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January 15, 2014
SUBJECT:
Dear Mr. Brown:
3. All logs were in order, consistent and up to date.
1. Wastewater Treatment Plant site inspection:
Mr. R. Danieley Brown, P.E.
Chief Executive Officer fc < 3^^
Roanoke Rapids Sanitary District
Roanoke Rapids, North Carolina, 27870
Pat McCrory
Governor
Compliance Evaluation Inspection
Roanoke Rapids Wastewater Treatment Plant
Permit No: NC0024201
Halifax County
John E. Skvarla, III
Secretary
NCDENR
North Carolina Department of Environment and Natural Res<
Division of Water Resources
Water Quality Programs
Thomas A. Reeder
Director
2. This wastewater treatment plant is a Class IV facility with a design flow rate of 8.34 MOD
and discharges treated effluent into the Roanoke River in the Roanoke River Basin. Gregg
Camp is the ORC and has a Grade IV certification. The back-up operators are Greta Glover with a
Grade IV certification and Brian Williams with Grade III certification. Greta Glover is also the Lab
Supervisor and Pretreatment Coordinator.
5. The facility samples and analyses for field parameters Total Residual Chlorine, pH. Temperature and
DO. The facility also sample and analyses for all other permitted parameters with the exception of
Phosphorus, TK.N and Aquatic Toxicity. Analytical for Phosphorus, TKN and Aquatic Toxicity are
performed by Meritech. Dates and times are documented and initialed. Buffers and standards are
stored appropriately. The facility conducts the sampling.
On December 20. 2013, Mack Wiggins of the North Carolina Division of Water Resources, Water
Quality Regional Operations Section, Raleigh Regional Office, conducted a compliance evaluation
inspection of the Roanoke Rapids Wastewater Treatment Plant, (135 Aqueduct Road, Weldon, NC).
The assistance and cooperation of Mr. Gregg Camp, ORC was very helpful and appreciated during the
inspection process.
1. The facility utilizes a manual bar screen. The facility has in place a Vortex primary and gravity grit
removal system as back-up. The manual bar screen was in good condition and adequately screening
debris and the grit removal was free of excessive organic matter at the time of the inspection. Grit and
dumpster material are collected and taken to the landfill weekly. One
NofthCarolina ---------------------------------------------------------------------------------Naturally
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh. NC 27699-1628 Phone [phone]
Internet: www.ncwaterquality orq Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
4. Bench data was found to be consistent with DMR data.
1. The current NPDES Permit became effective April 1, 2013 and expires March 31,2017.
3.
4.
5.
6.
7.
8.
9.
10.
The facility has 14 drying beds present that
beds are only used in case of emergencies.
Danny Sn/fth, Supervisor
Water Quality regional Operations Section
The facility has three rectangular aeration basins operating in parallel. Jet aeration is the type of
aeration system. The basins were free of dead spots and all diffusers were operational at the time of
the inspection.
cc: Mr. Gregg Camp, ORC, Roanoke Rapids WWTP. 135 Aqueduct Road, Weldon. NC 27890
Central Files
RRO File
per month. New Dixie Fuel is the local vendor that keepsThe stand-by power is tested at load once
the tanks full.
were not being used at the time of the inspection. Drying
2. The facility has dual primary clarifiers. One primary clarifier was off line because of low flow. The
primary clarifier in operation was free of weir blockage and showed no signs of short circuiting at the
time of the inspection.
The plant has two final clarifiers with one in use at the time of the inspection due to a reduction in
flow. The final clarifier utilizes a traveling bridge. The clarifier in use was free of short circuiting,
excessive floating sludge and clear of excessive solids/pin floc.
The facility utilizes two trickling filters. One filter was in use at the time of the inspection due to a
reduction in flow. I he filter was free of sloughing of excessive growth and distribution of flow
appeared to be even from the distribution arms at the time of the inspection.
Three anaerobic digesters with floating covers are utilized that yield class B sludge for land
application. Cynagro collects the sludge every three months on average and land applies at different
farms in Halifax, Northampton and Warren Counties.
Chemicals used at the site are Calcium Hydroxide for stabilization. Sodium Hypochlorite for
disinfection and Sodium Bisulfite for de-chlorination.
