NC0023337-Historical-CPA LV-2021--0085_20200406

TOWN OF SCOTLAND NECK
P.O. Box 537
1310 MAIN STREET
SCOTLAND NECK, NC 27874 NC Dept of Environmental Qual'ty
APR i S 2020
JWeigh Regional Office
April 6, 2020
Charles W. Baisey
Administrator
PO Box 537
Scotland Neck, NC 27874-0537
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section,
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Updated Response to Scott Vinson Letter dated February 28, 2020, NOTICE OF
VIOLATION & INTENT TO ASSESS CIVIL PENALTY, NOV-2020-PC-0115
N06 -a3337
Dear Mr. Vinson:
I am writing today to provide you an update on the status of the Town of Scotland Waste Water
Treatment Plant. As I noted in my letter of March 17, 2020 the Official Responsible -In -Charge
(ORC) has been facing a plant overrun by solids with many mechanical issues that preveni ixie
proper operation of the plant.
In our initial presentation to the Board they responded with unanimous support of the ORC's
efforts to fix the plant. The following items have been funded and completed:
1. A new controller at the Deep Well capable of supporting two Returned Activated Sludge
(RAS) pumps
2. The installation of a single RAS pump as requested by the ORC, instead of two, so we
could do more with the limited finances available to the Board. Second RAS pump is
budgeted for next fiscal year.
3. Contracted with Granville Farms to pump and land -apply 350,000 gallons of sludge,
primarily from the Digester
"This Institution is an equal opportunity provider and employer"
www.townofseotiandneck.com
Phone: [phone] • Fax: [phone] • email: [e-mail]

4. Replaced the internal rotating assemblies for both Variable Frequency Drive (VFD)
Tertiary Filter Gorham -Rupp pumps
5. Replaced the heater and the ventilation fan in the Tertiary filter pump station
6. Repaired the failed Contact Chamber Chlorine pump and replaced the clogged chlorine
supply hose. We also repaired the Chlorine Pump that serves to pre -treat the influent
from the Tertiary Filter pump station.
7. We replaced the failed Caustic pump located in the Main Influent Pump Station, and new
hoses were installed, and the new pump was relocated for better access.
8. We installed a new 400KW Tier 4 Backup Generator and new Transfer Switch
9. Placed Clarifier #2 online
10. Reconnected the Influent Pump Station alarm system, though adjustments are still
needed.
In addition, during the inspection by Cheng Zhang, it was noted the Oxidation Ditch was black in
color and septic. After the RAS pump was installed the ORC was able to run the Aerator for
sufficient time to bring the plant back into conformance. The Dissolved Oxygen (DO) was .3
mg/1 initially and is now steady at 1.3 mg/l. The Mixed Liquor Suspended Solids (MLSS),
initially at 16,000 mg/1 are now 5,400 mg/1 and the plant is brown and is not septic. At this point
we believe the plant has recovered and we are now in control of the plant dynamics.
Initially, our weekly testing was failing Bio-Chemical Oxygen Demand (BOD), Fecal Coliform,
and Ammonia/Nitrogen. However, in our most recent tests we have passed Fecal, but still are
failing BOD and Ammonia, although we are closer to meeting the required limits.
-MC Dot ofE MT0V ntb'1 Ouaiit)
APR 15 MO
Plan of Action leigh Fegioaal Office
The ORC has determined a course of action to return the plant to proper operational capability:
1. Brief the Town's Board of Commissioners on the status of the WWTP and receive
funding to achieve the following steps — COMPLETED 2/25/2020
2. Schedule a WWTP evaluation with Dwight Lancaster of the Rural Water Authority —
COMPLETED 3/4/2020
3. Identify source of Chlorine piping leak and replace piping to the pump inlet to support
proper dichlorination process operation. LEAK IDENTIFIED AND REPAIRED,
ADDITIONAL LINE INSTALLED FROM CHLORINE TANK TO PUMP,
OPERATION NORMAL. COMPLETED 315/2020
4. Request Charles Underwood & Associates, as the nearest dealer for our brand of Grit
Chamber, investigate design changes and/or repairs to bring it into an operational status.
2

Contract with Charles Underwood & Associates to install at least one RAS pump and
replace the controller and wiring - CONTROLLER AND ONE RAS PUMP
INSTALLED 3/30/2020
b. Contact Jason Smith of Granville Farms for the removal of 100 — 200,000 gallons of
sludge--350,000 GALLONS OF SLUDGE BEING LAND APPLIED 4/5/2020
7. Contract with Charles Underwood & Associates to rebuild Tertiary Filter Pumps 1 & 2
COMPLETED 3/31/2020
8. Contract with Charles Underwood & Associates to remove the Skimmer Box piping and
submersible pump from Clarifier #1 and return to pumping activated sludge through the
RAS pump
9. Return Clarifier #2 to service —RETURNED TO SERVICE 3/10/202
10. (Priority #2) Contract with Charles Underwood & Associates to repair Tertiary Filter
#1 and remove, or valve, the bypass piping around the Tertiary Filters. AWAITING
PROPOSAL FROM UNDERWOOD, EXPECT FUNDING FROM BOARD ON 4/7
11. Town personnel will replace.'repair the Heater and Exhaust fan in the Influent Pump
Room -- COMPLETED 3/7/2020
12. Remove sludge buildup in the Contact Chamber. COMPLETED AND WILL BE AN
ONGOING OPERATIONAL MAINTENANCE REQUIREMENT
13. Replace the missing blower unit on #1 Post Aeration Blower, there is currently no blower
installed.
14. (New Item Priority #1) Install new rotating assembly in Main Influent Pump #1 and
install a new motor. QUOTE RECEIVED, SEEKING FUNDING 4/7 FROM BOARD.
The Board has previously okayed the purchase, we just needed a proposal.
Future Actions
1. Modify the Town's permit to allow use of the Drying Beds for removal of sludge from
the Plant.
2. ORC, Collections and Administrator investigate lift stations to identify abnormal flows.
Once identified, if any, obtain services from the Rural Water Association to smoke test
the area in an effort to identify intrusion and infiltration sources.
As can be seen from the items above in the Plan of Action, the Town is moving forward to
provide the services and equipment needed to stabilize the plant operations. We have added a
new item, which is currently our priority number one to complete, the repair of the #1 Main
Influent pump, which has been out of commission for some years. Recently, during a high flow
situation, Main Influent Pump #3 experienced loss of all 3 drive belts. The flow could not be
3

