NC0025721_Permit (Issuance)_20100630

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0025721
Weldon WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Report
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
June 30, 2010
This document is printed on reuse paper - ignore any
cork -tent on the rezrerse side

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
June 30, 2010
Mr. Donald Crowder
Director of Public Utilities
Town of Weldon
P.O. Box 551
Weldon, North Carolina 27890
Subject: NPDES Permit Issuance
Permit No. NC0025721
Weldon WWTP
Halifax County
Dear Mr. Crowder:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued
pursuant. to the requirements of North Carolina General Statute 143-215.1 and the Memorandum
of Agreement between North Carolina and the U.S. Environmental Protection Agency dated
October 15, 2007 (or as subsequently amended).
4
The attached final permit has the following changes from the draft permit issued to you in April.
Specifically, these changes are:
> The equipment listed on the Supplement to Cover Page has been updated per review
comments from Weldon Staff and your consultant, Mr. Wright.
> EPA is requiring use of low level mercury test 1631E with clean sampling technique.
Current effluent data has revealed a few mercury detections above 200 ng/ L, which indicates the
Town may be contributing to mercury impairment of the Roanoke River. Use of clean sampling
and low level mercury analysis will allow the Division to evaluate the need for permit limits. For
those facilities using low level method 1631E, data has shown.that 95% of effluent samples are
below 20 ng/ L. If the Town continues to show mercury spikes, you should evaluate potential
mercury sources to the WWTP.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
..Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
,Naturally

If any parts, measurement frequencies or sampling requirements contained in this permit are 4
unacceptable to you, you have the right to an adjudicatory hearing upon written request within
thirty (30) days following receipt of this letter. This request must be in the form of a written
petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the
Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714).
Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water Quality
or permits required by the Division of Land Resources, the Coastal Area Management Act or any
other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Jim McKay at telephone number
[phone].
Sincerely,
tit
oleen H. Sullins
cc: Central Files
NPDES Unit Files
Raleigh Regional Office - via email
Aquatic Toxicology Unit - via email
PERCS, Attn. Dana Foley - via email
EPA Region 4 with Fact Sheet and RPA - via email
Mr. Kurt Wright, P.E. - via Email: [e-mail]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] l Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity l Affirmative Action Employer
NorthCarolina
Naturally

Permit NC0025721
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended, the
Town of Weldon
is hereby authorized to discharge wastewater from a facility located at the
Town of Weldon Wastewater Treatment Plant
Off of US Highway 301
East of Weldon, North Carolina
Halifax County
to receiving waters designated as the Roanoke River in the Roanoke River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV
hereof.
This permit shall become effective August 1, 2010.
This permit and authorization to discharge shall expire at midnight on March 31, 2012.
Signed this day June 30, 2010.
�oyten H. Sullins, Director
(ittlAvision of Water Quality
' By Authority of the Environmental Management Commission

Permit NC002572f
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
The Town of Weldon is hereby authorized to:
1. Continue to operate a 1.2 MGD wastewater treatment facility consisting of influent bar screening
and pH adjustment with caustic as needed, influent pumps, dual oxidation ditches, two secondary
clarifiers, one aerobic digester for sludge, one aerated sludge holding tank, 30 degree V notch
weir with continuous flow measurement, chlorinator, chlorine contact chamber, sulfur dioxide
dechlorination, cascade aeration, four sludge drying beds, 485,000 gallon positive displacement
air blower sludge tank, 450 KW standby generator, and polymer addition to the clarifiers.
These facilities are located at the Town of Weldon Wastewater Treatment Plant, east of Weldon
off of US Highway 301 in Halifax County.
2. Discharge from said treatment works at the location specified on the attached map into the
Roanoke River, a class C stream in the Roanoke River Basin.

Permit NC0025721
USGS Quad Name: Weldon
Receiving Stream: Roanoke River
Stream Class: C
Subbasin: Roanoke 030208, 2—(26)a
Lat.: 3Q°25'24"
Long.: 77°34'39"

Permit NC0025721
A. (1.) Effluent Limitations and Monitoring Requirements
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee
is authorized to discharge treated wastewater from outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
EFFLUENT
DISCHARGE LIMITATIONS
: MONITORING REQUIREMENTS
CHARACTERISTICS
.
Monthly
Average
Weekly
Average
Daily :
Maximum
Measurement
Frequency
Sample
Type
_
Sample Location
Flow
1.2 MGD
Continuous
Recording
Influent or Effluent
BOD I
15.0 mg/L
22.5 mg/L
3/Week
Composite
Influent and Effluent
Total Suspended Solids 1
30.0 mg/L
45.0 mg/L
3/Week
Composite
Influent and Effluent
NH3 as N
3/Week
Composite
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Total Phosphorus
Monthly
Composite
Effluent
Acute Toxicity 3
Quarterly
Composite
Effluent
Total Copper
Quarterly
Composite
Effluent
Total Zinc
Quarterly
Composite
Effluent
Temperature ° C
Daily
Grab
Effluent
Fecal Coliform
(geometric mean)
200/100 ml
400/100 ml
3/Week
Grab
Effluent
Total Residual
Chlorine
28 ug/ L
3/Week
Grab
Effluent
pH
Between 6.0 and 9.0 S.U.
3/Week
Grab
Effluent
Total Mercury 4
I
1
Quarterly
Grab
Effluent
NOTES:
1. The monthly average effluent BOD5 and total suspended solids concentrations shall not exceed 15% of their respective
influent values (85% removal).
2. TRC monitoring and limit requirements apply only if chlorine or chlorine derivative is used in the treatment process. The
facility shall report all effluent TRC values reported by a NC certified laboratory, including field certified.
However, effluent values below 50 ug/ L will be treated as zero for compliance purposes.
3. Acute Toxicity (Fathead Minnow 24 hr) No Significant Mortality at 90%; January, April, July, October; see Condition
A(2.) of this permit.
4. Sampling for Total Mercury shall be by EPA Low Level Method 1631E using clean sample techniques.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0025721
•
A. (2.) Quarterly Acute Toxicity Limit
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defmed in the North Carolina Procedure
Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised -July,
1992 or subsequent versions). The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static
test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defmed as treatment two in
the procedure document). Effluent samples for self -monitoring purposes must be obtained during representative effluent
discharge below all waste treatment. The tests will be performed during the months of January, April, July, and October.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the month in which it was performed, using the parameter code TGE6C. Additionally, DWQ Form AT-2 (original)
is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the
end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association
with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured
and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee
will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit
number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form.
The report shall be submitted to the Environmental Sciences Section at the address cited above.
Should airy single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin
immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to
quarterly in the months specified above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will
begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to
quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate
monitoring requirements or limits.
If the Perrnittee monitors any pollutant more frequently then required by this permit, the results of such monitoring shall be
included in the calculation & reporting of the data submitted on the DMR & all AT Forms submitted.

Permit NC0025721
A (3.) Effluent Pollutant Scan
The permittee shall perform an annual Effluent Pollutant Scan for all parameters listed in the table below (in accordance with
40 CFR Part 136). Samples shall represent seasonal variations. Unless otherwise indicated, metals shall be analyzed as
"total recoverable."
Ammonia (as N) Trans-1,2-dichloroethylene Bis (2-chloroethyl) ether
Chlorine (total residual, TRC) 1,1-dichloroethylene Bis (2-chloroisopropyl) ether
Dissolved oxygen 1,2-dichloropropane Bis (2-ethylhexyl) phthalate
Nitrate/Nitrite 1,3-dichloropropylene 4-bromophenyl phenyl ether
Total Kjeldahl nitrogen Ethylbenzene Butyl benzyl phthalate
Oil and grease Methyl bromide 2-chloronaphthalene
Total Phosphorus Methyl chloride 4-chlorophenyl phenyl ether
Total dissolved solids Methylene chloride Chrysene
Hardness 1,1,2,2-tetrachloroethane Di-n-butyl phthalate
Antimony Tetrachloroethylene Di-n-octyl phthalate
Arsenic Toluene Dibenzo(a,h)anthracene
Beryllium 1,1,1-trichloroethane 1,2-dichlorobenzene
Cadmium 1,1,2-trichloroethane 1,3-dichlorobenzene
Chromium Trichloroethylene 1,4-dichlorobenzene
Copper Vinyl chloride 3,3-dichlorobenzidine
Lead Acid -extractable compounds: Diethyl phthalate
Mercury P-chloro-m-cresol Dimethyl phthalate
Nickel 2-chlorophenol 2,4-dinitrotoluene
Selenium 2,4-dichlorophenol 2,6-dinitrotoluene
Silver 2,4-dimethylphenol 1,2-diphenylhydrazine
Thallium 4,6-dinitro-o-cresol Fluoranthene
Zinc 2,4-dinitrophenol Fluorene
Cyanide 2-nitrophenol Hexachlorobenzene
Total phenolic compounds 4-nitrophenol Hexachlorobutadiene
Volatile organic compounds: Pentachlorophenol Hexachlorocyclo-pentadiene
Acrolein Phenol Hexachloroethane
•
Acrylonitrile 2,4,6-trichlorophenol Indeno(1,2,3-cd)pyrene
Benzene Base -neutral compounds: Isophorone
Bromoform Acenaphthene Naphthalene
Carbon tetrachloride Acenaphthylene Nitrobenzene
Chlorobenzene Anthracene N-nitrosodi-n-propylamine
Chlorodibromomethane Benzidine N-nitrosodimethylamine
Chloroethane Benzo(a)anthracene N-nitrosodiphenylamine
2-chloroethylvinyl ether Benzo(a)pyrene Phenanthrene
Chloroform 3,4 benzofluoranthene Pyrene
Dichlorobromomethane Benzo(ghi)perylene 1,2,4-trichlorobenzene
1,1 -dichloroethane Benzo(k)fluoranthene
1,2-dichloroethane . Bis (2-chloroethoxy) methane
•
•
Test results shall be reported to the Division in DWQ Form- DMR-PPA1 or in a form approved by the Director, within 90 days
of sampling. A copy of the report shall be submitted to Central Files to the following address: Division of Water Quality,
Water Quality Section, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. A copy of these results shall be
submitted along with the NPDES permit renewal application.

NCDENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
Town of Weldon
Weldon Wastewater Treatment Plant
NPDES Permit Number NC0025721
Facility Information
(1.) Facility Name:
Weldon Wastewater Treatment Plant
(2.) Permitted Flow (MGD):
1.2
(6.) County:
Halifax
(3.) Facility Class:
3
(7.) Regional Office:
Raleigh
(4.) Pretreatment Program:
Yes
(8.) State Topo Quad:
B28NE
(5.) Permit Status:
Renewal
(9.) USGS Quad Name:
Weldon
Stream Characteristics
(1.) Receiving Stream:
Roanoke River
(2.) Sub -basin:
03-02-08
(8.) Drainage Area (mi2):
8,420
(3.) Stream Index Number:
23-(26)a
(9.) Summer 7Q10 (cfs):
1,100
(4.) Stream Classification:
C
(10.) Winter 7Q10 (cfs):
1,100
(5.) 303(d) Status:
Listed - Fish
Consumption
Advisory for Hg
(11.) 30Q2 (cfs):
2,400
(6.) 305(b) Status:
(12.) Average Flow (cfs):
6,000
(7.) Use Support:
Not supporting
(13.) IWC% @ 1.2 MGD:
0.17
1.0 Proposed Changes Incorporated into Permit Renewal
• Metals Monitoring: Due to the presence of copper and zinc in the effluent, quarterly monitoring for these
metals has been retained. Additionally, due to the 303(d) listed nature of the receiving stream, quarterly
mercury monitoring has been retained. Due to mercury impairment of the Roanoke River, EPA requires
Low Level Method 1631e be used for mercury sampling. The sample method has been changed to grab
from composite. No limit has been added until more data is available.
• Permit Expiration Date: The expiration date has been changed to March 31, 2012 in accordance
with the Roanoke River Basin permitting schedule.
2.0 Summary
This is a permit renewal for a major municipal wastewater treatment facility with a current facility design and
permitted flow of 1.2 MGD. The treatment facility serves a population of approximately 11,200 from Weldon
proper, the town of Halifax, and Northampton County, each operating its own collection system. Roughly
83% of the facility's average daily influent flow is domestic with the balance coming from industrial and
commercial users (see section 5.0 of this report).
The facility discharges its treated effluent into the Roanoke River, a class C stream in the Roanoke River
Basin. This portion of the Roanoke River is listed on North Carolina's 2008 303(d) list for a fish consumption
advisory due to the potential presence of mercury in fish tissue. Atmospheric deposition has been identified as
the primary cause of the mercury problem.
Solids handling is permitted via non -discharge permit number WQ0002368. That permit designates 250 acres
over 12 fields for land application of both liquid and dewatered sludges.

