NC0024112_Correspondence_20091204

CITY OF THOMASVILLE
P.O. Box 368
Thomasville, North Carolina 27361-0368
[phone]
Office of City Manager
December 4, 2009
VIA E-MAIL TO bouma.stacey@,enamail.ena.g_ov
AND FED -EX TO:
Ms. Stacy Bouma
U.S. Environmental Protection Agency
Clean Water Enforcement Branch
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
Re: Information Request- Section 308 of the Clean Water Act
NPDES Permit No. NCO024112
Thomasville Hamby Creek WWTP
Dear Ms. Bouma:
wcoaronw�so ..s,
On behalf of the City of Thomasville, I am timely responding to a letter from Douglas F.
Mundrick, P.E., Chief, Clean Water Enforcement Branch, Water Protection Division dated
October 16, 2009 regarding:
Information Request- Section 308 of the Clean Water Act
NPDES Permit No. NCO024112
Thomasville Hamby Creek WWTP
The letter included two numbered requests for information, Enclosure A at Paragraph 1
("Request I") and Paragraph 2 ("Request 2"). We understand that a response was originally due
30 days after receipt. Through counsel, we requested a 30-day extension for our response to the
letter and received a two week extension for our response to Request 1 and 30-day extension for
our response to Request 2. This letter timely responds to Request 1 and is organized for clarity.
The EPA's numbered information request is presented below in italics followed by the City's
response.
In addition to my own investigation of subjects related to the requests for
information, the City retained a law firm, Brooks, Pierce, McLendon, Humphrey &
Leonard, LLP, and Brown & Caldwell, Environmental Engineers and Consultants, to assist
in the City's investigation. The City obtained the assistance of both firms in drafting this
response.

The City of Thomasville, on advice of counsel, objects to Request 1 because the
request is overly broad, vague, and unduly burdensome and seeks information beyond the
scope of Clean Water Act Section 308. 33 USC § 1318. The City, without waiving its
objections, responds as follows:
1. The City of Thomasville Hamby Creek Wastewater Treatment Plant (WWTP) has
experienced many effluent violations over the past four years, including the items listed in
Enclosure A. Explain the reasons for the violations and provide a summary of actions taken by
the City to correct the problems and prevent future violations. If the City has records
demonstrating compliance with the parameters listed in Enclosure A, please submit these
records for the period October 2006 through October 2009.
Reasons for Violations
EPA's Enclosure A alleges 81 violations. Brown & Caldwell determined and the City agrees
that the reasons for the alleged violations itemized in Enclosure A include the following:
■ 77 of the 81 alleged violations referenced in Enclosure A are associated with
failure of the former 4.0 mgd WWTP and commissioning of the new 6.0 mgd
WWTP. However, an alleged chromium violation during the commissioning
period in March 2008 did not occur.
■ An alleged selenium violation for November 2008 and an alleged nickel violation
for January 2009 may be attributable to SIUs.
■ An alleged TSS violation for March 2009 is associated with the failure of a new
clarifier drive motor that was still under warranty.
■ The alleged May 2009 D.O. violation did not occur.
See Brown & Caldwell report (enclosed), which is incorporated in and made a part of this
response.
Summary of Actions to Correct Problems and Prevent Future Violations
The City completed construction of a new 6.0 mgd WWTP in February 2008 and
completed the commissioning of the new WWTP in May 2008. For the period prior to the
completion of construction and commissioning, beginning in October 2006, Enclosure A
alleges 77 violations, one of which has been documented as not having occurred. For the
period following the completion of construction and commissioning, Enclosure A alleges 4
violations, one of which has been documented as not having occurred. Stated differently,
95% of the violations are alleged for the first 19 months covered by the request for
information, but only 5% are alleged for the second 18 months covered by the request for
information.

The City spent approximately $27.5 million on the design, construction, and
commissioning of the new WWTP. This amount is nearly equal to the City's entire annual
budget. This commitment of financial resources was made against a backdrop of on -going
financial hardship faced by the City. The City's investment has produced dramatically
improved WWTP compliance.
Enclosure A alleges four violations since the construction and commissioning of the
new WWTP. One alleged violation was for selenium and one was for nickel. In order to
reduce the risk of future selenium or nickel violations, the City has continued to monitor and
work with local industries to reduce nickel levels. Additional industrial sampling/monitoring
and enforcement measures will be used as needed. One industry has been identified with
failure to maintain proper pH levels to precipitate out nickel prior to discharge. The industry
has been issued a warning; any future problems will be considered for enforcement action.
The City will continue to search for industrial sources of selenium and take appropriate
corrective actions, including enforcement action, where appropriate. One alleged violation
was for TSS which was associated with the failure of a clarifier drive motor that was still
under warranty. The manufacturer replaced the old drive motor. In order to reduce the risk
of future TSS violations, the City has requested that the old drive motor be repaired and
returned to the City in order to keep an extra drive motor on hand as a spare. One alleged
violation, a purported dissolved oxygen violation, did not occur.
Brown & Caldwell provides the following summary:
Construction of the new 6.0 mgd AWTP [i.e., Advanced Wastewater
Treatment Plant] was completed in February 2008. Seventy-seven of 81
alleged effluent violations in the EPA's Enclosure A are believed to have been
mitigated by construction of the new AWTP. The four alleged violations for the
post -commissioning period included one that did not occur, two metals excursions
(presumed to be associated with SIU discharges), and one TSS excursion
(associated with a single equipment failure which was promptly addressed). The
City continues to mitigate the risk of permit excursions through use of IUPs for
SIUs, utilization of preventative maintenance procedures for critical process
equipment, anddevelopment of an on -site inventory of critical spare parts.
Brown & Caldwell Report (enclosed) at p. 6.
Records Demonstrating Comaliance with Parameters Listed in Enclosure A for October
2006 through October 2009
The City understands the portion of the request for information dealing with "records
demonstrating compliance with the parameters listed in EPA's Enclosure A ... for the period
October 2006 through October 2009" as only requesting records that contradict EPA's
listing of alleged violations (rather than requesting all records demonstrating all occurrences
of compliance regarding the parameters identified in EPA's Enclosure A. The requested
records include the enclosed Brown & Caldwell Report and the attachments thereto that

demonstrate that there was no dissolved oxygen related noncompliance in May 2009 and no
chromium related noncompliance in March 2008. If EPA intends a different interpretation
than the one on which the City based its response, please notify us of the different
interpretation. The City reserves the right to revise and add records to this response.
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, I certify that 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 fine and imprisonment for knowing
violations.
cc: Matt Matthews, NC DENR
Douglas F. Mundrick, P.E., EPA
Enclosure