handled by only one Main Influent pump, and a Bypass occurred. The ORC immediately
contacted Mitch Hays, and a Bypass, 5-Day Reporting Form was submitted. This event required
us to add Main Influent pump #1 as our number 1 priority to decrease the chance of future
Bypass incidents.
If you have any questions regarding this update, please do not hesitate to contact me at
252.826.3152.
Sincerely,
Charles Baisey
Administrator
4
NC Dept Of Environmental Quality
APR 1.5 2a
Raleigh Regional office

r

G',�
Ree V ✓(& tea.,
W11/202n
TOWN OF SCOTLAND NECK
P.O. Box 537
1310 MAIN STREET
SCOTLAND NECK, NC 27874
April 6, 2020
Charles W. Baisey
Administrator
PO Box 537
Scotland Neck, NC 27874-0537
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section,
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Updated Response to Scott Vinson Letter dated February 28, 2020, NOTICE OF
VIOLATION & INTENT TO ASSESS CIVIL PENALTY, NOV-2020-PC-0115
Dear Mr. Vinson:
I am writing today to provide you an update on the status of the Town of Scotland Waste Water
Treatment Plant. As I noted in my letter of March 17, 2020 the Official Responsible -In -Charge
(ORC) has been facing a plant overrun by solids with many mechanical issues that prevent the
proper operation of the plant.
In our initial presentation to the Board they responded with unanimous support of the ORC's
efforts to fix the plant. The following items have been funded and completed:
1. A new controller at the Deep Well capable of supporting two Returned Activated Sludge
(RAS) pumps
2. The installation of a single RAS pump as requested by the ORC, instead of two, so we
could do more with the limited finances available to the Board. Second RAS pump is
budgeted for next fiscal year.
3. Contracted with Granville Farms to pump and land -apply 350,000 gallons of sludge,
primarily from the Digester
"This Institution is an equal opportunity provider and employer'
www.townofscotiandneck.com
Phone: [phone] • Fax: [phone] - email: [e-mail]

4. Replaced the internal rotating assemblies for both Variable Frequency Drive (VFD)
Tertiary Filter Gorham -Rupp pumps
5. Replaced the heater and the ventilation fan in the Tertiary filter pump station
6. Repaired the failed Contact Chamber Chlorine pump and replaced the clogged chlorine
supply hose. We also repaired the Chlorine Pump that serves to pre -treat the influent
from the Tertiary Filter pump station.
7. We replaced the failed Caustic pump located in the Main Influent Pump Station, and new
hoses were installed, and the new pump was relocated for better access.
8. We installed a new 40OKW Tier 4 Backup Generator and new Transfer Switch
9. Placed Clarifier #2 online
10. Reconnected the Influent Pump Station alarm system, though adjustments are still
needed.
In addition, during the inspection by Cheng Zhang, it was noted the Oxidation Ditch was black in
color and septic. After the RAS pump was installed the ORC was able to run the Aerator for
sufficient time to bring the plant back into conformance. The Dissolved Oxygen (DO) was .3
mg/l initially and is now steady at 1.3 mg/l. The Mixed Liquor Suspended Solids (MLSS),
initially at 16,000 mg/l are now 5,400 mg/l and the plant is brown and is not septic. At this point
we believe the plant has recovered and we are now in control of the plant dynamics.
Initially, our weekly testing was failing Bio-Chemical Oxygen Demand (BOD), Fecal Coliform,
and Ammonia/Nitrogen. However, in our most recent tests we have passed Fecal, but still are
failing BOD and Ammonia, although we are closer to meeting the required limits.
Plan of Action
The ORC has determined a course of action to return the plant to proper operational capability;
1. Brief the Town's Board of Commissioners on the status of the WWTP and receive
funding to achieve the following steps - COMPLETED 2/25!2020
2. Schedule a WWTP evaluation with Dwight Lancaster of the Rural Water Authority —
COMPLETED 3/4/2020
3. Identify source of Chlorine piping leak and replace piping to the pump inlet to support
proper dichlorination process operation. LEAK IDENTIFIED AND REPAIRED,
ADDITIONAL LINE INSTALLED FROM CHLORINE TANK TO PUMP,
OPERATION NORMAL. COMPLETED 3/5/2020
4. Request Charles Underwood & Associates, as the nearest dealer for our brand of Grit
Chamber, investigate design changes and/or repairs to bring it into an operational status.

