Revision #: 1 Prepared By: David Hux, Industrial Chemist Revision Date: 8/24/00 Approved By: Larry Cummings, Asst. Superintendent of WWTD

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City of Gastonia Wastewater Treatment Standard Operating Procedures EMS-0101.001 Name: Legal and Other Requirements Prepared By: David Hux, Industrial Chemist Revision Date: 8/24/00 Approved By: Larry Cummings, Asst. Superintendent of WWTD Signature: Page 1 of 9 Legal Requirements ISSUE Crowders Creek NPDES Permit Long Creek NPDES Permit Land Application Permit Crowders Creek Lab Certification Long Creek Lab Certification Pressure Vessel Certification Crowders Creek Elevator Certification Long Creek Elevator Certification Location of Control Document Division Files; Senior Plant Operator s Office Division Files; Senior Plant Operator s Office Division Files; Residuals ORC Office; Each WWTP; Biosolids Contractor Division Files; Laboratory Division Files; Lab Supervisor s Office Posted at each Facility Posted in Elevator Posted in Elevator Administrative Codes Permit Number Effective Expiration Renewal Application Due Time ORC/ Contact Back-up 15A NCAC 2H.0100; 0200; 0900; NC0074268 11/25/98 8/31/00 2/28/00 5 years David Morgan Cregg Beach 15A NCAC 2H.0100; 0200; 0900; NC0020184 11/25/98 1/31/00 7/31/99 5 years Jim Eiden 15A NCAC 2H 0900 15A NCAC 2H 0800 WQ0001793 6/22/98 9/30/01 3/30/01 210 1/1/99 12/31/01 15A NCAC 2H 0800 545 1/1/00 12/31/02 NC General Statutes Chapter 95, Article 7A; NCAC Chapter 13, Title 13 13 NCAC chapter 5; General Statutes 95 article 14A 13 NCAC chapter 5; General Statutes 95 article 14A 60 days prior to expiration 60 days prior to expiration * * * * 5 years 3 years 3 years N/A David Hux Steve Oakley Arlene Roman Jim Eiden Donna Blake; Jon Page Mike Cox; AMSCO David Shellenbarger Arlene Roman Steve Oakley; David Shellenbarger Senior Plant Operator 90-P-13, 916 1/21/00 1/21/01 N/A N/A David Morgan Cregg Beach 96-P-16,659 1/21/00 1/22/01 N/A N/A Jim Eiden Donna Blake Long Creek Pretreatment Pretreatment Files Program 15A NCAC 2H 0900 (Headworks) 1 Crowders Pretreament Program Pretreatment Files 15A NCAC 2H 0900 NC0074268 1/3/00 1/3/05 N/A 3 years (Headworks) 1 NC0020184 9/97 5/31/00 N/A 3 years Janet Maddox Beth Eckert Nancy Matherly Beth Eckert 1 Headworks must be submitted a minimum of once per five years or if significant POTW changes is made. * See Addendum EMS-0101.001A ****THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 1/31/2001 AT 10:41 AM**** Page 1

Page 2 of 9 ISSUE Location of Control Document Administrative Codes Permit Number Effective Expiration Renewal Application Due Time ORC/ Contact Back-up Process Safety Management / Risk Management Plan Chemical Hygiene Plan Air Quality permit for generator at Duhart Creek Lift Station Long Creek Operations Room, Crowders Creek Operations Room, and Public Library Long Creek Laboratory, Crowders Creek Laboratories, and Public Library 29 CFR 1910.119; 0101 NC Dept. of Labor Title VII F / 40 CFR 68.210 29 CFR 1910.1450 N/A N/A ; 6/29/99 N/A 10/14/93 Reviewed at least every 3 yrs. Reviewed Annually Division Files NC08848G00 2/25/00 1/31/05 8/1/04 * N/A * Steve Oakley David Morgan N/A * Arlene Roman Steve Oakley * Safety related documents and records of training must be maintained on file for 30 years following the date the last affected person ceased working for the City. Coleman Keeter Larry Cummings ****THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 1/31/2001 AT 10:41 AM**** Page 2

