NC0021156_NOV with Intent to Assess_20180830

ROY COOPER
irei'e�`n?I .
N41COAEL 5'_ REGiAN
Svpsefmy
LROD4 CULPEPPER
Iruiv6uDirwlor
NESFtTM CAROLINA
eavkonmerifal quallly
Certified Mail # 70161370 0000 2596 0320
Return Receipt Requested
August 27, 2018
Danny Jackson, City Manager
City of Mount Holly
PO Box 406
Mt Holly, NC 28120
RECEIVEDINCDENR/DWR
st:p 4 n18
WOROS
MOORESVILLE REGIONAL OFFICE
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2018-LV-0632
Permit No. NCO021156
Mount Holly WWTP
Gaston County
Dear Mr. Jackson:
A review of the June 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Vlolation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent Collform, Fecal MF, MFC Broth, 6/23/2018
400 903.04 Weekly Geometric Mean Exceeded
44.5 C (31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/30/2018
400 649.4 Weekly Geometric Mean Exceeded
44.5 C (31616)
001 Effluent Coliform, Fecal MF, MFC Broth, 6/30/2018
200 356.64 Monthly Geometdc Mean Exceeded
44.5 C (31616)
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
7046831699

A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of
not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or
fails to act in accordance with the terms, conditions, or requirements of any permit Issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten f0 bu in M Am after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 10 -day period, a civil penalty assessment may be
prepared. .
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Sed10 F the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you have any questions concerning this matter or to apply for an SOC, please contact Ori Tuvia of the
Mooresville Regional Office at 704-663-1699.
Sincerely,
Dorcyuftned by:
A14CC681AF27425... !
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
North Carolina Department of Environmental Quality I Divlslon of Water Resoumea
610 East Center Avenue, Suite 301, Mooresville, NC 28116
704663-1699

MOUrTTg
HOLLY CITY o, f MOUNT HOLLY
Cmm mg Cemn nrry tl h'erne
400 East Central Avenue
Post Office Box 406
Mount Holly, NC 28120
704-827-4261
704-827-6306 Fax
Website: www.mtholly.us
Thursday, August 30, 2018
Attn: Central File
Division of Water Quality
DENR
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Permit # NCO021156 June 2018 DMR
UTILITIES DEPARTMENT
WATER TREATMENT
WASTEWATER TREATMENT
STORMWATER
RECEIVEDINCDERR179WfN0L0cv
SEP 4 2018
WOROS
MOORESVILLE REGIONAL OFFICE
To whom it may concern,
During the month of June, 2018 The Wastewater plant for The City of Mount Holly had experienced high fecal results. We started
noticing the results coming back high. We started investigating the issue immediately. At the beginning June we started noticing
consistently high fecal counts in the effluent results. When we noticed this trend we started increasing the chlorine feed. On June 41h
we increased the dosage rate in the lower basin to 1.56 and the upper to 2.00. After increasing the chlorine dosage, the fecal number
still remained higher. On June 18'h we increased the chlorine again to 1.64 in the lower and 2.10 in the upper basins. We wanted to do
this in moderation because we did not want to exceed our TRC limit. We started investigating deeper into the cause of the increased
numbers. We sent Quality control samples to the tab to verify the lab was doing the test correctly and the sample was a Non -detect.
Contacted the lab on June 27 1h about the issue and we went through steps to see what may be affecting the sample, or if anything in the
plant may be making a false positive. The lab will be running our samples through fecal colilert 18 method along with membrane filter
method at the same time to make sure it is not the method that may be causing the issue. On June 271h we increased chlorine again to
2.00 in the lower basin and 2.5 in the upper basin. We have performed a TRC on the incoming water into each chlorine basin after
chlorine is injected in the water and the lower basin resulted a 2176ug/1(out of range) and the upper resulted a 225ug/I. We are taking
every precaution to find and fix the issue. We had river samples sent to the lab to show that we have not impacted the river. We had
separate samples from each chlorine basin sent to the lab to try and narrow down the problem.
Called Ori with DENR on 6/29/18 at 12:39 as soon as we found out that we would be over our permit limit. Ori mentioned that all that
was needed is to put non-compliant on the DMR.
On June 291h we put chlorine feed to the upper basin in hand instead of running it in automatic and the following weeks we started
noticing the fecal results go down. So from that point we used a jet/vac system to flush out the feed line to the upper basin and also on
July 13' we did a full cleanout of both chlorine basins. As we were cleaning the upper basin we found a build-up of algae in the front
portion of the upper chlorine basin. As we are stepping down our precautions to make sure as we start to put the chlorine basin back
into service and let it feed automatically we keep close eye on the fecal results to make sure that we have solved this issue. From this
moment on we will be performing more chlorine basin cleanout more often to make sure this issue does not re -accrue. We use a
contract lab to do our fecal samples and that is the reason for the long time span on resolving this issue.
Included with this are the results from the lab for this occurrence.
Best Regards,
Doug Should
Division Manager of Wastewater
City of Mount Holly
Office: (704)-827-4261
Cell: (704)-345-0839
E -Mail Dou [e-mail]
CC: David Johnson, PE Utility Director
Ray Clemmer, Deputy Utility Director

