ I I 74 75 I I 1 III ".
. .. _ --- - — ------- -
Section Bi Facility Data
, ... . .
Name and Location of Facility inspected(For Industrial Users discharging to PO TWi,also include ' Entrii Time/Date ' Permit Effective Dale
POTVii name and NPDES permit Number)
09:45 arii 05/11/09 05/10101
ill,15
. 7 04 fe, 116.,lly St : Exit Time/Date Permit Expiration Dale
Da 11 a 3 No 2 80 3,1
' it i 5.5 A11 06/11/09 10/01/1J1
Name(s)of Onsite Represerrative(s)ITitles(s)/Phone and Fax Number(s) Other Facility Data
1,.George ;4 1461g4-1 e 8/CRC/7 4 4-922-1309/
Name,Address of Responsible OfficiallTitletRhone and Fax Number
Contacted
'St:e v e Miller,210 NI Holland .6:4, fl,-z 1 1 a:3 NC 2833342 7 4 9,64'66.4.61
a'24 4'7 Go Niti.
Section C„ Areas Evaluated During Inspection(Check only those areas evaluated)------ ....
Permit III Flow Measurenlent II Operations& Maintenance III Records Reports
:4,•..,ii, Self Monitoring Program III Sludge Handling Disposal III Facilify, Site Review II EffluenfEeceiving Waters
Laboratory*
Section a Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessar))
(See attachment summary)
.. f
. „.......
' -- --
Name(5)and Signature(sti of inspector(s) Agency/Office/Phone and Fax Numbers Date
Son j a Basinger Z4160
_ 2 --. 1.10 v 2 Po 6.1
- - "
,
Dale
Sii fili.,re of Management QA Rexreiiver
- I. • )CC-3.13.._.C___it, $-61.--„,_.„._..,,,,e:'-..k,,,„Lar2.(1_,.. ,,C7.„,....,C)
Agency/Office/Phone and Fax Numbers
1„tic i a AlioCCO ---- - ---.' M RO ';'.1 QI/70,1-2 35-2201/ ,
Ep,s,Form 3560_3 (Rev 9594)!Previc,kUS editions are obsolete,
Page# 1

NPDES mo'day inspechon Type Tont 1
3
I MC110 698 8 I 11 12 17'08111109 18 1,8j,
Secbon D Summary of FtrychrgiComments(Attach addmna1 sheets of narratIve and checkhstS 3S neCessary1
RECORD KEEPING SECT ON continued'
DMRs were reviewed from August 2005 through July 2006, A Vileekly average effluent BOD violation was
reported for May 2005 Monthly average effluent BOD and ammonia-nitrogen violations were reported in
June 2006, VVeekly average effluent fecal rot form violations were reported for May 2005 and June 2006, A
TSS 99 removal efficiency violation was reported for June 2006 The Division has separately addressed the
above-noted violations by issuances of either a NOV or NOV/civil penalty assessment.
The facility did not comply with the monthly TSS removal efficiency for September 2005. This violation
will be addressed by this inspection report
Weekly average effluent BOO and ammonia-nitrogen violations, a monthly average effluent
ammonia-nitrogen violation, and three (3) weekly average effluent fecal coliforni violations for the April 2006
DMR will be addressed under separate cover,
As previously cited in the October 19, 2005 inspection, the CRC must ensure all "'less than values are
appropriately calculated for the monthly average values The DN1Rs are still being calculated incorrectly as
of this report's inspection date,
(Note The ORC was given a copy of the Division's DMR Calculating Procedures by the inspector on the
date of the inspection),
Page# 2

•
Permit: NiCli08888 Owner-.Facility: Dattas tillitvt/TP
Inspection Date: 1110912006 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? Unn n
Is all required information readily available, compete and current? U 0 El 0
Are all records maintained fOr 3 years (lab, reg required 5 years)? U 0 0 0
Are analytical results cc:insistent v th data reported on DMRs? • n n n
is the chain-of-custody complete? U n n
Dates, times and location of sampling 11
Name of individual performing the sampling •
Results of analysis and calibration
Dates of analysis
Name of person performing analyses •
Transported COCs •
Are DMPs complete do they include all permit.parameters? linnn
Has the facility submitted its annual compliance report to users and DWO? Ennn
of the facility'is =or> 5 MOD permitted flow) Do they operate 2417 with a certified operator on each shift? D El • n
Is the ORC visitation log available and current?
Is the CRC certified at grade equal to or higher than the facility classification? annn
IS the bar,,ikup operator certified at one grade less or greater than the facility classification? NOOD
Is a copy of the current NPDES permit available on site? U pn n
Facility has copy of previous year's Annual Report on file for review? II F..) no
Comment, See attached "Summary" section for additional comments,
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?. 00 • 0
Is the facility as described in the permit'? MOOD
#Are there any special conditions for the permit'? nnun
Is access to the plant:site restricted to the general public? RE100
Is the inspector granted access to all areas for inspection? MODE)
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? li000
Page# 3

Permit: NCOC.68388 Owner-Facility: Da as M"ITP
Inspection Date: 11.,'09/2006 inspection Type. Compliance Evaluation
aerations & Maintenance. Yes Na NA NE
Does the facility analyze process control parameters, for,ex, MLSS, MCRT, Settleable Solids, pH, DO, Sludge • 0 0 CI
Judge, and other that are applicable?
Comment. Maintenance invoices from contracted services were available for review
during the inspection. The facility does not maintain a maintenance log for daily
maintenance activities.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? U D D 0
Are all other pararneters(excluding field parameters) performed by a certified lab? • 0 D
Is the facility using a contract lab? • 0 0
Is proper temperature set tr sample storage(kept at 1..0 to 4.4 degrees Ceisius)? • 7 0 n
Incubator(Fecal Colifo.rm) set to 44.5 degrees Celsius+/- 0,2 degrees? 0 0 •
Incubator (BOO)set to 20 0 degrees Celsius +I- 1,0 degrees? 7 7 IN o
Comment. On-site field analysis are performed under Field Laboratory Certification #
5110, Contracted lab services are performed by Tritest (# 103).
During the inspection it was noted that the field lab staff are not documenting the units
of measure on the lab bench sheets and the sample volume for the Settleable Solids
parameter. In a response letter dated August 11, 2006, the Town of Dallas'
representative stated all lab deficiencies for the March 3, 2006 lab inspection were
corrected.
Flow Measurement - Effluent Yes No NA NE
# Os flow meter used for reporting? • 0 D E.1
Is flow meter calibrated annually? IN FL Li n
Is tbe flow meter operationaR Nunn
(If units are separated) Does the chart recorder match the flow meter? • n n n
Comment; Ken Nash Company, Inc, last calibrated the flow meter on 11/6/2006. The
flow meter is calibrated twice per year.
influent Sampling Yes No NA NE
# Is composite sampfing flow proportional? • 000
Is sample collected above side streams? • D 0 0
is proper volume collected? U n
Is the tubing clean'? NIDDD
is proper temperature set for sample storage (kept at 1 D to 4 4 degrees Celsius)7 MI 0 n
Is sampling performed according to the permit? U n 0 o
Page

