NC0026042_Correspondence_20121126

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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:
November 26, 2012
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content on the reirerse side

Belnick, Tom
From:
Sent:
To:
Cc:
Subject:
Tom:
Matt Echols [[e-mail]]
Monday, November 26, 2012 2:57 PM
Belnick, Tom
Charles Davis
Robersonville WWTP - NC0026042
Following up on a voicemail I just left for you regarding the Robersonville WWTP and determining a practical flow limit for
the lower tier of the discussed two -tiered NPDES Permit. A quick information primer/refresher is below:
The plant is permitted as a 1.8 MGD BNR-AS with tertiary filtration. The filter system is inoperable; however, the WWTP
has shown the ability to meet effluent limits at low flows. In order to delay the costs of replacing the filters, a two -tiered
permitting strategy has been suggested by the plant's contracted operator (Envirolink) which would remove the
requirement for filters as long as the plant operates at the lower flow tier.
Seth Robertson at IFS has stated that an engineering analysis demonstrating the plant's ability to meet effluent limits at
lower flows will be required to justify operation without filters. Before efforts are made in this regard, Seth suggested we
work with you to determine what the flow limit at the lower tier should be. A flow of 0.95 MGD has been suggested by
Envirolink; however, the plant has experienced monthly average flows up to 1.1 MGD as recently as March 2012. An
ongoing collection system rehabilitation project could significantly reduce I&I, but as I'm sure you know, quantifying the
anticipated flow reduction at the plant can be difficult.
Your input on this would be greatly appreciated. Please give me or Charlie a call at your earliest convenience at 919-828-
0531.
Regards,
Matt Echols, El
Assistant Project Engineer
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603
919.828.0531
Fax [phone]
www.thewootencompany.com
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Belnick, Tom
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From: Belnick, Tom
Sent: Thursday, November 15, 2012 5:02 PM
To: Adams, Amy; Thorpe, Roger; Bullock, Robert
Cc: Robertson, Seth; Pohlig, Ken
Subject: FW: Robersonville WWTP-NPDES Permit No. NC0026042
Attachments: Robersonville WVWTP - NC0026042 - BIMS Data - Jan 2006 - June 2012.xls
Just read Ken Polig's email on this one and thought I'd forward along this email from September 2012. NPDES has been
getting calls from both Wooten Consultants (pushing filters) and the contract operator (Mike Myers, pushing for no
filters, as recently as Tuesday). Both seem to be pursuing their own agendas. I hope the Town is at the meeting and all
can decide on a concerted path forward.
PS -Amy- haven't met you yet, but congratulations on the new job! Welcome to the world of NPDES!
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Belnick, Tom
Sent: Wednesday ptember 12, 2012 3:02 PM
To: 'Kinney, Maureen
Cc: Hennessy, John
Subject: FW: Robersonville WWTP-NPDES Permit No. NC0026042
Maureen- I just talked with WARO Robbie Bullock about Robersonville. Sounds like they were seeking SOC, but now
might not want it. Their consultant (Wooten Company) told town they would need tertiary filters to meet permit limits
for the 1.8 MGD discharge, but the Town's new ORC (Mike Myers) told the town that they don't need filters.
Construction Grants response was that filters are indeed needed. I think filters are part of SOC? I know Mike Myers was
meeting with Bob Guerra on this one.
Consultant called me about spec limits for 0.9 MGD- they were wondering if they received interim flow sheet for 0.9
MGD, whether filters would still be required. Construction Grants piped in that facility would have problems meeting
this flow limit, so spec request was dropped.
At this point, it sounds like just an SOC issue.
PS- WARO is strongly against any reduction in monitoring frequency, since previous ORC was canned for data
falsification.
From: Bullock, Robert
Sent: Wednesday, September 12, 2012 1:52 PM
To: Belnick, Tom
Subject: FW: Robersonville WWTP-NPDES Permit No. NC0026042
Robbie Bullock
1