Contract with Charles Underwood & Associates to install at least one RAS pump and
replace the controller and wiring CONTROLLER AND ONE RAS PUMP
INSTALLED 313012020
6. Contact Jason Smith of Granville Farms for the removal of 100 - 200,000 gallons of
sludge-350,000 GALLONS OF SLUDGE BEING LAND APPLIED 4/5/2020
7. Contract with Charles Underwood & Associates to rebuild Tertiary Filter Pumps 1 & 2 -
COMPLETED 3/3112020
8. Contract with Charles Underwood & Associates to remove the Skimmer Box piping and
submersible pump from Clarifier # 1 and return to pumping activated sludge through the
RAS pump
9. Return Clarifier #2 to service - RETURNED TO SERVICE 3/10/202
10. (Priority #2) Contract with Charles Underwood & Associates to repair Tertiary Filter
#land remove, or valve, the bypass piping around the Tertiary Filters. AWAITING
PROPOSAL FROM UNDERWOOD, EXPECT FUNDING FROM BOARD ON 4/7
11. Town personnel will replac&repair the Heater and Exhaust fan in the Influent Pump
Room COMPLETED 31712020
12. Remove sludge buildup in the Contact Chamber. COMPLETED AND WILL BE AN
ONGOING OPERATIONAL MAINTENANCE REQUIREMENT
13. Replace the missing blower unit on #1 Post Aeration Blower, there is currently no blower
installed.
14. (New Item Priority #1) Install new rotating assembly in Main Influent Pump 91 and
install a new motor. QUOTE RECEIVED, SEEKING FUNDING 4/7 FROM BOARD.
The Board has previously okayed the purchase, we just needed a proposal.
Future Actions
1. Modify the Town's permit to allow use of the Drying Beds for removal of sludge from
the Plant.
2. ORC, Collections and Administrator investigate lift stations to identify abnormal flows.
Once identified, if any, obtain services from the Rural Water Association to smoke test
the area in an effort to identify intrusion and infiltration sources.
As can be seen from the items above in the Plan of Action, the Town is moving forward to
provide the services and equipment needed to stabilize the plant operations. We have added a
new item, which is currently our priority number one to complete, the repair of the #1 Main
Influent pump, which has been out of commission for some years. Recently, during a high flow
situation, Main Influent Pump #3 experienced loss of all 3 drive belts. The flow could not be

handled by only one Main Influent pump, and a Bypass occurred. The ORC immediately
contacted Mitch Hays, and a Bypass, 5-Day Reporting Form was submitted. This event required
us to add Main Influent pump #1 as our number 1 priority to decrease the chance of future
Bypass incidents.
If you have any questions regarding this update, please do not hesitate to contact me at
252.826.3152.
Sincerely,
Charles Baise
Y
Administrator

Manuel, Vanessa
From: Vinson, Scott
Sent: Tuesday, April 7, 2020 8:57 AM
To: Manuel, Vanessa
Subject: FW: [External] FW: Attached Image
Attachments: Attached Image
fyi
Scott Vinson
Regional Supervisor
Raleigh Regional Office
Water Quality Regional Operations Section
NCDEQ -- Division of Water Resources
3800 Barrett Drive
Raleigh, NC 27609
[phone] office
[phone] direct line
Email: Scott.VinsonCa?ncdenr_gov
�D E_
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Hayes, Mitch
Sent: Tuesday, April 7, 2020 8:41 AM
To: Vinson, Scott <[e-mail]>
Subject: FW: [External] FW: Attached Image
Scott,
Notes from Scotland Neck attached.
Mitch
Mitch Hayes, Environmental Specialist
NCDEQ - Division of Water Resources
Water Quality Regional Operations Section
1629 MSC, Raleigh, NC 27699-1699
(P) 919.791.4261- (F) 919.788,7159
htto:l/portal.ncdenr.ore/web/wa/
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be disclosed to third parties.
From: [e-mail] <pbovd@townofscotland neck. com>
Sent: Tuesday, April 07, 2020 8:23 AM
To: Hayes, Mitch <[e-mail]>

Cc: [e-mail]
Subject: [External] FW: Attached Image
External #mail. Do'not click.links or open attachments upless you verify. Send all suspicious email as an aftachment-to
[e-mail]
Hey Mitch, Would you forward this letter to Scott Vinson please. A hard copy will go out in the mail today.
Thanks

o� SCOTIq �O
4
to 1Z�
RTC CA1�pv
TOWN OF SCOTLAND NECK
P.O. Box 537
1310 MAIN STREET
SCOTLAND NECK, NC 27874
March 17, 2020
Charles W. Baisey
Administrator
PO Box 537
Scotland Neck, NC 27874-0537
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section,
Raleigh Regional Office
Division of Water Resources, NCDEQ
1628 Mail Service Center
Raleigh, NC 27699-1628
?VC DeptOfEnvrrenMentil nc,
a1�ty
MAID 1 � 11�rl
Neigh Reg1plaal Office
Subject: 10-day Response to Scott Vinson Letter dated February 28, 2020, NOTICE OF
VIOLATION & INTENT TO ASSESS CIVIL PENALTY, NOV-2020-PC-0115
Attachment 1: Waste Water Treatment Plant Evaluation dated March 4, 2020, authored by
Dwight Lancaster of the Rural Water Association
Dear Mr. Vinson:
The Town of Scotland Neck (TSN) is in receipt of your subject letter and, as requested, we
submit this letter and attachment in response. We acknowledge the results of the inspection
completed by Cheng 'Lang and Mitch Hays on February 25, 2020 and do not find any issue with
the results as reported, the TSN is in complete agreement with the findings.
In 2003 the TSN entered into a contract with United Water for assistance in running the
municipal Waste Water Treatment Plant (WWTP). That initial assistance grew, and in 2011
United Water, then owned by, and renamed Suez, contracted to manage the Town's Public
Works Department including the Water and Streets Divisions as well as the WWTP. Over the
years Suez provided the services required by the Town in accordance with the contract, but
eventually the cost of this contract became an undue burden on the financial health of the Town.
On February 1, 2020 the Town of Scotland Neck resumed the oversight and management of the
Town employees in the Public Works Department including Water, Streets and Waste Water
Treatment Plant operations.
"This Institution is an equal opportunity provider and employer'
www.townofscotlandneck.com
Phone: [phone] • Fax: [phone] - email: [e-mail]