/VcnIYI(Z
s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
z A a
REGION 4
ATLAN"rA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA. GEORGIA 30303-8960
' 1 Q 2009
CERTIFIED MAIL 7005 1160 0001 9899 9935
RETURN RECEIPT REQUESTED
Mr. W. Kelly Craver
City Manager
City of Thomasville
10 Salem Street
Thomasville, North Carolina 27360
Re: Information Request - Section 308 of the Clean Water Act
NPDES Permit No. NCO0241 I'_
Thomasville Hamby Creek WWTP
Dear Mr. Craver:
Pursuant to Section 308 of the Clean Water Act (CWA), 33 U.S.C. § 1318, the
Environmental Protection Agency (EPA) hereby requests the City of Thomasville (the City) to
provide the information set forth in Enclosure A regarding the City's Hamby Creek Wastewater
Treatment Plant (WWTP) and also the associated sanitary sewer overflow event that occurred
between July 16 and August 4. 2009. The City is required to respond to this information request
within thirty (30) days of its receipt of this letter. The response should be directed to:
Ms. Stacey Bouma
U.S. Environmental Protection Agency
Clean Water Enforcement Branch
61 Forsyth Street, S.W.
Atlanta. Georgia 30303-8960
The City's response to this information request should specifically reference the
particular section and number of the request and should be organized for the purpose of clarity.
In addition, all information submitted must be accompanied by the following certification signed
by a responsible City official in accordance with 40 C.F.R. § 122.21:
"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. I certify that 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 fine
and imprisonment for knowing violations."
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Failure to comply with this information request may result in enforcement proceedings
under Section 309 of the CWA, 33 U.S.C. § 1319, which could result in the judicial imposition
of civil or criminal penalties or the administrative imposition of civil penalties. In addition, there
is potential criminal liability for the falsification of any response to the requested information.
If you believe that any of the requested information constitutes confidential business
information, you may assert a confidentiality claim with respect to such information except for
effluent data. Further details, including how to make a business confidentiality claim, are found
in Enclosure B.
Also enclosed is a document entitled U.S. EPA Small Business Resources-h:fortnation
Sheet which may assist you in understanding the compliance assistance resources and tools
available to the City. However, any decision to seek compliance assistance at this time does not
relieve the City of its obligations to EPA or the State, does not create any new rights or defenses,
and will not affect EPA's decision to pursue enforcement action. In addition, the Securities and
Exchange Commission (SEC) requires its registrants to periodically disclose environmental legal
proceedings in statements filed with the SEC. To assist you, EPA has also enclosed a document
entitled Notice of Securities and Exchange Conunission Registrants' Duty to Disclose
Environmental Legal Proceedings.
If you have questions regarding this notice and information request, please feel free to
contact Ms. Stacey Bouma at [phone].
Sincerely,
Douglas F. Mundrick, P.E., Chief
Clean Water Enforcement Branch
Water Protection Division
Enclosures (4)
cc: Matt Matthews, NC DENR✓

ENCLOSURE A
City of Thomasville, North Carolina
The City of Thomasville Hamby Creek Wastewater Treatment Plant (WWTP) has
experienced many effluent violations over the past four years, including the following.
Dissolved Oxygen
Biochemical Oxygen Demand,
5 Day (BODS), monthly average
Biochemical Oxygen Demand,
5 Day (BODS), weekly average
Total Suspended Solids,
monthly average
Total Suspended Solids,
weekly average
Nitrogen, Ammonia Total (as N),
monthly average
Nitrogen. Ammonia Total (as N),
weekly average
Total Nickel, weekly average
Total Nickel, daily maximum
Total Chromium, weekly average
Total Selenium, weekly average
Fecal Coliform, weekly geometric mean
pH
May 2009
Oct -Dec 2006: Jan -Oct, Dec 2007;
Jan -Apr 2008
Oct, Dec 2006: Jan -Oct 2007;
Jan -Apr 2008
Apr 2007; Jan -Feb 2008
Apr, Jun 2007; Jan -Mar 2008:
Mar 2009
Feb -Oct, Dec 2007. Jan -Apr 2008
Mar -Jun, Aug -Sep, Dec 2007:
Mar -Apr 2008
Feb 2008; Jan 2009
February 2008
Apr 2007; Feb -Mar 2008
May, Aug 2007; Nov 2008
Oct 2006; Jan 2007
Oct, Dec 2006; Nov 2007
Explain the reasons for the violations and provide a summary of actions taken by the City
to correct the problems and prevent future violations. If the City has records
demonstrating compliance with the above parameters, please submit these records for
the period October 2006 through October 2009.
9

2. Provide the following information for the Sanitary Sewer Overflow (SSO) that occurred
between July 16 and August 4, 2009.
,a. Date(s) of the SSO;
b. Time (and Date if other than a. above) when the City was notified that the SSO
event occurred;
C. Time (and Date if other than a. above) when the City (or contractor) crew
responded to the SSO;
d. Time (and Date if other than a. above) when the City notified the State that the
SSO event occurred:
e. Time (and Date if other than a. above) when the SSO ceased;
f. Time (and Date if other than a. above) when corrective action was completed;
g. Location of the SSO, including source (pump station, manhole, etc.);
h. Ultimate destination of the SSO, such as surface waterbody (by name, if
available), storm drain leading to surface waterbody (by name, if available), dry
land, building, etc.:
i. Volume of the SSO;
j. Cause of the SSO such as grease, roots, other blockages, wet weather (infiltration
and inflow), loss of power at pump station, pump failure, etc.;
k. Corrective actions taken to stop the SSO; and
I. Corrective actions taken to prevent this or similar SSOs in the future.

ENCLOSURE B
RIGHT TO ASSERT BUSINESS CONFIDENTIALITY CLAIMS
(40 C.F.R. Part 2)
Except for effluent data, you may. if you desire, assert a business confidentiality claim as to any
or all of the information that EPA is requesting from you. The EPA regulation relating to
business confidentiality claims are found at 40 C.F.R. Part 2.
If you assert such a claim for the requested information, EPA will only disclose the information
to the extent and under the procedures set out in the cited regulations. If no business
confidentiality claim accompanies the information, EPA may make the information available to
the public without any further notice to you.
40 C.F.R. §2.203(b). Method and time of asserting business confidentiality claim. A
business which is submitting information to EPA may assert a business confidentiality claim
covering the information by placing on (or attaching to) the information, at the time it is
submitted to EPA, a cover sheet, stamped or typed legend, or other suitable form of notice
employing language such as "trade secret," "proprietary," or "company confidential." Allegedly
confidential portions of otherwise non -confidential documents should be clearly identified by the
business, and may be submitted separately to facilitate identification and handling by EPA. ff the
business desires confidential treatment only until a certain date or until the occurrence of a
certain event, the notice should so state.

RESPONSE TO INFORMATION REQUEST
SECTION 308-CLEAN WATER ACT
CITY OF THOMASVILLE
HAMBY CREEK
WASTEWATER TREATMENT PLANT
Prepared for
City of Thomasville, North Carolina
December 2009

309 Fast Morehead Street
Suite 160
Charlone, NC 28202
Tel: [phone]
Eva- [phone]
December 2, 2009
ROW N AND
Mt. Kelly Craver
City Manager
City of Thomasville
10 Salem Street
Thomasville, North Carolina 26360
Re: Information Request - Section 308 of the Clean Water Act
NPDES Permit No. NCO024112
Thomasville Hamby Creek WWTP
Dear Mr. Craver:
138216
While Brown and Caldwell, under contract with the City of Thomasville, was
conducting an assessment of a reported July and August 2009 sanitary sewer
overflow (SSO), the Environmental Protection Agency (EPA) requested the
City to provide information regarding alleged effluent violations at the City's
Hamby Creek Wastewater Treatment Plant (WWTP). The EPA sent the
request by certified letter dated October 16, 2009, which the City received on
October 21, 2009. Brown and Caldwell gathered and assembled some of the
information requested by the EPA. The EPA's information request is presented
below in italics followed by information for use in the City's response.
Hamby Creek Wastewater Treatment Plant
The City of Thomasville Hamby Creek Wastewater Treatment Plant (IWWIP) has
experienced many effluent violations over the pad fouryearr, indmding the items listed in
Enclosure A. Explain the reasons for the violations and provide a summary of actions taken
by the City to correct the problems and prevent future violations. If the City has records
demonstrating compliance with the parameters listed in Enclosure A, please submit these
records for the period October 2006 through October 2009.
Background
In 2005 and 2006, the City began experiencing process equipment failures at
their WWTP, primarily due to equipment age, treatment capacity and hydraulic
capacity limitations. The equipment issues that resulted in the alleged effluent
violations listed in Enclosure A to EPA's letter included the following:
• Failure of au supply header to aeration tanks
• Multiple mechanical failures of belt press
• Failure of belt press feed pump
• Collapse of digester floating roofs
P:V 38216. Thomasville Sewage Spill Investigation\308 ResponseWTP 308 Response 2009-12-02.dw