Permit: NC00u88 8 Owner w Facility: Dallas VtiV/fP
Inspection Date: 1110 /2006 Inspection Type: Compliance Evaluation
Influent Sampling Yes No NA NE
Comment; The influent composite sampler was collecting 100 mis per aliquot. The
sampler was sampling every 10 pulses (10 pulses/ 2770 gallons).
The facility adds lime for pH adjustment to the influent,
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical ❑
Are the bars adequately screening debris? 0 ■ n n
Is the screen free of excessive debris'? ■ ❑ 0 n
Is disposal of screening in compliance'? II fl n °l
Is the unit in good condition'? U ODD
Comment, Debris (grease, plastics, etc) typically removed by the bar screen were
observed in the chlorine contact chamber. As.previously cited in the October 24, 2005
DWQ inspection letter, the bar screen and supporting concrete structure should be
evaluated (underneath the water level) to verify that there are no bypasses to
downstream treatment units.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots'? DOOM
Are surface aerators and mixers operational'? noon
Are the diffusers operational'? EDO n
Is the foam the proper color for the treatment process? n * n (�
Does the foam cover less than 25% of the basin's surface? 0 . 00
Is the DO level acceptable? ® Q n
Is the DO level acceptable? 1,0 to 3.0 mg/I) n n ■ n
Comment; Excessive foaming was observed in the aeration basins. The ORC stated
that one of the trains was taken down for digester maintenance.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastew.ater? 11000
Is the site free of excessive buildup of solids in center well of circular clarifier"? ■ n n
Are weirs level? ■ n 0 nl
Page # 5

Permit: NCOOF8dea Owner-Facility: Dallas NOifirlb
Inspection Date Iilher2006 Inspection Type. Compliance Evaltration
Secondary Clarifier Yes No NA NE
Is the site free of weir blocleage? 0
is the site free of evidence of short-circuiting? n 0 n
scum removal adequate? annn
Is the site free of excessive floating sludge? 0 0
ts the drive unit operational? 0 D
is ttie return rate acceptable how turbulence)? M000
is the overflow clear of excessive solids/pin floc? 11 a ri
is the sludge blanket level acceptable?(Approximately of the sidewall depth) n n 0
Comment. The clarifiers effluent appeared turbid on the day of the inspection,.
possibly due to the maintenance of the digester_
Aerobic Digester Yes No NA NE
is the capacity adequate n
is therrOxing adequate 0 0 n
is the site free of excessive foaming in the tank 2 Florin
#is the odor acceptable? Ennii
#is tankage available for properly waste sludge? annn
Comment Foam carry-over from the aeration basin was seen in the working digester.
Note; One of the digester's was out of service for maintenance on the day of the
inspection.
DiStrifectioneGas Yes No NA NE
Are cylinders secured adequately? M000
Are cylinders protected from direct sunlight, n000
Is there adequate reserve supply of disinfectant? n n
Is the level of chlorine residual acceptable? nn0a
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de of 10 natro 0 0 n
Does the Stationary Source have more than 2500 lbs of Chlorine(CAS No 7782-50-5)2 0 0 0
If yes, then is there a Risk Nlanagernent Plan on site? DODE
If yes, then what is the EPA twelve digit ID Nur:fiber?(1000- )
lf yes, then when was the RN1P last updated?
Page # 6

Permit: NOC)088888 Owner-Facility: Dallas' AP
• Inspection Date: 1110912006 inspection Type: Compliance.Evaluation
Disinfection-Gas Yes No NA NE
Comment Floatable debris, foam and grease was observed in the chlorine contact
chamber on the day of the inspection:
Standby Power Yes No NA NE
Is automatically activated standby power available? • n 0 n
is the generator tested by interrupting primary power source? Ennn
Is the generator tested under load? • nnn
Was generator tested & operational during the inspection? 0 N 0 0
Do the generator(s) have adequate capacity to operate the entire wastewater site? Minna
Is there an emergency agreement with a fuel vendor for extended run on back-up power? • 000
Is the generator fuel level monitored? Ennn
Comment: Documentation for the generator check (under load and fuel check) was
not available as requested during the inspection:
Effluent Sampling Yes No NA NE
is composite sampling flow proportional • 0 0 0
Is sample collected below all treatment units? 111 non
Is proper volume collected? WOOD
is the tubing clean? S U 0 0
Is proper temperature set for sample storage(kept at 1.0 to 4 4 degrees Celsius)? EU 0 Cr
Is the facility sampling performed as required by the per nit(frequency, sampling type representative)? • 0 0 C.1.
Comment: The facility was using a Tritest commercial sampler for effluent sampling on
the day of the inspection,
Effluent Pip_q Yes No NA NE
Is right of way to the outfall properly maintained? WOOD
Are the receiving water free of foam other then trace amounts and other debris? Dann
If effluent (diffuser pipes are required) are they operating properly? 0 0 Mi 0
Comment; There was approximately 4 feet of floatabie biological solids on the
receiving stream on the day of the inspection.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency., sampling type,, and sampling location)? • 0 0 0
Comment:
Page# 7