Upon gaining the WWTP back into the Town's operational responsibility, the prospective
Operator Responsible in Charge (ORC), Mr. Parks Boyd, and the Town Administrator, Mr.
Charles Baisey, toured the plant noting the many deficiencies that existed. There were three
non -permitted modifications to the plant:
1. Two bypass pipes had been installed around the Tertiary Filter providing a constant path
for solids to bypass the filters.
2. The Skimmer Pump box on Clarifier #1 has been modified into a sludge return (RAS)
pump through the installation of a pipe and submersible pump hanging by a rope tied to
the hand rail. This installation prevents the operation of the skimmer in Clarifier #1.
3. Clarifier #2 has been taken offline and is being used as a sludge storage tank. This
reduces the detention time of influent going to the Tertiary Filter and requires Clarifier #1
to carry the entire load of the plant.
These three non -permitted modifications have had a severe impact on the WWTP operations:
l . The non -isolable bypass pipes around the Tertiary Sand Filters are of great significance
in the degraded status of the plant. These pipes provide the majority of the flow during
plant operation, which occurs around the filters resulting in very little water from
Clarifier #1 being filtered at all. This is evident in the number of solids that exist in the
Contact Chamber, which cannot be reduced as long as the bypass pipes remain in place.
Given the circumstances of very high flow rates and a very high sludge blanket in the
Clarifier, any solids over the weir were bound to end up in the Contact Chamber as the
flow followed the path of least resistance through the Bypass pipes. These pipes should
never have been approved for installation.
2. The Clarifier #1 "Pump on a Rope" is confounding to say the least. Had the RAS pumps
been fixed or replaced this non -permitted modification would not have been necessary,
but the Operator chose to install piping, valving, and a submersible pump on a rope
instead. The pump cannot pump at the rate required to provide the needed sludge blanket
in Clarifier #1. This modification should never have been authorized.
3. Placing Clarifier #2 offline as a storage tank was a secondary function of the loss of the
RAS pumps. Since the RAS pumps were not installed, activated sludge could not be
returned to the Oxidation Ditch, so rather than repair the RAS pumps, the Operator chose
to take the Clarifier off line.
These three non -permitted modifications indicate to me that the previous Operator had a
capricious nature regarding their ability to make modifications at will, with no fear of any
consequential actions befalling them. These modifications were not approved by the TSN Board
2

of Commissioners. It brings to mind, to question, what modifications are being made without
approval at the other plants currently being operated by the previous operator of the TSN
WWTP.
Additionally, the following equipment is either out of commission, or has been removed and has
not been replaced:
1, The Grit Chamber is out of commission, and has been for several years
2. The Influent Pump #3 is inoperable, the motor has been disconnected and not repaired
over a period of years
3. The Oxidation Ditch Aerator #2 has an improperly repaired rotor, and is out of
commission, since 11/7/2019, until the installation of a new rotor
4. The Return Activated Sludge (RAS) Pumps are not installed in the Deep Well, nor have
they been installed for a period greater than two years.
5. Influent Filter VFD Pump #1 is out of commission, and has been for several months, if
not years, and requires a complete overhaul. Influent Filter VFD Pump #2 has a seal leak.
b. The Tertiary Filter #1 has been out of commission for years and requires a complete
overhaul
7. The Tertiary Filter #2 skimmer pump system has been out of commission for years and
requires replacement
8. The Pump House Heater and Exhaust fan have been out of commission for years and
both units require repair or replacement
9. Excessive sludge exists in the Contact Chamber
10. The Post Aeration Blower #1 is out of commission, missing the blower, fan belt and other
required items
11. Chlorine piping from the chlorine tank to the pump was clogged and a broken line was
discovered between the pump and the Contact Chamber
In addition to the points identified above, and on Cheng Zang's inspection report, the amount of
sludge in the plant is compromising the ability of the Operator to satisfactorily operate the plant.
This became apparent during the recent weather related high influent flow rates which limited
the Operator's courses of action. The weather in turn eliminated Land Application as a means of
3

sludge removal, requiring additional methods to be investigated and costed before adequate
sludge removal operations could be conducted.
It is important to note that none of the issues noted during Cheng Zang's inspection had been
reported to the TSN Board of Commissioners prior to 2/l/2020, nor was any financial request
made to fix, repair or replace any of the noted equipment deficiencies until after the TSN
personnel started operating the WWTP on 2/l/2020. Subsequent to our initial inspections, the
ORC sought out assistance from Dwight Lancaster of the Rural Water Association, Glen Holland
ORC of Mount Olive and instructor on WWTP operations, Roy Whitaker for sludge removal,
Jason Smith of Granville Farms for Land Application sludge removal, Russel Underwood and
Zac Scott of Charles Underwood and Associates for RAS pump identification and installation.
The ORC and Town Administrator worked together to determine possible courses of action and
to determine the best route to achieving a fully operational WWTP within the financial
restrictions of the Town.
Prior to Cheng Zang's inspection, the plant had reached a septic point, with the Dissolved
Oxygen (DO) in the Oxidation Ditch reaching a low of .3 mg/ml, and the foam had a very black
appearance with a strong septic smell. As of today, the DO is at 1.1 mg/ml and the foam is
brown with no septic smell present. The ORC, Parks Boyd, has worked with several industry
experts and Dwight Lancaster to improve plant operations but has been confounded by flows of
900,000 gallons a day for the first three weeks of February due to inflow and infiltration during
the heavy rains. Additionally, the huge amount of sludge in the plant reduced the options
available to the ORC and prevented running the aerators for any length of time without solids
overflowing the weir in the #1 Clarifier. This in turn reduced DO to .3 mg/ml and eventually
caused a septic condition in the plant. The ORC worked as hard, and as diligently, as any could
in those circumstances, and with a reduced flow through the plant brought on by good weather,
was able to regain control of the plant operations and bring the plant back into operational limits.
Plan of Action
The ORC has determined a course of action to return the plant to proper operational capability:
1. Brief the Town's Board of Commissioners on the status of the WWTP and receive
funding to achieve the following steps — COMPLETED 2/25/2020
2. Schedule a WWTP evaluation with Dwight Lancaster of the Rural Water Authority —
COMPLETED 3/4/2020, SEE ATTACHMENT 1
3. Identify source of Chlorine piping leak and replace piping to the pump inlet to support
proper dichlorination process operation. LEAK IDENTIFIED AND REPAIRED,
ADDITIONAL LINE INSTALLED FROM CHLORINE TANK TO PUMP,
OPERATION NORMAL. COMPLETED 3/5/2020
4