WWTP Consultant
252-948-3843 Phone
"E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties"
From: Pohlig, Ken
Sent: Thursday, August 30, 2012 10:18 AM
To: Robertson, Seth; Shankar Mistry
Cc: Bucky Moore; Charles Davis; Matt Echols; Gary Hartong; Bullock, Robert
Subject: RE: Robersonville WWTP-NPDES Permit No. NC0026042
Shankar:
Please see the attached Excel file, which supports Seth's e-mail below.
Ken Pohlig
DWQ, Infrastructure Finance Section
From: Robertson, Seth
Sent: Thursday, August 30, 2012 10:14 AM
To: Shankar Mistry
Cc: Bucky Moore; Charles Davis; Matt Echols; Gary Hartong; Bullock, Robert; Pohlig, Ken
Subject: RE: Robersonville WWTP-NPDES Permit No. NC0026042
Shankar,
Based upon the information provided in your email and a review of the subject facility NPDES permit and DMR data, we
feel strongly that tertiary filtration will be required to bring the plant back into compliance and to meet the limits going
forward. In addition, we have serious reservations regarding the facility's ability to comply with a 0.9 MGD flow sheet
since it appears that flows have exceeded 0.9 MGD as a monthly average multiple times over the last few years. If you
would like to discuss further please contact me.
Regarding the Town's need for funding, please also be aware that the Town may qualify for either principle forgiveness
for a portion of the project and/or a 0% interest loan through the SRF program. Our next funding application deadline is
September 4th. If you have any questions regarding funding please feel free to contact me.
Thanks,
Seth
Seth Robertson, P.E.
Design Management Unit Supervisor
Division of Water Quality
Infrastructure Finance Section
919-707-9175
http://ifs.nc.gov
2

E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Shankar Mistry [mailto:[e-mail]]
Sent: Wednesday, August 29, 2012 10:59 AM
To: Robertson, Seth
Cc: Bucky Moore; Charles Davis; Matt Echols; Shankar Mistry; Gary Hartong
Subject: Robersonville WWTP-NPDES Permit No. NC0026042
Dear Seth:
The Town of Robersonville operates 1.8 MGD BNR type wastewater treatment plant that has tertiary level effluent limits
on BOD5 of 5.0 mg/L and NH3-N of 2.0 mg/L. The plant was designed with tertiary filter to comply with the tertiary limits on
BOD5 and NH3-N. Due to dilapidated conditions of the filters the tertiary filtration system was taken out of service. Not
having the filter the plant was not able to consistently comply with the BOD5, TSS, and Fecal Coliform. At present because
of the low average daily flow (600,000 GPD) at the plant the Town is considering to apply for two sets of effluent limits for
monthly average daily flows of 0.9 MGD and !.8 MGD, respectively, The primary intention behind this is to reduce the
monitoring requirements to reduce the effluent parameters testing by the contract laboratory. At present the plant is
operated by Envirolink, contract Operation Company, and it is the opinion of Envirolink that tertiary filters are not needed.
As I understood from my past dealing with CG&L if the plant has a tertiary effluent limits then tertiary filters are required to
consistently comply with the tertiary level effluent limits as apart of the standard design practice.
Our position is to provide filters for consistent compliance with the effluent limits so that the Town does not have to deal
with the future Notice of Violations and paying civil penalties. Please note that the Town is currently under SOC for
violation of effluent limits and is seeking funding to install tertiary filters fof consistent compliance with the NPDES Permit
limits. As I understood in year 2014 the NCDWQ will also impose individual effluent limits on Total Nitrogen and Total
Phosphorous for all point source dischargers in the Tar -Pamlico River Basin. I will appreciate your opinion on the tertiary
filter system requirements for consistent compliance with the effluent limits. Thanks
Shankar R. Mistry, Ph.D., P.E.
Senior Process Design Engineer
The Wooten Company, Inc.
120 N. Boylan Avenue
Raleigh, NC 27603
919-828-0531 Phone
919-834-3589 Fax
3

