HomeMy WebLinkAboutNC0020737_NOV Inspection NOV-2018-PC-0410_20181101ROY COOPER
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MI HAEL S. RE AM
S-Mrerary
LINDA CULPEPPER
lrrredmi a'rertor
FORTH CAROLINA
Envimnmerrtaf (hfailly
CERTIFIED MAIL # 70161370 0000 2596 0436
RETURN RECEIPT REQUESTED
November 1, 2018
Mr. Ricky Duncan, Water Resources Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC28086
Subject: Notice of Violation
Compliance Evaluation/Bioassay
Inspection
NOV-2018-PC-0410
City of Kings Mountain
NPDES Permit No. NCO020737
Cleveland County
Dear Mr. Duncan:
Enclosed is a copy of the Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on October 16, 2018, by Ori Tuvia. The cooperation of Richelle
Meek and Kathy Moses during the site visit was much appreciated. Please advise the staff involved
with this NPDES Permit by forwarding a copy of the enclosed report.
At the time of the inspection split samples for toxicity were taken. The results will be sent
at a later date.
The main area of concern observed during the inspection was that a review of the lab data
for the period of August 22, 2017 - April 30, 2018, resulted in the discovery that the facility has
been testing for free chlorine rather than total residual chlorine, due to ordering incorrect chlorine
packets. The facility lab is certified for sampling total residual chlorine but not for free chlorine.
Amended eDMRs for the period of August 2017 through April 2018 have been submitted.
ef5:fDEQ5
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699
Additional areas of concern include:
1. Short-circuiting was observed at clarifier #4 due to an uneven weir;
2. The weir at the clarifier #3 showed signs of rusting;
3. Dead spots were observed in all three (3) aeration basins. Mixers, in addition to the existing
diffusers, would potentially eliminate the observed dead spots.
4. Grit was observed in downstream treatment units including the chlorine contact chamber.
A grit removal system would greatly improve treatment and significantly reduce the
accumulation of grit in other treatment units.
The report should be self-explanatory; however, should you have any questions concerning
this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at
ori.tuvia(a-,ncdenr. gov.
Sincerely,
EA
DocuSignedd by:
44 V �I P for
F161 FB69A2D84A3...
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
cc: NPDES, MRO files (Laserfiche)
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN 1 2 15 I 3 I NCO020737 111 12 I 18/10/16 I17 18 I Q I 19 I G I 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70 71 ty[ �, � 72 I �, I 73 � 74 751 I I I I I I I80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
09:30AM 18/10/16
15/06/01
Pilot Creek WWTP
200 Potts Creek Rd
Exit Time/Date
Permit Expiration Date
Kings Mountain NC 28086
12:15PM 18/10/16
18/08/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Kendrene Richelle Meek/ORC/704-739-7131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Kim Teresa Moss,PO Box 429 Kings Mountain NC
280860429//704-739-7131/7047344528 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signatures) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
pocuSigne by
Ori A Tuvia — - C— MRO WQ//704-663-1699/ 11/1/2018
C`
Signature of Management Q A Reviewer Agency/Office/Phone a &W"8bYSby: for CB Date
14-0� H ;P+4+t4 11/01/18
W. Corey Basinger Division of Water Quality//704-2;
F161FB69A2D84A3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
NPDES yr/mo/day Inspection Type
NCO020737 I11 121 18/10/16 117 18 JBI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Split sampling for toxcity second sample was collected on 10/18/2018
Page#
Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 10/16/2018 Inspection Type: Bioassay Compliance
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
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❑
application?
Is the facility as described in the permit?
0
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# Are there any special conditions for the permit?
0
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Is access to the plant site restricted to the general public?
0
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Is the inspector granted access to all areas for inspection?
0
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Comment: The subject permit expired on 8/31/2018.
The City implements an approved Industrial Pretreatment Program.
