NC0026042_Correspondence_20070309

NPDES DOCUMENT ! CANNINO COVER SHEET
NC0026042
Robersonville WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental
Assessment (EA)
Permit
History
Document Date:
March 9, 2007
This document is printed on reuse paper - 44 none airy
content on the reYerse side

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NCDENR DWO PAGE 03/07
THE
WOOTEN
COMPANY
ENGINEERING
PLANNING
ARC fHI T E CTUR C
I2n Nnrth Nov Avenn.,
Ralelrlx NC 27603-1123
919 828.0531
fax [phone]
March 9, 2007
Ms. Kristin C. Jarman
Wastewater Treatment Plant Consultant
NCDWQ
Washington Regional Office
943 Washington Square Mall
Washington, North Carolina 27889
Re: Comment Response to
Compliance Evaluation Inspection
Town of Robersonville
Dear Ms. Jarman:
RECEIVED
;';i;,Z 1 3 Z007
DWQ-WARO
ticoo "o9Z
On behalf of the Town of Robersonvillc, we are writing in response to your January 8,
2007 letter regarding the Compliance Evaluation Inspection held at the plant on 12/5/06. 1
understand that Mr. Willie Andrews with the Town submitted an initial response within
the time frame requested and identified that The Wooten Company would be following
up with additional comments which arc provided herein.
In 1999 the Town implemented variable frequency drives for improved control of the
existing 100 HP oxidation ditch aerators as part of a nutrient improvements project at the
plant- These VFDs offered operational flexibility by allowing the aerator motor speed to
vary up/down in response to maintaining the desired dissolved oxygen levels in the
aeration zone of the treatment process. These improvements not only enhanced the plant
process capabilities but also offered opportunity for significant electrical power savings.
Recently the plant staff has experienced problems with both of the VFD units such that
the plant currently operates the aerators at full speed without the aid of the VFD control.
In 2003 the Perdue processing plant shut down and influent flow to the plant has been
significantly reduced from around 1.2 mgd ADF in 2003 to around 0.45 mgd ADF today
The Wooten Company has been asked to assist the Town in developing a plan for optimal
use of the existing plant facilities under the reduced loading conditions. Currently three of
the six existing clarifiers have been taken out of service and other process changes may
be planned as well. One aspect of our approach is to repair the VFD control .system at the
oxidation ditch and implement measures that will improve and optimize the operation of
the existing oxidation ditch system under current loading conditions. Since the oxidation
ditch aerators constitute the single largest electrical load at the plant, it is vital to reduce
electrical costs in a time when the Town has lost significant water and sewer revenue
resulting from the Purdue closure.

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Ms. Kristin C. Jarman
Page 2
March 9, 2007
Therefore, in consideration of the above factors, the Town desires to primarily focus on repairs to the VFD
control system in the near term along with other plant optimization strategies as a result of reduced influent
loading. We acknowledge that improvements could be made to the plant's stand-by power capabilities;
however, there is potential to delay such expenditures if we can reduce the overall plant olcctrical power
consumption such that the current stand-by power systems can support the critical processes without the need
for supplemental stand-by power at this time.
Historically the Town of Robersonvillc has been an exemplary steward of the Statc's natural resources and
has alwaysworked closely with the Washington Regional Office. We respectfully ask for your consideration
of our planned approach ab V Tdwould welcome the opportunity to discuss these iss"es further with your
office if necessary.
If you have any questions our need additional information, please do not hesitate to contact me. Thanks for
your assistance in this matter and we look forward to your response.
Sincerely,
c: Mr. John Pritchard, Town of Robersonville
Mr. Willie Andrews, Town of Robersonvillc
Mr. Bucky Moore, The Wooten Company