) //2...vi 2,
Belnick, Tom
From: Pohlig, Ken
Sent: • - = = , ' ovember 15, 2012 12:26 PM
To: Adams, Amy; Bullock, Robert; Thorpe, Roger
Cc: Belnick, Tom; [e-mail]; Shankar Mistry; Robertson, Seth
Subject: FW: Robersonville WWTP-NPDES Permit No. NC0026042
Attachments: Robersonville WWTP - NC0026042 - BIMS Data - Jan 2006 - June 2012.xls
Amy and all:
I understand from Shankar Mistry (The Wooten Co.) that there is a meeting regarding the Robersonville WWTP next
week.
Please see the e-mail below from Seth Robertson (IFS), dated 8/30/2012, where Seth responded back regarding tertiary
filtration.
I have also included the same Excel spreadsheet with downloaded BIMS historical data for the Robersonville WWTP.
Their max. month flow to date has been about 1.1 MGD (in March 2012), and they have numerous exceedances of their
BOD and TSS monthly and weekly effluent limits (see charts imbedded in spreadsheet).
For monthly BOD limits of 5 mg/I, and Ammonia limits of 2 mg/k, we have always (historically) required tertiary
filtration, as is industry standard for such limits.
Please contact Seth Robertson or myself for any questions.
Thanks.
Ken Pohlig
DWQ, Infrastructure Finance Section
From: Robertson, Seth
Sent: Thursday, August 30, 2012 10:14 AM
To: Shankar Mistry
Cc: Bucky Moore; Charles Davis; Matt Echols; Gary Hartong; Bullock, Robert; Pohlig, Ken
Subject: RE: Robersonville WWTP-NPDES Permit No. NC0026042
Shankar,
Based upon the information provided in your email and a review of the subject facility NPDES permit and DMR data, we
feel strongly that tertiary filtration will be required to bring the plant back into compliance and to meet the limits going
forward. In addition, we have serious reservations regarding the facility's ability to comply with a 0.9 MGD flow sheet
since it appears that flows have exceeded 0.9 MGD as a monthly average multiple times over the last few years. If you
would like to discuss further please contact me.
Regarding the Town's need for funding, please also be aware that the Town may qualify for either principle forgiveness
for a portion of the project and/or a 0% interest loan through the SRF program. Our next funding application deadline is
September 4th. If you have any questions regarding funding please feel free to contact me.
Thanks,
Seth
1

Seth Robertson, P.E.
Design Management Unit Supervisor
Division of Water Quality
Infrastructure Finance Section
919-707-9175
http://ifs.nc.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Shankar Mistry [mailto:smistryOthewootencompany.com]
Sent: Wednesday, August 29, 2012 10:59 AM
To: Robertson, Seth
Cc: Bucky Moore; Charles Davis; Matt Echols; Shankar Mistry; Gary Hartong
Subject: Robersonville WWTP-NPDES Permit No. NC0026042
Dear Seth:
The Town of Robersonville operates 1.8 MGD BNR type wastewater treatment plant that has tertiary level effluent limits
on BOD5 of 5.0 mg/L and NH3-N of 2.0 mg/L. The plant was designed with tertiary filter to comply with the tertiary limits on
BOD5 and NH3-N. Due to dilapidated conditions of the filters the tertiary filtration system was taken out of service. Not
having the filter the plant was not able to consistently comply with the BOD5, TSS, and Fecal Coliform. At present because
of the low average daily flow (600,000 GPD) at the plant the Town is considering to apply for two sets of effluent limits for
monthly average daily flows of 0.9 MGD and !.8 MGD, respectively, The primary intention behind this is to reduce the
monitoring requirements to reduce the effluent parameters testing by the contract laboratory. At present the plant is
operated by Envirolink, contract Operation Company, and it is the opinion of Envirolink that tertiary filters are not needed.
As I understood from my past dealing with CG&L if the plant has a tertiary effluent limits then tertiary filters are required to
consistently comply with the tertiary level effluent limits as apart of the standard design practice.
Our position is to provide filters for consistent compliance with the effluent limits so that the Town does not have to deal
with the future Notice of Violations and paying civil penalties. Please note that the Town is currently under SOC for
violation of effluent limits and is seeking funding to install tertiary filters fof consistent compliance with the NPDES Permit
limits. As I understood in year 2014 the NCDWQ will also impose individual effluent limits on Total Nitrogen and Total
Phosphorous for all point source dischargers in the Tar -Pamlico River Basin. I will appreciate your opinion on the tertiary
filter system requirements for consistent compliance with the effluent limits. Thanks
Shankar R. Mistry, Ph.D., P.E.
Senior Process Design Engineer
The Wooten Company, Inc.
120 N. Boylan Avenue
Raleigh, NC 27603
919-828-0531 Phone
919-834-3589 Fax
2