NPDES Permit Fact Sheet — April 15, 2010 Town of Weldon
Page 2 NC0025721
3.0 Permit History
A summary of the permit history is bulleted below.
• Permit originally issued on June 29, 1981
• Most recently renewed on June 1, 2003
• Current application for renewal received December 1, 2006
• Due to workload and staffing constraints, the permit has been expired and on the backlog until work
on renewal was begun in April, 2010
• DENR regional office staff report received March 25, 2010
4.0 Treatment Facility
The treatment facility consist of influent bar screening and pH adjustment with caustic as needed, influent
pumps, dual oxidation ditches, two secondary clarifiers, polymer addition, aerobic digestion of sludge,
aerated sludge holding, V notch weir with continuous flow measurement, chlorinator, chlorine contact
chamber, sulfur dioxide dechlorination, cascade aeration, four sludge drying beds and backup power
generation.
5.0 Significant Industrial Users
The Town of Weldon has a DENR approved pretreatment program and currently has one Significant
Industrial User (SIU) and an unspecified number of non -permitted industrial/commercial users contributing
an average daily flow of approximately 0.2 MGD to its collection system. The primary facility is Roanoke
Valley Energy, which generates electrical power from burning coal and fuel oil. It produces approximately
0.1 MGD of wastewater. A previous SIU, Reser's Fine Foods has moved its discharge to Roanoke Rapids
WWTP from Weldon in August of 2009, along with Halifax County Water Reclamation Plant which was
providing pretreatment. This facility was a major cause of pH and BOD excursions for Weldon.
6.0 Compliance/Enforcement Summary
A review of the facility's effluent data was conducted for the period January 1, 2008 through December 31,
2009. The facility generally appears to be operating quite well. The Town's WWTP was determined to be in
chronic non-compliance in 2006. An investigation by the Town indicated that Reser's Fine Foods was
contributing to the violations by causing pass -through and interference by the introduction of excessive
amounts of BOD, TSS, and oil & grease. Reser's Fine Foods employed Halifax County Public Utilities to
pretreat its wastewater prior to discharge to the Town of Weldon WWTP. In August of 2009, Reser and
Halifax County Public Utilities switched their discharge over to Roanoke Rapid's WWTP from Weldon and
Weldon has been operating much better.
Weldon has passed 12 Whole Effluent Toxicity Tests from 2007 through 2009, with one failure in July 2009,
just before Reser's Fine Foods switched over to Roanoke Rapids WWTP.

NPDES Permit Fact Sheet - April 15, 2010 Town of Weldon
Page 3
The table below summarizes effluent data for the subject facility for the period of review.
NC0025721
Parameter
Min.
Max.
Average
BOD5 (mg/L)
<1
54
4.7
TSS (mg/L)
1
44
4.4
NH3-N (mg/L)
0.01
14.7
1.06
Coliform (#/100 ml)
1
12,800
5.1
TRC (❑g/L)
< 50
420
66.8
TN (mg/L)
2.77
44.6
10.2
TP (mg/L)
0.16
8.39
2.05
CN (mg/L)
0.006
0.017
0.01
Se (mg/L)
0.0008
0.016
0.01
Hg (mg/L)
0.000034
0.0007
0.000224
Ni (mg/L)
0.0035
0.01
0.01
Cu (mg/L)
0.002
0.020
0.006
Ag (mg/L)
0
<0.005
<0.004
Zn (mg/L)
0.015
0.203
0.063
Cd (mg/L)
Non Detect
Non Detect
Non Detect
Cr (mg/L)
Non Detect
Non Detect
Non Detect
Pb (mg/L)
Non Detect
Non Detect
Non Detect
The table below summarizes the removal rate for BOD and TSS for the period of review
Parameter:
BOD5
Total Suspended Solids
Influent, mg/ L
154
103
Effluent, mg/ L
5.4
4.5
% Removal Rate
96.5%
95.6%
85% Removal Rate is specified in the permit. The Weldon WWTP is successfully meeting the Removal Rate
Requirement. The average effluent values for BOD5 and TSS are different in the two tables because different
subsets of data were used. For the upper table, all data from 2008 and 2009 was used. For the lower table,
only 21 data points were evaluated.
7.0 Permit Development
• Conventional Parameters:
1. BOD5: has historically been water quality limited based on oxygen -consumption modeling. No
reason exists to modify this permitting strategy.
2. NH3-N: mass -balance calculations indicate that ammonia toxicity is not a concern. The 593:1
dilution ratio yields a very high allowable ammonia concentration. As such, and in accordance with
DWQ permitting strategy, no ammonia limits are proposed.
3. TSS: as is appropriate for a POTW permit, TSS limits are aligned with secondary requirements
outlined in 40 CFR 132.
4. Fecal: fecal coliform is limited at the water quality standard of 200 colonies per 100 ml.
5. TRC: Total Residual Chlorine limits are required for all facilities that discharge water treated with
chlorine or chlorine derivatives, with a maximum value of 28 ug/ L in fresh water as a daily
maximum. A standard footnote has been has been added to the permit stipulating that all lab results
for TRC must be shown on the DMRs, but for compliance purposes, any reading less than 50 ug/ L
is considered to be compliant with the permit limits. The facility already has dechlorination
equipment, so a compliance schedule has not been provided. No request for a compliance schedule
has been made during the review period.

NPDES Permit Fact Sheet - April 15, 2010 Town of Weldon
Page 4 NC0025721
• Reasonable Potential Analysis (RPA': RPAs were conducted for cyanide, arsenic, mercury, nickel,
copper, silver, selenium and zinc. The analyses indicated that reasonable potential does not exist for a
water quality standard violation for these metals. Cadmium, chromium, and lead samples were all
reported as less than detection.
8.0 Proposed Schedule for Permit Issuance
Draft Permit to Public Notice:
Permit Scheduled to Issue:
April, 2010
June, 2010
State Contact
If you have any questions on any of the above information or on the attached permit, please contact Jim
McKay at [phone].
NPDES Recommendation by:
Regional Office Comments:
Regional Recommendation by:
Reviewed and accepted by:
Regional Supervisor:
NPDES Unit Supervisor:
ArY71 jyt'
4-117
Signature
6 - 2v/o
Date
Signature Date
Signature Date
Signature Date

Weldon WWTP
NC002e721
REASONABLE POTENTIAL ANALYSIS
Outfall 1
Qw=1.2MGD
Ow (MGD)
1Q10S (cfs)
7Q10S (cfs)
7Q10W (cfs)
30Q2 (cfs)
Avg. Stream Flow, QA (cfs)
Rec'ving Stream
1.20
882.94
1100.00
1100.00
2400.00
6000.00
Roanoke River
WWTP Class ill
!WC (%) @ 1Q10S 0.21
(4) 7Q10S 0.17
@ 7Q10W 0.17
@ 30Q2 0.08
@ QA 0.03
Stream Class C
PARAMETER
TYPE
(1i
STANDARDS & CRITERIA (2)
PQL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
NC MS Chronic
X FAV /Acute
n
1 Dot 'lax Pred Cw Mantis Cw
Cyanide
NC
5.00
FW
22
10
ug/L
21
7
70.3
Acute: 10,465
- _ __-_ _ _
Chronic: 2,962
No Acute Limit
_ _ __-_-_-_-_-_---_---.
No Chronic Limit
Mercury
NC
12.00
FW
2
ng/l.
21
6
2464.0
Acute: N/A
_ _
- _ - 7,
Chronic: 7,109
_ _ _ __-_---_-----_-_-_-
No Chronic Limit
Selenium
NC
5.00
FW
56
ug/L
21
4
79.5
Acute: 26,639
- _ __-- _ _
Chronic: 2,962
No Acute Unit
_ _ _ __-_-_---------_---•
No Chronic Limit
Arsenic
C
50.00
FW
ug/L
21
8
15.2
Acute: N/A
- _ _--• _ _
Chronic: 29,620
_ _ _ __-------•---------
No Chronic Limit
Arsenic
C
10.00
HH
ug/L
21
6
15.2
Acute: N/A
_ _ __-_ _ _,
Chronic 32,268
------------_-_---_-_-----,
Copper(AL)
NC
7.00
FW
7.3
ug/L
27
27
48.4
Acute: 3,473
- _ _.-- _ _
Chronic: 4,147
No Acute Unit
_ _ _ __-•-----_- -_-.
No Chronic Limit
Nickel
NC
88.00
FW
261
ug/L
21
4
20.9
Acute: 124,157
- _--•_ _
Chronic: 52,131
No Acute Limit
_ __-_-_-_-•---_-_-_-
No Chronic Limit
Nickel
NC
25.00
WS
261
ug/L
21
4
20.9
Acute: 124,157
-_ _ _--_ _ _
Chronic: 14,810
No Acute Limit
_-_---------_-_-_-'
No Chronic Limit
Silver (AL)
NC
0.06
FW
1.23
ug/L
22
1
4.1
Acute: 585
__ _ __--____-
Chronic: 38
No Acute Limit
_ _ _ __-_-•-_-_-_-_-_-__
No Chronic Limit
Zinc (AL)
NC
50.00
FW
67
ug/i.
28
28
442.5
Acute: 31,872
- _ _--_ _ _
Chronic: 29,620
No Acute Limit
_ _ _ _-_-_---_-_-_-_-_-.
No Chronic Limit -
Copy of Weldon RPA NC0025721, rpa
6/29/2010

Table 1. Project Information
Facility Name
WWTP Grade
NPDES Permit
Outfall
Flow, Qw (MGD)
Receiving Stream
Stream Class
7Q10s (cfs)
7Q10w (cfs)
30Q2 (cfs)
QA (cfs)
1Q10s (cfs)
Data Source(s)
Weldon WWTP
III
NC0025721
1
1.2
Roanoke River
C
1100.0
1100.0
2400.0
6000.0
882.94
January 2008 - December 2009
Table 2. Parameters of Concern
Par01
Par02
Par03
Par04
Par05
Par06
Par07
Par08
Par09
Par10
Par11
Par12
Par13
Par14
Par15
Par16
Par17
Par18
Par19
Name
Type Chronic Modifier Acute PQL Units
Cyanide ,
Fluoride i
Mercury
Molybdenum
Phenols
Selenium ;
a
i
Arsenic
NC ;
5
1800
12
51000
1
-r
; 5
50
FW ;
FW
FW
FW
N
1 FW
FW
22
; 56
; 10 ;
2
; i
.,..
1
ug/L 0
ug/L
+ ng/L
+
Arsenic
C
10
HH
ug/L
Beryllium
NC
6.5
FW
ug/L
Cadmium
NC
2
FW
15
ug/L
Cadmium, Tr
NC
0.4
FW
2.1
ug/L
Chromium
NC
50
FW
1022
ug/L
Copper (AL)
NC
7
FW
7.3
ug/L
Lead
NC
25
FW
33.8
ug/L
Nickel
NC
88
FW
261
ug/L
Nickel
NC
25
WS
261
ug/L
Silver (AL)
NC
0.06
FW
1.23
ug/L
Zinc (AL)
NC
50
FW
67
ug/L
Copy of Weldon RPA NC0025721, input
6/29/2010

REASONABLE POTENTIAL ANALYSIS
Cyanide
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
< 5.0 5.0 Std Dev. 6.4335
< 5.0 5.0 Mean 8.0952
< 5.0 5.0 C.V. 0.7947
< 5.0 5.0 n 21
< 5.0 5.0
7.0 5.0 MultFactor= 2.8100
< 50.0 25.0 Max. Value 25.0 ug/L
< 50.0 25.0 Max. Pred Cw 70.3 ug/L
12.0 12.0
< 5.0 5.0
6.0 5.0
< 5.0 5.0
< 5.0 5.0
11.0 11.0
8.0 5.0
17.0 17.0
< 5.0 5.0
< 5.0 5.0
< 5.0 5.0
< 5.0 5.0
5.0 5.0
-1-
Copy of Weldon RPA NC0025721, data
6/29/2010

REASONABLE POTENTIAL ANALYSIS
Mercury
Selenium
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
< 200 100.0 Std Dev. 140.1575
700 700.0 Mean 135.3333
< 200 100.0 C.V. 1.0356
< 200 100.0 n 21
34 34.0
38 38.0 Mult Factor = 3.5200
< 200 100.0 Max. Value 700.0 ng/L
70 70.0 Max. Pred Cw 2464.0 ng/L
< 200 100.00
< 200 100.00
< 200 100.00
< 200 100.00
200 200.00
< 200 100.00
< 200 100.00
< 200 100.00
< 200 100.00
< 200 100.00
< 200 100.00
< 200 100.00
300.0 300.00
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
Date Data BDL=1/2DL Results
< 3 1.5 Std Dev. 3.3785
< 3 1.5 Mean 2.2429
< 3 1.5 C.V. 1.5064
< 3 1.5 n 21
< 6 3.0
< 6 3.0 Mult Factor = 4.9700
< 6 3.0 Max. Value 16.0
< 0.6 0.3 Max. Pred Cw 79.5
< 0.6 0.300
< 0.6 0.300
< 0.6 0.300
< 1 0.300
3 2.800
2 2.0
1 0.8
< 2 1.0
< 10 5.0
16 16.0
< 2 1.0
< 2 1.0
< 2 1.0
-2-
Copy of Weldon RPA NC0025721, data
6/29/2010

