NC0023337-EMC SOC WQ S01-008_20031114

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AUG-29--2997 11:24 AM
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SCOTLAND NECK WWTP UV SAMPLE RESULTS
Sample
Semple
Sample
Sample
Point
Point
Point
Point
Lab
Dale
#1
Before
UV
#2
After
#3
Post Air
#4
Effluent
Plant
plow Rainfall
UV
Effluent
Meter
m d in
Tritest
7/30/2007
>6000
18
54
60
0.231
Tritest
7/31/2007
>6000
20
570
550
0.34
Tritest
8/1/2007
>6000
1
<35
6
0.6
0.244
Tritest
8/2/2007
?6000
10
32
33
0.236
Tritest
8/3/2007
:-6000
10
38
0.236
Tritest
6/6/2007
>6000
50
0.231
Tritest
Tritest
8/7/2007
8/8/2007
5800
9
31
32
0.196
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CS 1110 �+Ii�/. A1fo Cl�.sw,wai of
R

t
F ljyA7'p Michael F. Easley
Governor
AZWilliam G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
-^ Alan W. Klimek, P.E„ Director
Coleen H. Sullins, Deputy Director
,.. Division of Water Quality
The Honorable Robert B. Partin, Mayor
Town of Scotland Neck
P.O. Box 537
Scotland Neck, North Carolina 27874
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7000 1530 0002 2100 5817
Subject: Special Order by Consent
Town of Scotland Neck - WWTP
NPDES Permit NC0023337; EMC SOC WQ SO1-008
Halifax County
Dear Mayor Partin:
Attached for your records is a copy of the signed Special Order by Consent (SOC) approved by
the Environmental Management Commission. As stipulated in item 2(a) of the SOC, the Town
is required to submit a certified check in the amount of $15,505.12 to the Division of Water
Quality upon receipt of the approved and executed Order. However, the Division has agreed to
allow the Town to submit payment of the up -front penalty in two (2) installments. The first
payment of $7,752.56 is due to the Division no later than fifteen (15) days following the date on
which the signed and executed Order is received by the Town. The balance of the up -front
penalty, $7,752.56, will be due on or before August 31, 2004. For each payment, send a certified
check in the amount of $7,752.56 payable to the Department of Environment and Natural
Resources; forward each payment to the Director of the Division of Water Quality at the
letterhead address.
The terms and conditions of the Order are in full effect, and you are reminded that all final
permit limits contained in the permit must be met except those modified by the conditions of the
Order.
Additionally, as specified in paragraph 2(e) of the Order, you are required to submit to this office
written notice of compliance or non-compliance with meeting any schedule date.
Pursuant to amended North Carolina General Statute 143-215.3D, effective January 1, 1999,
water quality fees have been revised to include an annual fee for any permit covered under a
Special Order by Consent, in addition to the annual fee for the permit. The Town will be subject
to a fee of $250.00 on a yearly basis while under this Order, in addition to an annual permit fee
of $715.00. The Town will be billed for this at a later date.
�VA
NCENR
N. C. Division of Water Oualrly 1617 Mad Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF HALIFAX
IN THE MATTER OF )
NORTH CAROLINA )
NPDES PERMIT )
NO. NCO023337 }
HELD BY THE )
TOWN OF SCOTLAND NECK )
SPECIAL ORDER BY CONSENT
EMC SOC WQ NO, SO 1-008
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2 and 143-215.67, this Special Order
by Consent is entered into by the Town of Scotland Neck, hereinafter referred to as the Town, and the North
Carolina Environmental Management Commission, an agency of the State of North Carolina created by G.S.
14313-282, and hereinafter referred to as the Commission:
1. The Town and the Commission hereby stipulate the following:
(a) The Town holds North Carolina NPDES Permit Number NC0023337 for operation of an
existing wastewater treatment works and for making an outlet therefrom for treated wastewater to
Canal Creek, Class C NSW waters of this State in the Tar Pamlico River Basin, but is unable to
consistently comply with the final effluent limitations for BODS, NH3 as N, Total Suspended
Residue, Fecal Coliform, Total Residual Chlorine, Total Nitrogen, Total Phosphorus and
Chronic Toxicity as set forth in the NPDES Permit. In addition, the Town has reported elevated
flows in the WWTP due to excessive inflow and infiltration (I&1). Compliance will require
preparation and implementation of a plan for WWTP upgrades and to identify and reduce I&I
into the sewer system.
(b) Noncompliance with final effluent limitations and unauthorized discharges of partially treated
sewage constitutes causing and contributing to pollution of the waters of this State named above,
and the Town is within the jurisdiction of the Commission as set forth in G.S. Chapter 143,
Article 21.
(c) The Town has secured a grant or otherwise secured financing for planning, designing, or
constructing a new or improved waste collection and waste disposal system which, once
constructed and operated, will be sufficient to adequately treat wastewater presently being
discharged, to the extent the Town will be able to comply with final effluent permit limits.
(d) Since this Special Order is by Consent, neither party will file a petition for a contested case or for
judicial review concerning its terms.
(e) Based upon the Town's acceptance into the Tar Pamlico Basin Association (TPBA) on April 12,
2002, the Division of Water Quality (DWQ), at the Town's request, removed the nutrient limits
from the Town's NDPES Permit. The Town is, however, still responsible for all monitoring
requirements for Total Nitrogen and Total Phosphorous. If at any time membership in the TPBA
is canceled, withdrawn, or not kept current, the Total Nitrogen and Total Phosphorous limits will
be immediately reinstated in the permit.
(f) That the Town desires to allow the discharge of 3,700 gpd of additional wastewater to the
treatment works, and that the discharge of such additional wastewater will not result in any
significant degradation of the quality of any waters. See item 5.