Mr. Kelly Craver
City of Thomasville
EPA 308 Response — W WTP
December 2, 2009
Page 2
• Failure of digester heat exchangers
• Failure of digester mixing systems
• Failure of primary clarifier sludge pumps
• Failure of trickling filter bearings and bearing races
• Failure of trickling filter distribution arms
• Failure of trickling filter recirculation pump
• Short-circuiting of electrical distribution system
In February 2006, the City began the construction of new facilities coupled with
the expansion and upgrade of existing facilities that produced the new
Advanced Wastewater Treatment Plant (AWTP). The AWTP has dramatically
improved the City's wastewater treatment reliability and regulatory compliance.
During construction of the new plant, the City worked with technical services
staff from the North Carolina Department of Environment and Natural
Resources (NC DENR) in an attempt to bring the old plant back into
compliance. However, given the significant refurbishment and replacement
needs of the older treatment facility, and the fact that the City was investing
significant capital in the construction of the AWTP, startup of the new plant
(and abandonment of the old plant) was the most viable path to achieving
consistent regulatory compliance.
A new 6.0 million gallons per day (mgd) AWTP replaced the City's aging 4.0
mgd secondary treatment facility. The new AWTP expanded the peak treatment
capacity and was designed to meet increasingly stringent effluent discharge
requirements. Figure 1 provides a timeline of alleged effluent violations in
question and the construction timeline of the new plant. As shown in the
construction timeline, the new plant was completed in February 2008, after
which a 4-month commissioning period commenced. The City's records
indicate that the first process train of the new plant was brought online March
11, 2008. The second treatment train was started up April 25, 2008, after which
an almost immediate improvement in effluent quality was observed.
The majority of the City's alleged effluent violations were the direct result of
equipment failures, which were addressed by construction of the new AWTP.
The alleged effluent violations that are not directly attributable to failure of old
plant equipment are discussed below. The alleged effluent violations in question
are presented relative to the timeline of the new AWTP startup.
P \i 38216 -Thomasville Sewage Spill Irrvestigation\308 Response\WW7 308 Response 200312-02.Ooo

Mr. Kelly Craver
City of Thomasville
EPA 308 Response — W WTP
December 2, 2009
Page 3
Alleged Pre -Commissioning Effluent Violations
May 2007 - Total Selenium Weekly Average Concentration
This alleged violation was reported on the May 2007 Daily Monitoring Report
(DMR) that was submitted to NC DENR. The discharge limit for total
selenium (weekly average concentration of 5.3 µg/L) was allegedly exceeded for
the May 8, 2007 sampling period with a concentration of 6 jig/L. No cause was
apparent for this alleged violation, but the selenium excursion was believed to
be the result of an industrial discharge into the City's collection system. The
City utilized industrial user pretreatment permits (IUPs) for significant industrial
users (SIUs) during this time period to minimize potential industrial heavy metal
discharges to the collection system.
August 2007 - Total Selenium Weekly Average Concentration
This alleged violation was reported on the August 2007 DMR. The discharge
limit for total selenium (weekly average concentration of 5.3 µg/L) was
exceeded for the August 22, 2007 sampling period with a concentration of 6
µg/L. No cause was apparent for this alleged violation as the City was unable to
detect selenium in the aeration basins or any SIU discharge. The City's
utilization of IUPs was intended to minimize potential industrial heavy metal
discharges to the collection system. More than one year elapsed before the next
alleged total selenium effluent violation (November 2008), indicating that the
issue was not a result of a prevalent upset in the treatment process.
Alleged Effluent Violations during Commissioning
Fourteen of the 18 alleged violations for February through May 2008 were
attributed to a startup period for the new AWTP. These alleged violations are
from a period prior to the establishment of the microbiological communities the
new plant needed for reliable treatment. The remaining alleged violations
during this time period (total nickel and total chromium) likely resulted from a
buildup of excess solids in the old plant, but SIU discharges could not be ruled
out as possible contributing factors. One of the alleged chromium violations
did not occur. These metals excursions are discussed below.
February 2008 - Total Nickel, Daily Maximum and Weekly Average
Concentrations
These alleged violations were reported on the February 2008 DMR. The
discharge limits for total nickel (daily maximum concentration of 261 µg/L and
weekly average concentration of 94.1 Ng/L) were allegedly exceeded for the
February 5, 2008 sampling period with a concentration of 281 µg/L. These
nickel excursions were attributed to elevated effluent total suspended solids
P1138218 - Thomasville Sewage Spill Imesugaem\30B RespanselWW7 308 Response 2009-12-02.tla

Mr. Kelly Craver
City of Thomasville
EPA 308 Response — W WTP
December 2, 2009
Page 4
(I'SS) concentrations. The City's efforts to reduce its solids inventory were
hampered during February 2008 because it was necessary to shut down the belt
press while the filtrate line was being tied into the new plant.
Additionally, the SIU discharges were not ruled out as a possible contributing
factor to the alleged total nickel violations. The City's management of IUPs
during this time was intended to minimize potential industrial heavy metal
discharges to the collection system. There has been only one alleged total nickel
violation Qanuary 2009) since that time.
February 2008 - Total Chromium, Weekly Average Concentration
Two alleged weekly average chromium violations were reported in the February
2008 DMR. The discharge limit for total chromium (weekly average
concentration of 53.5 µg/L) was allegedly exceeded for the February 5, 2008,
and February 27, 2008 sampling periods with total chromium concentrations of
61 µg/L and 66 µg/L, respectively. These chromium excursions were attributed
to elevated effluent TSS concentrations caused by the conditions described
above for the alleged February 2008 total nickel violations.
SIU discharges were not ruled out as possible contributing factors to the total
chromium excursions. As previously discussed, the City's utilization of IUPs
was intended to minimize potential industrial heavy metal discharges to the
collection system. There has not been another alleged total chromium violation
since February 2008.
March 2008 - Total Chromium, Weekly Average Concentration
The discharge limit for the total chromium weekly average concentration
(53.5 µg/L) was not exceeded in March 2008. The DMR and total chromium
laboratory results for March 2008 (see Attachment A) show that the highest
sample results for the month occurred on March 5, 2008, with a total chromium
concentration of 48 jig/L. This alleged violation appears to be incorrect as all
sample results for March 2008 were below the City's permitted discharge limit.
Alleged Post -Commissioning Effluent Violations
From June 2008 through October 2009 there were four alleged violations as
described below:
November 2008 — Total Selenium, Weekly Average Concentration
This alleged violation was reported on the October 2008 DMR. The discharge
limit for total selenium (weekly average concentration of 5.3 µg/L) was allegedly
exceeded for the October 29, 2008 sampling period with a concentration of
6 µg/L. No cause was apparent for this alleged violation, and no recent
industrial pretreatment violations for selenium have been recorded. The City's
P:A138216 -Thomasville Sewage Spill hwessga6anM Response\WWTP 3g6 Response 2669&12-02.dx