The Division received a SOC application from the City on 12/29/15 due to the WWTP's
inability to comply with the effluent thallium limits placed in the current permit (effective
6/1/15). SOC became effective July 18, 2016, removing the daily maximum limit for Thallium
sampling and increasing the monthly average to 60.1 ug/L.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
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Is all required information readily available, complete and current?
0
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Are all records maintained for 3 years (lab. reg. required 5 years)?
0
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Are analytical results consistent with data reported on DMRs?
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0
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Is the chain -of -custody complete?
0
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Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported CM
Are DMRs complete: do they include all permit parameters?
❑
0
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Has the facility submitted its annual compliance report to users and DWQ?
0
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility classification?
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Is a copy of the current NPDES permit available on site?
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Facility has copy of previous year's Annual Report on file for review?
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Page# 3
Permit: NCO020737
Inspection Date: 10/16/2018
Record Keeping
Owner - Facility: Pilot Creek WWTP
Inspection Type: Bioassay Compliance
Yes No NA NE
Comment: The records reviewed durina the inspection were oraanized and well maintained. DMRs
COCs, ORC visitation loq, Bench sheets, and calibration logs were reviewed for the period
December 2017 through Auqust 2018. For the period of August 22, 2017 - April 30, 2018,
due to ordering wrong chlorine packets, the facility has been testing for free chlorine rather
than total residual chlorine .
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
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❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
0
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❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
0
❑
❑
❑
Comment: Influent and effluent analvses are Derformed under the Citv's certified laboratory #222
Shealy Labs (metals, priority pollutants, total phosphorus, total nitrogen, oil & grease,
Thallium), and ETT, Inc.(toxicity) have also been contracted to provide analytical support.
For the period December 2017 through August 2018. For the period of August 22, 2017 -
April 30, 2018, due to ordering wrong chlorine packets, the facility has been testing for free
chlorine rather than total residual chlorine . The facility lab is certified for sampling total
residual chlorine but not for free chlorine.
Conductivitv meter was Dast due for calibration.lt was last calibrated on March 28. 2017.
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
0
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Is sample collected above side streams?
E
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Is proper volume collected?
0
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Is the tubing clean?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
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Celsius)?
Is sampling performed according to the permit?
0
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Comment: The subiect Dermit requires influent comDosite BOD and TSS samDles. The facilitv staff
perform and document monthly aliquot verifications. Influent
pH levels are continuously
monitored by an in -line monitoring system.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
❑
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Is sample collected below all treatment units?
0
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Is proper volume collected?
0
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Page# 4
Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 10/16/2018 Inspection Type: Bioassay Compliance
Effluent Sampling
Yes No NA NE
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
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❑
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representative)?
Comment: The subiect permit reauires composite and arab effluent samDles. The facilitv staff perform
and document monthly aliquot verifications
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Grit was observed in downstream treatment units includina the chlorine contact chamber. A
grit removal system would greatly improve treatment and significantly reduce the
accumulation of grit in other treatment units. The facility staff incorporate a comprehensive
process control program with all measurements beinq properly documented and maintained
on -site. The facility is equipped with a telemetry type alarm system that is tested (and
documented) on a monthly basis (at a minimum).
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment: Both screw pumps were operational and in-service.
Bar Screens
Type of bar screen
a.Manual
Yes No NA NE
• ❑ ❑ ❑
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• ❑ ❑ ❑
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Yes No NA NE
Page# 5
Permit: NCO020737
Inspection Date: 10/16/2018
Owner - Facility: Pilot Creek WWTP
Inspection Type: Bioassay Compliance
Bar Screens
Yes No NA NE
b.Mechanical
Are the bars adequately screening debris?
0
❑
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❑
Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
0
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Comment: Screenings are disposed at the Cleveland County Landfill.
Grit was observed in downstream treatment units including the chlorine contact chamber. A
grit removal system would greatly improve treatment and significantly reduce the
accumulation of grit in other treatment units.