".\\Q
0 WI I ham G.Ross ,S,t,t-cretary
7 North Carofintt Ettita.rtmcot of Eriviconant and Nattuat Resource:3
> • . • Alan'\,11 Kiarttk, P E. Director
5 • s -r, Division of Waret Quatiry
February 14, 2007
CERTIFIED NIAIE 7006 2760 0001. 8493 6968
RETURN RECEIPT REQUTSTED
N4r. Steve Miller, Town Manager
Town of Dallas
210 North I-loll:and Street.
Dallas, North Carolina 28034
Subject. Notice of Violation
Follow-up Compliance Evaluation
Inspection.
Dallas Wastew-iner Treatment Plant
NPDES Permit No, NC0068888
Gaston County, North Carolina.
Tracking No. NOV-2007-PC-0103
'Dear Mr. Miller,
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
follow-up inspection conducted at the subject .facility on February 7, 2007, by Mrs. Sonja
„Basinger of this Office., Please inform the facitity's Operator in Responsible Charge of our
findings by forwarding a copy of the enclosed report,.
This report is being issued as a Notice of Violation CN(iV) because of the previously cited.
permit condition violation of the subject NPDES Permit and North Carolina General Statute
143-215.1, as detailed in the Effluent Pipe section of the attached report. Pursuant to G.S,
143-215.6A, a it penalty of not more than twenty-five thousand dollars ($25,000.00) per
'violation, per day may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G,S„ 143-215.1.
It is requested that a written response be submitted to this 6)f:11ce by Ntarch 1 , 2007
addressing the violation noted in the Effluent Pipe section of the report. In responding, please
address your comments to the attention of:Mrs, Marcia Allocco In addition, the response shall
include the facility's corrective actions to address the excessive biological solids and foam in the
receiving stream..
4474
„.. . NCDENR
c. Dtvi.5,0,1 of Qualir? 1 Rqional OtIL e 61.0 Eas( .Stit%301 MoorosNittt NC IS 1 5. 663-]699 CastancT Si
1-ST7-623-6743

Mr. Steve Miller
Page
February 14, 2007
The report should be se1tn v:trlc r afar , however, should feu i a! c: arl\-questions
concerning the report, lea e do not hesitate to contact Mrs. Basinger or me at ( 0 ) t 3-16 99.
Sincerely,
108' J ihu Lesley
Acting Surface \\"ater 1'r to tin Regional Supervisor
Enclosure,
cc: Gaston County Health l)el rtrr1 t t
\ `l l
NCDENR
c 06688oc 7 'r,pater a tualtr,8 6268swk91c E et;pona1 Office, 31E East t ev r Avenue,Stnte'ti.t1,P xtoetae,c°rll°Svc.28115 (70,1)far,.1r.99 fi..sa,€osne¢S rVI

..ir _ Fed States Erraf me to p,-Qiiesaitir,Agency Form Approved_
EPA `a,h,n�r,c�,C a
QMB No2U40-0t'r57 d
Water Compliance Inspection Report Approval expires 8.31-93
Section A, Nationai Data System Coding (i e , PCS)
Ttar=saction.Cede NPCE,S yr:mo•"oay Insp.ection Type InsFecter - Fac Type
1 I NI 2 1 s1 3I C:00,1tr8ga 111 121 07;,`_, w_ I 1. 151_CI 191 1 20
' l
�� ti
Remarks
"1 1 1 I [ III. I I I I I I I I I I I I I I I l II 1 1LAL I I I I I I I L I L I I I I Ier
i nsFencn cvork Darr, Facility Self-Monitoring Earalrra.ior Rating B 1 0,A
671 2.0 I 69 70I_3I ° I°I 2It1I ��.� 4 "sI III III I o
Section B' Facility. Data
Name
and Locat name ion f tS isNumber)t For Industrial Users discharging to Pa; tti°!,also rn 'ride Entry Time Gal? Pe
rmit Effective Date
i 4 y: Ho 1 L y u;r ' 'xit TtmerDale Permit Expiration Dale
Dallas tic 2tll113; 11 :30 Ar' u ✓ 2/07 01I31
Name,(sl of Onsite Re.FF`resentative(s/Tttles(s),Fhone and Fax Number(s) Other Facility Data
if i
Nat':r.«e„Address of Responsible 0fftciat TitlelPtinrre and Fax Number
r.,+r) st lleA .? '� ,a _.,-,v ?`', 2903427,19 r`'I03,i:
Contacted4 .,_ _ ._`o' 17� i `� 11v,
Section C- Areas Evaluated During Inspection (Check only those areas evaluated)
is Permit IN Flow Measurement II Operations & Maintenance II Records/Reports
jSeif-Monitoring Program II Sludge Handling Disposal III Facility Site Review II EffluentiReceiving Wafers
III Laboratory
Section 0 Summary of Findinq(Ccr invents (Attach additional sheets of narrative and O henktists as necessarri
(See attachment summary)
Name(s) and Signatue(s) of d . ctor(s) Agency Offu erPhone and Fax Numbers Date
S±y1'iart�re of fianager CM^u Reviewer Agency ffice'r!one and Fax Number's Coate
PA Form 3 50-3(Rev 5-94) Previous editions are obsolete.
Page # 1

tat,
Permit: NCOO68888 Owner Facility: Dallas ibiriCITP
inspection bate: 026)71200d Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months, or less) Has The permitted submitted a new application"
is the laciley as described in the permit? n 0 n
#Are there any special conditions for The perma" nnan
Is access to the plant site restricted to the general public" n 0 ri
Gs the inspector gran1ed access hator msoection" n
Comment,
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping" anrin
Does the facility analyze erocess control parameters for ex; MLSS, MCRT, Settleable SolGds, pH, DO Sludge n000
„dodger and other that are agblmabte"
Con-talent,
Laboratory Yes No NA NE
Are field parameters' performed by certified personnel or laboratory' a Pi 0 n
Are all other harametershehthud[ng field parameters)performed by a certified iahn 0 0 0
Is the far My using a contract iab? ri n n
is proper Temperature set tor sample storage(kept at 1 0 to 4 4 degrees, Celsius)? annn
Incubator(Fecal Colitorm)set to 44 5 degrees Celsius's"-0 2 degrees? 0000
Incubator(BOD)set to 20 0 degrees Celsius Ho 0 degrees? 11 n n
Comment: Rease see Mr. Chet Whiting's report for the facility's on-site lab inspection
conducted on February 7, 2007.
Bar Screens Yes Na NA NE
Type of bar screen
aMarua
b Mechanical
Are Petars adequately screenisig debris? n0 n n
is the screen free of excessive debris? fl n n
is disposal of screening in compliance? n 0 171
lote unit in good coftition? fl 0 11
Comment: The. VONTP staff have increased the bar screen cleaning to 2 to 3 times a
day.
Aeration Basins Yes No NA NE
Page # 3