4. Request Charles Underwood & Associates, as the nearest dealer for our brand of Grit
Chamber, investigate design changes and/or repairs to bring it into an operational status.
5. Contract with Charles Underwood & Associates to install at least one RAS pump and
replace the controller and wiring — FUNDING OBTAINED INSTALLATION 3/30/2020
6. Contact Jason Smith of Granville Farms for the removal of 100 --- 200,000 gallons of
sludge — CONTRACT APPROVED AND FUNDED FOR 350,000 GALLONS
7. Contract with Charles Underwood & Associates to rebuild Tertiary Filter Pumps 1 & 2 —
CONTRACT APPROVED AND FUNDED SCHEDULED FOR 3/30/2020
8. Contract with Charles Underwood & Associates to remove the Skimmer Box piping and
submersible pump from Clarifier #1 and return to pumping activated sludge through the
RAS pump
9. Return Clarifier #2 to service - - RETURNED TO SERVICE 3/10/202 FOR 6 HOURS A
DAY UNTIL RAS PUMPS ARE INSTALLED
10. Contract with Charles Underwood & Associates to repair Tertiary Filter #land remove,
or valve, the bypass piping around the Tertiary Filters.
11. Town personnel will replace -'repair the Heater and Exhaust fan in the Influent Pump
Room COMPLETED 3/712020
12. Remove sludge buildup in the Contact Chamber. COMPLETED AND WILL BE AN
ONGOING OPERATIONAL MAINTENANCE REQUIREMENT
13. Replace the missing blower unit on #1 Post Aeration Blower, there is currently no blower
installed.
Future Actions
1. Modify the Town's permit to allow use of the Drying Beds for removal of sludge from
the Plant.
2. ORC, Collections and Administrator investigate lift stations to identify abnormal flows.
Once identified, if any, obtain services from the Rural Water Association to smoke test
the area in an effort to identify intrusion and infiltration sources.
This Action Plan is designed to bring the Town of Scotland Neck's Waste Water Treatment Plant
into conformance with the engineering plans and specifications, thereby achieving compliance
with the North Carolina Department of Environmental Quality, Division of Water Resources
governing system requirements. Additionally, Dwight Lancaster of the Rural Water Association
conducted an evaluation of the TSN WWTP, his results are contained in Attachment 1.
In closing, let me emphasize the support, both financially and personally, that has been provided
to this effort by the Mayor and Board of Commissioners of the Town of Scotland Neck. The
5

Mayor and the Board are committed to make continuous improvement in the WWTP as the
highest priority in the coming months and in the 2020-2021 Budget. As we focus the Town's
limited financial resources towards repairs on the WWTP, we would humbly request that your
office would consider waiving any financial penalty.
If you have any questions regarding this response, please do not hesitate to contact me at
252.826.3152,
Sincerely,
C krc��,B I
Charles Baisey
Administrator 77
P.

CL Ck on e (-) 4
Town of Scotland Neck
NPDES NCO023337
Plant Evaluation
March a, 2020
NCDePtofFnv rUnmentaI
Qua,
MAR 2.1 020
&lcigh Regional OfPic
e
On February 1, 2020, the Town of Scotland Neck resumed operation of the Wastewater Treatment Plant
(WWTP). The Town's staff encountered several challenges with the operation of the facility along with
permit non-compliance issues. The Town requested assistance from NC Rural Water Association in
evaluating the facilities. A cursory review of the WWTP was done on March 2"d and 31. The following
comments and observations are a result of this review:
Preliminary Treatment
Bar Screen
One of the bars at the bottom of the screen is broken and pulled out of the water flow. Several of the
other bars are pushed to the side. This creates a hole in the screen that will allow a significant amount
of debris to pass by the screen and enter the flow channel and impact downstream processes. The bars
should be repaired.
The drainpipe for the screenings auger is disconnected. This allows wastewater to flow on the ground.
Grit Removal
The grit removal system consists of two grit pumps and a grit classifier. All these units are out of service.
Grit is removed from the wastewater to prevent accumulation in downstream basins and to prevent
excessive wear on pumps. To accomplish grit removal, the flow needs to slowed to approximately 1 fps
to allow heavier grit to settle out. It appears that the existing grit removal system will not effectively
remove grit even if all components were operational. The grit system is the old original grit chamber
that had a flight and chain to move settled grit to a sump. The flight and chain were removed, the
chamber was cut in to just downstream of the grit sump to install a line to the newer influent pump
station. The suction for the two grit pumps are in this sump. It is not expected that significant grit
removal will be accomplished by gravity settling of grit into this sump.
Influent Pump Station
There are three influent pumps in the influent pump station. One of the pumps is out -of -service at this
time. Operational controls of the pumps were not evaluated.
Chemical Feed System
A caustic feed system is set up inside the influent pump station to provide pH adjustment as needed.
There is one chemical feed pump which sets on top of the control panel for the influent pumps. If this
pump or the tubing going to/from the pump fails, caustic could enter the control panel (door does not