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
0
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Comment: The influent flow meter is calibrated annually and was last calibrated on 3/30/2018.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/1)
Yes No NA NE
Ext. Air
Diffused
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■
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■
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Comment: Dead spots were evident in all 3 aeration basins. Mixers, in addition to the existing diffusers,
would potentially eliminate the observed dead spots. Three of four aeration basins were
operational and in-service. Sodium hydroxide is added to the aeration basin influent to
maintain appropriate alkalinity/pH levels.
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 6
Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 10/16/2018 Inspection Type: Bioassay Compliance
Chemical Feed Yes No NA NE
Is the site free of excessive leaking? 0 ❑ ❑ ❑
Comment:
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
❑
0
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
❑
❑
❑
Comment: 3 (1,3,4) clarifiers were in service.
The weir at the 3rd clarifier showed signs of rusting.
The 4th clarifier had some short circuiting.
Pumps-RAS-WAS
Yes No NA NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
❑
❑
0
❑
Comment:
Disinfection -Gas
Yes No NA NE
Are cylinders secured adequately?
0
❑
❑
❑
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
0
❑
❑
❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
0
❑
❑
❑
If yes, then is there a Risk Management Plan on site?
0
❑
❑
❑
Page# 7
Permit: NCO020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 10/16/2018 Inspection Type: Bioassay Compliance
Disinfection -Gas Yes No NA NE
If yes, then what is the EPA twelve digit ID Number? (1000- - ) 100000058965
If yes, then when was the RMP last updated?
Comment:
De -chlorination
Yes No NA NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
❑
❑
❑
Is storage appropriate for cylinders?
0
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
M
❑
❑
❑
Comment:
Are the tablets the proper size and type? ❑ ❑ 0 ❑
Are tablet de -chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
Comment: The flow meters (end of each chlorine contact chamber) are calibrated annually and were
last calibrated on 3/30/2018
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment: The effluent appeared clear with no floatable solids or foam.
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
Yes No NA NE
■
❑
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❑
■
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■
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Yes No NA NE
■
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■
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■
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Page# 8
Permit: NC0020737 Owner - Facility: Pilot Creek WWTP
Inspection Date: 10/16/2018 Inspection Type: Bioassay Compliance
Aerobic Digester Yes No NA NE
# Is the odor acceptable? 0 ❑ ❑ ❑
# Is tankage available for properly waste sludge? 0 ❑ ❑ ❑
Comment: Both aerobic digesters were operational and in-service.
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
0
❑
❑
❑
Is storage adequate?
❑
❑
0
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
❑
❑
❑
The facility has an approved sludge management plan?
0
❑
❑
❑
Comment: The belt press was not running at time of the inspection.
Standby Power
Yes No NA NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
0
❑
❑
❑
Is the generator fuel level monitored?
0
❑
❑
❑
Comment: The facility is equipped with two backup generators. The smaller generator powers
the
blowers for aeration basin #3 and the larger generator powers the rest of the
plant. Both
genreators have been tested under load
Page# 9
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CITY OF KINGS MOUNTAIN
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PO BOX 429A�
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KINGS MOUNTAIN NC 28086
ATTN: MR RICKY DUNCAN
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so that we can return the card to you.
■ Attach this card to the back of the mailpiece„
or on the front if space permits.
1. Artir•.la AdtfrP¢cart tn
CITY OF KINGS MOUNTAIN
PO BOX 429
KINGS MOUNTAIN NC 28086
ATTN: MR RICKY DUNCAN
dwr/ot 11/1/18
A. Sig ature
X
B. R¢ eived by (Printed Name)
D. Is delivery a
If YES7ent
❑ Agent
❑ Addressee
C. Date of Delivery
item 1? ❑ Yes
Dlow:',. ❑ No
it �'lll�l i'il l'i i� it i l lli l li
l l ll
ill' l i iii �li
11 du Service fiype ' ;
❑ AdultSignatur
❑ P"riority Mh i Expresso
El'Registe)ed MaUTM
9590 9402 2875 7069 6159 83
p:Adult Signatu--9 Restricted Delivery,.
