NC0026042_Response to Notice_20220923

September 23, 2022
Mr. Robert Tankard
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
RE: Notice of Violation &
Intent to Assess Civil Penalty
Tracking No. NOV-2022-PC-0489
Robersonville WWTP
Martin County
Dear Mr. Tankard,
On behalf of the Town of Robersonville, we acknowledge receipt of the above -referenced Notice
of Violation (NOV) & Intent to Assess Civil Penalty dated September 9, 2022. We also
acknowledge as the Permittee that we are responsible for the deficiencies described in the letter,
and we are working diligently to correct the issues to ensure we properly protect the environment,
particularly the waters of the Tar -Pamlico River Basin.
Envirolink, Inc. is currently operating the facility out of Raleigh and provides the Operator in
Responsible Charge (ORC) and the Backup ORC as part of an ongoing agreement with them. We
intend to follow up with Envirolink, review the O&M procedures, and determine if the operators
are keeping an operational log, which would have answered some of the questions noted in the
Regional Office's inspection visit. However, we wish to respond to the individual violations noted
in your September 9, 2022, NOV as follows:
Sludge Handling Disposal

Town of Robersonville
NOV-2022-PC-0489
September 23, 2022
Page No. 2
In the February 8, 2022 inspection, it was noted that the sludge digesters were full, and the ORC
stated that the sludge will be land applied in March 2022. On September 1, 2022, it was noted that
both digesters are full. The facility did not know if sludge was applied in March 2022.
We verified with the ORC that the sludge was land applied last spring and the digesters were
emptied then. Obviously, the facility has been able to waste sludge since the February visit, or the
sludge age would have caused various operational issues and affected the effluent water quality.
We plan to follow up with Envirolink to ensure they keep a daily operations log available for
inspection at any time, which would have provided the answers sought during the inspection.
Equalization Basins
The "Equalization Basin" is actually the Anaerobic and Anoxic basin. In the February 8, 2022
inspection, it was noted that none of the mixers in the Anaerobic Anoxic zone were in operation.
On September 1, 2022, only 2 of the 6 mixers were on. Tracy was not sure if the mixers that were
off were operational. All mixers need to be operational and running to prevent solids from settling
in the Anaerobic and Anoxic zones.
The first statement is correct; the report labeled these basins as equalization basins; however, they
are indeed the Anaerobic and Anoxic basins. They are an important part of the Biological Nutrient
Removal process, and all mixers should be running to avoid solids settling out within the basins.
The mixers in question are not operational. As with the sludge disposal, a daily operations log
should have been available for inspection during the visit, which would have answered this
question. We will address this issue with Envirolink to ensure the daily log is maintained. We will
address the corrective action plan for this item as part of addressing the secondary clarifier issues.
Secondary Clarifier
The #6 Clarifier was not operational during February 8, 2022, Compliance Inspection due to
damage to the gearbox. As of September 1, 2022, the #6 Clarifier has not been repaired.
We acknowledge that the gearbox has not been repaired due to a lack of funds. On October 6,
2020, the NC Local Government Commission (LGC) assumed control of the Town's financial
affairs. Therefore, all budgetary items and expenditures are controlled by the LGC. Thus, any
expenditures by the Town need to be approved by the LGC.
The Town was fortunate to receive a $6,000,000 SRP Grant from the NCDEQ-Division of Water
Infrastructure to address the above -stated issues and others at the facility. The project SRP-W-
ARP-0250 was awarded as part of their spring 2020 funding round, and a copy of the Letter of
Intent to Fund is attached for your reference.

Town of Robersonville
NOV-2022-PC-0489
September 23, 2022
Page No. 3
The project will include the following items; flood protection berm & Stormwater pump station,
replace old grit system, Anoxic Anaerobic Tanks, Digester Clean & replace mixers/aerators,
replace non -potable water pumps, replace cloth filters, rehabilitate clarifiers 5 & 6, Replace
aerators in the aeration basins, replace intermediate filter pumps, replace valve/pumps at the
influent pump station and RAS/WAS pump station, convert gaseous chlorine feed to liquid
hypochlorite and demolish the old building, new SCADA, and redistribute the load for the 600 Kw
Generator. A copy of the project budget stated in the funding application is also attached for your
reference.
The Town has procured Municipal Engineering, Inc. of Garner, in compliance with NCGS 143-
64.31, Article D, to be the Engineer of Record for the design, bid & award, and construction phase
services for the above -referenced improvements to the facility. The Town intends to utilize these
funds to correct the issues stated in the NOV and others to ensure the facility is operating in full
compliance with our NPDES permit. We also plan to consult with and possibly re-evaluate our
relationship with Envirolink, Inc., to ensure these types of issues do not re -occur and to ensure the
daily log is being kept and is accessible for inspection.
Once again, we acknowledge the violations and understand as the Permittee, the Town of
Robersonville is responsible for the proper operation of the plant and compliance with all of the
NPDES permit conditions. We regret the violations have occurred but ask the Regional Office to
consider the following before issuing a civil penalty:
a. We do not believe there has been any harm to the natural resources of the State, public
health, or private property.
b. There has been no negative effect on ground or surface water quality.
c. The violation was neither willful nor intentional.
d. Our current situation with the LGC is in control of our financial activities. We have actively
sought and received grant funding to correct the deficiencies at the facility, and we now
have a plan and schedule to do so.
If you have any questions or need additional information, please don't hesitate to contact me or
Mr. Michael McAllister with Municipal Engineering, Inc., who assisted in preparing this response,
and will be collaborating with us on the design to correct the deficiencies.

Town of Robersonville
NOV-2022-PC-0489
September 23, 2022
Page No. 4
Sincerely,
TOWN OF ROBERSONVILLE
Chris Roberson
Interim Town Manager
CC: Becky Dzingeleski, Local Government Commission
Richard Sink, Town of Robersonville
Bobby, Blowe, PE, Municipal Engineering, Inc.
Michael McAllister, M-ASCE, Municipal Engineering, Inc.
Attachments: Funding Application Project Budget
Letter of Intent to Fund SRP-W-ARP-0250