The Town, desiring to comply with the permit identified in paragraph 1(a) above, hereby agree,, to do the
following:
(a) As settlement of all alleged violations of NPDES Permit NCO023337 prior to entering into this
Special Order by Consent, the Town agrees to an up. front penalty in the amount of $31,262.81.
A certified check in the amount of $15,505.12 must be made payable to the Department of
Environment and Natural Resources and forwarded to the Director of DWQ at 1617 Mail
Service Center, Raleigh, North Carolina 27699-1617 by no later than fifteen (15) days following
the date on which this Order is approved and executed by the Commission and received by The
Town. The remaining balance of the up -front penalty ($15,757.69) will be waived in full upon
verification that the Town has successfully met compliance as called for in this Order. Should
the Town fail to meet compliance, as called for in this order, the Town will be required to pay in
full the balance of the up -front penalty amount and any other penalties called for in this Order,
and a certified check must be made payable to the Director of DWQ as noted above no later than
fifteen (15) days following the date on which this Order expires.
(b) Undertake the following activities in accordance with the indicated time schedule:
1) I&I Removal Phase I — Replace 8,266 linear feet of sewer line, 38 manholes, the #1
pump station, rehabilitate four (4) pump stations and install auto -dialers.
a) Submit an application for Sanitary Sewer System Improvements on or before
June 10, 2002. (MET)
b) Bid project on or before January 30, 2003. (MET)
c) Complete construction on or before February 28, 2004. i�'��►
2) 1&1 Removal Phase II — Replace 18,276 linear feet of sewer line, 88 manholes, and an
estimated 100 taps.
a) Submit an application for Sanitary Sewer System Improvements on or before
April 15, 2003. (MET)
b) Bid project on or before January 15, 2004. (MET)
c) Complete construction on or before January 1, 2005.
3) Evaluate the effectiveness of the I&.I rehabilitation and prepare a summary report and
submit it to the Raleigh Regional Office on or before February 28, 2005.
4) WWTP upgrades Phase I — Refurbish the influent pump station, renovate an existing
clarifier, and repair/replace the grit removal auger.
a) Submit an application for repair/upgrade on or before August 31, 2002. (MET)
b) Bid project on or before March 31, 2003. (MET)
c) Complete construction on or before February 28, 2004. AIJ14
5) WWTP upgrades Phase 11— Construct a flow reduction/spray application system, install
new automatic bar screen and new tertiary filter system.
a) Submit an application for WWTP upgrades on or before April 15, 2003. (MET)
b) Bid project on or before January 15, 2004. (MET)
c) Complete construction on or before January 1, 2005.
6) WWTP upgrades Phase III — Make repairs, renovations, and improvements to the
existing aeration basins, and construct a new sludge digester or retrofit existing
equipment to serve as a digester. rtettcf b
a) Submit an application for repair/upgrade on or before May 1, 2004. vn j�f I
b) Bid project on or before October 1, 2004. (Her)
c) Complete construction on or before July 1, 2005.
2

7) Achieve compliance with all final effluent limitations contained in NPDES Permit
Number NCO023337 on or before September 30, 2005. After this date, the Town
returns to final effluent limits, and the Town is subject to civil penalties for all
violations of NPDES Permit Number NC0023337.
8) Submit quarterly progress reports detailing the work and activities undertaken and
completed on the WWTP upgrades and I&I rehabilitation during the calendar quarter.
Also include an estimated amount of I&I eliminated during the calendar quarter. The
reports are to be submitted as follows: one copy must be mailed to the Raleigh Regional
Water Quality Supervisor, Division of Water Quality, 1628 Mail Service Center,
Raleigh, NC 27699-1628, and one copy must be mailed to the Point Source Compliance
Enforcement Unit, Division of Water Quality, 1617 Mail Service Center, Raleigh, NC
27699-1617. The copies of the reports are due in each respective office no later than the
thirtieth (30`h) day of January, April, July, and October for the duration of this Order.
(c) Comply with all terms and conditions of the permit except those effluent limitations identified in
paragraph 1(a) above. See Attachments A and B for all current monitoring requirements and
effluent limitations. The permittee may also be required to monitor for other parameters, as
deemed necessary by the Director, in future permits or administrative letters.
(d) During the time in which this Special Order by Consent is effective, the Town shall comply with
interim effluent limitations as contained in Attachments A and B. Note it is reflected on
Attachment A that the Town is still responsible for the monitoring requirements for Total
Nitrogen and Total Phosphorous. The permittee may also be required to monitor for other
parameters as deemed necessary by the Director in future permits or administrative letters.
Under this Special Order by Consent, ONLY the parameters listed below have been modified
from the most current NPDES Permit in effect for outfall 001.
Permit Limits
Modified Limits
SOC
Parameter
Unit
Monthly
Average
Weekly
Avera a
Monthly
Average
Weekly
Average
BODS
(April 1 — October 31
mg/L
5.0
7.5
30.0
45.0
11 BODS
(Nov. 1— March 31
mg/L
10.0
15.0
30.0
45.0
Total Suspended Residue
mr&
30.0
45.0
60.0
90.0
NH3 as N
(April 1— October 31
mg/L
2.0
6.0
NH3 as N
(Nov. 1—March 31
mg/L
4.0
9.0
a
Fecal Coliforni
#colonies/100 Rd
200
400
400
800
Total Residue Chlorine
u
17.0 D ily Maximum
Monitor Onl
Chronic Toxicity
P/F at 90%
QuarterIy Monitor Only No
Toxicity Limit '
'Copper and Zinc Action Level Policy October 25, 2000 applies
(e) No later than thirty (30) calendar days after any date identified for accomplishment of any
activity listed in paragraph 2(b) above, submit to the Director of DWQ written notice of
compliance (including the date compliance was achieved along with supporting documentation if
applicable) or noncompliance therewith. In the case of noncompliance, the notice shall include a

statement of the reason(s) for noncompliance, remedial action(s) taken, and a statement
idenitlying the extent to wNch subsequent dates or times for accomplishment of listed activities
may be affected.
(f) Enforce the North Carolina State Building Code as it applies to Water Conservation (Volume H -
Plumbing, Chapter 9, 901 General Requirements - Materials, 901.2 Water Conservation, and
Table 901.2.2 - Maximum Allowable Water Usage For Plumbing Fixtures),
3. The Town agrees that unless excused under paragraph four (4), the Town will pay the Director of DWQ,
by check payable to the North Carolina Department of Environment and Natural Resources, stipulated
penalties according to the following schedule for failure to meet the deadlines set out in paragraphs 2(b)
and 2(e), or failure to attain compliance with the modified effluent limitations/monitoring requirements
contained in Attachments A and B.
Failure to meet a schedule date listed in either paragraph $500 per missed schedule date within the first seven (7)
2(b)(1), 2(b)(2), 2(b)(3), 2(b)(4), 2(b)(5), or 2(b)(6). days of tardiness; $50 per day thereafter.
Failure to achieve compliance with final effluent limits $20,757.69 (single penalty including the $15,757.69
on or before September 30, 2005. balance of the Up -Front Penalty).
Failure to comply with any modified limit listed in
paragraph 2(d) of this order.
Monitoring frequency violations for modified
parameters listed in paragraph 2(d) (except for toxicity).
Monitoring frequency violations for toxicity.
$2,000 per violation for monthly average exceedance;
$500 per violation for weekly average exceedance.
$100 per omitted value per parameter.
$2,000 per omitted value.
Failure to submit progress reports as required by $500 for the rust violation; Penalty doubles with each
paragraph 2(b)(8) or 2(e). subsequent assessment for late reports.
4. The Town and the Commission agree that the stipulated penalties are not due if the Town satisfies DWQ
that noncompliance was caused solely by:
(a) An act of God;
(b) An act of war;
(c) An intentional act or omission of a third party, but this defense shall not be available if the act or
omission is that of an employee or agent of the defendant or if the act or omission occurs in
connection with a contractual relationship with the permittee;
(d) An extraordinary event beyond the permittee's control. Contractor delays or failure to obtain
funding will not be considered as events beyond the permittee's control; or
(e) Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or challenge them by a
contested case petition pursuant to G.S. 15013-23, will be grounds for a collection action, which the
Attorney General is hereby authorized to initiate. The only issue in such an action will be whether the
thirty (30) days has elapsed.
In accordance with the provisions of G.S. 143-215.67(b) the Commission allows the Town to accept the
4