The facility disinfects with Sodium Hypochlorite. Sodium Hypochlorite is stored in tanks with
secondary containment. The facility de-chlorinates with Sodium Bisulfite. Sodium Bisulfite is stored
in one tank at a volume of 4, 470 gallons. Disinfection and de-chlorination was functioning properly
at the time of the inspection.
79^4 y°Ur S C00peratl°n durinS the inspection. If you have any questions, please call Mack Wiggins at
11. The facility discharges directly into the Roanoke River. The effluent was clear with very little to no
foam at the time of the inspection.
February 18, 2013
Subject:NOTICE OF DEFICIENCY
Dear Mr. Brown:
Parameter Date
Flow 1/30/2013
11/20/2013 54.81 mg/L 45 mg/L Weekly
11/30/2013 34.7 mg/L 30 mg/L
1628 Mail Service Center, Raleigh, NC 27699-1628North Carolina Division of Water Resources
Internet: www.ncwaterflualitv.org
Total
Suspended
Solids
Total
Suspended
Solids
A review of the November 2013 Discharge Monitoring Report (DMR) revealed a monitoring and
limit violation of the following parameter(s) at Outfall 001:
Pat McCrory
Governor
Phone [phone]
Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Aclion Employer - 50% Recycled/10% Post Consumer Paper
Monthly Average
Exceeded
Mr. R. Danieley Brown
Roanoke Rapid Sanitary District
135 Aqueduct Rd.
Weldon, NC 27890
NOD-2014-LM-0001
Roanoke Rapids Sanitary District WWTP
Permit No.NC0024201
Halifax County
FEB 2 0 201-'i
ROANOKE RAPIDS
SANITARY DISTRIC1
John E. Skvarla, III
_ Secretary
RECEIVED
Customer Service
1-877-623-6748
NqrthCarolinaNaturally
Reported
Value
None
Limit
Value
n/a
Reporting
Requirement
Continuous
Failure to monitor and meet permit limits for parameters as per permit requirements. DMRs
reviewed November 2013 confirm lack of flow monitoring and exceedance of limits. DWR
received remedial actions taken to correct the cause(s) of this violation with the November 2013
DMR. If certifiable data for Flow monitoring violation described above is available an amended
DMR should be provided to rectify the noncompliance, please submit amended DMR (as
applicable) to the Division of Water Quality by March 18,2014.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Thomas A. Reeder
Director
Page 2 of 2 NOD-2014-LM-0001
Send copies of the amended report to:
AND
Raleigh Regional Operations Supervisor
Unresolved violations may lead to the issuance of a Notice of Violation and/or assessments of
civil penalties. Violations are subject to a civil penalty assessment of up to $25,000.00 per day
for each violation. Any efforts undertaken to bring the facility back into compliance are not an
admission and will be considered in any future actions undertaken.
If you have any questions or require any additional information, please contact Autumn
Romanski at [phone] ([e-mail]) or myself at [phone].
Division of Water Resources-Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Division of Water Resources-Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
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NPDS Permit NC0024201 ________
Facility Name:_______]_______________
Operator In Responsible Charge (ORC)
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Person(s) Collecting Samples: Lab Staff, Operators__________
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 2) Meritech,Inc.-Lab No. 165
Mail ORIGINAL and ONE COPY
ATTN: Central Files |
Division Of Water Quality
1617 Mall Service Center
Raleigh, NC 27699-1617
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ATTN: Central Files
Division Of Water Quality____
1617 Mail Service Center
Raleigh, NC 27699-1617
EFFLUENT_____________
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Discharge No. 001_______
Class IV
_________________ _______________________ I
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 (2) Meritech,Inc.-Lab No. 165
Person(s) Collecting Samples: Lab Staff, Operators
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February 18, 2013
Subject:NOTICE OF DEFICIENCY
Dear Mr. Brown:
Parameter Date
Flow 1/30/2013
11/20/2013 54.81 mg/L 45 mg/L Weekly
11/30/2013 34.7 mg/L 30 mg/L
1628 Mail Service Center, Raleigh, NC 27699-1628North Carolina Division of Water Resources
Internet: wAvw.ncwaterquality.org
Total
Suspended
Solids
A review of the November 2013 Discharge Monitoring Report (DMR) revealed a monitoring and
limit violation of the following parameter(s) at Outfall 001:
Pat McCrory
Governor
Phone [phone]
Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Monthly Average
Exceeded
FEB 2 0 2014
ROANOKE RAPIDS
SANITARY DISTRICT
Total
Suspended
Solids
NOD-2014-LM-0001
Roanoke Rapids Sanitary District WWTP
Permit No.NC0024201
Halifax County
Mr. R. Danieley Brown
Roanoke Rapid Sanitary District
135 Aqueduct Rd.
Weldon, NC 27890
Customer Service
1-877-623-6748
NoUhCarolitiaNaturally
Reported
Value
None
Limit
Value
n/a
Reporting
Requirement
Continuous
John E. Skvarla, III
___________ Secretary
RECEIVED
Failure to monitor and meet permit limits for parameters as per permit requirements. DMRs
reviewed November 2013 confirm lack of flow monitoring and exceedance of limits. DWR
received remedial actions taken to correct the cause(s) of this violation with the November 2013
DMR. If certifiable data for Flow monitoring violation described above is available an amended
DMR should be provided to rectify the noncompliance, please submit amended DMR (as
applicable) to the Division of Water Quality by March 18, 2014.
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Thomas A. Reeder
Director
»
Page 2 of 2 NOD-2014-LM-0001
Send copies of the amended report to:
AND
incei
/
Unresolved violations may lead to the issuance of a Notice of Violation and/or assessments of
civil penalties. Violations are subject to a civil penalty assessment of up to $25,000.00 per day
lor each violation. Any efforts undertaken to bring the facility back into compliance are not an
admission and will be considered in any future actions undertaken.
If you have any questions or require any additional information, please contact Autumn
Romanski at [phone] ([e-mail] ) or myself at [phone].
Danny Smitly
Raleigh Regional Operations Supervisor
Division of Water Resources-Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Division of Water Resources-Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
Month Year 2013
4
Date 12/6/2013
50050 80082 00610 00600 01002 01027 01067 00147 7i01042010510109200300
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JWQ Form MR-1 (01-00)
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NPDS Permit NC0024201____________
Facility Name:______~___________
Operator In Responsible^ Charge“(ORC)
I I I I
Check If ORC Has Changed_______________
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP^LabNor7b^2]TMedtechyinc^-Lab NoTT55
Mail ORIGINAL and ONE COPY
ATTN: Central Files |__
Division Of Water Quality
1617 Mall Service Center
Raleigh, NC 27699-1617
00530
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mg/l
50060
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(Signature of Operator In Responsible Charge)____
By this signature, I certify that this report is [
accurate and complete to the best of my knowledge.
00400
2013YearMonth
Person(s) Collecting Samples: Lab Staff, Operators
12/6/2013Date
34418003400055670301010597190000900
160.0
Nov
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4
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6
7
8
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11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
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Average
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Monthly Limi
DWQ Form MR-1 (01-00)
EFFLUENT
| __
Discharge No. 001______
Class IV
r_________________ __________________________ I
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 (2) Meritech,Inc.-Lab No. 165
Check if ORC Has Changed '
Mail ORIGINAL and ONECOPY to:
ATTN: Central Files______ __ _
Division Of Water Quality______ ______
1617 Mali Service Center__
Raleigh, NC 27699-1617l
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Roanoke Rapids Sanitary District
A. Gregg Camp ,Grade: j 4
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I I [UPSTREAM
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Roanoke Rapids Sanitary District WWTP 308 Rollingwood Road
I
Subject:
cc:
North Carolina Division of Water Resources 1628 Mail Service Center
Internet: www.ncwaterqualitv.org Location: 3800 Banett Drive
Pat McCrory
Governor
RRO File Copy
DWQ Central Files
John E. Skvarla, III
Secretary
NOTICE OF DEFICIENCY
NOD-2014-LV-0034
Roanoke Rapids Sanitary District
Permit No.NC0024201
Halifax County
Dear Mr. Brown:
Permit Limit
45.0 Weekly Average
April 22, 2014
CERTIFIED MAIL 7012 1640 0001 9606 4490
RETURN RECEIPT REQUESTED
Mr. R. Danieley Brown
Roanoke Rapid Sanitary District
135 Aqueduct Road
Weldon, NC 27890
A review of the February, 2014 Discharge Monitoring Report (DMR) revealed a violation of the
following parameter at Outfall 001:___________ ____________________ ______________
Parameter
Solids, Total
Suspended-
Concentration________
Remedial actions should be taken to correct the cause(s) of this violation. The violations described
above should be abated immediately and properly resolved.