Mr. Kelly Craver
City of Thomasville
EPA 308 Response — W WTP
December 2, 2009
Page 5
continued use of IUDs was intended to minimize potential industrial heavy
metal discharges to the collection system. There have been no alleged selenium
violations since November 2008.
January 2009 — Total Nickel, Weekly Average Concentration
The discharge limit for total nickel (weekly average concentration of 94.1 µg/L)
was allegedly exceeded for the January 7, 2009 sampling period with a
concentration of 101 µg/L. The sample was taken several days after a
significant rainfall, and it was believed that increased flows likely flushed
precipitates from the collection system.
Two of the City's SIUs are known as likely sources of nickel. One SIU has a
history of pretreatment nickel violations and was visited by the Wastewater
Treatment Superintendent in response to the January 7, 2009 sampling. The
Superintendent compared readings on the City s handheld pH probe with the
readings from the SIU's pH meter. Given the discrepancies found, the SIU was
advised to regularly calibrate their pH probes because of the important role pH
plays in the metals precipitation during industrial waste pretreatment. There
have been no alleged total nickel violations since that time.
March 2009 — Total Suspended Solids, Weekly Average Concentration
The discharge limit (weekly average concentration of 45.0 mg/L total suspended
solids) was allegedly exceeded for the March 3, 2009 sampling period with a
concentration of 297 mg/L. The alleged violation was attributed to a motor
failure on Final Clarifier Number 2 during a heavy rain event. The clarifier was
taken out of service to replace the motor, resulting in overload of Final Clarifier
Number 1. The City installed a new motor and returned Clarifier 2 back to
service. The City sent the old motor out for repair in order to maintain a spare
motor "on the shelf' for quick replacement. This incident has been the only
alleged violation resulting from equipment failure since commissioning of the
new plant was completed. There have been no alleged TSS violations since
March 2009.
May 2009 —Dissolved Oxygen Concentration
This effluent dissolved oxygen (DO) excursion did not occur. Operators
measured the DO of both the plant influent and plant effluent. The influent
DO concentration was inadvertently recorded as the effluent DO concentration
on the May 2009 DMR. The laboratory data sheet (see Attachment B) shows
that the effluent DO concentration measured on May 6, 2009 was actually
8.71 mg/L, well above the City's permitted minimum DO concentration of
6.0 mg/L. This reporting error was corrected in the May 2009 DMR revision
(see Attachment B).
P1133216 Thomasville Sewage Spill Inveshgation\306 Response\WWTP 308 Response 200g 12-02.doo

Mr. Kelly Craver
City of Thomasville
EPA 308 Response — W WTP
December 2, 2009
Page 6
Construction of the new 6.0 mgd AWTP was completed in February 2008.
Seventy-seven of 81 alleged effluent violations listed in the EPA's Enclosure A
are believed to have been mitigated by construction of the new AWTP. The
four alleged violations for the post -commissioning included one that did not
occur, two metals excursions (presumed to be period SIU discharges), and one
TSS excursion (associated with a single equipment failure which was promptly
addressed). The City continues to mitigate the risk of permit excursions
through use of IUPs for SIUs, utilization of preventative maintenance
procedures for critical process equipment, and development of an on -site
inventory of critical spare parts.
I am available to meet upon your request to discuss any of the information
provided herein. Please do not hesitate to contact me should you have any
questions or require additional information.
Sinc
A. Keith West, P.E.
Project Manager
AKW /*
Attachments
P:\13em-Thmasville Sewage Spill Inveshgation\308 Response\WWTP 308 Response 2009-12-02.doo

Figure
Figure 1 - WWTP Replacement Timeline 2006 - 2009
P:\I38216 - Thomasville Sewage Spill InvestigatioO08 ResponsMW WTP 308 Response 2009-12-01.da

F--:--A
Figure I -Plant Replacement Timeline 2006 .2009
Hamby Creek WWTP
City of Thomasville, North Carolina
Effluent Characteristic
11.
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30
Dissolved Oxygen
■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■
■■■■■
:..
■
■■■■■■■■■■■■■■■■■■
:..
■
■■
■■■■■■■■■■■■■■■■■■
TSS, monthly average
■■■■■■
■■■■■■■■
■■■■■■■■■■■■■■■■■■■■
ISS, weekly average
■■■■■■
■
■■■■■■
■■■■■■■■■■■
■■■■■■■
■■■■
■
■■■■■■■■■■■■■■■■■■
NHrN, Total as N, weekly average
■■■■■
■
■■
■■
■■■■■■■■■■■■■■■■■■
Nickel, Total, weekly average
■■■■■■■■■■■■■■■■
■■■■■■■■■■
■■■■■■■■■
Nickel, Total, daily maximum
■■■■■■■■■■■■■■■■
■■■■■■■■■■■■■■■■■■■■
Chromium, Total, weekly average
■■■■■■
■■■■■■■■■
■■■■■■■■■■■■■■■■■■■
Selenium, Total, weeklyaverage
■■■■■■■
■■
■■■■■■■■■■■■■■
■■■■■■■■■■■
Feclil Coliforn, weekly geometric mean
■■
■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■■
■
■■■■■■■■■■
■■■■■■■■■■■■■■■■■■■■■■■
end:
f:oa.Ms./or.., �sd,bp MNw AW1»

Attachment A:
Hamby Creek WWTP DMR, March 2008
Hamby Creek WWTP Lab Results, March 2008
P1138216 Thomasville Sewage Spill Invesiigation\308 Response\WWiP 308 Response 20091