additional waste specified beh- o its waste disposal system. The allocatio additional flow tributary
to the Town's WWTP will be allowed upon acceptable demonstration to the Director of the removal of
an amount of inflow and infiltration which is twice the amount of new flow to be connected. The
approval of additional flow will be in the form of a letter from the Director to the Town.
Domestic Flow Gallons per Day
New 30 room hotel 3,700
6. This Special Order by Consent and any terms, conditions and interim effluent limitations contained
herein, hereby supersede any and all previous Special Orders, Enforcement Compliance Schedule
Letters, terms, conditions, and limitations contained therein issued in connection with NPDES Permit
Number NC0023337. In the event of an NPDES Permit modification or renewal, any effluent limitations
or monitoring requirements contained therein shall supersede those contained in Attachments A and B of
this Special Order by Consent, except as modified and contained in paragraph 2(d) above.
7. Noncompliance with the terms of this Special Order by Consent is subject to enforcement action in
addition to the above stipulated penalties, including injunctive relief pursuant to G.S. 143-215.6.C.
8. The permittee, upon signature of this Special Order by Consent, will be expected to comply with
all schedule dates, terms, and conditions of this document.
9. This Special Order by Consent shall expire November 30, 2005.
For the Town of Scotland Neck:
1' obeR7" B. �R7iN /�3AYolz-
Print Name of Signing Official Title
96�� / !i —
Signature Date
For the North Carolina Environmental Management Commission
Chair of the Commission Dat

additional waste specified below to its wwttc disposal system. The allocation of additional flow tributary
to the Town's WWTP will be allowed upon ;acceptable demonstration to the Director of the removal of
an amount of inflow and infiltration which is twice the amount of new flow to be connected. The
approval ol` additional flow will be in the form of a letter from the Director to the Town.
Domestic Flow Gallons per Dax
New 30 room hotel 3,700
This Special Order by Consent and any terms, conditions and interim effluent limitations contained
herein, hereby supersede any and all previous Special Orders, Enforcement Compliance Schedule
Letters, terms, conditions, and limitations contained therein issued in connection with NPDES Permit
Number NC0023337. In the event of an NPDES Permit modification or renewal, any effluent limitations
or monitoring requirements contained therein shall supersede those contained in Attachments A and B of
this Special Order by Consent, except as modified and contained in paragraph 2(d) above.
7. Noncompliance with the terms of this Special Order by Consent is subject to enforcement action in
addition to the above stipulated penalties, including injunctive relief pursuant to G.S. 143-215.6.C.
S. The permittee, upon sit nature of this Special Order by Consent, will be expected to comply with
all schedule dates, terms, and conditions of this document.
9. This Special Order by Consent shall expire Novertrber 30, 2005.
For the Town of Scotland Neck:
Print Name of Signing Official
Signature
For the North Carolina Environmental Management Commission
Chair of the Commission
P o"
A-e- pAe- .
Title
Date
Date
5 C'+D 0 1 s+ L'n 6- aW-
r
}

ATTACHMENT A
Page I of 2
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — INTERIM
Beginning on the effective date of this Special Order by Consent and lasting until September 30, 2005, the Permittee. is
authorized to discharge treated wastewater from outfall 001. Such discharges shall be limited and monitored by the
Pernvttee as specified below:
EF LU9NT LIMITATIONS
MONITORING REQUIREMENTS.
-
9F UENT
014.ARAGTE RISTIC'S
monthly
Weekly
14"SUrement
Sample -Type
Sarhple Locafion:
Average,
Average
Ftocluency
Flow
0.675 MGD
Continuous
Recording
influent or Effluent
BOD, 5-day, (20°C)2
30.0 mg/I
45.0 mg/1
3/Week
Composite
Influent & Effluent
(SOC Relaxed)
Total Suspended Residue
60.0 mg/1
90.0 mg/1
31Week
Composite
Influent & Effluent
(SOC Relaxed)
NH3 as N
6.0 mg/1
3/Week
Composite
Effluent
(April 1— October 31)
(SOC Relaxed)
NH3 as N
9.0 mg/l
3/Week
Composite
Effluent
(Nov. 1 — March 31)
(SOC Relaxed)
Dissolved Oxygen
3/Week
Grab
Effluent
Dissolved Oxygen
3/Week
Grab
Upstream &
Downstream
Fecal Coliform (geometric
400/100 ml
800/100 m1
3/Week
Grab
Effluent
mean) (SOCRelaxed)
Fecal Coliform (geometric
3/Week
Grab
Upstream &
Mean)
Downstream
Total Residual Chlorine
Monitor Only
3/Week
Grab
Effluent
(SOC Relaxed)
Total Nitrogen5
Weekly
Composite
Effluent
Total Phosphorous -'Weekly
Composite
Effluent
Temperature (°C)
Daily
Grab
Effluent
Temperature (°C)
31Week
Grab
Upstream &
Downstream
Chronic Toxicity
Monitor Only
Quarterly
Composite
Effluent
(SOC Relaxed)
Copper
Quarterly
Composite
Effluent
Zinc
Quarterly
Composite
Effluent
pH
Daily
Grab
Effluent
(Footnotes on nest page)
Town of Scotland Neck — Scotland Neck W WT
NPDES Permit Number NCO02333
EMC SOC WQ SO1-00