REASONABLE POTENTIAL ANALYSIS
Arsenic
Arsenic
Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results
1 < 3 1.5 Std Dev. 1.4122 1 < 3 1.5 Std Dev.
2 < 3 1.5 Mean 1.6114 2 < 3 1.5 Mean
3 < 3 1.5 C.V. 0.8764 3 < 3 1.5 C.V.
4 4 4.0 n 21 4 4 4.0 n
5 0.7 0.7 5 0.7 0.7
6 1.9 1.9 Mult Factor = 3.0400 6 1.9 1.9 Mult Factor =
ugfL 7 < 0.6 0.3 Max. Value 5.0 ug/L 7 < 0.6 0.3 Max. Value
ug/L 8 2 2.0 Max. Pred Cw 15.2 ug/L 8 2 2.0 Max. Pred Cw
9 1 1.3 9 1.3 1.3
10 < 1 0.3 10 < 0.6 0.3
11 2 2.4 11 2.4 2.4
12 1 1.1 12 1.1 1.1
13 1 0.7 13 0.7 0.7
14 < 1 0.3 14 < 0.6 0.3
15 < 1 0.3 15 < 0.6 0.3
16 < 2 1.0 16 < 2.0 1.0
17 < 10 5.0 17 < 10.0 5.0
18 < 2 1.0 18 < 2.0 1.0
19 < 2 1.0 19 < 2.0 1.0
20 < 2 1.0 20 < 2.0 1.0
21 < 10 5.0 21 < 10.0 5.0
22 22
23 23
24 24
25 25
26 26
27 27
28 28
29 29
30 30
31 31
32 32
33 33
34 34
35 35
36 36
37 37
38 38
39 39
40 40
41 41
42 42
43 43
44 44
45 45
46 46
47 47
48 48
49 49
50 50
51 51
52 52
53 53
54 54
55 55
56 56
57 57
58 58
59 59
60 60
199 199
200 200
-3-
Copy of Weldon RPA NC0025721, data
6/29/2010

REASONABLE POTENTIAL ANALYSIS
Copper (AL)
1.4122
1.6114
0.8764
21
3.04
5.0 ug/L
15.2 ug/L
Date Data BDL=112DL Results
1 4 4.0 Std Dev. 4.3999
2 4 4.0 Mean 5.8519
3 3 3.0 C.V. 0.7519
4 20 20.0 n 27
5 4 4.0
6 3 3.0 Mult Factor = 2.4200
7 9 9.0 Max. Value 20.0 ug/L
8 2 2.0 Max. Pred Cw 48.4 ug/L
9 2 2.0
10 8 8.0
11 6 6.0
12 8 8.0
13 10 10.0
14 6 6.0
15 14 14.0
16 13 13.0
17 2 2.4
18 4 4.0
19 3 3.0
20 2 2.0
21 3 3.0
22 5 5.0
23 2 2.0
24 3 3.0
25 3 3.0
26 10 9.6
27 5 5.0
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
199
200
-4-
Copy of Weldon RPA NC0025721, data
6/29/2010

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
June 1, 2010
Mr. Kurt Wright, P.E.
Kurt D. Wright & Associates, Inc.
163 Heritage Lane
Bostic, NC 28018
Subject: Comments Response,
Draft of NPDES Permit
Renewal NC0025721
Weldon WWTP
Halifax County
Dear Mr. Wright:
Today the Division of Water Quality received both an email with attachments, and a hard copy of comments and
concerns regarding the Town of Weldon draft NPDES permit renewal. There are four areas of concern that have
comments: (1) Mercury Monitoring by EPA Method 1631E with Clean Sampling Requirements, (2) and (3) refer to
standard boilerplate wording, and (4) concerns corrections to an equipment list contained in the permit draft.
(1) Mercury. The Town of Weldon discharges treated wastewater to the Roanoke River, which is impaired for mercury
due to a fish consumption advisory that applies to the entire river. Currently Weldon monitors for mercury quarterly,
using an old analytical method (245.1 or 245.2) that is not very sensitive, able to detect to about 200 ng/ L. In order to get
meaningful data on mercury, EPA is requiring that the town use low level method 1631E with clean sampling, which can
detect mercury to about 0.5 ng/ L. The town is concerned about the cost of this analytical method, the possibility of
contamination causing false positive readings, and that contaminated samples might lead to mercury limits being
imposed.
Mercury is a very real problem in North Carolina. Essentially every waterbody in the state is impaired for mercury due to
fish consumption advisories. Most of the mercury contamination is believed to come from airborne deposition, but some
does come from point sources. EPA is requiring much more stringent monitoring for mercury, including requiring the
use of more sensitive tests. Weldon will have to test using method 1631E for mercury. It is part of the cost of business
for discharging treated wastewater containing mercury into a river that is impaired for mercury. The town must find a lab
with highly trained, skilled employees to take samples and run the tests. If the data show a reasonable potential to exceed
the State's water quality standard for mercury, then by law, limits will be imposed. If reasonable potential does not exist,
then no limits will be required.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.rtcwaterquality.org
An Equal Opportunity t Affirmative Action Employer
ho�rthCarolina
atura!!t�

(2) Proposed Language - Optimum Efficiency. The town objects to wording requiring that the wastewater treatment
plant be operated at "optimum efficiency". They believe that this wording is arbitrary, capricious and inconsistent with
law.
The wording the town objects to is part of what is called Boilerplate. This is a document added into permits by the
Division. It is reviewed and revised periodically in accordance with Federal EPA requirements. The document is
extensively reviewed by Division personnel, then reviewed by the Attorney General of North Carolina's office, and
finally reviewed and approved by EPA Region 4. It is therefore not arbitrary, capricious and inconsistent with law. The
Boilerplate is incorporated into every permit that the Division of Water Quality issues across the State and cannot be
changed or modified for an individual permit.
(3) Proposed Language - Part IV. The town objects that Part IV has been expanded by 5 pages, and that it incorporates
industrial pretreatment requirements into the NPDES permit, which may cause confusion and would be arbitrary,
capricious and inconsistent with law.
This is also part of the Boilerplate. Please refer to the paragraph above.
(4) Description of the Wastewater Treatment Plant. The town is concerned that the equipment listed in the
Supplement to Cover Page is not correct.
The town's consultant, Mr. Kurt Wright has already provided this information, and the equipment listing has been
corrected.
I want to thank the Town of Weldon for the very comprehensive review of the draft permit. The permit should be
finalized and issued on June 17, 2010, effective August 1, 2010.
Sincerely,
,2
Jim McKay
NPDES Permitting Program
cc: Raleigh Regional Office/Surface Water Protection Section - via email
NPDES File
Mr. Donald Crowder/ Director of Public Utilities/ Town of Weldon - via email
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service:1-877-23.6748
Internet www,ncwatenauality,org
An Equal Opportunity 1 Affirmative Action Employer
NonrthCarolina
Naturally

WRIGHT
May 28, 2010 Kurt D. Wright & Associates, Inc.
WATER / WASTEWATER ENGINEERING SERVICES
Mr. Jim McKay
Environmental Engineer
Point Source Branch
Surface Water Protection Section
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: COMMENTS TO DRAFT PERMIT
Weldon WWTP — NC0025721
Town of Weldon, NC
Halifax County, North Carolina
Dear Mr. McKay:
Attached are comments to the draft NPDES Permit for the town of Weldon which they received from the
Division on April 30, 2010.
If you should have any questions pertaining to the comments please do not hesitate to contact me.
Very truly yours,
Kurt Wright, PE, BCEE
President
Attachment
DENR-WA R QUALrY
r )!Nq S()IJRCE BRANCH
cc: Donald Crowder, DPU, Town of Weldon (w/ Attachment)
E. Leo Green, Jr., PE (w/ Attachment)
Solutions for a sustainable environment
163 Heritage Lane Bostic, NC 28018 Phone: [phone] Fax: [phone] Mobile: [phone] www.kdwa.us

Comments
regarding
Draft NPDES Permit Number NC0025721
Weldon Wastewater Treatment Plant
Town of Weldon
Halifax County, North Carolina
May 28, 2010
Prepared by:
Kurt D. Wright & Associates, Inc.
163 Heritage Lane
Bostic, NC 28018
in conjunction with
Green Engineering, PLLC
303 North Goldsboro Street
Wilson, North Carolina 27893
On behalf of:
The Town of Weldon, NC

Comments
regarding
Draft NPDES Permit Number NC0025721
Weldon Wastewater Treatment Plant
Town of Weldon
Halifax County, North Carolina
May 28, 2010
I. Draft Permit
The draft NPDES Permit for the town of Weldon, NC00252721, was received by the town on April 30,
2010. The town wishes to comment on four items in connection with the draft permit:
1. Mercury (Hg)
2. Proposed Language — Optimum Efficiency
3. Proposed Language — Part IV
4. Description of the Wastewater Treatment Plant
H. Mercury (Hg)
A. Proposed Changes
The draft NPDES permit modifies the current method of sampling and analysis for mercury, refer to
Table 1 below.
Table 1: Comparison of Mercury monitoring requirements
Permit
Status
Measurement
Frequency
Sample
Type
EPA
Approved
Test Method
Sampling Method
Current
quarterly
24-hr composite
245.1
No special Sampling method required
Draft
quarterly
grab
1631
Sample method 1669 ("clean hands -dirty
hands")
The town of Weldon has concerns regarding the proposed changes. It is understood that the North
Carolina Department of Environment and Natural Resources (NCDENR) will utilize the data obtained
from the monitoring program in the future to perform a Reasonable Potential Analysis (RPA). If some of
the data contain false positives due to contamination it could lead to erroneous effluent limits for
2

mercury in subsequent NPDES permits for the town of Weldon. This could have far reaching adverse
consequences to the town of Weldon and result in a significant financial burden.
B. Possibility of Contamination During Sampling
Sample Method 1669 provides for "clean hands -dirty hands" sampling techniques. However, even when
sampling using method 1669 the potential exists for possible contamination of the sample resulting in a
false positive reading for mercury. Note the following quotes extracted from Method 1669 Sampling
Ambient Water for Trace Metals at EPA Water Quality Criteria Levels, July 1996, US EPA.
1. "The ease of contaminating ambient water samples with the metal(s) of interest and interfering
substances cannot be overemphasized."
2. "Preventing ambient water samples from becoming contaminated during the sampling... process
is the greatest challenge faced in trace metals determinations."
3. "...it is imperative that extreme care be taken to avoid contamination when collecting...ambient
water samples for trace metals."
4. "There are numerous routes by which samples may become contaminated. Potential sources of
trace metals contamination during sampling include metallic or metal -containing sampling
equipment, containers, labware..., reagents, and deionized water; improperly cleaned and
stored equipment, labware and reagents; and atmospheric inputs such as dirt and dust from
automobile exhaust, cigarette smoke, nearby roads, bridges, wire, and poles."
These are statements extracted directly from the sampling method published by EPA. Due to the ease
of sample contamination it is a concern of the town of Weldon that some of the samples analyzed for
mercury under the proposed monitoring program may come back with false positives. That is, positive
values reported as mercury in the WWTP effluent that is in reality mercury from another source that
contaminated the sample.
C. Possibility of Contamination in the Laboratory
The same concerns stated above apply to the procedure performed in the laboratory, TM 1631. The
possibility of contamination within the laboratory itself is high. Note the following quotes extracted
from Method 1631, Revision E: Mercury in Water by Oxidation, Purge and Trap, and Cold Vapor Atomic
Fluorescence Spectrometry, August 2002, US EPA
1. " The ease of contaminating ambient water samples with mercury and interfering substances
cannot be overemphasized."
2. "Preventing samples from becoming contaminated during the...analysis process constitutes one
of the greatest difficulties encountered in trace metals determinations."
3. "...it is imperative that extreme care be taken to avoid contamination when collecting and
analyzing samples for trace metals."
4. "Samples may become contaminated by numerous routes. Potential sources of trace metals
contamination...include: metallic or metal -containing labware...containers...reagents and
3

reagent water; improperly cleaned or stored equipment, labware, and reagents; and
atmospheric inputs such as dirt and dust."
5. "Even human contact can be a source of trace metals contamination. For example, it has been
demonstrated that dental work (e.g., mercury amalgam fillings) in the mouths of laboratory
personnel can contaminate samples that are directly exposed to exhalation."
Again, these are statements extracted directly from the test method published by EPA. The town of
Weldon can exercise extreme care in performing clean sampling techniques but once the sample is
released the ability to control sources of possible contamination is out of their control. They are relying
entirely on the courier and the laboratory not to contaminate the sample. The ease of contamination
does not stop with sampling, it continues on throughout the entire procedure until the analysis is
complete.
D. Past Data
The town of Weldon has been monitoring for mercury since 2002 both through the NPDES permit and
the pretreatment program. The results of this data are presented in Exhibit A.
It should be pointed out that the following results extracted from Exhibit A (Table 2) were erroneously
reported by the laboratory. The values the laboratory reported are "J" values and are, therefore, not
valid. Also, they are reporting results in the low parts per trillion for samples which were not taken
based on the clean hands -dirty hands method.
Table 2: Erroneously Reported Data
Date
Sample Type
Test
Method
mg/L
ug/L
ng/L
5/22/2008
Pretreatment
245.2
0.000034
0.034
34
6/26/2008
Pretreatment
245.1
0.000038
0.038
38
8/13/2008
Pretreatment
245.1
0.00007
0.07
70
10/8/2008
DMR
245.1
0.000033
0.033
33
The correct reporting values should have been as follows:
Table 3: Corrected Data
Date
Sample Type
Test
Method
mg/L
5/22/2008
Pretreatment
245.2
<0.0002
6/26/2008
Pretreatment
245.1
<0.0002
8/13/2008
Pretreatment
245.1
<0.0002
10/8/2008
DMR
245.1
<0.0002
4