Permit: NCr_€D8v,. Owner F Faciisty Dada
Inspection plate. 02i0D2oort Inspection Type: Corrks nre Evraffation
Aeration Basins Yes No NA NE
Rode of operation in es
Type of aeration system t€u;s
Is the basin free of dead spots?. 0 0
Are surface aerators and mixers operational? 0 f 0
Are the diffusers operational? 0
Is the foam the proper color for the trFeatrnent process? a 11 nf�l
Does the foarir cover less than 25de of the basin's surface 0 {"l
is the DO level acceptable 11
is the DO level ac.eptahle"l t p to 3°raga a 0 0
Comment: Foaming in the aeration basins was still present! h w ver the foam
coverage has lessened to approximately 59/0 coverage.
e
Secondary Clarifier Yes Pao NA NE
Is the clarifier free of black and odorous wastewater ff l 1 l i
is the site fr e cf excess e buildup of solids in center well of cirsuiar clarifier? 0 0 1 1
Are weirs level' 0 El l
is the site free of weir blockage? son
Is the site free of evidence of sho.rt-orrcuitsr,pc
Is spurn removal adequate Cal El
is use site free rst excessive flvatrr7p sftrdtker..r
is the drive unit operational? annn
Is the return rate acceptable (ta,aw turbulence) II 0F1
Is the overflow clear of excessive suI dsi't n floc? a 0'
is the sludge blanket fekei acceptab pprc xtrs~rately da of the sidewall depth) l l l
r illrr e t: The east clarifier unit was clear with very little pin floc
The west clarifier unit was cloudy with light pin floc.
rat Cister Yes No NA NE
Is the capacity adequate? II a
is they MAIngadequate?r El 11 El
Is the site free of excessive fcr,r rarr c ar the tank? a E E f
#,s the odoracceptable? annn
Page# 4

Permit NCOOrtiaidrita Owner-F hey adas
Inspection Date. C2-011-20C11 inspection Type: Compharce Evaluation
Aerobic Digester Yes No NA NE
is tankage available for properly waste sludge', n
Comment, The irfist digester unit iwas back in service at the time of the inspection,
Standby Power Yes No NA NE
is at actuated standby power apailiiibie? go n n
Is the generator tested by interrupting hogiargi power source 0 0
is tine generator tested under lead? 0 n 0
Vales generator teSted &operational duang the inspection? 0 0
De the generater(h) have adequate capacity to operate the entre wastewater site? aOnn
is there en emergency agreement with a friel vencior for extended run on back-up power? ri 0 n
Is the generator fuel level rfforgoredff n U n
Comment, Craft Power will begin doing quarterly under load generator checks in 2007.
A quick connect (for the use of a portable pump) has been iiiistalled at the influent lift
station.
DiflueritsSamplibg Yes No NA NE
n
corripos m rt ite sapling flocs prapoiona[11 ▪ n
u
Is sample collected below all treatment f nnntsd
Is proper volume collected? 0 0
is the tubing cledn? gs n n n
15 Draper temperature set for sam ple storage (kept at 1 0 to 4 4 degrees Celsius)? ▪ 00
e nnn
St he facility sampling performed as required by the permit (frequency, sarspang type represecitativeff1
COMMenti The facility has an °see 3'7'0 composite sampler, The sampler samples. 100
iTils every 10 pfdses (1.0 pulses / 2770 gallons)
Yes No NA NE
Effluent Pepe
ta right of way to the pude]propeay masffalffeds jonnn
n
Are the receiving water free eti foam other than trace anou nd o Pit no n
rnts a er debris?
dff a d h ro ri
if effluent. ( iuser pipes re require ) are tey operating pperiyit
Cc ent: The effluent appeared turbid with excessive foarrii (white billowy) in the
stream
The facility staff failed to remove the accumulation of biological solids in the receiveig
stream as noted in the November 9, 2006 inspection report. in addition, the area
affected by the solids has increased to incluile white biiiowy foam,
Page F 5

A, t
13efore and After Pictures

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a �..

Permit Limits and Conditions

r
_
crz alit: `u=t...O06888
(1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During in. a period beginning on. October 1, 2005 and lasting until expiration, the Perna.ittee is autht-eu rvd to
di i,.ori from outC:,ll 001, Such. e.Fi r ir'a-Ex,e:•s shall be limited and monitored be the Pe mittee as .'17,,e3ci0,ed h,clos,
EFFLUENT LIMITS MONITORING REQUIREMENTS
CHARACTERISTICS _
Monthly: Weekly . Measurement ' mpl Sample Type Sample Location1
Averase Average Frequency
t=tvar 0,6 MOD • Continuous Recording influent or Effluent
13,0 mg_
19.5 mg'L.�__._
8,0D,5 day(20'0)
3r�"��ee (ernpC_.41 I,,uenl Z,nd Effluent
' (April 1 -October 31) '
600, 5 day(20°C) 2 26 0 mg/L 39,0 argil. 3,4eek Composite lfftuer+t and Effluent
• i
govember 1 -March 31)
Total Suspended'Salids2 30,0 mg.rL 45,0 mg/L 1 `lVeek Com�presttt _.. ,rifIt c'i and Effluent •
Ni1 as N ,2.0 o tL fi n9/L 3VVeek Composite _l_.__ E<<.itrtint
(April 1 October 31 _
l_
NH3 as N 4.0 mg/L. 12,0 mg'L 3/Week ' Composite 1 Effluent
(November 1 --March 31)
Dissolved Oxygen' 3z�'0leek Effluent
Ul s,'fre>�tn Downstream
Fecal Coliform(geometric mean) ' 2'00/ 100 mt 400/100 ml 3/Week. Cr at Effluent
lL daily maximum 3./Week Gras, �___-
Total Residual Chlorine/4 18 W9 ! Efsyj..nt
Temperature ��i°ti . . { - _. .to
EttlG
l ot
Lrclost am a Downstream_ _ __wTotal Nitrogen NO +NC1+TK:N) Quarterly Con or:. Cfflurt
m_.
Total Phosphorus h l�
,(
Quarterly rls r`:n l:,zns-e L.tilJ'-'tl
pH > 6,0 and < 9,0 standard units 3/Week Grao ' Effluent
Chronic.Toxicity's Quarterly Composite Effluent _�
Footnotes:
1, Upstream = at least 100 feet upstream.from the outiali Downstream at NCSIT 2275. :tnstrcam samples shad. 1.e.
collected three times per week from,Jayne through September,, and once per week t t (torn October rhwtrph May,
_, The monthly'a Venage effluent hOD and Total Suspended Reudtte conce nu a rions tih ill not exceed 15" of the.tespeetve
influent values (;tt removal).
3, ne daily averiige dissolved oxygen effluent concentration shall not.'se less than 5.0 ru ,?.t.,
.p The'FRC it takes
effect
f f ctt Apriylt1, 007.if l Until
e ttshtsc,the
for lcirnUttee than monitor'FRC [with no effluent Baal,]. I,unit and
5. chroak`c,Kilttr (Cer,J.;,/,,'cm) at 9t7°-v: February,Nfay,AupSt &ls'',0 Vein he,r (sCe :Part 1..A. (2.)),
'There shalt be no discharge of floating solids or visible foam in other than trace antotants.