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NCDENR Dw0 PAGE 02/07
February 6, 2Q07
¶IIJoartz of CROt EZS.onuittE
P.O. BOX 487
ROBERSONVILLE, N. C. 27871
PHONE [phone]
RECEIVE.
FEB 0/700/
D'` 0-MVA62Q
Kristin C. Jarman
Wastewater Treatment Plant Consultant
Division of Water Quality
943 Washington Square Mall
Washington, NC 27889
Subject: Response to December 5, 2006 Compliance Evaluation Inspection
Town of Robersonville
Robersonville WWTP
Permit No.: NC0026042
Martin County
Dear Kristin Jarman:
The Town of Robersonville is responding to our main aerators not on any emergency
power source in the event of an electrical power failure. By the town owning their
electrical system our priority is making sure that the waste treatment system is back on
line first. If the main substation goes out, North Carolina Power is on the scene fairly
quickly. As of this letter our engineers, The Wooten Company, is working on a solution
to the Town's emergency power for the main aerators. The Wooten Company said they
would address a letter to you and the Division within two weeks. During any event, the
Town and I will do all we can do to keep untreated waste water from being discharged.
If you have any questions please contact John H. Pritchard, Jr., Town Manager at 252-
795-4006 of Willie Andrews, WWTP ORC at 252-795-4558 or 252-799-8047.
Sincerely,
WU& OWAIAI
Willie Andrews
WWTP ORC

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and -Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 8, 2007
John H Pritchard, Jr
Town of Robersonville
PO Box 487
Robersonville NC 27871
SUBJECT: December 5, 2006 Compliance Evaluation Inspection
Town of Robersonville
Robersonville WWTP
Permit No: NC0026042
Martin County
Dear Mr Pritchard:
Enclosed please find a copy of the Compliance Evaluation Inspection form from the inspection conducted
on December 5, 2006. The Compliance Evaluation Inspection was conducted by Kristin C Jarman of the
Washington Regional Office. The facility was found to be in Compliance with permit NC0026042.
Part II, Section C (7) of your permit states that "The Permittee is responsible for maintaining adequate
safeguards (as required by 15A NCAC 2H.0124- Reliability) to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures either by means of alternate power sources,
standby generators or retention of inadequately treated effluent." The two generators at the Wastewater
Treatment Plant will not run the entire plant. The grit chamber, oxidation ditch aerators and 5 of the
clarifiers will not be fully operable during an electrical power failure. If no other power source is to be
added, a written verification is needed from the Permittee stating that during an electrical power failure
there will be no discharge of untreated or inadequately treated wastes. Please send this verification within
30 days from the date this letter is received.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff
have any questions, please call me at 252-948-3918.
Sincerely,
Kristin Cinan
Wastewater Treatment Plant Consultant
cc: Willie Lee Andrews, ORC
Central Files
Washington Files
North Carolina Division of Water Quality Washington Regional Office Phone [phone] Customer Service
Internet www.newaterquality.org 943 Washington Square Mall, Washington, NC 27889 FAX [phone]
V�
Won` Carolina
ataral4'
An Equal Opportunity/Affirmative Action Employer- 50% Recyctedll0% Post Consumer Paper

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmo/day Inspection
1 HI 2 15' 31 NC0026042 111 121 06/12/05 117
�--t �-_� 1 1
Type Inspector Fac Type
181 r-1 191 cI 201 i
U �J !J
I I I I 1 1 1 I I 1 I I I I 166
Remarks
211 I I I I I I I 1 I J 1 1' 11 1 1 1 1 1 1 1 1 1 I I I I 1 I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67 69 70111 7111 72 tJ
Reserved
73 u 74 75f I I I I , I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Robersonville WWTP
1149 Rogerson Rd
Robersonville NC 27871
Entry Time/Date
10:00 AM 06/12/05
Permit Effective Date
05/06/01
Exit Time/Date
11:15 AM 06/12/05
Permit Expiration Date
09/11/30
Name(s) of Onsite Representative(s)/Titles(s)!Phone and Fax Number(s)
///
Willie Lee Andrews/ORC/252-795-4558/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
John H Pritchard, PO Box 487 Robersonville NC 27871/Town Contacted
Manager/252-795-4558/2527954607 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 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 Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Kristin C Jarman 116WARO WQ//252-945-6481 Ext.3151 Jig/o7
Sign of nag ment Q A Reviewer Agency/Office/Phone and Fax Numbers Date
tikv),..",---- ,R C - 79' t ,4 7,Q1 // et t ?
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page #

31
WOES
NC0026042
ill 121
yrlmolday Inspection Type
06/12/05 I17 18U
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
DMRs were reviewed from May 2005 through August 2006. There were 3 daily maximum violations for
Mercury. The bar screen needs to be repaired as well as the skimmer arm on one of the clarifiers. Five
weirs need replacing. The outside wall of the dechiorination tank needs to be repaired. All walkways and
rails need to be checked for safety issues. The two generators on site will not run the entire wastewater
plant. The grit chamber, oxidation ditch aerators and 5 of the clarifiers will not be fully operable during an
electrical power failure. If no other power source is to be added, a written verification is needed from the
Permittee stating that during an electrical power failure there will be no discharge of untreated or
inadequately treated wastes.
Page # . 2