NPDES Permit No. NCO024112 DISCHARGE NO. 001
FACILITY NAME: CRy of Thomasville, Hamby Creek W WTP CLASS IV
CERTIFIED LABORATORY (1) Thomasville, Hamby Creek W TP Laboratory
(list Wditimul Iabmat a m the becksiae/Payc 3 n7i1•iis Waim)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Morgan D. Huffman
PERSON(S) COLLECTING SAMPLES Laboratory and Operations Staff
MONTH March YEAR 2008
COUNTY Davidson
CERTIFICATION NO. 92
EFFLUENT
GRADE IV CERTIFICATION NO. 25204 NO FLOW
ORC PHONE [phone] CHECKaOXIPORCHASCHANGED
--
Mw7ORIGmAL-0NF.CMY,e. ATTN. CENTRAL F n e c DIVISION DF WATER QUALPIT
1617 MAIL SERVICE CENTER. RALEIGH, NC 2769 1617
Sylmmoof ORC 13me
By this signeNra, I certify that this fepon is wwrate and wmpleft, 0 the best of my knmiedge.
50Ma
MIS
00100
M060
0a110
00610
00510
31616
Si
MIS
0Y00
MWI
MP30
0ISTI
OIO.H
0IM2
00720
01M1
DIM
71M
01147
01077
01093
110
DIM
0100E
01002
Q
FF
O n
c
u
now
RIFF ®
U
Iguv
07
g
S
O
ZZ
o aZ
o 5
W v
k1
O O
(7
pCC
at
6
u
=
EE
up�i
w
T
d
KW
F
-WI
F
,r,
u
o
f
U
HRS
MS
Y/
MDD
°C
l ITN
UGh
MGh
MGh
MGh
NIMIML
MGIL
MGh
MGh
M d
U(n
UGIL
UGh
UCJL
UGh
WJL
UWL
NDIL
UGL
UGIL
UGIL
ll h
UOh
VwL
1
7:00
24
B
2.85
2
7:00
24
N
3.39
3
7:00
24
Y
2.28
14.7
7.3
500
12.3
4.49
6.80
7
9.4
465
4
7:00
24
B
3.50
14.9
7.5
310
13.8
3.71
M6
33
9.3
552
5
700
24
Y
4.94
15.6
7.1
325
153
2.58
261
6
8.8
364
33 9
6.99
Q
48
137
9
15
50
<5
6
266
6
7:00
24
Y
3.72
14.4
7.2
350
38.3
0.919
27.0
20
9.2
376
7
7:00
24
Y
4.18
14.3
7.3
360
18.3
2.01
8.00
3
9.2
436
8
7:00
24
B
4.95
9
7:00
24
N
3.80
10
7:00
24
Y
3.60
13.9
7.4
368
11.0
IA5
7.00
580
9.3
412
Il
7:00
24
Y
4.83
12.4
7.4
225
Q
233
10.00
24
10.0
459
12
7:00
24
Y
3.56
14.1
7.5
<50
3b3
3.04
<5
<1
to.]
518
1.33
<2
<5
12
<5
42
<5
<5
44
13
7:00
24
Y
3.22
15.1
7.5
80
3.61
929
5.25
<1
9.6
533
14
7:00
24
B
4.05
15.0
7.2
105
4.55
13.8
<5
9
10.0
557
15
7:00
24
Y
3.59
16
7:00
24
N
3.80
17
7:00
24
Y
3.44
14.5
7.4
115
10.5
16.6
5.50
9
10.6
461
18
7:00
24
Y
3.51
14.2
7.5
120
11.1
14.1
<5
11
10.0
544
19
7:00
24
Y
3.68
14.8
7.5
115
9.03
ISA
<5
58
10.1
539
0.410
<2
<5
8
25
16.1
<5
20
7:00
24
Y
3.50
15.8
7.3
170
9.12
14A
3.40
>1400
9.4
537
21
7:00
24
H
3.01
22
7:00
24
N
2,83
23
7:00
24
N
2.83
24
7:00
24
Y
3.07
14.8
7.2
75
6.95
12.3
5.00
<1
9.4
4%
25
7:00
24
Y
2.86
15.8
7.6
<50
6.78
10.0
1 4.80
1 <(
1 8.6
438
26
7:00
24
Y
2.85
15.9
7.3
<50
7.15
14.9
2.00
10
1 8.9
499
1 0.2101
Q
<5
1 7
<5
<5
14E1<5
<5
17
27
7:00
24
B
2.60
15.5
7.3
<50
7.53
13.2
2.00
<1
9.5
595
28
7:00
24
Y
3.22
16.2
7.4
<50
8.64
16.4
5.00
110
8.9
605
29
7:00
24
N
2.94
30
7:00
24
N
2.86
31
7:00
24
Y
3.63
15.2
7.3
<50
8.44
17.9
5.00
48
9.7
552
AVERAGE
MAXIMUM
3.45
4.94
14.9
16.2
7.6
230
500
18.1
153
9.44
17.8
23.0
261
12
>1400
9.5
10.6
4%
605
33.9
33.9
2.24
6.99
Q
<2
48
48
52
137
9
9
15
15
33
50
1
1
6
6
109
266
MINI6tUM
2.28
12.4
7.1
<50
3.6
0.92
2.00
<I
8.6
364
33.9
0.21
Q
<5
<5
<5
<5
14
1
<5
17
(C)IGnb(q
Monthly Limit
4.0ev
G
G
G
C
C
C
G
G
G
C
C
C
C
C
C
G
C
5.3wk
C
26Jwk
9i5.3NnklYLbOlr
C
C
C
C
C
C
6.0-90
601W
Ia3w
IM
06.0
908
2.1 wk
Aswk
S0 "y
7.501
&W
e5m9i
100
a60
760ry
t0226s9
Ild9y
33.8NY
M56
ONQ farm 91R-1 (111N)

Facility Status: (Please check one of the following)
Ali monitoring data and sampling frequencies meet permit requirements
❑
(including weekly averages, if applicable)
Compliant
❑X
All monitoring data and sampling frequencies do NOT meet permit requirements
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part II.E.6 of the NPDES permit.
"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 managed 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."
Morgan D. Huffman
Permittee (Please print or type)
Signature of Permittee*** Date
(Required unless submitted electronically)
PO Box 368, Thomasville, NC 27361 3364754222 4/30/2009
Permittee Address Phone Number e-mail address Permit Expiration Date
ADDITIONAL CERTIFIED LABORATORIES
Certified Laboratory (2) Research and Analytical Laboratories Certification No. 34
Certified Laboratory (3) Oxford Labs Certification No. 75
Certified Laboratory (4)
Certified Laboratory (5)
PARAMETER CODES
Certification No.
Certification No.
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by visiting the Surface
Water Protection Section's web site at b2o.enr.state.nc.us/wos and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
**' Signature of Permittee: If signed by other than the perminee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2

Influent
NPDES Permit No. NC0024112 DISCHARGE NO. 001 MONTH March YEAR 2008
FACILITY NAME: City of Thomasville, Hamby Creek WWTP COUNTY Davidson
DWQ Fa MR-2 (Revised 7/20DO) Page 3

EFFLUENT
NUTRIENTS WORKSHEET
NPDES PERMIT NO. NCO024112 DISCHARGE NO.
FACILITY NAME: Thomasville, Hamby Creek WWTP
By this signature,) certify that this report is accurate and
001
CLASS: IV
complete to the best of my knowledge. %
Signature of Dparatar In Responsible Charge
MEMBER OF COMPLIANCE
ASSOCIATION? Yes X No ❑
If'Yes,' provide name of association:
Yadkin Pee Dee River Basin
(Association
E (1) (2) (3) (4)
YEAR 2008
COUNTY Davidson
Date
INSTRUCTIONS
-Submit two (2) copies of this Effluent Nutrients Worksheet, each with an original signature,
with the facility's regular Discharge Monitoring Report form(s)This Worksheet is a reporting
form for nutrients. It supplements but does not replace the regular DMR forms.
-Each Worksheet must include all nutrient data for the current yearEither (1) fill in a new
Worksheet for each report, each time entering all nutrient data for the year-to-date, and submit with the
regular DMR; or (2) maintain the original Worksheet at the facility, entering nutrient data as they are
generated, and submit photocopies with the DMR. In either case, each Worksheet must carry an
original signature (photocopied signatures are not acceptable).
See reverse side for additional mshuctions on completing the Worksheet.
(5) (6) (7) (8) (9) (10) (111
Date
Total
Flow
Total Nitrogen
Total Phosphorus
Monitoring: c irML q llMo. q 11Dr. q
Reporting: glftk. g1/0r. q_
Monitoring: [M lMk. ❑ 11Mo. _Volt. q
Reporting: ®LMo. DI/oh. q
I
Average
Conic.
Mass Loading
Current Period
Mass Loading
Year -to -Date
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Average
Conc.
Q
TN
TN Load
Cumul TN Load
TP
TP
TP
TP
TP
.Avg. TP
WC
ini
(Ib)
(lb).
(mg/L)-
(mg/Li
(mg/L)
(Mg/U.
(mg/L)
(mg/Ll
Jan
2.11
3.06
2.88
2.12
2.78
2.59
Feb
2.99
2.72
2.59
5.14
3.36
Mar
6.99
1.33
0.41
0.21
2.24
I"Qtr.
Apr
May
Jun
Jul
Aug
Sep
3`d Qtr.
Oct
Nov
Dec
4m Qtr.
Year
(lambed
I
TN Load - Q x TN x 8.34
(4) (2) (3)
Avg. TP in monitoring period = (Sum of all TP values) / (# Samples)
(11) (6)thru 001
DWQ Fomm MR-N W I(9/00) Page 41