Pont'
A. (2.) CHRONIC TOXICITY PERMLI LIMIT - Quarterly
The effluent discharge shall at no time exhibit obsertN`able inhibition of reptciducuon or s4rniFicant user'altry
dzehici:at a effluent concentration of 90"A),
the permit holder shall perform at a minimum, quarterly monitoring using, test procedures outlined in the "North
Carolina Cmoda7,-,,bria Chronic Effluent Bioitssay Procedure," Revised February -1998, or subsequent version:, or
"North Carolina Phase Ti Chronic V,lhole Effluent Toxicity Test Procedure" (Revised.-February 1998) or
subsequent.versions. `Ihe tests will be performed during the months of February, May,August and November,
Effluent sampang for this testing shall be performed at the NPDES permitted final effluent discharge below all
treatment procci SS es.
f the rest procedure prrforined as the first test of any single qu.arter results in a failure or ON below the permit
limit, fit en multi:1)1i>(501.colt aduon tei-rting shall he performed at a minimum, in each of the two folloNkting months as
di 'bed 115 'Nord). Phase 11. Chronic Whole Effluent'Toxicity Test Procedure" (Revised-February 1998)
or 111.1b11041,...1 t v
te.11iC rouItrille conceurrsition tC5t ciU be determined using the geometric mean of the highest
coiiceinoration having no detectable impairment of reproduction or survival and the lowest.concentration that does
isrirea t1, 1.f1C1cfrl.e ric minent of reproditCdCrn or s.urvival The definition of"detectable impairment," collection
eNfiosore ri,a;inicE., and further.Statisticid inethods are specified in the 'North Carolina Phase II Chronic
Wnsilis Effluent Toxicity i Fe' r ediirc" (Revised-February 1998) or subsequent versions,
ty rirriuired is hatt of this permit c.ondition wdi at entered us the Effluent.Discharge
nit taring f';ocin i':d.2.-1) for the months.. in which test', svere performed, using the parameter code TG' P3B fc-..ir the
pas.s/fail (os:tilts ansi T1111')13 for the:Clironic Value. Additionally, 1,7„)WQ Form AT-3 (original) is to be sent to the
followiur
Atm:rids/I: DESilslR / DWQ if Environmental Sciences Secti,:ni
1.6ln Service Center
Raleigh, North C a rci lina 27699-1621
Crimplaried rinritlsus'7.1"cr,t Forms shall be filed with the Environmental Sciences Branch no later than 30
&ITS after 6iir fir' firporting period for which the report Is made,
isompirrie, accurate, include all supporting cheinical/physical measurements and all
concentration/re.spods.e Chi 11111i CI be certified by lithoratory supervisor and ORC or approved designate signature,
Total tesidual chlorine cif the efilint toxicity sample must be measured and reported if chlorine is employed for
11.11 S 11,r1 c tion of the V.1,1.S1c,1 F1.1
S1101.J3 dISChJr.gt; t to r the facility during a nionth in winch toxicity mon„itoring is required, the
tieribirtec will complete the information located at the cop of the aquatic toxicity (AT) test farm indicating the
nerrint number,pipe number, county., and the month/year of the report\kith the notation of"No
11)W". ptlic con)'Men t.area of the. .florin. The report shall he submitted to the Environmental Sciences Branch at
use aeldreSS ,1:11;eti above,
Should the perriiirree fail to.monitor during a month in which. toxicity monitoring is rcued,inonitorir' he
required durn..g the following rnonth.
Should any test data Itiriin this inoMnpring requirement or tests performed by the Nt)rth, Carolina Division of Water
c)uality indicate pritential impacts to tf,e receiving stream, this permit may be re-opened and modified to incluide
alternate monitoring requirements or limits.
NOTE. Pailtini to achieve test conditions ;Ai;,:=;pecift-ed in the cited document, such as minimum control organism survival,
minimum control organism reproduction,and iipp.n)priiite envirrinnicamil controls,shall cc,mititute an it'ividiri test and cciii
require immediate follow-up testing to he completed no la tet than the List ShiV of the.month following the month of the tin iii
trioni totlag.
„„ „

NI'DES Pennit Requirements
Page I of t 5
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events,
3/\Week
Samples are collected three times per week on three separate calendar days.
Actor "°the Act"
The Federal !Water Pollution Control Act, also known as the Clean Water Act, as amended, 33 USC 1251, et. seq.
Annual Average
The arithmetic mean- of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
conform, the geometric mean of such discharges.
Anthmetic Mean
The summation of the individual values divided by the number of individual values.
ti
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system,which
is not a designed or established or operating mode for the facility.
Calendar Day.
The period from midnight of one day until midnight of the next day. However, for 'purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may he used for. sampling..
Calendar Quarter
One of the following distinct periods January' through. March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 rrl in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number, and size of aliquots necessary, the time
interval between grab samples, etc.) on a case-by-case basis. Samples may be collected manually or automatically.
Composite samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow,
C2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour
period of discharge and combined proportional to the rate of flow measured at the time of individual sample--
collection, or
(3) Variable tune/constant volume: a series of grab samples of equal volume collected over a 24 hour period
with the time intervals between samples determined by a preset number of gallons passing the sampling
point. Flow measurement between sample intervals shall be determined by use of a flow recorder and
totalizet, and the preset gallon interval between sample collection fixed at no greater than 1/24 of the
expected total daily flow at the treatment system, or
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at
a constant time interval. This method may only be used in situations where effluent flow rates vary
less than 15 percent. The grab samples shall be taken at intervals of no greater than 20 minutes apart
during any 24-hour period and must be of equal size and of no less than 100 milliliters, Use of this method
requires prior approval by the Director.
1/.....:......CA-VIM/ln0