ATTACHMENT A
Page 2 of 2
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - INTERIM
Footnotes:
1. Sample locations: Upstream at least 50 feet, Downstream at least 900 feet. Stream samples shall be grab
samples and shall be collected 3/Week during June September and 1 /Week during the remaining
months of the year.
2. The monthly average effluent BODr, and Total Suspended Residue concentrations shall not exceed 35% of
the respective influent value (65% removal).
3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/l.
4. Residual Chlorine shall be monitored if chlorine is used as a disinfectant or elsewhere in the process.
5. See Special Condition A. (3.) of the permit regarding nutrients. Nutrient limits have been removed based
on Scotland Neck's acceptance into the Tar Pamlico Basin Association on April 12, 2002. If at any time
membership in the Tar Pamlico Basin Association is canceled, withdrawn, or not kept current, Total
Nitrogen and Total Phosphorous limits will be immediately reinstated.
6. See Attachment B. Monitor quarterly during February, May, August, and November. Copper and Zinc
Action Level Policy dated October 25, 2000, applies.
7. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge offloating Ioating solids or visible foam in other than trace amounts.
Town of Scotland Neck - Scotland Neck WWTP
NPDI;S Permit Number NCO023337
E1VIC SOC WQ S01-008

ATTACHMENT B
Town of Scotland Neel
NPDES Permit No. NCO02333
CHRONIC TOXICITY MONITORING (QUARTERLY)
The permittee shall conduct quarterly chronic toxicity tests using test procedures outlined in the "North Carolin
Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions.
The effluent concentration defined as treatment two in the procedure document is 90%. The permit holder shall
perform quarter monitoring using this procedure to establish compliance with the SOC condition. The tests
will be performed during the months of February, May, August and November. Effluent sampling for this
testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of the SOC condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGP3B.
Additionally, DWQ Form AT -I (original) is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 3(
days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed
in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly
monitoring will begin immediately until such time that a valid test is submitted. Upon submission of a valid
test, this monthly test requirement will revert to quarterly in the months specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, then the NPDES permit may be re -opened an(
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.
QCM P/F Version 919

RESOLUTION FOR A SPECIAL ORDER BY CONSENT (SOC)
WHEREAS: The Town of Scotland Neck has a permit to discharge treated wastewater
to Canal Creek, Class C NSW waters of this State in the Tar -Pamlico
River Basin; and
WHEREAS: This discharge is allowed under NPDES Permit Number NCO023337
effective June 1, 2001, and scheduled to expire on October 31, 2004; and
WHEREAS: The Town of Scotland Neck intends to make necessary improvements
and/or modifications to the wastewater treatment system; and
WHEREAS: The Town of Scotland Neck agrees to maintain and operate the wastewater
treatment system at its maximum level of efficiency during the interim
period of the Special Order by Consent and thereafter; and
WHEREAS: The Town of Scotland Neck has or will secure funding for necessary
treatment plant improvements in the form of grants, loans, or other cash
reserves; and
WHEREAS: The Town of Scotland Neck hereby authorizes
Nancy Jackson (Full Name), Town Admin. /Clerk(Tytle),
to have the authority to sign and execute the Special Order by Consent on
behalf of the Town; and
THEREFORE, BE IT RESOLVED that the Town of Scotland Neck requests a Special Order
by Consent from the Environmental Management Commission and the Town hereby authorizes
Nancy Jackson (Full Name), Town Admin. /clerk(Title), to sign and execute this
document on behalf of the Town.
Adopted this 28th day of January g 2003
Nancy Jackson Town Administrator/Clerk
(Type or Print) Full Name and Title of person authorized to execute SOC
(Signature) Fu of person authorized to execute SOC
Robert B. Partin Town/City Seal
(Type or Print) Full Name of Mayor is to be placed here.
QL4
63.
(Signature) Full Name of Mayor)

Need help with storm water
Subject: Need help with storm water
From: <scotneck(4 ;embargmail.com�
Date: Thu, 10 Apr 2008 13:08:48 -0400
To: "Myra Nisely" myrl.nisely mcmai1.net>
Mr. Nisely,
asz- 3 -3c�
We have a home owner who has done some extensive remodeling to a house he has purchased. He
deliberately connected his gutter runoff to his sewer line. He was asked by Code Enforcement to
disconnect the stormwater, however, the has refused to do so. Any recourse we can take?
Thanks so much for your help.
Nancy
Town of Scotland Neck
0) WJJ40
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1 of 1 4)1 U2008 8:15 A

of wArF9
`OC1 QG Michael F. Easley, Governor
UJ r William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
O 'C
Coleen H. Sullins, Director
Division of Water Quality
March 17, 2008
CERTIFIED MAIL7006 0810 0002 6050 3268
RETURN RECEIPT REQUESTED
Honorable Robert B. Partin, Mayor
Town of Scotland Neck 44
1310 Main Street
Scotland Neck, North Carolina 27874
Subject: Notice of Violation
NOV-2008-LV-0124
Permit No. WQ0022697
Town of Scotland Neck Reclaimed
Water Generation and Utilization System
Halifax County
Dear Mayor Partin,
On February 13, 2008, Jane Bernard, Matthew Fleahman, and Alice Wessner of the
Division of Water Quality Raleigh Regional Office conducted an inspection of the subject
reclaimed water program. James Pittman, ORC was present during this inspection. As a result
the following was noted:
• Spray irrigation fields appear to be maintained.
• Operation and disposal records in the past have reported irrigation events incorrectly.
Gerald Brannon with United Water submitted new forms to be used by the ORC. The
forms appear to contain the proper information, and will be used by field staff. The ORC
will transfer required information to the monthly NDAR and NDAR as required by
permit.
• Condition I.8 requires public access to the irrigation site to be controlled and posted. A
sign was posted at the irrigation site.
• Condition II.7 requires a Minimum Cumulative Loading over any 12-month period of
19.5-inches/per year....
A review of the past NDMR's submitted from July of 2007, through December of 2007
indicate less than .05 inches have been applied to date.
Aquifer Protection Section - Raleigh Regional Office
None Carolina
1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone] Customer Service 1-877-623-6748 ifth
3800 Barrett Dr. Raleigh, NC 27609 FAX [phone] Internet: MpAyww.ncwaterquality org `sp,
An Equal Opportunity/Affirmative Action Employer- 50% Recydedllo% Post Consumer Paper