MOUNT
HOLLY CITY o, f MOUNT HOLLY
Ce nneung Lbwn�niry VNar�re
400 East Central Avenue
Post Office Box 406
Mount Holly, NC 28120
704-827-4261
704-827-6306 Fax
Website: www.mtholly.us
Thursday, August 30, 2018
Lab Results Index
1. Shows results for Upper chlorine basin
2. Shows results for Lower chlorine basin
3. Shows results for QC sample sent to lab for proof of sample Quality Control
4. Shows results for Upstream of river
5. Shows results for Downstream of river, to show plant is not affecting the river
6. Shows results of the Effluent before manual chlorine override
7. Shows results after system was put into manual mode on Upper basin.
UTILITIES DEPARTMENT
WATER TREATMENT
WASTEWATER TREATMENT
STORMWATER
GIs TECHNOLOGY

Client:City of Mount Holly Laboratory ID:TF29048-001
Description: UPPER CL2 BASIN Matrix: Aqueous
Date Sampled:06/29/2018 1046
Date Received: 06/29/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 06/30/2018 1304 MSG 06/29/2018 1738
CAS Analytical
Parameter Number Method Result Q LOQ DL Units Run
Fecal Coliform (MPN) Colilert-18 ( >2419.6 1 MPN/100mL 1
LOQ = Limit of Quantitation 8 = Detected in the method blank F = Quantitation of compound exceeded the calibration range DL = Detection Limit
NO= Not detected at or above the DL N= Recovery is out of criteria P= The RPD between two GC columns exceeds 40% J= Estimated result c L00 and >_ OL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax[phone] v. hvw.shealylab.com
Page 5 of 9

Client: City of Mount Holly Laboratory ID:TF29048-002
Description: LOWER CL2 BASIN Matrix: Aqueous
Date Sampled:06/29/20181045
Date Received: 06/29/2018
Run Prep Method
1
Ino
Analytical Method Dilution
(Fecal Colifo) Colilert-18 (2010) 1
yanic non-metals
Analysis Date Analyst Prep Date Batch
06/30/20181304 MSG 06/29/20181738
CAS Analytical
Parameter Number Method Result Q LOO DL Units Run
Fecal Coliform (MPN) Colilert-18 ( ND 1 MPN/100mL 1
LOQ = Limit of Quanitalion B = Detected in the method blank E = Quantitation of compound exceeded the calibration range OL = Detection Limit
ND = Not detected at or above the OL N = Recovery is out of criteria P = The RPD between two GG columns exceeds 40% J = Estimated result <LOO and> DL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 6 of 9

Client:City of Mount Holly Laboratory ID: TF26041-001
Description: CLARIFIER EFFLUENT Matrix: Aqueous
Date Sampled:06/26/2018 1010
Date Received: 06/26/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 06/27/2018 1443 SA1 06/26/2018 1750
CAS Analytical
Parameter Number Method Result Q LOQ DL Units Run
/Fecal Coliform (MPN) Colilert-18 ( ND 1 MPN/100mL 1
l�tU0.�i i -t' %o1�+rul SGYh�11 +C
LOO = Limit of Quantitation a = Detected in the method blank E =Quantitation of compound exceeded the calibration range DL= Detection Limit
ND = Not detected at or above the DL N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax[phone] www.shealylab.com
Page 5 of 8