Reported Value
46.19
Thank you for your attention to this matter. This office requires that the violations as described
above be properly resolved. Unresolved violations may lead to the issuance of a Notice of
Violation and/or assessments of civil penalties.
NorthCarolina---------------------------------Naturally
Raleigh, NC 27699-1628 Phone [phone] Customer Service
Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
_______Date
02/1/14
Mncerdly, /
[/
'Dahny Smith, Supervisor"'
Division of Water Resources, NCDENR
If you have any questions or require any additional information, please contact Mack Wiggins at or
myself at 919-791-4200. /
NCDEHR ^f///
North Carolina Department of Environment and Natural Resources
Month
Class IV
4 Phone
FEB 28IDate2/7/2014
50050 00400 80082 00530 00665 01002 01042
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ATTN: Central Flies_______
Division Of Water Resources
1617 Mail Service Center___
Raleigh, NC 27699-1617
Flow EFF
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NPbS Permit NC0024201___ _____
Facility Name:_____
Operator In Responsible Charge (ORC)
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Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 (2) Meritech,lnc.-Lab No'Y65.. .. ....... i • I
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__________________________Discharge No. 001
Roanoke Rapids SanitaryJ)istrlct
A.JSregg Camp Grade:
Personfs) Collecting Samples:LabStaff, Operators
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(Signature Operator in Responsible Charge)
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accurate and complete to the best of my knowledge.
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13.7
11.8
11.6
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10.6
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3.7
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3.7
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62
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72
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9.7
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0800
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___ _____I ___
71900 01062 01067 00147 01092 00300~50060
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24
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24
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Person(gColie^ngSamplesFLib• Staff, Operators
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---------------
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Discharge No. 001
-----i J___ Class IV
3
4
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6
7
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9_
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11
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25
27_
28
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Average_____
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Monthly Limit
DWQ Form MR-1 (01-00)'
7.4
7.4
7.1
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31616 TPG 38
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NPDS Permit NC002420‘2
Facility Name;__
Operator in Responsible Charge (ORC)
___IE ZXEEZLZZJ _ _
Checkjf ORC Has Changed
0800
0800
0800“
0800
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0800
FEB
_____County:
Phone [phone]
f
I 1: ug/l mg/l
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01042 00720 01051
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By th|s signature^ certify that this report is
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::::o 8oo82 ~ ——— —
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-------------- -----------------
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igJ3amp
ATTN: Central Files '
Division OfWateijlesou rces
IjMTjSajrSeryice Center
Raleigh, NC 27699-1617
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.Date 12/6/2013
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49
ATTN: Central Files
Division Of Water Quality
1617 Mall Service Center
Raleigh, NC 27699-1617
NRDS Permit NC0024201
Facility Name:j _
Operator in Responsible Charge (ORC)
mg/l
------
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o
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z
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---[
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3.0
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7.6
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23.9
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Phone [phone]
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mg/l
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2.7
2.7
2.8
2.8
2.9
2.8
2.3
2.2
2.3
2.5
2.1
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2.8
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4.7
3.8
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19.6
19.0
19.5
20.4
19.5
IIf
mg/l
d______L_
J______ ____, |____, | ____,____,
i Discharge No. 001
Roanoke Rapids Sanitary District I [Class IV
A. Gregg Camp Grade: 4___. ___.____ i rill II
Check^lf ORC Has Changed | Person(s) Collecting Samples: Lab Staff, Operators
Certified Laboratories (1) Roanoke Rapids Sanitary District WWfP-Lab No. 70 (2) Merltech,Inc.-Lab No. 165
Mall ORIGINAL and ONE COPY

I (Signature of o/efator in/Responsible Charge)
By this signature/l certify that this report is
0
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22 (
23 (
24 (
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26 I
27 I
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Monthly Limit
DWQ Form MR-1 (01-00)
’ 18.4
21.0
715.9 ‘
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z____^_E
mg/l mg/l
I ,
mg/l
<14.12' 1.17 '
By this signature/l certify that this report is
_______accurate and complete to the best of my knowledge. ______
00010 00400 80082 00530 00610 00600 00665 01002 01027
tn
2
Flow EFF s
1X1 UJ
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21.0