Permit NC0026042
Owner - Facility: Robersonville WWTP
Inspection Date: 12/05/2006 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally dean with acceptable housekeeping? M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ 0 0 0
Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? 0 0 • 0
Is the facility as described in the permit? 0 • 0 0
# Are there any special conditions for the permit'? • ❑ ❑ ❑
Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: Facility has a BNR basin before the oxidation ditches. They have 6
clarifiers and 3 chlorine contact chambers.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑
Is all required information readily available, complete and current? • 0 0 0
Are all records maintained for 3 years (lab. reg. required 5 years)? • ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? • ❑ ❑ ❑
Is the chain -of -custody complete? • 0 ❑ ❑
Dates, times and location of sampling ❑
Name of individual performing the sampling 0
Results of analysis and calibration 0
Dates of analysis 0
Name of person performing analyses 0
Transported COCs 0
Are DMRs complete: do they include all permit parameters? • ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ? ■ ❑ ❑ ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? 0 0 • 0
Is the ORC visitation log available and current? • ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? • ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facilityvclq.sifi ation? ■ ❑ ❑ ❑
iiw i a y u bL .i� :14A + .�:t wia�
Page # 3

• Permit: NC0026042 Owner - Facility: Robersonville WIIVTP
Inspection Date: 12/05/2006 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is a copy of the current NPDES permit available on site? 11000
Facility has copy of previous year's Annual Report on file for review? 1.000
Comment: •
Y
Effluent Pipe es No NA NE
Is right of way to the outfall properly maintained? • ❑
0
Are the receiving water free of foam other than trace amounts and other debris? • 0
If effluent (diffuser pipes are required) are they operating properly? Q 0 • 0
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? 11000
Is flow meter calibrated annually? • 0 0 .0
Is the flow meter operational? 11000
(If units are separated) Does the chart recorder match the flow meter? 0 0 ■ 0
Comment: Meter was calibrated on 4-4-06.
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? •
000
Is the wet well free of excessive grease? 0 • 0 0
Are all pumps present? • 0 0
Are all pumps operable? M 0 0
Are float controls operable? ® C3 0 0
Is SCADA telemetry available and operational? 0 0 • 0
Is audible and visual alarm available and operational? 1 ❑ 0 ❑
Comment: Wet well had Tots of old grease and needs to be cleaned.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual 0
b.Mechanical
Are the bars adequately screening debris? • ❑
00
Is the screen free of excessive debris? • ❑ 0 0
is disposal of screening in compliance? • ❑
0
Page # 4

Permit NC0026042
Inspection Date: 12/05/2006
Owner « Facility: Robersonville W%NTP
inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
Is the unit in good condition? 0 • 0 0
Comment: The bar screen side panel is rusted out and needs replacing.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual 0
b. Mechanical ■
Is the grit free of excessive organic matter? • 0 0 0
Is the grit free of excessive odor? ■ ❑ 0 ❑
# Is disposal of grit in compliance? • 0 0 0
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? • 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ■ 0 0
Are weirs level? ❑ ■ 0 0
Is the site free of weir blockage? ■ 0 ❑ 0
Is the site free of evidence of short-circuiting? 0 • 0 0
Is scum removal adequate? ■ 0 0 0
Is the site free of excessive floating sludge? ■ ❑ ❑ ❑
Is the drive unit operational? ■ 0 ❑ ❑
Is the retum rate acceptable (low turbulence)? • 0 0 0
Is the overflow clear of excessive solids/pin floc? ■ 0 0 ❑
Is the sludge blanket level acceptable? (Approximately'/. of the sidewall depth) ■ 0 0 0
Comment: Five of the six weirs need replacing. Weirs are not level and cracked with
flow going under the weir in places. One of the clarifiers has the skimmer arm out. This
clarifier was not discharging at the time of the inspection. Skimmer arm needs to be
fixed.
Oxidation Ditches
Are the aerators operational?
Are the aerators free of excessive solids build up?
# Is the foam the proper color for the treatment process?
Does the.foam cover less than 25% of the basin's surface'?
Lv lJ I is 1
Yes No NA NE
■ ❑ ❑ ❑
■ ❑❑❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page #