EFFLUENT
PHOSPHORUS WORKSHEET SUPPLEMENT
NPDES PERMIT NO. NCO024112 DISCHARGE NO. 001
FACILITY NAME: Thomasville, Hamby Creek W WTP CLASS: IV
By this signature, I certify that this report is accurate and
complete to the best of my knowledge. X
Sighown, of Operator n Responside Charge
YEAR
COUNTY Davidson
Due
2008
Compliant with seasonal loading limits? Yes �No
(1) (2) (3) (4) (5) (6) (7) (8) (9) 10, (11)
Total Phosphorus Loading
Total Phosphorus
Date
IFlow
Total
Monitoring: ® Wik. _ VW - iXW. q _
Repotting: ®7/Mo. `'. VOa. q _
Average
Conc.
Mass Loading
Current Period
Mass Loading
Season -to -Date
Sample 1
Sample 2
Sample 3
Sample 4
Sample S
Average
Conc.
Q
TP:
TP Load
CUmgk:TP Load
IP
TP
TP
TP
TP
Avg;:TP
I
tMGt
(mg/U
,(Ib1
(ihl
(my;L)
(mg/1)
(i
(mq/LI
Img, II
{mlaj.Lj".
Previous
Seasonal
Total
----
4364
Jan
84.1
2.59
1817
6181
2.11
3.06
2.88
2.12
2.78
2.59
Feb
87.2
3.36
2444
8624
2.99
2.72
2.59
5.14
3.36
Mar
107.0
2.24
1994
10619
6.99
1.33
0.41
0.21
2 24
Seasonal
Loading
10619
::1":tnc:..
Apr
May
Jun
:2"d Qtr..
. .
Jul
Aug
Sep
3-: Qtr.
........
Oct
Seasonal
Loading
0
Nov
Dec
I �Qtl
L6255
Yearto
Date Load
TP Load = Q x TP x 8.34
(4) (2) (3)
Avg. !P in monitoring period = Sum of all TP values) / (# Samples)
(II) (6)thm (le)
Page 5

NPDES Permit No. NCO024112
FACQdTY NAME: City of Thomasville, Hamby Creek WWTP
Non Compliance Issues:
MONTH March YEAR 2008
COUNTY Davidson
Impact: Corrective Action or Comments:
1
BOD - The monthly average and 1 weekly limit is exceeded.
Significant
Loss of nitrification in the aeration basins continues to be a problem
resulting in less breakdown of wastes. Also one rain event caused high
solids, resulting in one exceptionally high day of BOD.
2
Ammonia -The monthly average and 2 weekly limits are
exceeded.
Significant
Loss of nitrification in the aeration basins continues to be a problem
resulting in less breakdown of wastes.
3
TSS - One weekly limit is exceeded.
Significant
A rain event resulted in higher than normal solids in the effluent.
4
Lead, Silver - One weekly limit is exceed for each metal
Significant
A rain event resulted in higher than normal solids in the effluent.
5
Nickel - Two weekly limits are exceeded.
Significant
A rain event resulted in higher than normal solids in the effluent.
Note: Hamby Creek W WTP is operating under SOC WQ SO4-013 which raises chlorine limits and removes phosphorus loading limits.
Data Qualifications:
Impact: Corrective Action or Comments:
1
Chlorine - The MDL for our hand held meter is 50 mg/L. UV
None
disinfection started after 3/11108 and most readings after that
date are <50 mg/L. Some chlorinated potable water used for
washing out tanks may have contributed to the occasional higher
chlorine values.
2
BOD - GGA failed to meet acceptance criteria on 3/20 samples.
Significant
Samples cannot be repeated. Technician error in pipeting is a possible
SCF failure occurred on 3/6, 317, 3/27, 3/28
cause. Retraining of this staff member continues.
3
Fecal - influent positive control failed on 317, 3/14 and 3117.
Significant
Samples cannot be repeated. Technician error is the cause.
The 3/11 sample was not property incubated. Sample was placed
Retraining of this staff member continues.
in the incubator about 6 hours late.
4
Impact ratings: None - No affect on compliance or data quality
Slight - No affect on compliance, QC controls exceed acceptance limits but don't affect validity of results
(QC control should be noted as blank, duplicate RPD, or SSCV recovery.)
High - Reported value doesn't affect compliance, however QC controls exceed acceptance limits or other factor may affect validity.
Test cannot be repeated to verify validity of reported value.
(QC control should be noted as blank, seeded blank acceptance failure, SCF failure, or other. Other may include known operator error.)
Significant - Affects compliance, specify known problem.
Page 2A

RESEARch & ANA[yTICAI
LABORATORIES, INC.
Analytical/Process Consultations
t' paw
NC#m Z.
City of Thomasville Date Sample Collected 03/05/08
P.O. Box 368 Date Sample Received 03/05/08
Thomasville, NC 27361 Date Sample Analyzed 03/05/08
Attn: Misty Conder Date of Report 03/25/08
Analyses Performed by KP -SK -YJ -KL -DW
Lab Sample Number
611447
Parameter Storet # Results
BOD-5
(00310)
153 mg/l
Cadmium,Tot
(01027)
<0.002 mg/l
Chromium,Tot
(01034)
0.048 mg/l
Copper,Tot
(01042)
0. 117 mg/1
Lead,Tot
(01051)
0.015 mg/).
Nickel,Tot
(01067)
0.050 mg/1
Selenium,Tot
(01147)
<0.005 mg/1
Silver,Tot
(01077)
0.006 mg/l
Zinc,Tot
(01092)
0.266 mg/l
Cyanide
(00720)
0,009 mg/l
Phos,Tot
(00665)
6.99 mg/l
TKN
(00625)
32.1 mg/l
NO2+NO3
(00630)
2.80 mg/l
--------------------
Clients Sample Source EFFLUENT
Number
Time Collected (Hrs) 0950
P.O. Box 473. 106 Short Street • Kernersville, North Carolina 27264 •336-996-2641 • Fax [phone]
w .randalabs.com

RESEARCh & ANA1yTICA1
=T LAbORATORIES, INC.
Analytical, Process Consultations
City of Thomasville
P.O. Box 368
Thomasville, NC 27361
Attn: Misty Conder
Parameter
TSS
Storet #
(00530)
Date Sample Collected 03/12/08
Date Sample Received 03/12/08
Date Sample Analyzed 03/12/08
Date of Report 03/20/08
Analyses Performed by YJ -SK
Lab Sample Number
612128 612129
Results Results
317 mg/1 <5.0 mg/l
Cadmium,Tot
(01027)
<0.002
mg/l
Chromium,Tot
(01034)
<0.005
mg/1
Copper,Tot
(01042)
0.012
mg/1
Lead,Tot
(01051)
<0.005
mg/l
Nickel,Tot
(01067)
0.042
mg/1
Selenium,Tot
(01147)
<0.005
mg/1
Silver,Tot
(01077)
<0.005
mg/1
Zinc,Tot
(01092)
0.044
mg/1
-------------------- --------------------
Clients Sample Source INFLUENT EFFLUENT
Number
Time Collected (Hrs) 0956 0959
P.O. Box 473. 106 Short Street • Kernersville, North Carolina 27284 • 336.996-2841 • Fax [phone]
www.randelabs.com