Of the 124 data points shown in Exhibit A there were only 4 samples that were reported with values
higher than the reporting limit of 0.0002 mg/L. This constitutes 3.2% of the samples taken and could
easily represent contaminated samples. In other words based on the statistical probability of sample
contamination all four samples could be the result of contamination.
Table 4: Samples with Reported Values above 0.0002 mg/L
Date
Sample Type
Test
Method
mg/L
ug/L
ng/L
7/15/2003
DMR
245.2
0.0003
0.3
300
8/11/2005
Pretreatment
245.1
0.0003
0.3
300
2/7/2008
Pretreatment
245.1
0.0007
0.7
700
10/28/2009
DMR
245.1
0.0003
0.3
300
It is the position of the town of Weldon that the monitoring data shows there is no cause for concern for
mercury in the town's effluent so far as the reporting limit of TM 245.1 is concerned.
E. Cost of TM 1631
The current cost of NPDES monitoring for mercury utilizing TM 245.1 is $35/ sample and does not
require clean hands -dirty hands sampling. The annual cost for monitoring is, 4 samples X $35/sample =
$140.00/year. The cost for monitoring utilizing TM 1631 is approximately $200 / sample. This cost does
not include the cost for collecting the sample utilizing the clean hands -dirty hands method. The
minimum annual cost for monitoring would be 4 samples X $200/sample = $800.00/year. This is well
over 5 times the cost for current mercury compliance monitoring. Over the five year life of the permit
the additional cost will be at least $3,300.00. At a time when the town of Weldon is struggling to
maintain its water and sewer system on reduced revenues, even this amount would be a hardship.
F. Summary
In summary the town of Weldon does not believe mercury is a concern in its effluent based on past
data. The town has significant concerns in switching to monitoring utilizing TM 1631 due to the ease of
contamination of the sample during collection or in the laboratory (or both) and the resulting potential
for false positives. These false positives could later be used in a RPA by NCDENR to set an effluent for
mercury.
NCDENR has not shown any rationale for utilizing TM 1631 for monitoring, and as noted above the
method can pose significant harm to the town of Weldon. Therefore, the town believes that including
the standard in the final permit would be arbitrary, capricious and inconsistent with law.
5

III. Proposed Language - Optimum Efficiency
A. The Existing Language in Section C. 2. Proper Operation and Maintenance
"The permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control (and related appurtenances) which are installed or used by the permittee to achieve
compliance with the conditions of this permit."
B. The Proposed Language in Section C.2.
"The Permittee shall at all times provide the operation and maintenance resources necessary to operate
the existing facilities at optimum efficiency. The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control (and related appurtenances) which are
installed or used by the Permittee to achieve compliance with the conditions of this permit."
C. Objection
NCDENR has added in the draft permit the requirement of the town of Weldon to operate the existing
facilities at "optimum efficiency." Who determines "optimum efficiency" of the Weldon WWTP? This is
a subjective requirement. The town of Weldon is not aware of any statutory requirement that its plant
operate at "optimum efficiency." Moreover, it does not believe that this subjective standard can be
applied in a way that is fair, equitable, and transparent. Therefore, the town believes that including the
standard in the final permit would be arbitrary, capricious and inconsistent with law.
IV. Proposed Language - Part IV
It is noted that Part IV has been replaced with a totally new section in the draft NPDES permit.
A. Existing Part IV Language in the Current Permit
The wording in the current permit is as follows:
"A. The permittee must pay the annual administering and compliance monitoring fee within 30
(thirty) days after being billed by the Division. Failure to pay the fee is a timely manner in
accordance with 15A NCAC 2H .0105(b)(4) may cause this Division to initiate action to revoke the
permit."
B. New Part IV Language in the Draft Permit
The new section proposed in the Draft Permit constitutes five new pages. Five full pages of
additional text to the NPDES permit is a considerable addition of new requirements. The context of
these pages appears to be industrial pretreatment. It appears that the industrial pretreatment
requirements that are already imposed upon the town of Weldon through regulation, are being
added to the NPDES permit.
6

C. Objection
The town of Weldon objects to the addition of its industrial pretreatment requirements to the
NPDES permit. The addition of industrial pretreatment requirements is stretching the purpose of
the NPDES permit to far reaching areas of the management and operation of the wastewater
treatment system. The town of Weldon does not object to performing its industrial pretreatment
requirements and understands the need for them. However, the town objects to NCDENR adding
them under the purview of the NPDES permit.
NCDENR has not shown any rationale for incorporating the town of Weldon's industrial
pretreatment requirements into its NPDES permit. It runs the risk of confusing or inconsistent
application of the pretreatment requirements, among other things. Therefore, the town believes
that including the standard in the final permit would be arbitrary, capricious and inconsistent with
law.
V. Description of the Wastewater Treatment Plant
The description of the wastewater treatment plant should be corrected. This was already pointed out in
an earlier email to Jim McKay; however it is added to these comments for the Division's convenience.
Here's the part of the text that applies:
"...two secondary clarifiers, two aerobic digesters for sludge, aerated sludge holding, 30 degree V notch
weir with..."
It should be revised to:
"...two secondary clarifiers, twe one aerobic digesters digester for sludge, one aerated sludge holding
basin, 30 degree V notch weir with..." (Note the "aerated sludge holding basin" refers to the older below
ground basin and not the newer aerated tank constructed in 2005. That is referred to later in the
description.)
7

Exhibit A
Weldon Wastewater Treatment Plant Effluent NPDES Permit # NC0025721
For Years 2002 through 2010
Town of Weldon, NC
No.
Date
mg/I
Sample Type
Year
Comments
1
1/31/2002
< 0.0002
Pretreatment
2002
Note: < 0.0002 mg/L is also <0.200 ug/L or < 200 ng/L and so throughout this
table.
2
2/21/2002
< 0.0002
Pretreatment
All samples in 2002 were below the reporting value of 200 ng/L.
3
3/28/2002
< 0.0002
Pretreatment
4
4/23/2002
< 0.0002
Pretreatment
5
5/22/2002
< 0.0002
Pretreatment
6
6/27/2002
< 0.0002
Pretreatment
7
7/25/2002
< 0.0002
Pretreatment
8
8/29/2002
< 0.0002
Pretreatment
9
9/27/2002
< 0.0002
Pretreatment
10
10/29/2002
< 0.0002
Pretreatment
11
11/26/2002
< 0.0002
Pretreatment
12
12/12/2002
< 0.0002
Pretreatment
13
1/31/2003
< 0.0002
Pretreatment
2003
14
2/28/2003
< 0.0002
Pretreatment
15
3/27/2003
< 0.0002
Pretreatment
16
4/17/2003
< 0.0002
Pretreatment
17
5/29/2003
< 0.0002
Pretreatment
18
6/19/2003
< 0.0002
Pretreatment
19
7/15/2003
0.0003
DMR
1st sample over the reporting value of 200 nq/L. (300 nq/L)
20
7/29/2003
< 0.0002
Pretreatment
21
8/21/2003
< 0.0002
Pretreatment
22
9/25/2003
< 0.0002
Pretreatment
23
10/7/2003
< 0.0002
DMR
24
10/30/2003
< 0.0002
Pretreatment
25
11/20/2003
< 0.0002
Pretreatment
26
12/11/2003
< 0.0002
Pretreatment
27
1/16/2004
< 0.0002
DMR
2004
All samples in 2004 were below the reporting value of 200 ng/L.
28
1/15/2004
< 0.0002
Pretreatment
29
2/12/2004
< 0.0002
Pretreatment
30
3/11/2004
< 0.0002
Pretreatment
31
4/13/2004
< 0.0002
DMR
32
4/28/2004
< 0.0002
Pretreatment
33
5/20/2004
< 0.0002
Pretreatment
34
6/17/2004
< 0.0002
Pretreatment
35
7/13/2004
< 0.0002
DMR
36
7/22/2004
< 0.0002
Pretreatment
37
8/26/2004
< 0.0002
Pretreatment
38
9/23/2004
< 0.0002
Pretreatment
39
10/12/2004
< 0.0002
DMR
40
10/23/2004
< 0.0002
Pretreatment
41
11/19/2004
< 0.0002
Pretreatment
42
12/16/2004
< 0.0002
Pretreatment
8

Exhibit A (continued)
No.
Date
mg/I
Sample Type
Year
Comments
43
1/11/2005
< 0.0002
DMR
2005
44
1/27/2005
< 0.0002
Pretreatment
45
2/17/2005
< 0.0002
Pretreatment
46
3/17/2005
< 0.0002
Pretreatment
47
3/12/2005
< 0.0002
DMR
48
3/21/2005
< 0.0002
Pretreatment
49
4/13/2005
< 0.0002
DMR
50
4/21/2005
< 0.0002
Pretreatment
51
5/12/2005
0.0003
Pretreatment
52
6/16/2005
< 0.0002
Pretreatment
53
7/5/2005
< 0.0002
DMR
54
7/14/2005
< 0.0002
Pretreatment
55
8/11/2005
0.0003
Pretreatment
2nd sample over the reporting value of 200 ng/L. (300 ng/L)
56
9/22/2005
< 0.0002
Pretreatment
57
10/5/2005
< 0.0002
DMR
58
10/20/2005
< 0.0002
Pretreatment
59
11/17/2005
< 0.0002
Pretreatment
60
12/15/2005
< 0.0002
Pretreatment
61
1/13/2006
< 0.0002
DMR
2006
All samples in 2006 were below the reporting value of 200 nglL.
62
1/19/2006
< 0.0002
Pretreatment
63
2/23/2006
< 0.0002
Pretreatment
64
3/31/2006
< 0.0002
Pretreatment
65
4/11/2006
< 0.0002
DMR
66
4/20/2006
< 0.0002
Pretreatment
67
5/4/2006
< 0.0002
Pretreatment
68
6/22/2006
< 0.0002
Pretreatment
69
7/11/2006
< 0.0002
DMR
70
7/20/2006
< 0.0002
Pretreatment
71
8/17/2006
< 0.0002
Pretreatment
72
9/28/2006
< 0.0002
Pretreatment
73
10/10/2006
< 0.0002
DMR
74
10/19/2006
< 0.0002
Pretreatment
75
11/30/2006
< 0.0002
Pretreatment
76
12/28/2006
< 0.0002
Pretreatment
77
1/25/2007
< 0.0002
DMR
2007
All samples in 2007 were below the reporting value of 200 ng/L.
78
1/25/2007
< 0.0002
Pretreatment
79
2/8/2007
< 0.0002
Pretreatment
80
3/15/2007
< 0.0002
Pretreatment
81
4/10/2007
< 0.0002
DMR
82
4/5/2007
< 0.0002
Pretreatment
83
5/3/2007
< 0.0002
Pretreatment
84
6/7/2007
< 0.0002
Pretreatment
85
7/17/2007
< 0.0002
DMR
86
7/12/2007
< 0.0002
Pretreatment
87
8/16/2007
< 0.0002
Pretreatment
88
9/13/2007
< 0.0002
Pretreatment
89
10/4/2007
< 0.0002
DMR
90
10/11/2007
< 0.0002
Pretreatment
91
11/15/2007
< 0.0002
Pretreatment
92
12/13/2007
< 0.0002
Pretreatment
9