%. f

seal properly) and cause electrical failure of the influent pumps. Additionally, placement of the pump is
a safety hazard.
The storage tank for the 25% caustic is inside the influent pump station building. It appears that
fumes/spills from this tank has caused deterioration of the building and could possibly cause premature
failure of electrical components.
Biological Treatment Process
Oxidation Ditch
The oxidation ditch has two brush aerators to provide mixing and dissolved oxygen (DO) to the biological
system. The operation of the aerators is -essential to the successful operation of the biological
treatment system. One of the aerators is out -of -service and will have negative impacts on plant
operations. During the evaluation period, the DO levels in the oxidation ditch were significantly less
than the recommended DO levels for proper treatment.
The oxidation ditch is approximately four feet deep with sloped sides. Information was not readily
available to determine the volume or dimensions of the oxidation ditch. The ditch was probed from
each side in an effort to determine the amount of grit/sludge accumulation in the bottom of the
oxidation ditch. Two locations had a "sludge bank" in which the debris was nearly to the top of the
water level and extended for b+ feet. Several locations had accumulations of 2 -3 feet.
When the debris was probed, a significant release of hydrogen sulfide gas was released. The production
and release of hydrogen sulfide in the ditch can cause a drop in pH. The debris accumulation in the ditch
also reduces the amount of detention time for biological treatment and could negatively affect
compliance.
Secondary Clarifiers
There are two secondary clarifiers: Clarifier #1— the larger peripheral feed clarifier, and; Clarifier #2 --
the smaller center feed clarifier. The purpose of the clarifiers is to allow the biological floc to settle to
the bottom and a clarified effluent to flow over the top into the weirs and then to filtration. The settled
sludge is returned to the oxidation ditch.
Clarifier #2 was not in service during the evaluation because the Return Activated Sludge (RAS) pump
was inoperable. The clarifier was cut on briefly and it does appear to be operational. The caulking at
weirs is coming out and the concrete is showing signs of erosion.
Clarifier #1 was in operation during the evaluation. The clarifier appears to have been modified by
installing a small pump in the scum pit for return sludge pumping. This may have been necessitated by
the failure of the RAS pumps in the Return Sludge Pump Station. The purpose of the RAS pump is to
remove the settled sludge/bacteria from the clarifier and return to the oxidation ditch. Insufficient RAS
pumping can cause a high sludge blanket to develop in the clarifier and possible overflow of the blanket

I

to the following treatment processes. During the evaluation, the pump was insufficient to maintain a
low sludge blanket in the clarifier. The aerator in the oxidation ditch was having to be cut off to reduce
the solids going to the clarifier and allow the return pump to catch up.
Excessive debris has accumulated between the outside wall and the influent baffle on Clarifier #1. The
baffle wall is somewhat deflected at this area, possibly due to this buildup.
Return Sludge Pump Station
This pump station not only serves as the RAS pump station but also directs different flows (wastewater
and sludge) to different locations around the plant site. The pumps in the pump station were
inoperable. Clarifier #2 can not properly operate with this station out -of -service which increases the
hydraulic and sludge loading on Clarifier #.i The loss of this station impacts wasting of excess sludge
and other areas of wastewater operation.
Filter Pump Station
This pump station takes effluent flow from the clarifier and pumps it to the sand filters. A failure of this
system could cause a spill. There are two pumps in this station. Pump #1 is out -of -service. The door
closure to the pump control panel is broken and will not latch. This will allow insects to enter and
possibly cause problems. There is also a strong hydrogen sulfide odor in the pump station. This gas is
corrosive and could damage electrical and mechanical components.
Advanced Treatment
Sand Filters
Sand filters provide enhanced treatment by both physical and biological process. There are two sand
filters. #2 sand filter is out -of -service and #1 sand filter can only me operated in manual mode.
Necessary repairs and programming should be made to place the filters in automatic operation. The
operation of the sand filters is also hampered by the lack of room in the digestor for storage of the filter
backwash.
Disinfection
Chlorination/Dechlorination
Chlorination is accomplished by adding sodium hypochlorite to the wastewater flow prior to the
chlorine contact chamber. The dosage is dependent on several factors, including: quality of
wastewater, temperature, pH, detention timr_, etc. The chlorine contact chambers had an accumulation
of sludge in the bottom of the basin of 12+ inches. This accumulation can impact disinfection. The state
generally wants the chlorine contact chamber when the sludge accumulation reaches six inches. The
chamber was dye tested to determine actual detention time. The chamber is designed for a detention

Im

time of 30 minutes at design flow. The detention time was approximately 20 minutes at one-half the
design flow.
Disinfection is a critical process and it is recommended that there be spare pumps and parts for both the
chlorination and dichlorination pumps.
Sampling
Sampler
The permit requires effluent sampling to be flow proportional. This requirement is not enforced equally
among the seven NC DWR Regional Offices and has not been enforced at this facility. The samples are
time composited.
Each discrete sample taken is required to be a minimum of 100 mi. Sample volume and number of
samples taken in a 24-hour period should be adjusted to achieve the 100 ml sample volume and the
minimum amount of composite sample volume needed for testing.
Sludge Handling
Digestor
The sludge digestor was completely filled at the time of the evaluation. Plant staff had cut off the
aeration system to allow the sludge to settle and to decant clear water from the top, but the sludge was
too thick.
Every biological wastewater treatment plant creates new sludge/bacteria at all times. A successful
operation requires the excess sludge to wasted out of the system on a regular basis. With the full
digester, the staff can not remove the extra sludge and the failure to do so is having negative impacts on
plant operation and compliance.
Operations
Major Issues
At the time of the evaluation, there were several operational issues occurring that were detrimental to
proper operations and compliance. The major contributory factor is the inability to waste excessive
sludge from the system. This failure affects the oxidation ditch, clarifiers, filters and disinfection. Some
(but not all) of the issues are:
• High MLSS— normal range for MLSS concentration is 2,500 — 3,500 mg/L. Lab data from January
2020 shows the MLSS concentration to have been in the 8,000 — 9,000 mg/L range. Most
recently, due to minimum wasting, the MLSS was approximately 6,000 mg/L.
• DO in Oxidation Ditch — bacteria growing in the oxidation ditch require minimum DO levels for
respiration. The normally accepted DO level for proper operation is approximately 2.0 mg/L.

t�.