NPDES Permit Requirements .„
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in accordance with (4) above, influent grab samples shall not be collected more than once per hour,
Effluent grab samples shall not be collected more than once per hour except ar wastewater treatment systems
having a detention time of greater than 24 hours, In such cases, effluent grab samples may be collected ar
intervals evenly spaced ov.er the 24-hour period that are equal in number of hours to the detention time of the
system in number of days. Eiowever, the interval between effluent grab samples may not exceed six hours nor
the number of samples less than four during a 24-hour sampling period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device,
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. The "daily discharge" concentration comprises the mean
concentration for a 24-hour sampling period as either a composite sample concentration or the arithmetic mean of all
grab samples collected during that period (40 CFR 122,3)
Daily Maximum
The highest "daily discharge" during the calendar month,
Daily Sampling
Parameters requiring dad y sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. The Division expects that sampling shall be conducted on weekdays except where holidays or other
disruptions of normal operations prevent weekday sampling, If sampling is required for all seven days of the week
for any permit parameter(s), that requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
D\XIQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources,
EMC
The North Carolina Environmental Management Commission,
Facility Closure
The cessation of wastewater treatment at a permitted facility„ or the cessation of all activities that require coverage
under the NPDES. Completion of facility closure will allow this permit to be rescinded,
Geometric Mean
The Nth root of the product of the individual values where N the number of individual values, For put-poses of
calculating the geometric mean, values of"0°' (or "< (detection leven shall be considered = 1,
Grab Sample
Individual samples of at least 100 mi collected over a period of time not exceeding 13 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the Clean Water Act,
Instantaneous flow measurement
A measure of flow taken at the time of sampling, when both the sample and flow will be representative of the total
discharge.
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NPDLS Permit Requirements
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Monthly Average (concentration limit)
The arithmetic mean of all 'daily discharges" of a pollutant measured during, the calendar month., In the case of fecal
conform,. the geometric mean of such discharges,
Permit Is suin Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration
The average of all samples taken over a calendar quarter.
Severe properly damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable,
or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass, Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the Clean Water Act,
Upset
An incident beyond the reasonable control of the Perrnittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements, An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation,
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week, In the case of fecal
colifoon, the geometric mean of such-discharges,
Section B. General Conditions
1. Duty to Comply
The Perrruttee must comply with all conditions of this permit. .Any pert-rut noncompliance constitutes a violation
of the Clean Water Act and is grounds for enforcement action, for permit termination, revocation and reissuance,
or modification; or denial of a permit renewal .application [40 CFR 122,41].
a. The Perraitiee shall comply with effluent standards or prohibitions established under section 307(a) of the
Clean Water Act for toxic pollutants and with standards for sewage sludge use or disposal established under
section 405(d) of the Clean Water Act within the time provided in the regulations that establish these
standards or prohibitions or standards for sewage sludge use or disposal, even if the permit has not yet been
modified to incorporate the requirement.
b. The Clean Water Act provides that any person who violates section 301, 302, 306, 307, 308, 318 or 405 of the
Act, or any permit condition or limitation implementing any such sections in a permit issued under section
402, or any requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8)
of the Act,. is subject to a civil penalty not to exceed $25,000 per day for each violation„ [40 CFR 122.41 (a)
(2))
c. The Clean Water Act provides that any person who 17 es) n violates sections 301, 302, 306, 307, 308, 318, or
40.5 of the Act, or any condition or limitation implementing any of such sections in a permit issued under
section 402 of the Act, or any requirement imposed in a pretreatment program approved under section
402(a)(3) or 402(b)(8) of the Act, is subject to crinainal penalties of$2,500 to $25,000 per day of violation, or
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a
negligent violation, a person shall be subject to criminal penalties of not more than $50,000 per day of
violation,or by imprisonment of not more than 2 years, or both. [40 CFR 122..41 (a) (2)]

NPOES Permit Requirements
Page,4 of 16
d, Any person who knoa,iy violates such sections, or such conditions or Limitations is subject to crunnal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than .3 years, or both. In
the case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day (it-violation, or imprisonment of not more than 6 ears, or both
[40 CFR 122.41 (a). (21
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act,
and who knows at that time that he thereby places another person in imminent danger of death or serious
bodily injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not
more than 15 years, or both, In the case of a second or subsequent conviction for a knowing endangerment
violation, a person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than
30 years, or both, An organization, as defined in section 309(c)(3)(B)(ail of the C\VA, shall, upon conviction
of violating the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined
up to $2,000,000 for second or subsequent convictions. [40 CFR 122.41 (a) (2))
E. Under state a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes 143-215.6A1
g, A.ny person ITLIY be assessed an administrative penalty by the Administrator for violating section 301, 302,
306,, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such
sections in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are
riot to exceed $10,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$25,000. Penalties for Class 11 violations are not to exceed $10,000 per day for.each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $125,000. [40 CFR
122.41 (a) (31
2, Duty to Nlitigate
The Perrnittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit which has a reasonable likelihood of affecting human health or the environment
[40 CFR 122.41 (d}[.
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part IL C. 4), "Upsets" (Part II. C. 5) and "Power
Failures" (Part II, C. 7), nothing in this permit shall be construed to relieve the Permittee from any
responsibilities, liabilities, or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309
of the Federal Act, 33 USC 1.319, Furthermore, the Permittee is responsible for consequential damages, such as
fish kills, even though the responsibility for effective compliance may be temporarily suspended.
4, Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the instirution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Perrnittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Pertnittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5, Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any
exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor
any infringement of Federal, State or local laws or regulations [40 CFR 122.41 (g)].
6.. Onshore or Offshore Construction.
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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NPDES Permit Requirements
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7, Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of it
permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remains
of this permit, shall not be affected thereby [NCGS 130B-231
8, Duty to Provide Information
The Permittee shall furnish to the Perrrut Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Perrnittee shall also furnish to the
Permit Issuing Authority upon request, copies of records required by this permit [40 CFR 122,41. (h)]..
9. Duty to Reapply
lithe Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122,41 (b.)].
1,0. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic
authorization to discharge beyond the expiration date, the Perrnittee shall submit such information, forms, and.
fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date.
Any Permitter that has not requested renewal at least 180 days prior to expiration, or any Permittee that does not
have a permit after the expiration and has not requested renewal at least 180 days prior„to expiration, will su.bject.
the Permittee to enforcement procedures as provided in NCGS143-215,6 and 33 USC 1251 et, seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified
[40 CFR1,22,41 (k)).
a, All permit applications shall be signed as follows:
(1) .For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means; (a) a president, secretary, treasurer or vice. president of the corporation in
charge of a principal business function, or any other person who performs similar policy or decision ;
making functions for the corporation, or (b) the manager of one or more manufacturing, production, or
operating facilities, provided, the manager is authorized to make management decisions which govern the.
operation of the regulated facility including having the explicit or -implicit duty of making major capital
investment recommendations, and initiating and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and regulations; the manager can ensure that.
the necessary systems are established or actions taken to gather complete and accurate information for
permit application requirements; and where authority to sign documents has been assigned or delegated
to the manager in accordance with corporate procedures ,
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.221
H. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if.
1. The authorization is made in writing by a person described above;
2. The authorization specified either an individual or a position having responsibility for the overall
operation of the regulated facility or activity, such as the position of plant manager, operator of a well or
well field, superintendent, a position of equivalent responsibility, or an individual or position having
overall responsibility for environmental matters for the company. (A duly authorized representative may
thus be either a named individual or any individual occupying a named position.); and
3. The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.221