Page 3 of 9 Regulatory Reporting Month Due Report Regulator Responsible Note January * Crowders DMR (Dec) (including Toxicity) DENR Crowders Creek ORC 5 Years * Long DMR (Dec) (including Toxicity) DENR Long Creek ORC 5 Years February 19 th Biosolids Annual Report EPA Residuals Management ORC 5 Years * Crowders DMR (Jan) DENR Crowders Creek ORC 5 Years * Long DMR (Jan) DENR Long Creek ORC 5 Years March 1 st Biosolids Annual Report DENR Residuals Management ORC 5 Years 1 st Pretreatment Annual Report DENR Industrial Chemists 5 Years 1 st Pretreatment SNC Publication DENR Industrial Chemists 5 Years Gaston Gazette 1 st SARA Tier 2 Reports EPA Division Safety Coordinator ** Superfund Amendments and Reauthorization Act 1986 Section 312 Public Law 99-499 * Crowders DMR (Feb) DENR Crowders Creek ORC 5 Years * Long DMR (Feb) DENR Long Creek ORC 5 Years April * Crowders DMR (Mar) (including Toxicity) DENR Crowders Creek ORC 5 Years * Long DMR (Mar) (including Toxicity) DENR Long Creek ORC 5 Years 30 th RRF Groundwater Monitoring Report DENR Residuals Management ORC 5 Years May * Crowders DMR (Apr) DENR Crowders Creek ORC 5 Years * Long DMR (Apr) DENR Long Creek ORC 5 Years June * Crowders DMR (May) (Including APAM) DENR Crowders Creek ORC 5 Years * Long DMR (May) (Including APAM) DENR Long Creek ORC 5 Years 30 th Pretreament Industrial Waste Survey DENR Pretreatment/Industrial Chemist 5 Years July * Crowders DMR (Jun) (including Toxicity) DENR Crowders Creek ORC 5 Years * Long DMR (Jun) (including Toxicity) DENR Long Creek ORC 5 Years August * Crowders DMR (Jul) DENR Crowders Creek ORC 5 Years * Long DMR (Jul) DENR Long Creek ORC 5 Years th Annual Wastewater Treatment Performance Long Creek Lab Supervisor Distributed to Public, 1999 28 DENR 5 Years Report and Pretreatment Staff NC Clean Water Act 31 st RRF Groundwater Monitoring Report DENR Residuals Management ORC 5 Years September * Crowders DMR (Aug) DENR Crowders Creek ORC 5 Years * Long DMR (Aug) DENR Long Creek ORC 5 Years * All DMRs are reported no later than 30 days after the last day of the report period. ** Safety documents and records of training must be maintained on file for 30 years following the date the last affected person ceased working for the City. ****THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 1/31/2001 AT 10:41 AM****

Page 4 of 9 Regulatory Reporting Continued Month Due Report Regulator Responsible Note October * Crowders DMR (Sep) (including Toxicity) DENR Crowders Creek ORC 5 Years * Long DMR (Sep) (including Toxicity) DENR Long Creek ORC 5 Years November * Crowders DMR (Oct) DENR Crowders Creek ORC 5 Years * Long DMR (Oct) DENR Long Creek ORC 5 Years December * Crowders DMR (Nov) DENR Crowders Creek ORC 5 Years * Long DMR (Nov) DENR Long Creek ORC 5 Years 31 st RRF Groundwater Monitoring Report DENR Residuals Management ORC 5 Years * All DMRs are reported no later than 30 days after the last day of the report period.

Page 5 of 9 Compliance Audits Issue Facility Permit Number Date of Last Occurrence Frequency Responsible Crowders Sr. Plant Crowders Creek WWTP Inspection Crowders Creek NC0020184 Once/year 5 years 7/00 Operator Long Creek WWTP Inspection Long Creek NC0074268 5/00 Once/year 5 years Long Sr Plant Operator Pretreatment Inspection All SIUs N/A * Once/year 3 years Industrial Chemists Crowders and Risk Management Plan N/A Every 3 years 5 years Crowders Lab Supervisor Long Creek 6/99 Pressure Vessel Inspection All Facilities ** ** Once/Year 5 years Senior Plant Operators Crowders Creek Lab Audit Crowders Creek 210 4/00 Once/Year 3 years Lab Supervisor Long Creek Lab Audit Long Creek 545 2/00 Once/Year 3 years Lab Supervisor Dam Inspection Crowders Creek 079 & 080 12/99 Once/ 3 Years 5 years Senior Plant Operator State Pretreatment Audit Both WWTP s NC0020184; Every 5 Years Pretreatment Industrial 4/96 5 years NC0074268 Chemist State Pretreatment Inspection Both WWTP s NC0020184; Once/Year Pretreatment Industrial 2/00 5 years NC0074268 Chemist EPA Laboratory Performance Samples Both Laboratories 210 & 545 8/98*** Once/Year 5 years Laboratory Supervisors * SIUs are inspected annually by Industrial Chemist at various times throughout each year. ** See Addendum EMS-0101.001A ***Due to issues surrounding approved distributors of performance samples, the 99 requirement was waived by EPA.