Notice of Violation
Town of Scotland Neck
Permit No. WQ0022697
Halifax County
March 11, 2008
Page 3
You are required to provide a written irrigation application schedule showing how you plan
to meet Condition 1I.7, requiring a Minimum Cumulative Loading over any 12-month period of
19.5-inches/per year. Schedule should include "suggested" weekly and monthly gallons to
apply, approximate time to irrigate based on gallon per minute, and estimated daily/hourly
loading rates. Our records show irrigations began July 2007. Current schedule should be based
on July 2007 thru June 2008.
Additionally, and based on information gathered during this inspection, the Division
considers that the Town of Scotland Neck to be in violation of the following permit conditions:
1. Condition I.9 requires all reclaimed water valves, storage facilities, and outlets to
be tagged or labeled to warn public or employees...
During the site evaluation Water Quality Staff could not locate tags or labels on or in the
reclaimed water valves located at the Waste Water Treatment Facility or at the irrigation
site.
2. Condition I.10 requires reclaimed water piping, valves, outlets and other
appurtenances to be color -coded, taped or otherwise marked.........
During the site evaluation Water Quality Staff could not verify any type of markings on
or in the reclaimed water valves located at the Waste Water Treatment Facility or within
the irrigation site.
3. Condition II.10 requires all waste water to be discharged in strict accordance
with the conditions of the facility's existing NPDES permit should the limit for
fecal coliform (daily maximum concentration of 25 per 100 ml) or turbidity
(instantaneous maximum of 10 NTU) be exceeded, until such time that the levels
have stabilized below these maximum levels.
a. July 3- applied 419 gallons with a fecal count of 82 per 100 ml.
b. July 25- applied 71.6 gallons with a fecal count of 220 per 100 ml and
Turbidity of 60 NTU.
4. Condition III.2 requires an indicator of proper operation and maintenance, the
facility shall produce an effluent in compliance with the following limitations....
a. July 3- applied 419 gallons with a fecal count of 82 per 100 ml.
b. July 25- applied 71.6 gallons with a fecal count of 220 per 100 ml and
Turbidity of 60 NTU.

Notice of Violation
Town of Scotland Neck
Permit No. WQ0022697
Halifax County
March 11, 2008
Page 3
c. July 2007 missing parameters Total Dissolved Solids, Settleable Matter, Total
Organic Carbon, Chloride, and Nitrate.
d. December 2007 missing parameter Turbidity.
5. III.3 requires adequate records maintained by the Permittee tracking the
amount of wastewater disposed.
a. September NDMR and NDAR missing.
b. Past reports show "Spray Field 1" as 16 acres. It is the Divisions
understanding that there are three irrigation zones totaling 16.54 acres.
Failure to comply with conditions in a permit may result in a recommendation of
enforcement action, to the Director of the Division of Water Quality who may issue a civil
penalty assessment of not more that twenty-five thousand ($25,000) dollars against any "person"
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit
under authority of G.S. 143-215.6A.
Please respond to this Notice in writing, within thirty (30) days of receipt, and provide an
explanation concerning the above listed discrepancies. The Aquifer Protection Section staff will
review the information submitted and make a determination as to what further action, if any, may
be required in this matter. If you have any questions concerning this matter, please do not
hesitate to contact either Jane Bernard, or myself at [phone].
Sincerely,
4w
S. mmerman, L.G.
Environmental Program Supervisor
cc: RRO-APS Central Files
Halifax County Health Department
Aquifer Protection Section Central Files
Gerald Brannon, United Water

o�oF w A rFgQG Michael F. Easley, Governor
William G. Ross Jr., Secretary
rNorth Carolina Department of Environment and Natural Resources
>_
Coleen H. Sullins, Director
Division of Water Quality
^'7h
February 18, 2008
,lay Zimmerman
3800 Barrett Drive
Raleigh, NC 27609
Subject: Town of Scotland Neck Site Visit
Application Number WQ0022697
Conjunctive Wastewater Treatment
and Reclaimed Water Utilization System
Halifax County
Dear Mr. Zimmerman:
This letter is in reference to a site visit that was conducted by Alice Wessner, Jane Bernard and myself on
February 13, 2008 as a part of a permit renewal request for the subject wastewater disposal facilities. While
our permit only covers the conjunctive use of the treated effluent stream, we did walk through the plant to
ensure reclaimed water treatment was being conducted in accordance with the subject permit. Prior to the site
visit, the Town of Scotland Neck received approximately 1.0 inches of rain.
Upon arrival at the site it was noted that areas around the primary oxidation ditch as well as the control box
had ponded water. The water level in the oxidation ditch was less than 0.5 inches from top of bank and
"scum" from the oxidation ditch was noted on the ground surface at three different areas around the oxidation
ditch. Wave action from the brush aerators was blamed for "scum" leaving the oxidation ditch. Please note
that the brush aerators were not running while we were on site, so this explanation could not be verified.
Effluent was chlorinated post filtration and dechlorinated prior to discharge. The chlorination occurred by an
un-metered pump from an above ground PVC storage tank. It did not appear that chlorine concentrations
were monitored or controlled on site. Dechlorination occurred prior to discharge and was conducted by an
un-metered pump staged on a concrete pad, covered with a plastic tarp, heated with a heat lamp, and wrapped
in loose fiberglass insulation. The dechlorination pump had a large mass of white precipitate on one side that
stretched down to the concrete pad. Upon review of the NPDES permit, it did not appear that either of these
treatment steps were permitted.
Inflow and Infiltration of the collection system were blamed in conjunction with the rain for the inundation of
the wastewater treatment system. Wastewater flow had exceeded 700,000 gallons by the time of our site visit
and was expected to exceed a million gallons by the end of the day. With high flow, the oxidation ditch
turned off, and no other active treatment process, it did not appear that any treatment was occurring at the
facility.
If you have any questions regarding this matter, pleas(
[e-mail].
Environmental Engineer I
15-6173 or
IhCarolina
yrallil
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone : [phone]
antemet: www.ncwatergualit .00r Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax I: [phone]
Fax 2: [phone]
A n Equal Opportunity/Affirmative Action Employer.. 50% Recycled110% Post Consumer Paper Customer Service; [phone]

Meeting between the Town of Scotland Neck and DWQ
January19, 2006 10 AM
Town Hall, Scotland Neck, NC
Agenda
■ Oxidation Ditch ! "! .�` G40 uss
Solids
o Brushes -- jct": 'It"
,�« ► wry �: S�%a
-nnpp, 1��z1 o Digestor,
61
■ Clarifiers r> AqZ
aw , (col 7 o Broken shaft on small clarifier
o Operation
■ Tertiary Filters --1 f
o 1/1 events 1 � I 1
■ UV Disinfection `� (J
o Plans �� r
o Chlorination/Dechlorination
Mi"t kel
i1V
30) RVId
U" �►. �JI ' ISM l /1 t1 a
��OW j� �.