NPDES Permit Requirements
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c, Changes to authorization: If an authorization under paragraph (la) of this section is no longer accurate
because a different individual or position has responsibility for the overall operation of the facility, a new
authorization satisfying the requirements of paragraph (b) of this section must be submitted to the Director
prior to or together with any reports, information, or applications to be signed by an authorized
representative [40 CFR 122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the
following certification [40 CFR 121221
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate
the information submitted* Based on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete* I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned
changes or anticipated noncompliance does not stay any permit condition (40 CFR 122.41 ()1.
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the
permit, revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Tide 15A of the North Carolina
Administrative Code, Subchapter 2H „WOO; and North Carolina General Statute 143-215.1 et. al.
1.4. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 2H.0105 (b) (4)
may cause this Division to initiate action to revoke the permit,
Section C.. Operation and Maintenance of Pollution Controls
I. Certified Operator
Upon classification of the permitted facility by the Certification Commission, the Permittee shall employ a
certified water pollution control treatment system operator in responsible charge (ORC) of the water pollution
control treatment system. Such operator must hold a certification of the grade equivalent to or greater than the
classification assigned to the water pollution control treatment system by the Certification Commission. The
Permittee must also employ one or more certified Back-up,ORCs who possess a currently valid certificate of the
type of the system. Back-up ORCs must possess a grade equal to (or no more than one grade less than) the grade
of the system [15A NCAC 8G.0201].
The ORC of each Class I facility must:
)..4 Visit the facility at least weekly
Comply with all other conditions of 15A NCAC 8G,0204.
The ORC of each Class II, III and IV facility must:
Visit the facility at least daily, excluding weekends and holidays
Properly manage and document daily operation and maintenance of the facility
Comply with all other conditions of 15A NCAC 8G.0204„
Once the facility is classified, the Permittee shall submit a letter to the Certification Commission designating the
operator in responsible charge:
a. Within GO calendar days prior to wastewater being introduced into a new system.
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NPDES Per iit Requirements
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b. Within 120 calendar days of.
y' Receiving notification of a change i�n the classification of the system requiring the designation of a
new ORC and back-up ORC
A vacancy in the position of ORC or back-up ORC.
2. Proper Operation and Maintenance
The Perr ittee shall at all times provide the operation and maintenance resources �necess�r to operate the existing
facilities at optimum efficiency. The Permattee shall at all times properly operate and maintain all facilities and
systems of treatment and control (and related appurtenances) which are installed or used by the Permitter. to
achieve compliance with the conditions of this permit. Proper operation and maintenance also includes adequate
laboratory controls and appropriate quality assurance procedures. This provision requires the Permittee to install
and operate backup or auxiliary facilities only when necessary to achieve compliance with the conditions of the
permit [40 CFR 122.41 (e)].
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permitter in an enforcement action that it would have been necessary, to halt or
reduce the permitted activity° in order to maintain compliance with the condition of this permit [40 C:FR 122,41
(c)].
4. Bypassing c>f Treatment Facilities
a. Bypass not exceeding limitations [4t0 CFR 122.4'1 (m) (2)]
The Permittee may allow any bypass to occur which,does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41 (m) (3)]
(I) Anticipated bypass. If the Perm.ittee knows in advance of the need for a bypass, it shall submit prior
notice, if possible at least ten days before the date of the bypass; including an evaluation of the
anticipated quality.and effect of the bypass.
(2) Unanticipated bypass. The Perrittee shall submit notice of an unanticipated bypass as required in. Part
II. E... 6, (24-hour notice).
A
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
actionagainst a Permittee for by-pass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the.use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permitter for a brass as provided in any current or future system-wide collection system
permit associated with the treatment facility.
(3) The Permit Issuing Authority: may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of thiis section.
5. Upsets
a. Effect of an upset [40 C.FR 122.41 (n) (2)]: An upset constitutes an affirmative defense to an action
brought for noncompliance with such technology based permit effluent limitations if the requirements of
paragraph b. of this condition are met. No determination made during administrative review of claims that

NPDES Permit Requirements
P.agc 8 of 16
noncompliance was caused by upset, and before an action for noncompliance, is final administrative action
subject to judicial review.
b. Conditions necessary for a demonstration oC, upset. A Permittee who wishes to establish the
affirmative defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or
other relevant evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II. E. 6. (b) (B) of this permit.
(4) The Permittee complied with any remedial measures required under Part II. B. 2. of this permit.
d. Burden of proof [40 CFR .1.22,41. (n) (4)]: The Permittee seeking to establish the occurrence of an.
upset has the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters.
shall be utilized/disposed of in accordance with NCGS .143-215,1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States. The Permittee
shall comply with all existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of
40 CFR Part 503, any permit issued by the Permit Issuing Authority for the utilization/disposal of sludge may be
reopened and modified, or revoked and reissued, to incorporate applicable requirements at 40 CFR 503. The
Permittee shall comply with applicable 40 CFR 503 Standards for the Use and Disposal of Sewage Sludge (when
promulgated) within the time provided in the regulation, even if the permit is not modified to incorporate the
requirement. The Permittee shall notify the Permit Issuing Authority.' of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 214.0124 — -
Reliability) to prevent the discharge of untreated or inadequately treated wastes during electrical power failures
either by means of alternate power sources, standby generators or retention of inadequately treated effluent,
Section D. Monitoring and Records
1, Representative Sampling
Samples collected and measurements taken, as required herein, shall be characteristic of the volume and nature of
the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is
characteristic of the discharge over the entire period the sample represents. All samples shall be taken at the
monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted
by any other wastestream, body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Permit Issuing Authority [40 CFR 1.22.41 (1)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the 28th day following the completed reporting period.
The first DNER is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of
these, and all other reports required herein, shall be submitted to the following address:
NC DENR / Division of Water Quality / Water Quality Section
Alik.,NTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1,617
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3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges, The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device, Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10°/"0 from the true discharge rates throughout the range of expected discharge
volumes,. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device,
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once-through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I
of this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4, Test Procedures.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to..
NCGS 1.43-21563 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to
Section 304.(g), 33 'USC 1314, of the Federal Water Pollution Control Act (as Amended), and 40 CFR 136; or in
the case of sludge use or disposal, approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless
other test procedures have been specified in this permit [40 CFR 122.41j.
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum
detection and reporting levels that are below the permit discharge requirements and all data generated must be.
reported down to the minimum detection or lower reporting level of the procedure, if no approved methods are
determined capable of achieving minimum detection and reporting levels below permit discharge requirements,
then the most sensitive (method with the lowest possible detection and reporting level) approved method must
be used,
5, Penalties for Tampering
The Clean N,Vater Act provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any
monitoring device or method required to be maintained under this permit shall, upon conviction, be punished by
a fine of not more than $10,000 per violation, or by imprisonment for not more than two years per violation, or
by both. If a conviction of a person is for a violation committed after a first conviction of such person under this
paragraph, punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more
than 4 years, or both [40 CFR 122,41],
6 Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge
use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40
CFR 503), the Permittee shall retain records of all monitoring information, including-,
all calibration and maintenance records
all original strip chart recordings for continuous monitoring instrumentation
)> copies of all reports required by this permit
copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122,41],
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record
the following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;