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30
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4.3
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P c
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HRS
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24
24
24
24
24
24
24
21_
24
24
24
24
24
24
24
24_
24
24
24
24
24
24
24
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24
24
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18.6
17.7
17.8 7.5
15.9
16.1
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' H
H
f
April 23,2014
Subject:
Dear Mr. Brown, CEO PE:
Limit ValueDate
400 #/l 00ml12/21/13
38.83 mg/130 mg/112/31/13
Coliform, Fecal MF, M-FC
Broth,44.5 C
Solids, Total Suspended -
Concentration
Pat McCrory
Governor
Raleigh, NC 27699-1628
Raleigh, NC 27609
John E. Skvarla, III
Secretary
R Danieley Brown, CEO PE
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids NC 27870
NOTICE OF VIOLATION AND RECOMMENDATION FOR
ENFORCEMENT
Permit No. NC0024201
Roanoke River WWTP
Case No. NOV-2014-LV-0190
Halifax County
CERTIFIED MAIL 7012 1640 0001 9606 4148
RETURN RECEIPT REQUESTED
The Division of Water Resources has reviewed Roanoke River WWTP's monitoring report for
December 2013 and we noted the following violation(s) had been reported:
Parameter/Outfall
Monthly
Average
Exceeded
A Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the subject
NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1. If you wish to provide additional information regarding the noted violation, please
submit it within 10 days of receipt of this Notice. Your response should be mailed to Danny
Smith at the below listed letterhead address. A review of your response will be considered in the
enforcement/assessment decision process along with any information provided on the Discharge
Monitoring Report.
Limit Type
Weekly
Geometric
Mean
Exceeded
Reported Value
502 #/100ml
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone]
Internet: www.ncwaterqualitv.org Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
NCDENR
North Carolina Department of Environment and Natural Resources
-One, ,.NorthCarolina Naturally
2 '
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water Resources may pursue enforcement actions for this and any additional
violations. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities, you may wish to
consider applying for a Special Order by Consent. You may contact this office for additional
information.
xc: Central Files
RRO SWP files
Sincerely, / / /
\j
Bwmy Smith; Supervisor v
Division of Water Resources, NCDENR
If you have any questions regarding this notice or need additional information, please contact
Mack Wiggins at 919-791 -4200. /
Month Year 2013
HalifaxClass IV
4
Date 12/6/2013
50050 00610 00600 01002 01027 01042 71900 00147 01092 TPG 38007200105100300
I
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18
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20
21
22
23
24
25
26
27
28
29
30
31
Xverajs
Maximum
Minimum ~__
k>mp/Grab _ _____
Monthly Limit__________
)WQ Form MR-1 (01-00)
H
Y
Y
Y
Y
Y
Y
Y
Y
Y
x
Y
Y
Y
Y
Flow EFF
X. 'NF _
MGD
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3.0
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2.7
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2.8
2.9
2.8
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2.3
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2.1
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2.5
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2.4
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2.8
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##### #####
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Mall ORIGINAL and ONE COPY
ATTN: Central Files |
Division Of Water Quality
1617 Mall Service Center
Raleigh, NC 27699-1617
<2.0
2.1
Nov
County:
Phone'252-536-4884
_47_
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4.2
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19.6
18.6
17.7
17.8
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*
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mg/l
I 0800
0800
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33.3
16.8
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13.5
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13.4
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142.0
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3
5
2 _
2 5
NPDS Permit NC0024201_____________
Facility Name: |
Operator In Responsible Charge (ORC)
I | | I
Check If ORC Has Changed _ _________ __________
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 (2) Meritech,Inc.-Lab No. 165„ -
00530
•g
EFFLUENT
_________________I I
______ Discharge No. 001
Roanoke Rapids Sanitary District
A. Gregg Camp Grade:
Person(s) Collecting Samples: Lab Staff, Operator^
50060
Ss
S8
s S So
IO
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Units mg/l
i e
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mg/l
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31616
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2
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18.7
17.7
17.5
17.6
co E
_______(Signature of Operator in Responsible Charge)
______By this signature, I certify that this report is
accurate and complete to the best of my knowledge.
' 00010 00400! 80082
co
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01062 01067
*
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2013Year
Halifax
Date 12/6/2013
34413 344180034000556703010090001059
160.0
X
Q
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mg/1
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UJ
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NPDS Permit NC0024201 ________
Facility Name: | ___
Operator in Responsible Charge (ORC)
Il[■Yi'i i ill Nov
County:
Phone [phone]
Check if ORC Has Changed
I ' 1
Mail ORIGINAL and ONE COPY to:
ATTN: Central Files__________
Division Of Water Quality
1617 Mail Service Center___________
Raleigh, NC 27699-1617 1
#DIV/0!