Scotland Neck SOC Phase III Construction Timeline
05/04/04 Submitted A-to-C application for phase III construction
08/06/04 In memo to Gil Vinzani concerning plans for phase III construction, Barry Herzberg
states that plans are incomplete. The piping plan -electrical site plan does not show
existing or proposed profile (grade) information. Also the elevations of existing utilities
and the tie-in elevations for the new utilities are not given. There is no record in the file
of this information being passed to the Town's engineer.
09/03/04 A-to-C (# 0023337AC03) sent to Town from CG&L
10/26/04 Quarterly progress report submitted; states that bids have been received for phase III
construction.
i1/0404 REGON Miat--
11/24/04 Memo between Brian Cox and Water & Waste Systems Construction, company which
submitted the low bid for phase III construction, that the replacement of the fine bubble
aeration system with a jet aeration system would reduce costs by $73,000
12/08/04 NOVA sent to Town concerning violation of fecal coliform limit -- penalty set at $500
12/17/04 CG&L received revised construction plans from Town which lowers costs from $518,000
to $445,000
01/05/05 CG&L receives letter from Brian Cox, project engineer, requesting an "expedient
review" of revised construction plans due to rising material costs
01/05/05 CG&L emails comments to Brian Cox concerning modified plans
I1l4or AGCoN MYRL �P+CS) 'MM f0e-
01/26/05 RRO receives letter from Brian Cox concerning missed phase II deadline-- reasons:
weather (excessive rain), delay in approval of the Part B application, delay in equipment
delivery. Also states that CG&L is reviewing modification to A-to-C for Phase III.
01/2&05 Quarterly progress report submitted -- Phase II reported as scheduled to be completed by
February 15, 2005 -- SOC deadline was January 1, 2005. The bid for Phase III
construction was awarded. Awaiting A-to-C.
01/31/05 CG&L sends report to Town concerning January 12, 2005 construction inspection
02/02/05 RRO sends NOV concerning missed construction deadline (NOV-2005-SP-0003)
02/02/05 NOV (NOV-2005-LV-0061) sent concerning BOD and NH3 violations in October 2004
02/02/05 NOV (NOV-2005-LV-0062) sent concerning BOD and NH3 violations in November
2004
02/25/05 Town sends 1/I report to RRO - effluent flow was reduced 24% by I/I work. Also stated
that work on phase III is scheduled to begin in June of 2005.
03/17/05 RRO sent assessment letter to Town (LV-2005-0109) for October 2004 violations
penalty $4616.73
03/17/05 RRO sent assessment letter to Town (LV-2005-0110) for November 2004 violations
penalty $4116.73

03/17/05 NOV (NOV -2 005 -LV -0 150) sent concerning BOD and NH3 violations in December
2004
03/23/05 Town issues Notice to Proceed to Water and Waste Systems, Inc., to begin construction
on or before March 23, 2005 -- scheduled date of completion is September 19, 2005
04/27/05 Quarterly progress report submitted. Phase III improvements had begun. Equipment
had been and own is awaiting delivery. "Some stages of work have begun."
y fsjoS KeGotq H L
05/16/05 A-to-C received from CG&L for modified plans
06/28/05 Town submits letter to RRO stating that Phase III construction is not complete - Ste'
deadline was duly 1, 2005
QC -Co" 36NNt!< A hykL
07/22/05 Brian Cox sends letter to RRO explaining the delay in completion of phase III
construction. Reasons - high construction costs requiring a change in plans and a
resubmission of plans to CG&L, delivery delays of equipment. Estimated completion
date is September 30, 2005.
07126'05 In progress report, Town states that phase III construction is approximately 25%
complete.
09126/05 In letter to RRO, Brian Cox states that phase III construction will not be completed
until November 4, 2005 due to unexpectedly large sludge level in oxidation ditch.
Sludge volume was estimated to be 220,000 gallons. Estimates construction will be
completed November 4, 2005.
09/26/05 Nancy Jackson requests an extension of the SOC until November 4, 2005 in a letter
to the RRO.

8. The Town of Scotland Neck is currently operating under Special under by Consent EMC SOC
WQ S01-008, which expires November 30, 2005. As of August 2, 2004, all schedule dates
given in the SOC have been met with the exception that we have not yet received the quarterly
progress report due July 30, 2004.
9. SOC compliance deadline is 30 September 2005. The schedule for the Phase III work under
review is as follows:
a) Submit an application for repaire'upgrade on or before May 1, 2004.
b) Bid Project on or before October 1, 2004.
c) Complete construction on or before July 1, 2005.
10. Procedure 4 review shows Paper 1~ low percentage of 69.6 and Actual Flow percentage of 60.7.
1 l . There is no mention in the specifications or drawings of the Ultraviolet Disinfection system. It
is our understanding that the existing system has not been in service for many years. We can
find no calculations or reports that the existing UV system is properly sized, meets the
requirements of the NPDES UV Disinfection Systems Reliability Guidelines, or is still
functional. Both the current NPDES permit (NPDES NC0023337) and the application for
renewal of this permit show Ultraviolet Disinfection.

o Q

Items Pending with Scotland Neck
Subject: Items Pending with Scotland Neck
From: Myrl Nisely <[e-mail]>
Date: Tue, 04 Sep 2007 10:58:48 -0400
To: Nancy Jackson <[e-mail]>
CC: Paul Rawls <[e-mail]>
Hello, Nancy,
Hope you had a grand Labor Day weekend. Mine was delightfully low key!
On 8/29 I received faxed data from James Pittman showing several rounds of Fecal
testing around the UV system. It was by this date that we agreed that the Town
would declare either that UV would work and the use of temporary chlorine addition
would stop, or an Authorization to Construct would be sought for the installation
of a permanent Chlorination/Dechlorination system. What is the Town's
interpretation of this data, and what is the decision?
A recent inspection of the Scotland Neck collection system stipulated that the Town
was to contact the Emergency Management office in Halifax to discuss and clarify
protocols regarding how the telephone operators would respond when lift station
alarms were received by them. Can you provide a report to me on what was worked
out?
Thanks,
Myrl
Myrl A. Nisely
Environmental Chemist
NC DENR - Div. Water Quality Raleigh Regional Office 1628 Mail Service Center
Raleigh, NC 27699-1628 Telephone: [phone] or x4255
Fax: [phone]
[e-mail] ><((((°>
I of 1 12i27i2007 11:29 A