****THIS IS AN UNCONTROLLED COPY OF A CONTROLLED DOCUMENT PRINTED 1/31/2001 AT 10:41 AM**** Page 6 of 9 Monitoring of Regulations ISSUE Facility Responsible How Regulations will be Monitored NPDES Permits/Regulations All Superintendent, Assistant Superintendent Lab Regulations/Procedures All Laboratory Supervisors Land Application Program All Land Application ORC Safety Program All Division Safety Coordinator Pretreatment Regulations All Industrial Chemists

Page 7 of 9 Safety Programs/Requirements Topic/Issue Facility Frequency Responsible Comments Hazard Communications All Once/Year Facility Safety Coordinator * 29 CFR 1910.1200 Emergency Response All Once/Year Facility Safety Coordinator * Emergency Action Plan All Once/Year Facility Safety Coordinator * Chemical Hygiene Labs Monthly Laboratory Supervisor * Confined Space Entry Program All Once/Year Facility Safety Coordinator * Fall Protection Program All Once/Year Facility Safety Coordinator * Hot Work Permit System All Once/Year Facility Safety Coordinator * Safety Related Electrical Work Practices All Once/Year Facility Safety Coordinator * Lockout/Tagout Program All Once/Year Facility Safety Coordinator * Medical Services and First Aid All Once/Year Facility Safety Coordinator * Bloodborne Pathogen Program All Once/Year Facility Safety Coordinator * Respirator Protection Program All Once/Year Facility Safety Coordinator * Personal Protective Equipment Program All Once/Year Facility Safety Coordinator * Fire Safety All Once/Year Facility Safety Coordinator * Fume Hood Inspections Crowders Lab Once/Year Lab Supervisor * Fume Hood Inspections Long Lab Once/Year Lab Supervisor * Fume Hood Inspections Pretreatment Once/Year Facility Safety Coordinator * Eye Wash Inspections All Weekly Facility Safety Coordinator * Safety Shower Inspections All Monthly Facility Safety Coordinator * Fire Extinguisher Inspections All Monthly Facility Safety Coordinator * First Aid Kit Inspections All Monthly Facility Safety Coordinator * Gas Detectors Crowders & Long * Annually Facility Safety Coordinator Creek WWTPs Calibration * Safety documents and records of training must be maintained on file for 30 years following the date the last affected person ceased working for the City.

Page 8 of 9 Other Requirements ISSUE Microwave Digester Maintenance Contract Perkin Elmer Spectrophotometer Maintenance Contract Analytical Balance Calibrations / Fume Hood Inspections FIAS Maintenance Contract ICP-MS Maintenance Contract Dracor Water System(Crowders & Long Creek Labs) Lab Instrumentation Calibrations (internal) NIST Calibrations (Thermometers & Temperature Probes) Power Supply Contract (Crowders & Long Creek) - (No renewal needed) Patented Process Contract (Crowders & Long Creek ) - (no renewal needed) Generator Maintenance (Long & Crowders Creek) Biosolids Handling (Professional Services Agreement for biosolids handling at Long, Crowders, RRF & Application Sites) Location of Contract Company Performing work Frequency Crowders Lab CEM Annually 3 years Crowders Lab Perkin Elmer Annually 3 Years N/A Long Creek Lab (under warranty-no need for contract until 9/00) Crowders Lab (under warranty-no need for contract until 7/01) Environmental Service Professionals ORC/Contact Crowders Lab Supervisor Crowders Lab Supervisor Twice/Year 3 years Lab Supervisors OI Analytical Annually 3 years Perkin Elmer Annually 3 years Long Creek Lab Supervisor Crowders Lab Supervisor Long Creek Divisional Files Dracor Annually 3 years Lab Supervisors N/A Internal Daily 3 years Lab Supervisors N/A Internal Quarterly 3 years Lab Supervisors Long Creek Divisional Files Duke Power N/A 5 Years Superintendent Long Creek Divisional Files Kruger N/A 5 years Superintendent Long Creek Divisional Files Carolina Tractor & Equipment (Caterpillar) Annually 5 years Superintendent Biosolids Files Synagro N/A 5 years Biosolids ORC Screw Pump Contract Long Creek Divisional Files Kemp Annually 5 years Superintendent Blower Maintenance (Mechanical) (Long Creek) Long Creek Divisional Files Lamson Annually 5 years Superintendent

Page 9 of 9 Other Requirements ISSUE Instrumentation Calibrations at the WWTPs* Location of Contract Company Performing work Frequency ORC/Contact Long Creek Divisional Files ISI Annually 5 years Superintendent Security Contract at RRF Biosolids Files Scott Edwards Annually 5 years Biosolids ORC Upgrading Crowders Creek WWTP (Professional Services Agreement) Permitting Issues (Professional Services Agreement) Long Creek Divisional Files Arcadis N/A 5 years Superintendent Long Creek Divisional Files CH2MHill N/A 5 years Superintendent Fire Extinquisher Maintenance Safety Files City Fire Department N/A 5 years Air Compressors (Long Creek) Long Creek Divisional Files Air Components & Systems Division Safety Coordinator Annually 5 years Superintendent Air Compressors (Crowders Creek) N/A Internal N/A N/A ORC/Contact Waste Removal Long Creek Divisional Files BFI Annually 5 years Superintendent Elevator Maintenance Long Creek Divisional Files Ace Annually 5 years Superintendent Wet Well Cleaning (Professional Services Agreement) Long Creek Divisional Files 3R N/A 5 years Superintendent