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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
Average
Maximum
Minimum
Comp/Grab
Monthly Limr
DWQ Form MR-1 (01-00)
EFFLUENT
I __
Discharge No. 001_______
Class IV
_______________________________________________________I
Certified Laboratories (1) Roanoke Rapids Sanitary District WWTP-Lab No. 70 (2) Meritech,Inc.-Lab No. 165
Person(s) Collecting Samples: Lab Staff, Operators___
#####
0
0
G
160.0
160.0
160.0
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0
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Roanoke Rapids Sanitary District
A. Gregg Camp_____Grade: | 4
II
#■•####
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(Signature of Operator in Rasponslblt Charpe) __
By this eipnature, I certify that thia report it
accurate and complete to the best of my knowledge.
32730
cotit
Ss
O K
00900000100030000010 00300 3161600300719000090000010
68.016.6 9.28.516.8
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269.7
301.1
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Comp/Grab
HRS
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
273.8
365.3
196.5
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277.2
238.1
259.5
283.3
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365.3
221,5
528.0
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192.0
147.0
332.0
236.0
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111.0
396.0
220.0
196.0
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0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
Average
Maximum
Minimum
I
| ; UPSTREAM
Roanoke River
308 Rollingwood Road
15.0
16.8
13.2
G
9.2
9.9
8.5
G
#DIV/0!
0_
0
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52.0
52.0
52.0
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HRS
0800
0800
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0800
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0800
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0800
0800
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0800
0800
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#DIV/0!
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#DIV/0!
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G
0
0
G
J_______[DOWNSTREAM
Roanoke River______________
US 158 Crossing ______
HRS
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
0800
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[INFLUENT
NPDES No. NC002420^ Pipe No. 001
Roanoke Rapids Sanitary District WWTP
Halifax Count Mo.
Nov
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Waste Water Treatment Plant
135 Aqueduct Rd.Weldon, NC 27890 [phone] Fax [phone]
The Roanoke Rapids Sanitary District Wastewater Plant (WWTP) has a monthly Total Suspended
Solids (TSS) limit of 30 milligrams per liter (mg/l) and an 85 % removal requirement. The WWTP
was noncompliant for January 2014 with a 47.1 mg/l TSS and an 81.4% removal.
The WWTP is experiencing bulking sludge. Microscopic examination reveals no filamentous
organisms. The sludge is finely dispersed and will not settle and therefore easily washes out
with higher than normal effluent flow.
The WWTP has two Trickling Filters that buffers flow from the Primary Clarifiers before reaching
the Activated Sludge System. With the lower plant flows of recent one Filter with recirculation
will accomplish the buffering needed. The Filters had both Rotary Distributors replaced in the
mid to late nineties. Unlike the Distributors of the past these Distributors were built with
bottom load bearings rather than top load bearings. The WWTP has experienced much trouble
with this style of Distributor. In 2012 funding was budgeted to have both Distributors rebuilt in
2013 and retrofitted with top load bearings. The first Distributor was in the process of being
machined for retrofitting when the bearing of the Distributor still in service failed. The lack of
no buffering between the Primaries & Activated Sludge System led to bulking sludge.
The bulking sludge caused two extremely high TSS results that led to the noncompliance. The
numbers were 570 and 152 mg/l. Without these anomalies the monthly average would be 22.0
and the percent removal 88.2. The two high numbers were due to higher than normal flows
and or pump malfunction. The average flow for 2013 was 3.6MGD. Flow average for January
2014 was 4.2, 600,000 gallons higher than 2013 average flow. January 2013 Influent TSS
average was 229 mg/l as compared to January 2014 187 mg/l or a 20 % decrease. This
contributed to the lower monthly % removal.
Waste Water Treatment Plant
135 Aqueduct Rd.Weldon, NC 27890 [phone] Fax [phone]
The WWTP spent significant funds and put in a great deal of effort to obtain compliance.
During high flow day's equalization tanks were used to store flow to minimize solids wash out.
Also, extra sampling and testing was done to improve the TSS monthly average.
To control the loss effluent solids the WWTP did the following. Approximately $77,500 was
spent to rebuild the first distributor. It is back on line but the zoogleal mass has been slow to
return due to more than normal overcast & rainy days and colder temperatures. Around
$9,900 was spent on polymer to aid settling.