[Fwd: Re: [Fwd: Disinfection System WWTP]]
Subject: [Fwd: Re: [Fwd: Disinfection System WWTP]]
From: Myrl Nisely <myr][e-mail]>
Date: Tue, 30 Oct 2007 12:17:50 -0500
To: Nancy Jackson <[e-mail]>
Nancy, you will need to have a design worked up by a professional engineer per the message below.
Myrl
-------- Original Message--------
Subject:Re: [Fwd: Disinfection System WWTP]
Date:Tue, 30 Oct 2007 13:15:30 -0400
From:Cecil Madden <cecil.madden ncmail.net-=-
Organization: Construction Grants and Loans Section
To:Myrl Nisely <myri.nisely(a),ncmail.net>
References: <4727542A. 8070201 ncmaiI.net>
Hello Myrl,
They are required to have an Authorization to Construct. This implies plans, specifications, and
calculations that are signed and sealed by a North Carolina Professional Engineer. They should use
the most recent application form which is found at:
http://www.p_pc l.net/Engineering/ATC%20Applicationq:o2OAugust°-o202007.doc
Regards,
Cecil Madden
Myrl Nisely wrote:
Cecil, how would you answer the question from Scotland Neck. We have been telling them that an
AtC is needed. Are there enough engineering details in a vendor's presentation to allow your
reviewers to say yes or no?
Myrl
------- Original Message--------
Subject:Disinfection System WWTP
Date:Tue, 30 Oct 2007 10:14:10 -0400
From:<[e-mail]>
To:Myrl Nisely <myrl.nisely(a,ncmail.net>
Mr. Nisely,
We have secured 2 quotes on putting in a permanent chlorine drip system at our WWTP. Both are
far less expensive than I thought they would be - around $1,500 to $1,800. Will we be required to go
through an engineer for this installation? We just hate to add engineering fees to the cost. Any help
will be greatly appreciated!
Nancy
1 of 2 12{27i2007 11:32 A

Re: Disinfection System
Subject: Re: Disinfection System
From: <[e-mail]>
Date: Wed, 7 Nov 2007 11:53:24 -0500
To: "Myrl Nisely" <[e-mail]>
Thanks for your reply. I just wanted to make SURE we are clear to continue the temporary system.
----- Original Message -----
From: M +rl Nisely
To: scotneck(a�.embargmail. com : Cecil Madden
Cc: Danny Smith ; BMenard@ncdol.9ov
Sent: Wednesday, November 07, 2007 11:42 AM
Subject: Re: Disinfection System
Yes, use of the temporary system should continue until the permanent one is in place, Nancy. No
further approval will be needed. Mr. Cecil Madden (919-715-6203) can best answer questions about
the A to C process.
[e-mail] wrote:
Mr. Nisely,
Brian Cox with Engineering Services has indicated to me that an A to C. could take 4 to 6 months to
complete. Will we be allowed to continue our temporary chlorine system throughout this process?
To whom do I need to address this with?
Thanks for your help.
Nancy
Town of Scotland Neck
Myrl A. Nisely
Environmental Chemist
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: [phone] or x4255
Fax: [phone]
[e-mail]
1 of 1 1 U712007 11:43 A

November 6, 2007
Mr. Danny Smith, Raleigh Regional Supervisor
Division of Water Quality
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Mr. Smith,
In response to your letter dated October 17, 2007 in regard to the Settlement Agreement
with the Town of Scotland Neck and DWQ, the Town of Scotland Neck has exhausted
what we feel are extensive measures trying to remediate the problems with our LTV
System. We have followed engineering suggestions, manufacturer suggestions, changed
bulbs, cleaned the system repeatedly, but to no avail. Our WWTP operators are quite
anxious with the sampling we have taken most recently. We feel it is in the best interest
of the Town to switch to a permanent chlorine disinfection system. We have spent the
past three weeks taking quotes from various companies on systems we feel will best suit
our operational needs. Our WWTP operators have chosen what they feel will be the best,
most operational system. We will pass this on to our engineers for their approval.
At the present time, I am hoping to confirm an expense for this project to pass on to my
Town Board. My board meets November 27, 2007. At that time, I hope we will have all
necessary information in order to move forward with this project.
The Town of Scotland Neck is working vigilantly to get our WWTP in top operational
order. We appreciate the support we have received from DWQ. Should you have any
questions or concerns, please do not hesitate to contact me at 252-826-3152 or
seotneck a embar mail.com.
Sincerely,
Nancy Jackson
Town Administrator.. -Clerk

Permanent Chlorine System
Subject: Permanent Chlorine System
From: <[e-mail]>
Date: Mon, 17 Dec 2007 14:56:37 -0500
To: "Myrl Nisely" <myrl.ni sely@ncmail. net>
Mr. Nisley,
As you are aware, the Town of Scotland Neck has decided to install a permanent chlorine disinfection
system. We are currently applying for grant funds for more I & I work and we are including this system
in the grant as well. We have been advised that the contact chamber for this system is approximately
$52,000.00. In the meantime, do you think it would be possible for the Town to receive relaxed limits on
our testing until we can get the permanent system in place? With the grant process and installation, we
are looking at several months before we will have the permanent system in place.
Please advise.
Thank you so much for your help.
Nancy
Town of Scotland Neck
1 4);,1 12/27/2007 11:33 A

Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
October 17, 2007
CERTIFIED MAIL 7006 0810 0002 6049 4986
RETURN RECEIPT REQUESTED
Honorable Robert B Partin, Mayor
Town of Scotland Neck
PO Box 537
Scotland Neck, NC 27874
SUBJECT: Status of Disinfection Decision as Directed by Settlement Agreement
Town of Scotland Neck WWTP
NPDES Permit NCO023337
Halifax County
Dear Mayor Partin:
The Raleigh Regional Office is preparing to revisit the compliance status of the Settlement Agreement between
Scotland Neck and DWQ dated 5r"15i2007, and the respective compliance status of permit NC0023337.
Specifically, the Settlement Agreement required the Town to have either a satisfactory, functioning disinfection
system (UV) in place by the end of six months (11;`15/2007) or submit an application for an Authorization to
Construct (AtQ for a permanent chlorineldechlorination system. It is the understanding of this office that the UV
system is not achieving a reliable level of disinfection necessary to assure compliance, and no AtC has been
submitted.
We ask you to explain when either the UV disinfection system will be operating satisfactorily or when you will
submit an AtC request for replacing the UV. Please provide this in writing within 20 days of receipt of this letter.
Your response will be weighed as a part of the RRO effort to revisit this matter with the Attorney General's office,
with consideration of whether additional penalties, as appropriate, are merited.
Thank you for your attention to this matter. If you have any questions please do not hesitate to contact Myrl Nisely or
myself at [phone].
Sincerely,
Danny Smith
Raleigh Regional Supervisor
Surface Water Protection Section
cc: Brenda Menard, Attorney General's Office
Vanessa Manuel, Central Office
RRO/SWP files
Central Files
tCaro))ina
mr ,)Zjl
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Intemet: www.ngwterqualily.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper

W A T ,Z p Michael F Easley, Governor
William G. Ross, Jr., Secretary
co 7
>~ North Carolina Department of Environment and Natural Resources
y
❑ C Coleen H. Sullins., Director
Division of Water Quality
December 31, 2007
CERTIFIED MAIL 7006 0810 0002 6049 6348
RETURN RECEIPT REQUESTED
The Honorable James Mills, Mayor
Town of Scotland Neck
1310 Main Street
Scotland Neck, North Carolina 27874
Subject: Status of Disinfection at the Scotland Neck WWTP
NPDES Permit NCO023337
Halifax County
Dear Mayor Mills:
During 2006 -2007 the Town of Scotland Neck developed a rehabilitation project for the Wastewater
Treatment Plant. The Town entered into a Special Order by Consent, EMC SOC WQ # SO1-008 with the
North Carolina Environmental Management Commission whereby the operation of Scotland Neck
Wastewater Treatment Plant was placed under interim effluent limits and an enforceable construction
schedule. The Town experienced difficulties with both interim (relaxed) effluent limit compliance and
meeting the work schedule requirements of the SOC.
The Town contested the stipulated penalty in the Office of Administrative Hearings. [Note: the stipulated
penalty amount was approximately $50,000.] With the assistance of the Attorney General's Office
representation, the abovementioned stipulated penalties were negotiated to $12,000. To formally resolve
this matter, Scotland Neck and Division of Water Quality entered into a settlement agreement. Item 4. of
subject settlement agreement states the following:
"Respondent agrees to allow Petitioner to continue to operate the existing temporary chlorine
system for up to six months while a permanent system is perfected. At the end of that time period
[November 30, 2007], Petitioner shall have put in place a permanent system, or Petitioner shall have
filed an application for an authorization to construct an appropriate system."
A DWQ site visit and file review confirms that this time period, a requirement of the settlement agreement,
was not met. It is currently the understanding of the Raleigh Regional Office that efforts to achieve
compliance via a UV system continued into November. The Town has now decided to install
chlorination/dechlorination system. However, no application for an authorization to construct (AtC) has
been received to date.
In the form of an email, the Raleigh Regional Office (RRO) received a request (12/17/2007) for "relaxed"
limits until a permanent chlorine system is installed. The email did not state which effluent limits merit
changing, duration of change, proposed new limit amounts, why limits need to be revisited and Naomi Caro 'na
)VatmMAY
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Intemet: h2o.enr.state.nc.us 1628 Ma:l Service Center Raleigh, NC 27699-t 628 FAX [phone]
An Equal OpportunirylAffirmative Action Employer— 50% Recycledl10% Post Consi mer Paper

Scotland Neck WWTP Request for Modified Limits to Install Chlorination/Dechiorination System Page 2 of 2
what process control changes may be used to prevent exceedances. For any of permitted limit to be
"relaxed" a formal SOC is re aired.
In light of the previous SOC compliance history, compliance with the terms of a formal settlement
agreement pursuant to an Office of Administrative Hearing Case No,06 EHR 1758 and the failures to have
in place a permanent system or an application for an authorization to construct an appropriate system; this
office believes that entering into a second SOC at this time is inappropriate. It is the expectation of the
Raleigh Regional Office that Scotland Neck comply with the permit limits and fully meet the terms of the
settlement agreement.
Within 30 days of receipt of this letter, submit a schedule to include funding, engineering time, submittal of
application to the State, and construction time once the AtC is granted. This Office will review the detail
provided and the proposed implementation timeline of your response. Your response to this letter and your
efforts to meet the terms of the settlement agreement will be considered in the recommendations for penalty
collection and settlement agreement enforcement to Attorney General's Office.
Thank you for your attention to this matter. If you have any questions about this letter, please contact Myrl
Nisely at (919)-791-4255or Vanessa Manuel at [phone] extension 532 in our Central Office.
Sincerely,
Danny Smith
Water Quality Regional Supervisor
Raleigh Regional Office
cc: Nancy Jackson, Town Administrator
Brenda Menard, AG Office
Vanessa Manuel, Eastern NPDES Program
SWP/RRO files
Central Files

The Settlement Agreement signed on 5/15/07, item 4. required the Town of Scotland
k to either have a satisfactory, fully functional disinfection system in place by th end
of si month (I III5i07), or have submitted an application for an Authorization to
Const t (AtQ an "appropriate" system. Though the details were not explicitl stated, it
was unde tood by DWQ and the Town that the fully functional system refe d to an
Ultraviolet stem, and the "appropriate" system would be an engineered rmanent
chlorination/ hlorination system to replace the temporary one in use r many months.
With the above ti line looming, the Division requests that Scotl d Neck declare in
writing which syste will be chosen.
The UV System will I wi not our disinfection systeNancy Jackson, Town Ma\be
obert Partin, Mayor
If the UV equipment cannot be cou d n for compliance, a statement of intent to pursue
the chlorination route must be ex uted b ovember 15, 2007 (see below). This timing
fails to meet the six month pe d stated in t Settlement Agreement for having
engineered plans available r submittal with a application for the AtC, but DWQ will
grant more time with th ollowing conditions:
Provide a writtenAedule by which the AtC will be �Vbmitted. This should take into
consideration t time for engineering and funding.
The Divi ' n expects complete installation by May 31, 200 . Prove over a one month
period at compliance can be achieved (by June 30, 2008).
Failure to what permit conditions can we cite???
LVAJ
W-M