\\1U1g11lff
RESEARCh & ANAIyTICAi ;�',� .h
LAbo INC. �= A
RATORIES� t ¢ :� NC q Z `"
Ana ical/Process Consultations 0� P .`
lyt •, RECt�.,: �g �.
RED 1At1\"%, ��.
City of Thomasville Date Sample Collected : 03/19/08
Date Sample Received : 03/19/08
P.O. Box 368 Date Sample Analyzed : 03/19/08
Thomasville, NC 27361 : 04/01/08
Date of Report Attn: Misty Conder Analyses Performed by : YJ -SR
Lab Sample Number
-------- -----------
612755 612756
Results Results
Parameter Storet #
TSS (00530)
116 mg/1 <5.0 mg/1
<0.002 mg/l
Cadmium,Tot (01027)
<0.005 mg/l
Chromium,Tot (01034)
0.025 mg/1
Nickel,Tot (01067)
<0.005 mg/l
SelerliUm,TOt (01147)
0.008 mg/l
Cyanide (00720)
-------------------- ---------------
Clients Sample Source
INFLUENT EFFLUENT
Number
Time Collected Mrs)
P.O. Box 473. 106 Short Street • Kernersville. North
alrolina m7284. 336.996.2841 • Fax [phone]
r

RESEARCh & ANAIyTICA[
LABORATORIES, INC.
Analytical/Process Consultations
City of Thomasville
P.O. Box 368
Thomasville, NC 27361
Attn: Misty Conder
Parameter Storet #
Date Sample Collected 03/26/08
Date Sample Received 03/26/08
Date Sample Analyzed : 03/26/08
Date of Report : 04/04/08
Analyses Performed by : SK
Lab Sample Number
---------------------
613166
Results
Cadmium,Tot
(01027)
<0.002 mg/l
Chromium,Tot
(01034)
<0.005 mg/l
Copper,Tot
(01042)
0.007 mg/1
Lead,Tot
(01051)
<0.005 mg/l
Nickel,Tot
(02.067)
0.014 mg/l
Silver,Tot
(01077)
<0.005 mg/l
Selenium,Tot
(01147)
<0.005 mg/l
Zinc,Tot
(01092)
0.017 mg/l
--------------------
Clients Sample Source EFFLUENT
Number
Time Collected (Hrs) 0954

Attachment B:
Hamby Creek WWTP Daily Grab Bench Sheet, May 2009
Hamby Creek WWTP DMR, May 2009
(Amended November 16, 2009)
P:\138216- Thoinasville Sewage Spill Investigation\308 ResponseNWTP 308 Response 200912-01.da

l
1
Daily Grab Samples Probe Anal is Bench Sheet
Date: 5/6/09 Analyst: , QC CaI/c.'s By:
Influent Collection Time: Effluent Collection Time:
Note: Al times are recorded based a 24 hour clock Sampan iders0ed vAth a'D^ an, dupkats samples.
Dissolved Oxygen ! (Hach HQ30d Meter)
/.J
Temp of Calibration: , • S°C Conc. Calibration:
Sample ID
Meter
Readin
Units
Time
Collected
PIn11-DO- 060609
esi
mcifL
I 3:sZ
PEff 1 - DO - 050609
4-7/
L
3
PEff 1 - Temp- 050609
AVI
C
8
Note: Effluent temperature is measured with calibrated DO meter temperature sensor.
Note: Effluent DO s ef0uera temperature collection time and analysis time are the same unless noted othenvise.
pH (Fisher AR 50)
q5. slope
Slope: Acceptance: 95.5 - 102
Sample ID
Meter
Reba/din
Units
Time
Anal ad
Acceptance
Ran su
4.0 Standard
-t -6)
Sid Units
3.9 - 4.1
7.0 Standard
7.0
Sid Units
.c
Q Q
6.9 - 7.1
10.0 Standard
• 0
Sid Units
•0 7
9.9 - 10.1
Plnf 1 - H - 050609
Sid Units
Sz
PEff 1 - pH - 050609
1 1,36
Std Units
i
PEff 1 D - H - 050609
7.
Std Units
3:5
dwlko;ater.
Z
Conductivity A(Fisher AR 50)
Cell Constant: (! t
(measured)
Time: 3• .Z
Method Source:
Hach 10300
Method Source: Standard Methods 25508, 20m
Edition
Time: 7:6 7
Method Scarce: SM 450011- 9, 2011r Edition
Lot N 4.0 SU Bk#W.
073720
Lot N 7.0 SU S Mar:
067187
lM N 10.0 SU eueec
067695
4.0 Sid. % Recovery
%
7.0 Sid %Recovery %
10.0 Sid % Recovery %
Cell Cortstant rl�
Acceptance:Ti 0.90 - 1.10 me:
Method Source: Standad Method 2510 A and 9, lath Edition
Meter
std. Percent
Time
Temp °c at
Std Prep Log
Sample ID
Readln
Units
Recow
Anal ed
Analysis
Number
1412 umho/cm standard
umho/cm
(
Con1412-09.
717 umho/cm standard
7 Z
umho/cm
T. i
s j
con717-09. 4
73.9 umho/cm standard
f
umho/cm
7 : o,
cnnn.eao-
RPD of
Range of
Re rt
Units
-
-
Duplicate
Duplicate
PEff 1 - Cond - 050609
[/
{ 53
5
umho/cm
2 e
2
%
p°° grnp
PEff1D - Cond - 050609
_
Conductivity QC Data: • 0 0
Standards Acceptance Criteria: Duplicates Acceptance Criteria: !� _ 10
I Rising. % RPD of Dups Range of Dups
1412 umho/cm sld 1270.8 - 1553.2 90 -110 % RPD UW L 1.27 % Range UWL 5.60 Std Derv.
717 umtolOm std 645.75-789.25 90 - 110 %
73.9 umholcm sld 166.51 - 81.2 90 - 110 % RPD UCL 1.91 % Range UCL 8.41 Std Dev.
City of Thomasville
Document N MC12230201, RevMC1027051 Page 1 of 1

NPUCS Pe 3t No. NCO024112 DISCHARGENO. 001
FACILITY NAME: City of Thomasville, Hamby Creek WNTP CLASS IV
CERTIFIED LABORATORY (1) Thomasville, Hamby Clack W WTP Labonatory
(list OUtionel Montoriec on the b .i page o la rat
OPERATOR IN RESPONSIBLE CHARGE (ORC) Leigh A. Conder
PERSON(S) COLLECTING SAMPLES Laboratory and Operations Staff
MONTH May YEAR 2009
COUNTY Davidson
CERTIFICATION NO. 92
EFFLUENT
Revised ll/I ND9
GRADE IV CERTIFICATION NO. 9191992 NO FLOW / DISCHARGE FROM SITE e
ORC PHONE [phone] CRECK ROX IF ORC HAS CHANGED
Me MIOmAL.a ONE y10 ATTN: CENIRM. FILM DIVISION OF WATER QUALITY
1617 MAIL SERVICE M2 - RALEIGH, NC 2760 1617
Sapp of ORC Et,[
1 By this Signalum, I certify Nat this ra d is accurate and COmptete to the best of my knowledge.
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0.046
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9
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5
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28
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24
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29
7:00
24
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0.40
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0.105
30
7:00
24
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1.92
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7:00
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2.05
AVERAGE
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0.51
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8.6
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7.78
0.068
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8
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15
15
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1.00
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0.124
Pus
Q
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4
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MINIMUM
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DWQ corm M2.1 (II/N)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages, if applicable) X
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements ❑
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part II.E.6 of the NPDES permit.
"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 managed 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."
Leigh A. Corder
Permittee (Please print or type)
Signature of Permittee*** Date
(Required unless submitted electronically)
PO Box 368, Thomasville, NC 27361 336-475-4222 4/30/2009
Pemrittee Address Phone Number e-mail address Permit Expiration Date
ADDITIONAL CERTIFIED LABORATORIES
Certified Laboratory (2) Research and Analytical Laboratories Certification No. 34
Certified Laboratory (3) Oxford Labs Certification No. 75
Certified Laboratory (4)
Certified Laboratory (5)
PARAMETER CODES
Certification No.
Certification No.
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by visiting the Surface
Water Protection Section's web site at h2o.enr.state.nc.us/wgs and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC most visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2