The DO in the ditch has been in the 0.4 mg/L range. This low number affects bacterial health,
thereby affecting BODs, Ammonia Nitrogen, TSS and TP reduction.
o The minimum DO level is not being achieved because: The aerators can not be run
continuously due to the high MLSS concentrations overwhelming the clarifiers and
because one of the aerators in inoperable.
• Return Sludge Pump Station — The failure of this station prevents #2 clarifier from being put in
service, which puts a strain on the #1 clarifier.
• #1 Clarifier Return Pump — a combination of high MLSS and the low pumping capacity of the
return sludge pump causes the sludge blanket in the clarifier to rise and to get excessively thick.
Reducing the MLSS, increasing the capacity of this pump and/or returning the RAS Pump Station
to service are needed.
• Digestor — immediate sludge removal from the digestor is needed. The sludge can be land
'Applied as a liquid or a dewatering box or other dewatering device can be used to remove tha
sludge from the facility.
Anoxic Zone
The anoxic zone at the digestor does not appear to have been used recently. The anoxic zone is
designed to reduce the total nitrogen content of the wastewater. If the facility is not meeting their Total
Nitrogen limits as required by the Tar -Pamlico River Association, then this process should be placed in
service.
Process Control
To properly operate the WWTP and maintain the optimal operating environment, staff needs to
evaluate and document plant activities.
■ MLSS meter
■ Microscope
■ Computer
■ Various process test modules for the spectrophotometer
Miscellaneous
This evaluation reviewed the most serious of the mechanical and operational issues that were apparent
during a quick review of the facilities. During the evaluation, several safety deficiencies and possible
OSHA violations were observed. In addition to the major mechanical and equipment failures, there
were a number of minor maintenance issues that have not been addressed that could result in larger
problems if not addressed.

Town of Scotland Neck
NPDES NC0023337
Plant Evaluation
March 4, 2020
On February 1, 2020, the Town of Scotland Neck resumed operation of the Wastewater Treatment Plant
(WWTP). The Town's staff encountered several challenges with the operation of the facility along with
permit non-compliance issues. The Town requested assistance from NC Rural Water Association in
evaluating the facilities. A cursory review of the WWTP was done on March 2"d and 3`d. The following
comments and observations are a result of this review:
Preliminary Treatment
Bar Screen
One of the bars at the bottom of the screen is broken and pulled out of the water flow. Several of the
other bars are pushed to the side. This creates a hole in the screen that will allow a significant amount
of debris to pass by the screen and enter the flow channel and impact downstream processes. The bars
should be repaired.
The drainpipe for the screenings auger is disconnected. This allows wastewater to flow on the ground.
Grit Removal
The grit removal system consists of two grit pumps and a grit classifier. All these units are out of service.
Grit is removed from the wastewater to prevent accumulation in downstream basins and to prevent
excessive wear on pumps. To accomplish grit removal, the flow needs to slowed to approximately 1 fps
to allow heavier grit to settle out. It appears that the existing grit removal system will not effectively
remove grit even if all components were operational. The grit system is the old original grit chamber
that had a flight and chain to move settled grit to a sump. The flight and chain were removed, the
chamber was cut in to just downstream of the grit sump to install a line to the newer influent pump
station. The suction for the two grit pumps are in this sump. It is not expected that significant grit
removal will be accomplished by gravity settling of grit into this sump.
Influent Pump Station
There are three influent pumps in the influent pump station. One of the pumps is out -of -service at this
time. Operational controls of the pumps were not evaluated.
Chemical Feed System
A caustic feed system is set up inside the influent pump station to provide pH adjustment as needed.
There is one chemical feed pump which sets on top of the control panel for the influent pumps. If this
pump or the tubing going to/from the pump fails, caustic could enter the control panel (door does not

seal properly) and cause electrical failure of the influent pumps. Additionally, placement of the pump is
a safety hazard.
The storage tank for the 25% caustic is inside the influent pump station building. It appears that
fumes/spills from this tank has caused deterioration of the building and could possibly cause premature
failure of electrical components.
Biological Treatment Process
Oxidation Ditch
The oxidation ditch has two brush aerators to provide mixing and dissolved oxygen (DO) to the biological
system. The operation of the aerators is essential to the successful operation of the biological
treatment system. One of the aerators is out -of -service and will have negative impacts on plant
operations. During the evaluation period, the DO levels in the oxidation ditch were significantly less
than the recommended DO levels for proper treatment.
The oxidation ditch is approximately four feet deep with sloped sides. Information was not readily
available to determine the volume or dimensions of the oxidation ditch. The ditch was probed from
each side in an effort to determine the amount of grit/sludge accumulation in the bottom of the
oxidation ditch. Two locations had a "sludge bank" in which the debris was nearly to the top of the
water level and extended for 6+ feet. Several locations had accumulations of 2 -3 feet.
When the debris was probed, a significant release of hydrogen sulfide gas was released. The production
and release of hydrogen sulfide in the ditch can cause a drop in pH. The debris accumulation in the ditch
also reduces the amount of detention time for biological treatment and could negatively affect
compliance.
Secondary Clarifiers
There are two secondary clarifiers: Clarifier #1— the larger peripheral feed clarifier, and; Clarifier #2 —
the smaller center feed clarifier. The purpose of the clarifiers is to allow the biological floc to settle to
the bottom and a clarified effluent to flow over the top into the weirs and then to filtration. The settled
sludge is returned to the oxidation ditch.
Clarifier #2 was not in service during the evaluation because the Return Activated Sludge (RAS) pump
was inoperable. The clarifier was cut on briefly and it does appear to be operational. The caulking at
weirs is coming out and the concrete is showing signs of erosion.
Clarifier #1 was in operation during the evaluation. The clarifier appears to have been modified by
installing a small pump in the scum pit for return sludge pumping. This may have been necessitated by
the failure of the RAS pumps in the Return Sludge Pump Station. The purpose of the RAS pump is to
remove the settled sludge/bacteria from the clarifier and return to the oxidation ditch. Insufficient RAS
pumping can cause a high sludge blanket to develop in the clarifier and possible overflow of the blanket