Exhibit A (continued)
No.
Date
mg/I
Sample Type
Year
Comments
93
1/9/2008
< 0.0002
DMR
2008
94
1/17/2008
< 0.0002
Pretreatment
95
2/7/2008
0.0007
Pretreatment
3rd sample over the reporting value of 200 ng/L. (700 ng/L)
96
3/20/2008
< 0.0002
Pretreatment
97
4/2/2008
< 0.0002
DMR
98
4/10/2008
< 0.0002
Pretreatment
99
5/22/2008
0.000034
Pretreatment
he value reported for this sample should have been < 0.0002 mg/L
he value reported for this sample should have been < 0.0002 mg/L
100
101
6/26/2008
7/9/2008
0.000038
< 0.0002
Pretreatment
DMR
102
7/23/2008
< 0.0002
Pretreatment
103
8/13/2008
0.00007
Pretreatment
he value reported for this sample should have been < 0.0002 mg/L
104
9/17/2008
< 0.0002
Pretreatment
105
10/8/2008
0.000033
DMR
The value reported for this sample should have been < 0.0002 mg/L
106
10/15/2008
< 0.0002
Pretreatment
107
11/19/2008
< 0.0002
Pretreatment
108
12/17/2008
< 0.0002
Pretreatment
109
1/7/2009
< 0.0002
DMR
2009
110
1/14/2009
0.0002
Pretreatment
111
2/25/2009
< 0.0002
Pretreatment
112
3/11/2009
< 0.0002
Pretreatment
113
4/15/2009
< 0.0002
DMR
114
4/15/2009
< 0.0002
Pretreatment
115
5/13/2009
< 0.0002
Pretreatment
116
6/10/2009
< 0.0002
Pretreatment
117
7/29/2009
< 0.0002
DMR
118
7/15/2009
< 0.0002
Pretreatment
119
8/27/2009
< 0.0002
Pretreatment
120
9/30/2009
< 0.0002
Pretreatment
121
10/28/2009
0.0003
DMR
4th sample over the reporting value of 200 ng/L. (300 ng/L)
122
1/7/2010
< 0.0002
DMR
2010
123
4/14/2010
< 0.0002
DMR
124
4/15/2010
< 0.0002
Pretreatment
NOTES
1. Total no. of samples = 124
2. Four of the 124 samples were above the reporting value. Three were 300 ng/L and one sample was 700 ng/L.
3. Only 3.2% of the 124 samples reported values above the reporting value.
4. These samples were taken from a composite sampler, the same sampler used repeatedly for all other DMR samples.
10

Mckay, James
From: [e-mail]
Sent: Thursday, May 20, 2010 3:16 PM
To: Mckay, James
Subject: RE: comment on NC0025721, Weldon WWTP
EPA has no comments on this draft permit.
1

Mckay, James
From: Mckay, James
Sent: Thursday, May 20, 2010 12:59 PM
To: '[e-mail]'
Subject: RE: comment on NC0025721, Weldon WWTP
Marshall:
I have added a footnote for mercury testing, requiring clean technique Method 1361E. Would it
be acceptable to add to the footnote that if one year of data (4 quarterly samples) shows no
potential to exceed the State's WQ standard of 12 ug/ L with no dilution credit, that they
could revert back to the older standard mercury test?
Thanks for your help.
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6495 (fax)
**Please note, my email address has changed to James.McKayOncdenr.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.
Original Message
From: [e-mail][mailto:[e-mail]]
Sent: Thursday, May 13, 2010 11:05 AM
To: Mckay, James
Subject: comment on NC0025721, Weldon WWTP
The facility discharges to the Roanoke River, which is on the Clean
Water Act Section 303(d) list for mercury due to a statewide fish
advisory. EPA recommends that mercury monitoring be conducted using
Method 1631E via grab sample because there is no assimilative capacity
for mercury in the receiving water. Ensuing data using mercury clean
techniques will determine if this facility is causing or contributing to
this impairment.
1

Mckay, James
From: [e-mail]
Sent: Thursday, May 13, 2010 11:05 AM
To: Mckay, James
Subject: comment on NC0025721, Weldon WWTP
The facility discharges to the Roanoke River, which is on the Clean Water Act Section 303(d)
list for mercury due to a statewide fish
advisory. EPA recommends that mercury monitoring be conducted using
Method 1631E via grab sample because there is no assimilative capacity for mercury in the
receiving water. Ensuing data using mercury clean techniques will determine if this facility
is causing or contributing to this impairment.
1

AFFIDAVIT OF PUBLICATION CATHY C. PRUITT being first duty sworn, deposes
and says: That (he) (she) is the Agent to the Publisher of THE
STATE OF NORTH CROLINA) DAILY HERALD newspapers printed and published five days a
:SS.
COUNTY OF HALIFAX ) week in the County of Halifax, State of North Carolina, and of
general circulation in the cities of Roanoke Rapids, County of
Halifax, State of North Carolina and elsewhere, and thehereto
Public Notice
North Carolina
Environmental
Management
Commission/
NPDES Unit
1617 Mail Service
Center
Raleigh, NC 27699-
1617
Notice of Intent to
Issue a NPDES
Wastewater Permit
The North Carolina
Environmental
Management
Commission propos-
es to issue a NPDES
wastewater discharge
permit to the
person(s) listed
below.
Written comments
regarding the pro-
posed permit will be
accepted until 30
days after the publish
date of this notice.
The Director of the
NC Division of Water
Quality (DWQ) may
hold a public hearing
should there be a sig-
nificant degree of
public interest.
Please mail com-
ments and/or infor-
mation requests to
DWQ at the above
address. Interested
persons may visit the
DWQ at 512 N.
Salisbury Street,
Raleigh, NC to review
information on file.
Additional information
on NPDES permits
and this notice may
be found on our web -
site: www.ncwa-
terquality.org, or by
calling (919) 807-
6304.
The Town of Weldon
has applied for
renewal of its NPDES
permit NC0025721,
discharging treated
wastewater to the
Roanoke River in the
Roanoke River Basin.
attached
PUBLIC NOTICE
was printed and published correctly in the regular and entire issue of said
THE DAILY HERALD for l sues, that the first was
made on the 2n`�ay of MAY 20 10
and the last publication thereof was made on the 2 nd day of
MAY
20 10 that said publication
was made on each of the following dates, to wit:
05/02/10
Request of
By
NC DIVISION OF WATER QUAL
The Daily Herald
Subscribed sworn to before me this
20
Signed
10
2n17y of MAY
Notary Public in and for the County of Halifax,State of North Carolina
My Commission Expires: My Commission Fypirps May 13, 201:2
May 2; 2010

Removal Rate Calculations
Sample Date
1/2/2008
2/ 1 /2008
3/4/2008
4/ 1 /2008
5/2/2008
6/3/2008
7/1/2008
8/5/2008
9/2/2008
10/1/2008
11/4/2008
12/2/2008
1/2/2009
2/3/2009
3/3/2009
4/1/2009
5/5/2009
6/2/2009
7/ 1 /2009
8/4/2009
10/1/2009
Column Averages =>
Spreadsheet
Instructions:
1) Data
entered only in
Heavy
Bordered cells.
Rest of
worksheet is
protected,
password is
"2"
2) For below
detection data,
enter "<" in "<"
column, and
enter detection
level in Influent
or Effluent
mg/I columns.
Spreadsheet
will auto-
matically
calculate
averages and
removal rates
using 1/2
value entered.
3) Document
removal Rate
choice
4) Formulas in
Compre-
hensive Guide
HWA Chapter,
Section E,
page 1.
Influent Used in
mg/L Calculation <
62.5
62.5
Effluent
mg/L
4.3
Used in
Calculation
4.3
135.0
172.0
135
172
2.0
2.1
1
2.1
524.0
524
4.6
4.6
148.0
148
2.4
2.4
199.0
199.0
10.2
10.2
252.0
252.0
4.3
4.3
108.0
108.0
2.0
1.0
171.0
171.0
2.5
2.5
77.9
77.9
6.8
6.8
104.0
104.0
2.0
1.0
103.0
72.6
103.0
72.6
2.3
2.2
2.3
2.2
96.1
96.1
2.4
2.4
92.8
92.8
2.6
2.6
70.7
139.0
70.7
139.0
3.9
2.0
3.9
1.0
255.0
255.0
255.0
255.0
35.0
20.9
35.0
20.9
134.0
134.0
2.0
2.0
64.5
64.5
154.1
2.0
Unpaired Site Specific RR =>
Literature/Default RR =>
12 % of data is BDL
RR for this HWA =>
Weldon_removal_rate 08_09_2010 Renewal
Removal Rates
Page 1 of 1 pages
4/12/2010, 1:57 PM
Revision: August 1999
1.0
5.40
96.49%
85.00 %
98.28%
<
Influent
mg/L
TSS
Used in
Calculation <
Effluent
mg/L
Used in
Calculation
89.0
89
6.0
6
101.0
101
2.0
2
107.0
107
13.0
13
168.0
168
4.0
4
80.0
80
7.0
7
188.0
188.0
12.0
12.0
114.0
114.0
3.0
3.0
92.0
92.0
2.0
2.0
86.0
86.0
1.0
1.0
74.0
74.0
2.0
2.0
132.0
132.0
3.0
3.0
93.0
93.0
5.0
5.0
59.0
59.0
3.0
3.0
109.0
109.0
3.0
3.0
72.0
72.0
4.0
4.0
68.0
68.0
4.0
4.0
155.0
155.0
7.0
7.0
110.0 ,
110.0
5.3
5.3
124.0
124.0
3.9
3.9
88.0
88.0
1.8
1.8
54.2
54.2
2.4
2.4
Unpaired
103.01
RR =>
RR =>
4.50
Site Specific
Literature/Default
95.64 %
85.00 %
0 % of data is BDL
RR for this H WA =>
94.10 %
<
Influent
mg/L
AMMODIIA
Used in
Calculation <
Effluent
mg/L
Used in
Calculation
9.2
9.2
2.3
2.3 I
12.5
12.5
0.46
0.46
12.8
12.8
1.04
1.04
15.3
15.3
<
0.1
0.05
6.50
6.5
r
0.23
0.23
15.3
15.3
3.0
3.0
10.7
10.7
0.7
0.7
15.4
15.4
<
0.1
0.1
14.0
14.0
0.5
0.5
7.4
7.4
2.8
2.8
12.6
12.6
<
0.1
0.1
12.9
12.9
0.6
0.6
7.4
7.4
<
0.1
0.1
12.1
12.1
0.2
0.2
7.0
7.0
0.9
0.9
6.2
6.2
0.7
0.7
10.9
10.9
0.5
0.5
11.8
11.8
2.5
2.5
12.2
12.2
<
0.1
0.1
26.8
26.8
1.1
1.1
12.0
12.0
<
0.1
0.1
Unpaired
11.95238
RR =>
RR =>
0.849095
Site Specific
Literature/Default
92.90 %
85.00 %
17 % of data is BDL
RR for this HWA =>
93.56%