Addendum Revised 11/16/09
NPDES Permit No. NCO024112 DISCHARGE NO. 001 MONTH May YEAR 2009
FACILITY NAME: City of Thomasville, Hamby Creek WWTP COUNTY Davidson
ucn [influent
DWQ Porn MR-2 (Revised 2/2000) Page6

Influent
Revised 11/I6109
NPDES Permit No. NCO024112 DISCHARGE NO. 001 MONTH May YEAR 2009
FACILITY NAME: City of Thomasville, Hamby Creek W WTP COUNTY Davidson
rt
M1
R
'
DWQ F rt MR-2 (Revise¢ 7/2000) Page 3

EFFLUENT
NUTRIENTS WORKSHEET
Revised
NPDES PERMIT NO. NCO024112 DISCHARGE NO. 001 11116109
FACILITY NAME: Thomasville, Hamby Creek 1W WTP CLASS: IV
By this signature, I certify that this report is accurate and
complete to the lest of my knowledge. x
signature of Operator in Reepon4de Charge
MEMBER OF COMPLIANCE
ASSOCIATION? Yes x No ❑
If *Yes," provide name of association:
Yadkin Pee Dee River Basin
Association
YEAR 2009
COUNTY Davidson
Date
INSTRUCTIONS
-Submit two (2) copies of this Effluent Nutrients Worksheet, each with an original signature,
with the facilitys regular Discharge Monitoring Report forml(s)ihis Worksheet is a reporting
form for nutrients. It supplements but does not replace the regular DMR forms.
-Each Worksheet must include all nutrient data for the current yealEither (1) fill In a new
Worksheet for each report, each time entering all nutrient data for the year-to-date, and submit with the
regular DMR; or (2) maintain the original Worksheet at the facility, entering nutrient data as they are
generated, and submit photocopies with the DMR. In either case, each Worksheet must carry an
original signature (photocopied signatures are not acceptable).
See reverse side for additional instructions on completing the Workshaef.
(7) (2) (3) (4) (5) (6) (7) (8) (9) (10) 0 1)
Date
Total
Flow
Total Nitrogen
Total Phosphorus
Monitoring: gIAYk gIR4o. g11Qtr. q_
Reporting: ql/W. gI101r. q_
Monitoring: ®1MM. All _1/Dtr. q
Reporting: Ellin �IiQtr. q_
Average
Conc.
Mass Loading
Current Period
Mass Loading
year -to -Date
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Average
Conc.
Q
IN
TN Load
Cumul TN Load-
_ TP
TP
TP
TP
TO
AJgrTP-.:
IMCI
fmg'LI
(lbi
Uo,
(mg/L)
lmg/U
(ni
trng,❑
(mW.L)
(mg/w--.=
Jan
0.158
0.057
0.095
0.085
0.535
0.186
Feb
0.111
0.053
0.054
0.055
0.068
Mar
0.852
1 0.051
0.057
1 0.057
0.053
1 0.214
Apr
0.050
0.05
0.057
0.107
0.069
0.067
May
0,060
0.051
0.067
0.101
0.070
Jun
V4 Qtr,,
Jul
Aug
Sep
Oct
Nov
Dec
Year
Dan -Dec)
TN Load - Q x TN x 8.34
(4) (2) (3)
Avg. TP in monitoring period = (Sum of all TP values) / (N Samples)
(I1) (6)thm (TO)
Note: Samples listed are an average for all phosphorus samples run for that week.
DWQ Form MR -NW 1(9W Page 4

EFFLUENT
PHOSPHORUS WORKSHEET SUPPLEMENT
Revised
11116109
NPDES PERMIT NO. NCO024112 DISCHARGE NO. 001
FACILITY NAME: Thomasville, Hamby Creek WWTP CLASS: IV
By this signature, I certify that this report is accurate and
complete to the best of my knowledge. X
Signature of Operator in Responsible Charge
Compliant with seasonal loading limits? Yes
0 (2) (3) (4) (5) (6) (7) (8)
YEAR 2009
COUNTY Davidson
Date
�No
(9) (10) 0 1)
Total Phosphorus Loading
Total Phosphorus
Date
Total
Flow
Monitoring: © 1M,l - 1/Mo. i 11/Qtr. q
Reporting: ©tlMo. tlQtr. q
I
Average
Cone.
Mass Loading
Current Period
Mass Loading
Season -to -Date
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Average
Conc.
Q.
TIP
TP Load
Cumul TP Load.
TP
TP
TP
TP ,
TP,
Avg: TP_-
I
(MG)
mg/L)
(lb)
(lb),
(mg/L)
mmg/1,)
(mg/L)
(mg/U.
(mg/L)
{mg/L)
Previous
Seasonal
Total
711
:-..
Jan
77.4
0.186
120
831
0.158
0.057
0.095
0.085
0.535
0.186
Feb
62.8
0.068
36
867
0.111
0.053
0.054
0.055
0.068
Mar
116.9
0.214
209
1075
0.852
0.051
0.057
0.057
0.053
0.214
Seasonal
Loading
...
1075
to Qtr.
Apr
78.3
0.067
43
43
0.050
0.05
0.057
0.107
0.069
0.067
May
66.8
0.070
39
82
0.060
0.051
0.067
0.101
0.070
Jun
20E.. Qtr.
...
...
Jul
Aug
Sep
_bra-Qtr. .
Oct
Seasonal
Loading
82
Nov
Dec
4!h mir.
Yearto
Date Load
447
TP Load = Q x TP x 8.34
(4) (2) (3)
Avg. TP in monitoring period = (Sum of all TP values) / (# Samples)
(11) (6)thru(10)
Note: Samples listed are an average for all phosphorus samples run for that week. Page 5

NPDES Permit No. NC0024112 MONTH
FACILITY NAME: City of Thomasville, Hamby Creek WWTP
YEAR 2009
COUNTY Davidson
Corrective Action or comments:
Note: Hamby Creek WWTP is operating under SOC WO SO4-013 which raises chlorine limits and removes phosphorus loading limits.
Data Qualifications:
Impact: Corrective Action or Comments:
1
Chlorine - Low level chlorine testing has been initiated. Levels
Slight
No source of chlorine identified.
exceed chlorine limits that will be in effect once we emerge from the
SOC. RPD limits were exceeded on 5/19 and 5/27.
Duplicate range limits were exceeded on 5/5.
2
BOD - Dilution water did not meet acceptance criteria on 5/1 -517,
High
Samples cannot be repeated.
5/11 -5/12, 5119, 5/22- 5/28. SCF was too low on 5/1 and 5/22.
GGA was out of limits 5/1.
3
TSS - Duplicates did not meet the 5% rule on 517 and 5/11.
Slight
Failure of the 5% rule is primarily due to the low TSS levels and is not significant.
4
5
6
Impact ratings: None - No affect on compliance or data quality
Slight - No affect on compliance, OC controls exceed acceptance limits but don't affect validity of results
(QC control should be noted as blank, duplicate RPD, or SSCV recovery.)
High - Reported value doesn't affect compliance, however QC controls exceed acceptance limits or other factor may affect validity.
Test cannot be repeated to verify validity of reported value.
(QC control should be noted as blank, seeded blank acceptance failure, SCF failure, or other. Other may include known operator error.)
Significant - Affects compliance, specify known problem.
Page 2A