Client: City of Mount Holly Laboratory ID:TF29046.001
Description: UPSTREAM Matrix: Aqueous
Date Sampled:06/2912018 0958
Date Received: 06/29/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 06/30/2018 1304 MSG 06/29/2018 1738
CAS Analytical
Parameter Number Method Result Q LOQ DL Units Run
Fecal Coliform (MPN) Colilert-18 ( 275.5 1 MPN/100mL 1
LOQ = Limit of Quantitation a = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
ND= Not detected at or above the DL N= Recovery is out of criteria P= The RPD between two GC columns exceeds 40% J= Estimated result< LOQ and >DL
H= Out of holding time W= Reported! on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 5 of 9

Client: City of Mount Holly Laboratory ID: TF29046.002
Description: DOWNSTREAM Matrix: Aqueous
Date Sampled:06/29/2018 0947
Date Received: 06129/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 06/30/2018 1304 MSG 06/29/2018 1738
CAS Analytical
Parameter Number Method Result Q LOQ DL Units Run
Fecal Coliform (MPN) Colllert-18 ( 21.8 1 MPN/100mL 1
LOQ = Limit of Quantitation 8 = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
NO= Not detected at or above the DL N= Recovery is out of criteria P=The RPD between two GC columns exceeds 40% J= Estimated result< LOQ and> DL
H = Out of holding time IN= Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] wwwshealylab.com
Page 6 of 9

Client: City of Mount Holly Laboratory ID:TF29047-003
Description: EFFLUENT Matrix: Aqueous
Date Sampled:06/2912018 1000
Date Received: 06/29/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) SM 9222D-2006 1 06/30/2018 1845 MSG 06/29/2018 1754
CAS Analytical
Parameter Number Method Result Q LOO DL Units Run
Fecal Coliform -MF SM 9222D- 1400 1 col/100ml- 1
Footnote(s): *estimated
LOO = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL = Detection Limit
ND = Not detected at or above the OL N = Recovery is out of criteria P =The RPD between two GC columns exceeds 40% J = Estimated result <LOO and > OL
H= Out of holding time V1 Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 7 of I I

Client:City of Mount Holly Laboratory ID:TF29047-004
Description: EFFLUENT Matrix: Aqueous
Date Sampled:06/29/2018 1000
Date Received: 06129/2018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 06/30/2018 1304 MSG 06/29/2018 1738
CAS Analytical
Parameter Number Method Result Q LOQ DL Units Run
Fecal Coliform (MPN) Colilert-18 ( >2419.6 1 MPN/100mL 1
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of Compound exceeded the calibration range DL= Detection Limit
ND = Not detected at or above the OL N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result I LOQ and> DL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 8 of I I

Client:City of Mount Holly Laboratory ID:TGO2017-003
Description: EFFLUENT Matrix: Aqueous
Date Sampled:07/02/2018 1000
Date Received: 07/0212018
Inorganic non-metals
Run Prep Method Analytical Method Dilution Analysis Date Analyst Prep Date Batch
1 (Fecal Colifo) Colilert-18 (2010) 1 07/03/2018 1302 AMM1 07/02/2018 1551
1 (Fecal Colifo) SM 9222D-2006 1 07/03/2018 1720 AMM1 07/02/2018 1638
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL= Detection Limit
ND = Not detected at or above the DL N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 7 of 10
CAS Analytical
Parameter
Number Method
Result Q
LOQ
DL Units
Run
Fecal Coliform (MPN)
Colilert-18 (
14.8
1
MPN/100ml-
1
Fecal Coliforni
SM 9222D-
19
1
col/100mL
1
LOQ = Limit of Quantitation B = Detected in the method blank E = Quantitation of compound exceeded the calibration range DL= Detection Limit
ND = Not detected at or above the DL N = Recovery is out of criteria P = The RPD between two GC columns exceeds 40% J = Estimated result < LOQ and > DL
H = Out of holding time W = Reported on wet weight basis
Shealy Environmental Services, Inc.
106 Vantage Point Drive West Columbia, SC 29172 [phone] Fax [phone] www.shealylab.com
Page 7 of 10