NC0023337_additional information requested_20111107

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 7, 2011
70081300 0000 1109 4697
RETURN RECEIPT REQUESTED
Ms. Nancy Jackson, Town Administrator
Town of Scotland Neck
P.O. Box 537
Scotland Neck, NC 27874-0537
Subject: Information Request
Scotland Neck WWTP
NPDES Permit No. NC0023337
Dear Ms. Jackson:
The Staff of the Raleigh Regional Office (RRO) appreciate your attendance at the Show Cause Meeting
on Monday, October 17, 2011 to discuss items contained in the Notice of Violation letter, dated August
12, 2011. Present at the meeting were yourself, Gerald Brannon, Gary Stainback, and James Pittman of
United Water and Danny Smith, Dave Parnell, and Mandy Hall of the RRO. United water is contracted
by the Town to operate and maintain the Scotland Neck Wastewater Treatment Plant.
Mr. Stainback and Mr. Pittman explained the status of each of the treatment units and the current plans
for repair of each unit. Presented to the RRO staff were the following documents:
• WWTP Current Status of Conditions
• Sewer Collection System and WWTP Repair Efforts To Date
• Inflow and Infiltration Projects and Subsequent Flow Data for the WWTP
It is the understanding of the RRO the Town plans to repair several of the treatment units in the WWTP
but that Inflow and Infiltration remains a factor in the continuing occurrences of non-compliance with
the limits of the NPDES permit. Mr. Pittman indicated that a rainfall event of approximately one inch
causes problems with WWTP operation and compliance.
Further, it is the understanding of the RRO the following is true regarding the maintenance and
operation issues with wastewater treatment units:
• Influent bar screen is overwhelmed during high flow events
• Grit removal system is not operational
• One of the clarifiers is not operable (rather, it is used for storage during high flows and has to be
manually pumped to empty)
North Carolina Division of Water Quality Raleigh Regional Office
Internet: www.ncwaterquality.org
Surface Water Protection Phone [phone] Customer Service
1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
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Town of Scotland Neck
November 7, 2011 Page 2 of 2
• Return activated sludge (RAS) piping for second clarifier is broken and the function of returning
and wasting sludge must be conducted manually
• Inflow and infiltration causes routine filter bypassing
• Sludge. drying beds are in need of maintenance (removal of accumulated material)
• Digester has dead zones
Accordingly, RRO requests the Town of Scotland Neck provide written monthly updates, to be
submitted to the RRO, Surface Water Protection Section of the Division of Water Quality. These
monthly reports should be sent to the attention of Danny Smith at the letterhead address of this
correspondence and mailed by the last day of each month. Specifically, these reports must minimally
address the following:
1) current wastewater treatment plant status and conditions
2) new and reoccurring problems (since last update)
3) any additional information or efforts to abate Inflow and Infiltration
4) repair and maintenance efforts that have occurred during the past month, and
5) operational status of all treatment units
In addition, during the aforementioned Show Cause Meeting, the RRO asked the Town to consider
entering into a Special Order by Consent (SOC) Agreement. During the meeting RRO staff explained
how this type of agreement would be beneficial to the Town. Please contact Mandy Hall, WWTP
Consultant, at [phone] if you have further questions about the SOC process. Finally, please
respond to this office within 60 days of this receipt of this correspondence such that we may clearly
understand whether the Town intends to submit a SOC application. (Note: an application may be found
at www.ncwaterquality.org/permits)
The Raleigh Regional Office appreciates your willingness to meet with us and your preparedness for the
meeting. Please do not hesitate to contact me if you have any questions.
Sincere y, 4 '
Danny Smi , Supervisor
Surface ater Protection
Raleigl'i Regional Office
cc: Central Files
Joe Corporon
RRO File Copy