to the following treatment processes. During the evaluation, the pump was insufficient to maintain a
low sludge blanket in the clarifier. The aerator in the oxidation ditch was having to be cut off to reduce
the solids going to the clarifier and allow the return pump to catch up.
Excessive debris has accumulated between the outside wall and the influent baffle on Clarifier #1. The
baffle wall is somewhat deflected at this area, possibly due to this buildup.
Return Sludee Pump Station
This pump station not only serves as the RAS pump station but also directs different flows (wastewater
and sludge) to different locations around the plant site. The pumps in the pump station were
inoperable. Clarifier #2 can not properly operate with this station out -of -service which increases the
hydraulic and sludge loading on Clarifier #1. The loss of this station impacts wasting of excess sludge
and other areas of wastewater operation.
Filter Pump Station
This pump station takes effluent flow from the clarifiers and pumps it to the sand filters. A failure of this
system could cause a spill. There are two pumps in this station. Pump #1 is out -of -service. The door
closure to the pump control panel is broken and will not latch. This will allow insects to enter and
possibly cause problems. There is also a strong hydrogen sulfide odor in the pump station. This gas is
corrosive and could damage electrical and mechanical components.
Advanced Treatment
Sand Filters
Sand filters provide enhanced treatment by both physical and biological process. There are two sand
filters. #2 sand filter is out -of -service and #1 sand filter can only me operated in manual mode.
Necessary repairs and programming should be made to place the filters in automatic operation. The
operation of the sand filters is also hampered by the lack of room in the digestor for storage of the filter
backwash.
Disinfection
Chi orination/Dechlorination
Chlorination is accomplished by adding sodium hypochlorite to the wastewater flow prior to the
chlorine contact chamber. The dosage is dependent on several factors, including: quality of
wastewater, temperature, pH, detention time, etc. The chlorine contact chambers had an accumulation
of sludge in the bottom of the basin of 12f inches. This accumulation can impact disinfection. The state
generally wants the chlorine contact chamber when the sludge accumulation reaches six inches. The
chamber was dye tested to determine actual detention time. The chamber is designed for a detention

time of 30 minutes at design flow. The detention time was approximately 20 minutes at one-half the
design flow.
Disinfection is a critical process and it is recommended that there be spare pumps and parts for both the
chlorination and dichlorination pumps.
Sampling
Sampler
The permit requires effluent sampling to be flow proportional. This requirement is not enforced equally
among the seven NC DWR Regional Offices and has not been enforced at this facility. The samples are
time composited.
Each discrete sample taken is required to be a minimum of 100 mi. Sample volume and number of
samples taken in a 24-hour period should be adjusted to achieve the 100 ml sample volume and the
minimum amount of composite sample volume needed for testing.
Sludge Handling
Dieestor
The sludge digestor was completely filled at the time of the evaluation. Plant staff had cut off the
aeration system to allow the sludge to settle and to decant clear water from the top, but the sludge was
too thick.
Every biological wastewater treatment plant creates new sludge/bacteria at all times. A successful
operation requires the excess sludge to wasted out of the system on a regular basis. With the full
digester, the staff can not remove the extra sludge and the failure to do so is having negative impacts on
plant operation and compliance.
Operations
Maior Issues
At the time of the evaluation, there were several operational issues occurring that were detrimental to
proper operations and compliance. The major contributory factor is the inability to waste excessive
sludge from the system. This failure affects the oxidation ditch, clarifiers, filters and disinfection. Some
(but not all) of the issues are:
• High MLSS— normal range for MLSS concentration is 2,500-3,500 mg/L. Lab data from January
2020 shows the MLSS concentration to have been in the 8,000-9,000 mg/L range. Most
recently, due to minimum wasting, the MLSS was approximately 6,000 mg/L.
• DO in Oxidation Ditch — bacteria growing in the oxidation ditch require minimum DO levels for
respiration. The normally accepted DO level for proper operation is approximately 2.0 mg/L.

The DO in the ditch has been in the 0.4 mg/L range. This low number affects bacterial health,
thereby affecting BOD5i Ammonia Nitrogen, TSS and TP reduction.
o The minimum DO level is not being achieved because: The aerators can not be run
continuously due to the high MLSS concentrations overwhelming the clarifiers and
because one of the aerators in inoperable.
• Return Sludge Pump Station —The failure of this station prevents #t2 clarifier from being put in
service, which puts a strain on the ##1 clarifier.
• # 1 Clarifier Return Pump — a combination of high MLSS and the low pumping capacity of the
return sludge pump causes the sludge blanket in the clarifier to rise and to get excessively thick.
Reducing the MLSS, increasing the capacity of this pump and/or returning the RAS Pump Station
to service are needed.
• Digestor— immediate sludge removal from the digestor is needed. The sludge can be land
applied as a liquid or a detvatering box or other dewatering device can be used to remove the
sludge from the facility.
Anoxic Zone
The anoxic zone at the digestor does not appear to have been used recently. The anoxic zone is
designed to reduce the total nitrogen content of the wastewater. If the facility is not meeting their Total
Nitrogen limits as required by the Tar -Pamlico River Association, then this process should be placed in
service.
Process Control
To properly operate the WWTP and maintain the optimal operating environment, staff needs to
evaluate and document plant activities.
■ MLSS meter
■ Microscope
■ Computer
■ Various process test modules for the spectrophotometer
Miscellaneous
This evaluation reviewed the most serious of the mechanical and operational issues that were apparent
during a quick review of the facilities. During the evaluation, several safety deficiencies and possible
OSHA violations were observed. In addition to the major mechanical and equipment failures, there
were a number of minor maintenance issues that have not been addressed that could result in larger
problems if not addressed.

5 � y
;:�t.,
Y•
:��
Y +
,�:
_
1:..
��
t ;�
..
�I
.
R
IFS
k
�nf4
~'rM1
�}-
z