Permit NC0026042
Inspection Date: 12/05/2006
Owner - Facility: Robersonville VWVTP
inspection Type: Compliance Evaluation
Oxidation Ditches Yes No NA NE
Is the DO level acceptable? 0 a 0 0
Are settleometer results acceptable (> 30 minutes)? • 0
00
Is the DO level acceptable?(1.0 to 3.0 mg/I) • 0 0 0
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes) • 0 0 Q
Comment: DO is high, 4-5 ppm. The aerators can not be regulated. The normal DO in
an oxidation ditch is between 1 and 3. Overaeration can cause floc shearing and be an
additional energy cost burden on the Town.
Nutrient Removal Yes No NA NE
# Is total nitrogen removal required? • 0 0 0
# Is total phosphorous removal required? • 0
Type Biological
# Is chemical feed required to sustain process? 0 0 •
CI
Is nutrient removal process operating properly? • ❑ 0
0
Comment:
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the fitter media present? • 0 0 0
Is the filter surface free of clogging? • 0 ❑ 0
Is the filter free of growth? ■ 0 0
Is the air scour operational? • 0 0 0
Is the scouring acceptable? • ❑ 0 ❑
Is the clear well free of excessive solids and filter media? • 0 0
Comment: Tertiary filter #4 has a ruptured plate and is not being used. Three filters
are running. The rails and walkways are rusted and should be checked for safety issues.
Disinfection -Gas Yes No NA NE
Are cylinders secured adequately? I 0 CI
Are cylinders protected from direct sunlight? • 0
Is there adequate reserve supply of disinfectant? • 0 0 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 0 01
Page # 6

•
Permit NC0026042 Owner - Facility: Robersonville WWTP
Inspection Date: 12/05/2006 Inspection Type: Compliance Evaluation
Disinfection -Gas Yes No NA NE
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? 0 0 • 0
If yes, then is there a Risk Management Plan on site? 0 0 • ❑
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment:
De -chlorination Yes No NA NE
Type of system ? Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)? • 0 0 0
Is storage appropriate for cylinders? 0 0 • 0
# Is de -chlorination substance stored away from chlorine containers? • 0 0 0
Comment:
Are the tablets the proper size and type? 0 0 • 0
Are tablet de -chlorinators operational? 0 0 • 0
Number of tubes in use?
Comment: Rails of walkways are rusted. Outside wall of the dechiorination tank has a
hole in it and needs to be fixed . Inside wall is ok.
Standby Power Yes No NA NE
Is automatically activated standby power available? • ❑ ❑ 0
Is the generator tested by interrupting primary power source? • ❑ ❑ ❑
Is the generator tested under load? • 0 0 0
Was generator tested & operational during the inspection? 0 • 0 0
Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ■ 0 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 0 0
Comment: Facility has 2 generators. They can not run the entire plant. The grit
chamber, oxidation basin aerators, and 5 of the 6 clarifiers will not operate properly
during a power failure. The Permittee is.responsible for maintaining adequate
safeguards to prevent the discharge of untreated or inadequately treated wastes during
electrical power failures.
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational? '
c.0 v l
Yes No NA NE
■ ❑❑❑
■ ❑ ❑ CI
Page # 7

Permit NC0026042
Inspection Date: 12/05/2006
Owner - Facility: Robersonville WWTP
Inspection Type: Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Are there adequate spare parts and supplies on site? • 0 ❑ 0
Comment:
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • 0 0 ❑
Are all other parameters(excluding field parameters) performed by a certified lab? • 0 0 0
# Is the facility using a contract lab? • 0 0
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ 0 0 0
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? • 000
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? • 0 0 0
Comment:
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional? 0 • 0 0
Is sample collected above side streams? 0 • 0 0
Is proper volume collected? • • 0 0 0
Is the tubing dean? 0 0 0 •
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? • 000
Is sampling performed according to the permit? • ,0 0 0
Comment: Sampling is time proportional. Sample is collected prior to decant from
digestor and domestic from office.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 • 0 0
Is sample collected below all treatment units? • 0 0 0
Is proper volume collected? • 0 0 0
Is the tubing dean? 0 0 0 •
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)? ■ 0 0 0
Is the,facility sampling performed as required by the permit (frequency, sampling type representative)? ■ 0 0 0
Comment: Sampling is time proportional
Page # 8
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