Certified WHO .
❑Registered Mail Restricted
Delivery
2. Article Number (Transfer from service /aBe/)
ertifled Mail Restrl&41 Delivery
❑ Collect on Delivery
❑ Collect on Delivery Restricted Delivery
Return Receipt for
Merchandise
tSignatureConfirmationTM
7 016 13 7 0 0000 2 5 9 6
""ail
0436 all Restricted Delivery
❑ Signature Confirmation
Restricted Delivery
PS Form 3811, JUIy2015 PSN 7530-02-000-9053
Domestic Return Receipt
U.S.
Postal
ServiceTM
CERTIFIED
MAIL°
RECEIPT
Domestic
Mdi/
Only
For delivery
information.
visit
-a OF IC9A U
l
0-' Certified Mall Fee
ru
rt7 $ v
Extra Services & Fees (checkbox, add fee as appr,p ta,
C3 ❑ Retum Recelpt (hardcopy) $
r3 ❑ Return Receipt (electronic) $ ---
ED ❑ Certified Mail Restricted Delivery $ Postmark
p ❑Adult Signature Required $ Here
❑Adult Signature Restrtcted Delivery $
C3 Postage —
[`- $
TO CITY OF KINGS MOUNTAIN
$ PO BOX 429
set KINGS MOUNTAIN NC 28086
Sti ATTN: MR RICKY DUNCAN
------------
crr dwr/ot 11/.1/18
ASPS TRACKING # --
9590 9LI02 2575 7069 6159 53
United States
Postal Service
First -Class Mail
Posta�e & Fees Paid
USPS
Permit No. G-10
• Sender: Please print'your name, address, and ZIP+40 in this box•
� z
NCDEQ/WQROS <
610 EAST CENTER AVE
)
SUITE 301
MOORESVILLE NC 28115 �1
47
Certified Mail service provides the following benefits:
Z1 A receipt (this portion of the Certified Mail label),
for an electronic return receipt, see a retail
o A unique identifier for your mailpiece.
associate for assistance. To receive a duplicate
a Electronic verification of delivery or attempted
return receipt for no additional fee, present this
delivery.
USPS®-postmarked Certified Mail receipt to the
n A record of delivery (including the recipient's
retail associate.
signature) that is retained by the Postal Service-
Restricted delivery service, which provides
for a specified period.
delivery to the addressee specified by name, or
Important Reminders:
to the addressee's authorized agent
■ You may purchase Certified Mall service with
Adult signature service, which requires the
signee at least 21 years of age (not
First -Class Mail®, First -Class Package Service®,
g
or Priority Mail® service.
availabllee at retail).
• Certified Mail service is notavailable for
Adult signature restricted delivery service, which
requires the signee to be at least21 years of age
international mail.
ra Insurance coverage is notavailable for purchase
and provides delivery to the addressee specified
by name, or to the addressee's authorized agent
with Certified Mail service. However, the purchase
(not available at retail).
of Certified Mail service does not change the
insurance coverage automatically included with
® To ensure that your Certified Mail receipt is
certain Priority Mail items.
accepted as legal preof of mailing, it should bear a
If
USPS postmark you would like a postmark on
® For an additional fee, and with a proper
endorsement on the mailpiece, you may request
this Certified Mail receipt, please present your
the following services:
- Return receipt service, which provides a record
Certified Mail item at Post Office' for
postmarking. If you don't need a postmark on this
of delivery (including the recipients signature).
You can request a hardcopy return receipt or an
Certified Mail receipt, detach the barcoded portion
of this label, affix it to the mailpiece, apply
electronic version. For a hardcopy return receipt,
appropriate postage, and deposit the mailpiece.
complete PS Form 3811, Domestic Return
Receipt; attach PS Form 3811 to your mailpiece;
IMPORTW. Save this receipt for your records.
PS Form 3800, April 2015 (Reverse) PSN 7530-02-000-9047