NPDES/Aquifer Protection Permitting Unit Pretreatment Information Request Form
PERMIT WRITER COMPLETES THIS PART:
PERMIT WRITERS - AFTER You pet this form
•
Check all that
back from PERCS:
apply
Notify PERCS if LTMP/STMP data we said should
Date of Request
3/24/2010
municipal renewal
X
-
be on DMRs is not really there, so we can get it for
Requestor
Jim McKay
new industries
you (or NOV POTW).
Facility Name
Weldon
WWTP expansion
- Notify PERCS if you want us to keep a specific
Permit Number
NC0025721
Speculative limits
POC in LTMP/STMP so you will have data for next
Region
Raleigh
stream reclass.
permit renewal.
Basin
Roanoke
stream relocation
- Email PERCS draft permit, fact sheet, RPA.
- Send PERCS paper copy of permit (w/o NPDES
7Q10 change
boilerplate), cover letter, final fact sheet. Email RPA
other
if changes.
other
I
check applicable
PERCS staff:
Other Comments to
PERCS:
X
CTB, CHO, LUM, NEW, ROA - Dana Folley (523)
•
HIW, LTN, NEU, YAD - Monti Hassan (371)
q�
BRD, CPF, FRB, TAR - Sarah Morrison (208)
o a
1
'0,
..aso
PERCS
Status of
PRETREATMENT STAFF COMPLETES THIS PART:
Pretreatment Program (check all that apply)
4-t
al. ail
1) facility has no SIU's, does have Division approved Pretreatment Program
that is INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment
Program -
3) facility has SIUs and DWQ approved Pretreatment Program (list "DEV"
if program still under developmen
4
3a) Full Program with LTMP
o ie rogram with STM
,
. e•
4) additional conditions regarding Pretreatment attached or listed below
STMP time frame: - !,
Most recent:
V it '*
Flow, MGD
Permitted
Actual
Time period for Actual
Next Cycle:
�h
, 0 % P. 00
Industrial6.146,0
0,, 11-
'D.0071•
Uncontrollable
nla
0,5lc.5
ao04.
? (�
POC In
LTMP!
STMP
Parameter of
Concern (POC)
Check List
POC due to
NPDES/ Non-
Disch Permit
Limit
Required
by EPA'
Required
by 503
Sludge"
POC due
to SIU***
POTW POC
(Explain
below)""
STMP
Effluent
F
q
LTMP
Effluent
Freq
CI(
i
t ..
✓
BOD
I/
d
4
Q M
. ,
t/
TSS
V
v
4
Q M
Q = Quarterly •
,/
NH3
v?
14
Q M
M = Monthly Vl11
✓
Arsenic
V
' 4
Q M
--
I/
Cadmium r0uj*
-4
v
4
Q M
4
Chromium
4
V
k 4
Q M
4
Copper ' i
4
v
4
Q M
® a'
✓
Cyanide
4
Q M
all dat on DMRs?
4
Lead it ''1i
4
✓
‘/
4
Q M
ES
V
v
Mercury
V
4
Q M
NO (attar data)
t/
Molybdenum
✓c
4
Q M
,J
Nickel
4
V
✓
4 ‘
Q M
0 1/
Silver
4
Q M
Selenium
✓
4
Q M
4
Zinc '`
4
V
v
li
Q M
data in spreadsheet?
Q M
YES to
—Total
Nitrogen
-
(email writer)
- ---sPhosphsrus
..............................................*A
—4---Q-M.
NO
__
:'✓
roll
v
Q M
is,✓
es +L's
v
4
Q M
t, /
c L,lortck-..'
4
Q M
• V
o-14vers
,.,
4
Q M
*Always in the LTMP/STMP ' '" Only in LTMP/STMP if sludge land app or composte (dif POCs for incinerators)
"' Only in LTMP/STMP while SIU still discharges to POTW '**' Only in LTMP/STMP when pollutant is still of concem to POTW
Co� to Permit Writer (ex.. xpla of n OCs: info you hay on IU rela d investigation into NPDES problems):
nation
19-411-1-eit° CfAiv't):6"41 .."-VIA-0-) 4 c5VJA- PN EP tti �w- : aao �naw
NPDES_Pretreatment request form 3 24 2010
Revised: July 24, 2007

(/)'-c4rfid-* A...A._
u-i4Pr-(rit- °-4- 'rk6 /14-
�dufl" S � 12- lortev,-
4./J(A
��-p ^
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t rpa( I (� !tee f IA s��J
Po (� Go LA t o& re 0 e e r ^^e
- JT I<<'1 J k e ri i [ 1 k w., �av' L u w� A. .15Y\.. )
YVVIMIUetvv•17-11-2—I

Mckay, James
From: [e-mail]
Sent: Monday, March 29, 2010 9:04 AM
To: Mckay, James
Subject: Town of Weldon NPDES Permit information
Mr. McKay,
Listed below is the equipment added at the Town of Weldon WWTP since the last NPDES permit was issued.
1 - 485,000 gallon positive displacement (Sanitaire) air blower sludge tank.
2 - 450kw Cummins Backup Power Generator.
The Town of Weldon's wastestream consist of the follow:
1 - Town of Weldon
2 - Halifax County
3 - Northampton County/Garysburg, NC
4 - Town of Halifax, NC
Should you have any questions or comments concerning this matter, please contact me at [phone] or
[e-mail]
Thank you,
Donald L. Crowder
Public Utilities Director
Town of Weldon
1

Mckay, James
From: Nisely, Myrl
Sent: Thursday, March 25, 2010 7:11 AM
To: Mckay, James
Subject: Weldon thoughts
Attachments: WeldonSfRpt308.doc
Jim, attached is an update to my 2007 staff report in which I note several additions to the plant since the last permit.
Not sure whether you have a copy of it or not. Additions since the last permit are:
A new 285,000 gal aerated sludge digester, a standby generator, polymer addition and caustic addition. The caustic was
put in to deal with pH swings from Reser's Foods, but that flow has recently been transferred to the Roanoke Rapids
WWTP, so the caustic feed system is seeing no use. Also since last permit, the Town of Halifax has closed their lagoon
system and now sends the flow to Weldon. There is one error in the revised staff report — I stated that Hobgood flow
goes to Weldon. Wrong- it goes to Scotland Neck WWTP.
Myrl
Myrl A. Nisely <°))))><
Environmental Chemist
NC DENR - Div. Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Telephone: [phone] or x4255
Fax: [phone]
myrl.niselyQncdenr.Rov ><((((°>
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.
1

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(This form is best filled out on computer, rather than hard copy)
Date: 1/11/2007, 'update dlfi 4/2008 County: Halifax
To: NPDES Discharge Permitting Unit Permitee: Town of Weldon
Attn. NPDES Reviewer: Jim McKay Application/ Permit No.: NC0025721
Staff Report Prepared By: Mvrl Nisely
Project Name:
SOC Priority Project? (Y/N) N If Yes, SOC No.
A. GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Modification
2. Was a site visit conducted in order to prepare this report? ® Yes or ❑ No.
a. Date of site visit: 1/4/2007, 1/10098
b. Person contacted and telephone number: Donald Crowder 252-536-3478
c. Site visit conducted by: Myrl Nisely
d. Inspection Report Attached: ® Yes or ❑ No.
3. Keeping BIMS Accurate: Is the following BIMS information (a. through e. below) correct?
❑ Yes or ® No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missine)
(If there is more than one discharge pipe, put the others on the last page of this form.)
a. Location OK on Existing Permit ❑, OR, if not, is
OK on Application ❑, or if neither is right, provide Location: More accurate in d. below
b. Driving Directions OK on Existing Permit ❑, OR, if not, is
OK on Application ❑, or provide Driving Directions (please be accurate):
c. USGS Quadrangle Map name and number OK on Existing Permit ❑, OR, if not, is
OK on Application ❑, or provide USGS Quadrangle Map name and number:
d. Latitude/Longitude OK on Existing Permit ❑, (check at http://www.topozone.com These are
often inaccurate) or is OK on Application ❑, or provide Latitude: 36-25-24 Longitude: 77-
34-39
e. Receiving Stream OK on Existing Permit ®, OR, if not, is
OK on Application ❑, or provide Receiving Stream or affected waters:
a. Stream Classification: C
b. River Basin and Sub basin No.: Roanoke River, 23-(26)
c. Describe receiving stream features and downstream uses: Flow varied by hydroelectric
generation

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
For NEW FACILITIES Proceed to Section C, Evaluation and Recommendations
(For renewals or modifications continue to section B)
B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only)
1.!Describe the existing treatment facility: Same as old permit but add new 285,000 gal aerated digester,
polymer addition to the clarifiers, a standby power generator and caustic addition to the influent for pH
adjustment if needed.
2. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Donald Crowder Certificate # 11136 (Available in BIMS or Certification
Website)
Back- Operator in Charge: Russell Wheeler Certificate # 24059
3. Does the facility have operational or compliance problems? Please comment: Yes, in 2006. Sec
attached Compliance Evaluation Inspection report.
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): Each of the months listed except November have received
enforcements.
Are they currently under SOC, ❑ Currently under JOC, ❑ Currently under moratorium ❑? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? ❑ Yes
or ❑ No. If no, please explain:
4. Residuals Treatment: PSRP ® (Process to Significantly Reduce Pathogens, Class B) or
PFRP ❑ (Process to Further Reduce Pathogens, Class A)?
Are they liquid or dewatered to a cake? Liquid
Land Applied? Yes ® No ❑ If so, list Non -Discharge Permit No. WQ00023 68
Contractor Used: Synagro
Landfilled? Yes ❑ No If yes, where?
Other?
Adequate Digester Capacity? Yes ® No El Sludge Storage Capacity? Yes ® No ❑
Please comment on current operational practices: Historically strong, lots of extra process control
testing. In 2008 they appear to be making good use of this data for process control. Were able to
give examples of proactive steps taken before a rain to avoid problems from increased inflow.
5. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? El Yes or ® No. If yes, please explain: No longer. See attached a corrective action plan
for maintaining compliance. Better operating at HCPU has greatly improved operations at Weldon.
FORM: NPDES-RRO 06/03, 9/03 2

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
C. EVALUATION AND RECOMMENDATIONS
1. Alternative Analysis Evaluation: has the facility evaluated the non -discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation: Not a reasonable alternative for this much flow
Connect to Regional Sewer System: No regional treatment plant exists
Subsurface: Flow too large
Other Disposal Options:
2. Provide any additional narrative regarding your review of the application: Question A(8)c. was
answered incorrectly. Sludge is land applied, but wastewater is not. This is done intermittently, now
about once per quarter.
3. List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
Recommended Additional Information
Reason
Updated site map to show new digester, standby
generator, polymer addition and caustic addition.
These components have been added since the
last permit
Estimated flows from Hobgood and Town of
Halifax that were tied in during 2007. Don't know
if this info is of help to you or not, but wish to
bring it to your attention.
Get most accurate estimate of flows for near
future. Town engineer estimates capacity
can be increased from 1.2 MGD to 1.6 MGD
by using UV disinfection. Yet they did not
request an increase in permit flow limit. _
4. List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
Recommended Removal
Reason
5. List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
Recommended Addition
Reason
In the description, effluent flow is measured via a
30 degree V notch weir, not a Parshall flume
More accurate description of the plant
6. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office;
❑ Hold, pending review and approval of required additional information by NPDES permitting
office; ® Issue; ❑ Deny. If deny, please state reasons:
FORM: NPDES-RRO 06/03, 9/03 3

NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
Reminder: attach inspection report if Yes was checked for 2 d.
7. Signature of report preparer:
Signature of WQS regional supervisor:
Date:
D. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
If next page is not used, PLEASE set printer for pages 1 through 3 to avoid wasting paper.
Use this page for facilities with more than one Discharge Pipe
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a. Location OK on Application ❑,
OK on Existing Permit ❑, or provide Location:
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate):
c. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit ❑, or provide USGS Quadrangle Map name and number:
d. Latitude/Longitude OK on Application 0, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
e. Receiving Stream OK on Application ❑,
OK on Existing Permit 0, or provide Receiving Stream or affected waters:
a. Stream Classification:
b. River Basin and Sub basin No.:
c. Describe receiving stream features and downstream uses:
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a. Location OK on Application ❑,
OK on Existing Permit ❑, or provide Location:
b. Driving Directions OK on Application ❑,
OK on Existing Permit ❑, or provide Driving Directions (please be accurate):
c. USGS Quadrangle Map name and number OK on Application ❑,
OK on Existing Permit 0, or provide USGS Quadrangle Map name and number:
d. Latitude/Longitude OK on Application ❑, (check at http://topozone.com These are often
inaccurate) OK on Existing Permit ❑, or provide Latitude: Longitude:
FORM: NPDES-RRO 06/03, 9/03 4

NPDES REGIONAL WATER QUALITY
• STAFF REPORT AND RECOMMENDATIONS
e. Receiving Stream OK on Application El,
OK on Existing Permit 0, or provide Receiving Stream or affected waters:
a. Stream Classification:
b. River Basin and Sub basin No.:
c. Describe receiving stream features and downstream uses:
FORM: NPDES-RRO 06/03, 9/03 5