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•Page 10 of 10
e. The analytical techniques or methods used;and
f. The results of such analyses...
S. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting
as a representative of the Director), upon the presentation of credentials and other documents as may be required
by law, to;
a, Enter upon the Perrnittee's premises where a regulated facility or activity is located or conducted, or where,
records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this
permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment),practices,
or operations regulated or required under this perrnit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the Clean Water Act, any substances or parameters at any location [40 CFR 122.41 (4
Section E _Reporting Requirements
1, Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions. of this permit. The discharge
of any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall
constitute a violation of the permit.
2. Planned Changes. •
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or
additions to the permitted facility [40 CFR 122.41 (1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122,29 (b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42 (a)'(l).
c. The alteration or addition results in a significant change in the Perrruttee's sludge use or disposal practices,
and such alternation, addition or change may justify the application of permit conditions that are different
from or absent in the existing permit, including notification of additional use or disposal sites not reported
during the permit application process or not reported pursuant to an approved land application plan,
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41 (1) (2)].
4. Transfers
This permit is not transferable to any person except after notice to the Director. The Director may require
modification or revocation and reissuance of the permit to document the change of ownership. Any such action
may incorporate other requirements as may be necessary under the Clean Water Act [40 CFR 122.41 (I) (3)].
5, Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122,41 (1) (4)].
a. Monitoring results must be reported on a Discharge Monitoring Report ('DMR) (See Part II. D. 2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permirtee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation and reporting of the data submitted on the DMR..
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6, Twenty-four_I°lour Reporting
a_ The Permirtee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Perrrtittee became a'aare of the circumstances. A written submission shall also be
provided within 5 day of the time the Permittee becomes aware of the circumstances. The written
submission shall contain a description of the noncompliance, and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the anticipated time it is
expected to continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the
noncompliance [40 CIF 122.41 (I)
b. The Director may waive the written report on a case-by-case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part 11. 'E. 5 and 6. of this permit at
the time monitoring reports are submitted, The reports shall contain the information listed in Part II. F. 6, of
this permit [40 CFR 122,41 (l) (7)]_
8. Other Information
\ here the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or
submitted incorrect information in a permit application or in any report to the Director, it shall promptly submit
such facts or information [40 CFR 122.41`(1) (8)].
9.. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the
Division as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the followings
a. Any occurrence at the water pollution control facility.which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester, the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to receiving
waters without treatment of all or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215,3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, al.l reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division of Water Quality. As required by the Act, effluent data shall not be considered confidential.
Knowingly making any false statement on any such report may result in the imposition of criminal penalties as
provided for in NCGS 143-215.1 (b)(2) or in Section 309 of the Federal Act,
11. Penalties for Falsification of Reports
The Clean Water Act provides that any person who knowingly makes any false statement, representation, or
certification in any record or other document submitted or required to be maintained under this pen-nit,including
monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of

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not more than $25,000 per violation, or by 'unprisonment for not more than two years per violation, or by both
[40 C.FR 122.41 I.
12. Annual Performance Reports
'Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittec (\CGS 143-215.1(2).
The report shall summarize the performance of the collection or treatment system, as well as the extent to which
the faciliry was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality.
The report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon
which annual period is used for evaluation.
PART III
OTHER REQUIREMENTS
Section A. Construction
The Perm:Mee shall not commence construction of'wastewater treatment facilities, nor add to the plants treatment
capaciry, nor change the treatment process(es) utilized at the treatment plant unless the Division has issued an
Authorization to Construct (AtC) permit. Issuance of an AtC will not occur until Final Plans and Specifications for
the proposed construction have been submitted by the Permittee and approved by the Division.
Section B. Grounclwater Monitorin
The Permittee shall, upon'written notice from the Director of the Division of Water Quality, conduct groundwater
monitoring as may be required to determine the compliance of this NPDES permitted, facility with Me current
groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR. 122.42):
a. That am activity has occurred or will occur .which would result in the discharge, on a routine or frequent
basis, of any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(I) One hundred micrograms per liter (100 tig/L);
(2) Two hundred micrograms per liter (200 ag./1._) for acrolein and acrylonitrile; five hundred micrograms
per liter (500 tig/L) for 2.4-dinitrophenol and for 2-methy1-4.6-dinitrophenoli and one milligram per liter
mg/L) for antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non-routine or
infrequent basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the
highest of the following "notification levels";
(1) Five hundred micrograms per liter(500 pug/I...),
(2) One milligram per liter mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Evaluation of Wastewater Discharge Alternatives
The Permittee shall evaluate all wastewater disposal alternatives and pursue the most environmentally sound
alternative of the reasonably cost effective alternatives. If the facility is in substantial non-compliance with the terms
and conditions of the NPDES permit. or governing rules, regulations or laws, the Permittee shall submit a report in
such form and detail as required by the Division evaluating these alternatives and a plan of action within 60 days of
notification by the Division.
Section E. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system
covered by this perrnit. The Division may require specific measures during deactivation of the system to prevent
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