Roanoke River Basin Roanoke River 8-Digit Subbasin 03010107
Assessment Unit Number Name
Description
Classification Old DWQ Subbasin Miles/Acres
Use
Support
Category
Use
Support
Rating
Reason for
Rating
Parameter of Collection Listing IR
Interest Year Year Category
24-2-(15) Cashie River
From N.C. Hwy. 45 to Albemarle Sound (Batchelor Bay)
B;Sw 03-02-10 1.2 FW Miles
Fish hnpaired Standard Violation
Consumption
Mercury
2000 2002 5
24-2-(9) Cashie River Fish Impaired Standard Violation Mercury 2000 2002
Consumption
From a point 1.0 mile upstream from Bertie County SR 1500 to the Thoroughfare (The Gut
between Cashie and Roanoke Rivers)
B;Sw
03-02-10 2.3 FW Miles
23-30b
Quankey Creek
From Little Quankey Creek to Roanoke River
03-02-08 3.4 FW Miles
ROANOKE RIVER
From a line across the river 50 fl downstream of NC Hwy 48 bridge to the confluence of Sandy
Run Cr at the Bertie Northampton Halifax`Co. line
C ?3-02-08 50.1 FW Miles
Aquatic Life Impaired Fair Bioclassification EcologicaUbiological Integrity 1999 1998 5
Benthos
Fish Impaired Standard Violation Mercury 2000 2002 5
Consumption
23-(26)bl ROANOKE RIVER Fish Impaired Standard Violation Mercury 2000 2006 5
Consumption
From the confluence of Sandy Run Cr at the Bertie/Northampton/Halifax Co. line to subbasin
8/9 boundary
03-02-08 24.8 FW Miles
23-(26)b2 ROANOKE RIVER Fish Impaired Standard Violation Mercury 2002 2002 5
Consumption
From subbasin 8/9 boundary to Hwy 17 Bridge in Williamston
C 03-02-09 28.9 FW Miles
23-(26)b3 ROANOKE RIVER
From Hwy 17 bridge at Williamston to the 18 mile marker at Jamesville
C 03-02-09 17.8 FW Miles
Aquatic Life Impaired Standard Violation Low Dissolved Oxygen
Fish Impaired Standard Violation Mercury
Consumption
2006 2008 5
2006 2002 5
23-(53) ROANOKE RIVER Fish Impaired Standard Violation Mercury 2000 2002 5
Consumption
Fish Impaired Standard Violation Dioxin 2006 2000 4a
Consumption
From 18 mile marker at Jamesville to Albemarle Sound (Batchelor Bay)
C;Sw 03-02-09 18.3 FW Miles
23-55 Welch Creek Fish Impaired Standard Violation Mercury 2000 2002 5
Consumption
From source to Roanoke River
Fish Impaired Standard Violation Dioxin 2006 2000 5
C;Sw 03-02-09 13.3 FW Miles Consumption
Tar -Pamlico River Basin
liar Ricer Headwaters 8-Digit Subbasin 03020101
All NC' Waters are in Category 5 due to statewide Fish Consumption Advice for Mercury Category 5 Assessments require TJ)JDL development per Clean Water Act Section 303(d)
2008 North Carolina Integrated Report Category 4 and 5 Impaired Waters List- 2010311 Page 76 of 139

RRO
'PERMIT (OWNER
NC0021024 City of Roxboro
NC0021024 City of Roxboro
NC0021024 City of Roxboro
NC0021024 City of Roxboro
NC0021024 City of Roxboro
NC0021024 City of Roxboro
NC0021024 Ci of Roxboro
NC0035491 Vance County Schools
NC0035491 Vance County Schools
NC0035491 Vance County Schools
NC0035491 Vance County Schools
NC0035491 Vance County Schools
NC0035491 Vance County Schools
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025437 Town of Rich Square
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0025721 Town of Weldon
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027826 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027626 NC Department of Correction
NC0027826 NC Department of Correction
NC0027642 NC Department of Correction
NC0027642 NC Department of Correction
NC0027842 NC Department of Correction
NC0027642 NC Department of Correction
NC0027642 NC Department of Correction
NC0027642 NC Department of Correction
NC0027642 NC Department of Correction
FACILITY
City of Roxboro WWTP
City of Roxboro WWTP
City of Roxboro WWTP
City of Roxboro WWTP
City of Roxboro WWTP
City of Roxboro WWTP
Cit of Roxboro WWTP
E.O. Young, Jr. Elementary School
E.O. Young, Jr. Elementary School
E.O. Young, Jr. Elementary School
E.O. Young, Jr. Elementary School
E.O. Young, Jr. Elementary School
E.O. Young, Jr. Elementary School
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Rich Square WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Weldon WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Caledonia WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
Odom Correctional Institute WWTP
(REGION
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Ralei. h
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
Raleigh
(CASE -NUMBER IPARAMETERIPENALTY$ ITOTALPAID
LV-2001-0529
LV-2002-0047
LV-2004-0007
LV-2004-0072
LV-2006-0083
NOV-2004-LV-0040
NOV-2008-LV-0188
LV-2003-0510
LV-2006-0105
NOV-2003-LV-0109
NOV-2004-LV-0310
NOV-2004-LV-0584
NOV-2006-LV-0146
LM-2003-0300
LM-2004-0009
LM-2d04-0033
LM-2004-0034
LM-2005-0005
LV-2004-0101
LV-2004-0466
LV-2004-0515
LV-2004-0580
NOV-2003-LV-0293
NOV-2004-LR-0012
LV-2003-0588
LV-2004-0352
LV-2004-0441
LV-2005-0266
NOV-2003-LV-0132
NOV-2004-LR-0009
NOV-2004-LV-0532
PC-2003-0323
TX-2002-0012
WQ-2001-0008
LV-2001-0023
LV-2001-0196
LV-2005-0411
LV-2005-0464
NOV-2004-LV-0288
NOV-2004-LV-0289
NOV-2004-PC-0062
NOV-2005-LV-0484
NOV-2005-PC-0111
NOV-2005-PC-0200
NOV-2006-LV-0067
LV-2003-0438
LV-2003-0883
LV-2003-0684
LV-2004-0097
LV-2004-0442
NOV-2003-LV-0010
NOV-2003-LV-0215
CYANIDE
FEC COLT
CN, Ni
FEC COLI
NICKEL
FEC COLI
NH3-N
BOD
BOD
FEC COLI
BOD
TRC,fec,do
BOD,flow,teml
BOD,TRC,flovt
FLOW,temp
FLOW,temp
BOD,flow,ph
FLOW
FEC,flow
FLOW
FLOW
$291.40 $291.40
$291.40 $291.40 Response to be prepared by
$545.27 Chad Coburn
$545.27 $545.27
$1,051.42
$0.00 $0.00
$0.00 $0.00
$498.91 $498.91
$284.38 $284.3 Response to be prepared by
$0.00 $0.0Shannon Langley
$0.00 $0.00
$0.00 $0.00
$o.00 $0.00
$294.74 $294.74 Rich Square has recently completed
$298.29 $298.29 I&I sewer rehab and upgraded all lift SOS
$1,048.29 $1,048.29 stations, installed a mechanical bar
$798.29 $798.29 screen and influent flow meter. They
$1,173.29 $1,173.29 have heavy I&I, though, and will need lip
$1,298.29 $1,298.29 do another round.
$985.79 An illegal bypass is to be removed in
$985.79 $985.79 the next project, already funded, to
$1,173.29 upgrade the chloddechlor, enlarge the
$0.00 $0.00 effluent flow meter etc. We expect to do
$0.00 $0.00 an SOC with them soon
$544.74 $544.74
$298.29 $298.29 Problems have been different each
$298.29 $298.29 time. Recently started using a huge
$548.29 $548.29 new sludge digester that should help
$0.00 $0.00 solids handling.
$0.00 $0.00 No special conditions anticipated,
$0.00 $0.00 although they do take strong influent
$4,675.55 $4,675.55 from Reser's Food, but Reser's have
$1,039.24 $1,039.24 been within their permit limits.
$8,600.00 $8,600.00
$1,041.00 $1,041.00 Installing a UV unit for Fecal, at present
$5,541.00 there is no method used for to disinfect
$1,540.73 $1,540.73 effluent coming from the artificial
$2,040.73 $2,040.73 wetlands.
$0.00 $0.00 Efforts are being made to lower the
$0.00 $0.00 water level in the cells for better plant
$0.00 $0.00 growth and propagation.
$0.00 $0.00 RRO still is unhappy about the sparse
$0.00 $0.00 coverage in many of the cells.
$0.00 $0.00 Should improve soon, for more certain
$0.00 $0.00 BOD removal.
$1,044.74 $1,044.74
$744.00 $744.00 1
$344.00 $344.00 Installing a UV unit for Fecal. Expected
$298.29 $298.29 to take care of high Fecals and
$748.29 $748.29 avoid high chlorine residuals.
REGION DBACK
BOD
BOD
BOD
BOD,fec,tss
FEC COLI
BOD
FEC COLI
FEC COLI
BOD
BOD
FEC COLT
FEC COLI
trc,tss
FEC COLI
FEC COLI
OIL-GRSE
FEC COLI
CHLORINE
CHLORINE
$0.00 $0.00
$0.00 $0.00
evto{ 1,
Page 1

Re: [Fwd: [Fwd: Roanoke Basin/Compliance in NPDES Renewals]]
A'evI%r,rIr/hi
r13,44014.
Subject: Re: [Fwd: [Fwd: Roanoke Basin/Compliance in NPDES Renewals]]
From: Myrl Nisely <[e-mail]>
Date: Fri, 13 Oct 2006 11:41:58 -0400
To: Chuck Wakild <[e-mail]>
CC: Tom Belnick <[e-mail]>
Tom, see my responses on the spreadsheet. Contact me if any further questions.
RRO is expecting to do a staff report for each facility in the basin, even if only an email
saying all is well.
Myrl
Chuck Wakild wrote:
Tom Belnick wrote:
Last Call! At this point I still have not received RRO feedback (any special permit
conditions recommended, etc) for 7 NPDES facilities in the Roanoke Basin, before NPDES
begins permit renewals. You can respond on the attached spreadsheet, or NPDES can
visit RRO to go over the facilities.,Just let me know. Thanks.
Subject:
[Fwd: Roanoke Basin/Compliance in NPDES
From:
Tom Belnick <[e-mail]>
Date:
Thu, 21 Sep 2006 16:40:05 -0400
To:
steve tedder <[e-mail]>,
To:
steve tedder <[e-mail]>,
Renewals]
Chuck Wakild <[e-mail]>
Chuck Wakild <[e-mail]>
Steve/Chuck- I still need your feedback on the Roanoke Basin NPDES compliance. I'm out
of the office Oct2-4, so if you could respond by October 6, that would be great.
Thanks.
Subject:
Roanoke Basin/Compliance in NPDES Renewals
From:
Tom Belnick <[e-mail]>
Date:
Mon, 07 Aug 2006 14:47:33 -0400
To:
Steve Tedder <[e-mail]>, Chuck Wakild <[e-mail]>, Al
Hodge <[e-mail]>, "DENR.EASTNPDES.DWQ" <[e-mail]>,
"DENR.WESTNPDES.DWQ" <DENR.WASTNPDES.DWQ®ncmail.net>
To: •
Steve Tedder <[e-mail]>, Chuck Wakild <[e-mail]>, Al
Hodge <Al.Hodge®ncmail.net>, "DENR.EASTNPDES.DWQ" <DENR.EASTNPDES.DWQ6incmail.net>,
"DENR.WESTNPDES.DWQ" <[e-mail]>
CC:
Matt Matthews <[e-mail]>
The Roanoke Basin (subbasins 030201-030210) is next in line for NPDES wastewater permit
renewals, with 77 permit renewals falling within three regions: WSRO (n=47), RRO
(n=18), and WARO (n=12). The Roanoke permits begin to expire 1/31/2007, which means
that NPDES staff will start sending drafts to public notice in December06. NPDES staff
attempts to incorporate compliance into permit renewals by reviewing the compliance
record toidentify problem facilities, and discussing with the applicable Regions
1 of 2 . 10/13/2006 4:16 PM

Re: [Fwd: [Fwd: Roanoke Basin/Compliance in NPDES Renewals]]
whether the permit renewal should contain any special conditions to address continuing
compliance problems.
Similar to the Cape Fear renewals, I reviewed a BIMS download of enforcement cases
during 2001-05, and used a subjective compliance threshold of 3+ enforcement cases over
the last 2 years, or 5+ enforcement cases over the past 5 years, to identify potential
problem facilities. This threshold resulted in 30 facilities, spread between WSRO
(n=20), RRO (n=7), and WARO (n=3). These facilities are listed by Region in the
attached spreadsheet. The next step is for NPDES/Region to review the facility lists
and determine what permitting conditions, if any, would be appropriate for each listed
facility. For some facilities, the cases may be older and the problem may already be
resolved, or is currently being addressed through SOC, etc, in which case no permitting
action is necessary. The most common permiting action for a problem facility has been
to add a Special Condition requiring preparation of a Wastewater Management Plan that
focusus on specific problems and how the facility plans to resolve them.
I'll leave it to the Regions to determine how they want to proceed. Regions can either
review their listings and enter comments on the spreadsheet and send back, or NPDES can
call/visit the Region to discuss each listed facility. Both ways have worked in the
past. Either way, I'd like to complete this task BY SEPTEMBER 30, before NPDES staff
begins the permit renewals. Any permitting conditions deemed appropriate by
Region/NPDES will then be placed in the permit renewal files, and ultimately
incorporated into the draft permit. If Regions have any questions, feel free to
contact me or the following NPDES Regional Office Contacts: WSRO- Charles Weaver; RRO-
Vanessa Manuel; WARO- Karen Rust.
Tom,
Sorry I've let this fall through. Most of these will be in Myrl's area and we will
respond. Thanks.
Myrl A. Nisely <°))))><
Environmental Chemist II NC DENR - Div. Water Quality Raleigh Regional Office 1628 Mail
Service Center Raleigh, NC 27699-1628 Telephone: [phone] or x4255
Fax: [phone]
[e-mail] ><((((°>
ROANOKE Basin Enforcement Summary 2001-06Comments.xls
Content -Type: application/msexcel
Content -Encoding: base64
2 of 2 10/13/2006 4:16 PM

,Rofekto 3 0? Pro-vv\c‘G )e
NPDES/Aquifer Protection Permitting Unit Pretreatment Information Request Form .'
PERMIT WRITER COMPLETES THIS PART:
PERMIT WRITERS - AFTER You get this form
Check that
b
back from PERCS:
all apply
Date of Request
8/28/2008
municipal renewal
x
- Notify PERCS if LTMP/STMP data we said should
be on DMRs is not really there, so we can get it for
Requestor
Jim McKay
new industries
you (or NOV POTW).
Facility Name
Weldon WWTP
WWTP expansion
- Notify PERCS if you want us to keep a specific
Permit Number
NC0025721
Speculative limits
POC in LTMP/STMP so you will have data for next
Region
Raleigh
stream reclass.
permit renewal.
Basin
Roanoke
stream relocation
- Email PERCS draft permit, fact sheet, RPA.
- Send PERCS
7Q10 change
paper copy of permit (w/o NPDES
boilerplate), cover letter, final fact sheet. Email RPA
other
if changes.
other
check a
plicable PERCS staff:
Other Comments to PERCS: I will be working on this next week or
the week after
x
CTB, CHO, LUM, NEW, ROA - Dana Folley (523)
HIW, LTN, NEU, YAD - Monti Hassan (371)
BRD, CPF, FRB, TAR - Sarah Morrison (208)
PERCS
Status of
PRETREATMENT STAFF COMPLETES THIS PART: '
Pretreatment Program (check all that apply)
.
1) facility has no SIU's, does have Division approved Pretreatment Program that is INACTIVE
2) facility has no SIU's, does not have Division approved Pretreatment Program
`"
3) facility has SIUs and DW oved Pretreatment Progra (list "DV' ' if pro ram still under development) CAS
V
3a) Full Program with LTMP cr
L**, P.- P4' -
v
3b) Modified Program with STMP541..
titAkt1/4,1
4) additional conditions regarding Pre reatment attached or listed below
STMP time frame:
Most recent:
Flow, MGD
Permitted
Actual
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Comments to Permit Writer (ex., explanation of any POCs' info you have on IU related Investigations into NPDES problems):co-041,
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Revised; Judy 24, 2007•
w
erM

November 30, 2006
Ms. Carolyn Bryant
NC DENR
Water Quality / Point Source Branch
1617 Mail Service Center
Raleigh, NC 2769901617
RE: Town of Weldon
Halifax County, NC
NPDES Permit NC 0025721
SUB: NPDES Permit Renewal Application
Dear Ms. Bryant:
DEC 1 2006
On behalf of the Town of Weldon Green Engineering hereby submits the NPDES Permit
renewal application for the continued operation of the Town of Weldon Wastewater
Treatment Plant.
Enclosed please fine one original and two copies of EPA Form 2A as well as the
following attachments.
1. Map of the point discharge
2. Schematic of the plant process
3. Copies of the Town's 18 toxicity tests from January through October 2006.
Dates of tests — 1/13; 1/15; 1/17; 1/18; 2/21; 3/20; 4/9; 4/13; 4/17; 4/28;
7/9; 7/13; 7/18; 7/22; 10/14; 10/16; 10/22; 10/29
Please note the following regarding Part D. Expanded Effluent Testing Data.
1. Most of the parameters had different minimum detection limits from the three
analyses. In this case the minimum detection limit reported in Part D was the
highest of the three.
2. Most of the parameters had at least one sample with a value less than the
minimum detection limit. In these cases the average of the three scans was
reported with a "Iess than" sign. Similarly the values for the pounds per day were
reported with a "less than" sign.
3. A few parameters had only two samples. This is due to the fact that the
laboratory performing the analyses omitted some parameters without informing
the Town and this was not detected until the application was filled out. A third
sample will be taken for those parameters that had only two samples analyzed
GREEN ENGINEERING, PLLC
WATER, WASTEWATER SURVEYING, PLANNING, PROJECT MANAGEMENT
303 N. GOLDSBORO ST. PO BOX 609 WILSON N.C. 27893 TEL [phone] FAX [phone] WWW.GR EENENGIN EE RI NG.COM

Ms. Carolyn Bryant
November 30, 2006
Page 2 of 2
Please note the following regarding Part E. Toxicity Testing Data.
I discussed this part of the form with a representative of DENR relative to extracting the
data from the toxicity tests to fill out the various questions in the form. It was suggested
that the toxicity tests be attached to the renewal application in lieu of attempting to
complete this part of the form. That is what I have done.
If you should require additional information regarding the NPDES Permit renewal
application please do not hesitate to contact me at [phone] or my mobile phone at
[phone].
Very truly yours,
vv Ai --
Enclosure
Donald Crowder, DPU, Town of Weldon (w/ enclosure)
Green Engineering (w/ enclosure)

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'GREEN
ENGINEERING
WATER
WASTERWATER
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PLANNING
PROJECT MANAGEMENT
303 N. GOLDSBORO ST.
P.O. BOX 609
WILSON. NC 27893
TEL [phone]
FAX [phone]
officoOgrearang.com
pH MONITORING
AND CONTROL
SYSTEM
TOWN OF
WELDON
HALFAX COUNTY
NORTH CAROLNA
WELDON
WASTEW
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REVISION
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FACIUTY NAME AND PERMIT NUMBER:
Town of Weldon, NC0025721
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Roanoke
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INFORMATION r ,
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All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.1. Pretreatment program. Does the treatment works have, or is subject
ot, an approved pretreatment program?
0 Yes • No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (ClUs). Provide the number
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs. 3
of each of the following types of
b. Number of ClUs. 0
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges
provide the information requested for each SIU.
to the treatment works, copy questions F.3 through F.8 and
See following pages
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 18

1 SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and provide the
information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Resers' Fine Foods
Mailing Address: 11251 Highway 903
Halifax, NC 27839
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Manufacture refrigerated food products. Use steam to cook some raw materials like potatoes and pastas. Other vegetables are cleaned and
chopped for use in refrigerated food products. Use of steam to cook some raw materials, like potatoes and pastas. Other vegetables are cleaned
and chopped for use in refrigerated side dish salad products. No raw meats are used in the manufacturing process.
F.5. Principal Products) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Potato salads, pasta salads, vegetable salads, puddings and meat salads (meat fully cooked prior to the plant receiving
the meats.
Raw material(s): Potatoes. cabbage, carrots. onions. baked beans, salt. sugar, starch, red peppers. cooked Chicken, cooked ham, cooked
tuna, cheeses. soybean oil, vinegar, green peppers, cooked baked beans. pudding mixes, banana puree. pimentos, potassium sorbate, cucumbers,
celery, cranberries, mushrooms, apples, olive oil, cracker meal, kidney beans, and other similar ingredients.
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
130,000 (2005) gpd ( continuous or X intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
50,400 (2005) gpd (X continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits
b. Categorical pretreatment standards
® Yes
O Yes
❑ No
® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
0 Yes ® No If yes, describe each episode.
Note: Wastewater from Resers' Fine Foods is discharged to an Industrial Pretreatment Facility owned and
operated by the County of Halifax. This Industrial Pretreatment Facility is listed on the following page as an SIU.
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 19

FACILITY NAME AND PERMIT NUMBER:
Town of Weldon, NC0025721
SIGNIFICANT INDUSTRIAL USER INFORMATION:
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Roanoke
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Halifax County Water Reclamation Plant
Mailing Address: 3820 Aurelian Springs Road
Halifax County. NC 27839
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Pretreatment of Industrial Waste from Resers' Fine Foods
F.5. Principal Product(s) and Raw Material(s). Describe ail of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): DAF sludge, secondary sludge and treated effluent
Raw materia!(s): Food processen waste, NAOH, Sulfuric Acid, polymers (anionic and cationic), coagulant, ammonia
F.6. Flow Rate.
c. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
116,000 (2005) gpd ( continuous or X intermittent)
d. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
NIA gpd ( continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits
b. Categorical pretreatment standards
® Yes ❑ No
❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
® Yes ❑ No If yes, describe each episode.
Exceeded Industrial Pretreatment Permit limits resulting in the Town issuing a Special Consent Order. The SOC required specific plant
improvements. The deadline for completing the improvement is December 15, 2006
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 20

a
FACILITY NAME AND PERMIT NUMBER:
Town of Weldon; NC0025721
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Roanoke
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Roanoke Valley Energy Facility
Mailing Address:
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Cooling Town Blowdown. reverse osmosis reiect water. laboratory wastes, eauipoment washdown, floor drains
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Electricity
Raw material(s): Bituminous coal
F.6. Flow Rate.
e. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
197.000 (2005) gpd (X continuous or intermittent)
f. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
9,000 (2005) gpd (X continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
0 Yes ® No If yes, describe each episode.
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 21

e
FACILITY NAME AND PERMIT NUMBER:
Town of Weldon, NC0025721
PERMIT ACTION REQUESTED:
Renewal
RIVER BASIN:
Roanoke
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three
years received RCRA hazardous waste by truck, rail or dedicated pipe?
that apply):
(volume or mass, specify units).
Units
• Yes C.4 No (go to F.12)
F.10. Waste transport. Method by which RCRA waste is received (check all
• Truck • Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount
EPA Hazardous Waste Number Amount
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been
notified that it will) receive waste from remedial activities?
other remedial waste originates (or is excepted to origniate in
■ Yes (complete F.13 through F.15.) ® No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or
the next five years).
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment
works?
efficiency):
■ Yes ❑ No
If yes, describe the treatment (provide information about the removal
b. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
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3 �� {Eli D F SPA 1 �; -
aR - r ER � T A►RP L G�Ai 'I` r N a Eby" SPA ') TOi , , TT MI ,- t IC;H(`OTHE ARTS
i . t 41I } ' r �° , F u }t r21A QU ' i ST 4GL1; ATE , t ,
• 3 ifi �G�tf1 j, "� 1 tt ,�; N . r Ali 'i t flit ' }
t 4 — .r: . ` f {�FL'fi-i� �.:.: 45 � I=GI {1 } �# i4 r �_ _.M-:=d � ti—�+i �,•�• I �u:;�_ t G,.`
._,._�_�•���¢ '��li� f •_.1..�__ti� f+N .13::,�; t .�::'J s4'� li�}:t.�{lie}�si_t,::.. �k �:_��.: .:kr .�%� �i �i:..:�u.:is3Ji:�.�.r##1=,�'.�::�2::,.:zE�..n.S1..th i.:e..:r.':s�#
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 22

pf FACT SHEET FOR EXPEDITED PERMIT RENEWALS
Basic Information to determine potential for expedited permit renew
Reviewer/Date -
' If 0)../.(.
Permit Number
2 ,?--2
Facility Name
te 6 F L PL...,4)-6\.)
Basin Name/Sub-basin number
Receiving Stream
P(.443j V- -- PA V\t---R---
Stream Classification in Permit
Does permit need NH3 limits?
•
Does permit need TRC limits?
Lf Att ? I')C�6�
Does permit have toxicity testing?
Does permit have Special Conditions?
•
Does permit have instream monitoring?
Is the stream impaired (on 303(d) list)?
PO r s v cs4-77A6 •
Any obvious compliance concerns?
Any permit mods since last permit?
Existing expiration date
Reissued permit expiration date
New proposed permit effective date
Miscellaneous Comments
FL-6-).o I , s( c>S
c�-P�► d1,FQ
YESThis is a SIMPLE EXPEDITED permit renewal (administrative
renewal with no changes, or only minor changes such as TRC, NH3,
name/ownership changes). Include conventional WTPs in this group.
YES_ This is a MORE COMPLEX EXPEDITED permit renewal (includes
Special Conditions (such as EAA, Wastewater Management Plan), 303(d)
listed, toxicity testing, instream monitoring, compliance concerns, phased
limits). Basin Coordinator to make case -by -case decision.
This permit CANNOT BE EXPEDITED for one of the following reasons:
Major Facility (municipal/industrial)
Minor Municipals with pretreatment program
• Minor Industrials subject to Fed Effluent Guidelines (lb/day limits for BOD, TSS,
etc)
imits based on reasonable potential analysis (metals, GW remediation organics)
ermined flow > 0.5 MGD (requires full Fact Sheet)
Permits determined by Basin Coordinator to be outside expedited process
TB Version 8/18/2006 (NPDES Server/Current Versions/Expedited Fact Sheet)
E