No
A j
Was WWTP compliant with permit requirements? yZYes
Were samples taken during event? i,/^ Yes No
Incident Started:
Incident Ended:
.(must be given even if it is a rough estimate)
No
Source of the Upset/Spill/Bypass (Location or Treatment Unit):
Time: o
Time: ^6
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Date: V-//
Date: X-/ - } 7
WWTP Upset, Spill, or Bypass S-Dav Reporting Form
(Please Print or Type Use Attachments if Needed)
e y. J re st, /■
Estimated Volume of Spill/Bypass: J, t? 3 <0 Q
Did the Spill/Bypass reach the Surface Waters?
If yes, please list the following:
Volume Reaching Surface Waters: 2^. 3<0O Surface Water Name: (^0 & a fb/Gp
Did the Spill/Bypass result in a Fish Kill? ___Yes y^No
P'
> '
Permitteef(/>f/ch ^/7//Permit Number: ^JC6C)
FacFrty Name: no K f3 / j/ e y County: y/4 ><
North Caroli^Department of Environment and Natural Resources
Division of Water Quality
DIO’s
Level of Treatment: r. / re^o u«/
None Primary Treatment Secondary Treatment Chlorination/Disinfection Only
Cause or Reason for the Upset/Spill/Bypass:
<Z 3 7/ o-P A0^r a*cP J#
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Describe the Repairs Made or Actions Taken:
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24-Hour Report Made To:
Date: -5~~~/Time: .* 3^
Other Agencies Notified (Health Dept, etc):
Person Reporting Event: fl Phone Number - ‘j
//
Spill/Eiypass Reporting Form (August 1997)
WWTP Upset, Spill, or Bypass 5-Day Reporting Form
Page 2
Did DWQ Request an Additional Written Report?
If Yes, What Additional Information is Needed:
/>’zi e
Action Taken to Contain Spill, Clean Up and Remediate the Site (if applicable):
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Action Taken or Proposed to be Taken to Prevent Occurrences:
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Yes No
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Emergency Management
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Other Agencies Notified (Health Dept, etc):
Phone Number: 2^pi -
Yes No
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WWTP Upset, Spill
Page 2
Did DWQ Request an Additional Written Report?
If Yes, What Additional Information is Needed:
Action Taken to Contain Spill, Clean Up and Remediate the Site (if applicable):
A'
, ^3ypass 5 Day Reporting Form
Time:
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Person Reporting Event:/)
Additional Comments About the Event:
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24-Hour Report Made To: Division of Water Quality
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Action Taken or Proposed_to be Taken to Prevent Occurrences:
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Spill/Bypass Reporting Form (August 1997)
CP
April 23,2014
Subject:
aDear Mr. Brown, CEO PE:
Limit ValueDate
45 mg/101/04/14
106.29 mg/145 mg/101/18/14
47.08 mg/130 mg/101/31/14
I
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
John E. Skvarla, III
Secretary
Weekly
Average
Exceeded
R Danieley Brown, CEO PE
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids NC 27870
NOTICE OF VIOLATION AND RECOMMENDATION FOR // I
ENFORCEMENT /\<1
Permit No. NC0024201 - ' / / T
Roanoke River WWTP '
Case No. NOV-2014-LV-0191
Halifax County -— J
CERTIFIED MAIL 7012 1640 0001 9606 3448
RETURN RECEIPT REQUESTED
The Division of Water Resources has reviewed Roanoke River WWTP's monitoring report for
January 2014 and we noted the following violation(s) had been reported:_________________
Parameter/Outfall
Solids, Total Suspended -
Concentration
Limit Type
Weekly
Average
Exceeded
Reported Value
78.93 mg/1
W NCDENR
Carolina Department of Environment and Natural Resources
cp
i*4 J
Monthly
Average
Exceeded
A Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the subject
NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1. If you wish to provide additional information regarding the noted violation, please
submit it within 10 days of receipt of this Notice. Your response should be mailed to Danny
Smith at the below listed letterhead address. A review of your response will be considered in the
NorthCarolina Naturally
k X
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone]
Internet: www.ncwaterqualitv.org Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
Roanoke Rapids Sanitary District
June 6, 2014
Re:
Dear Sir:
Please be advised that all known remedial actions have been taken to correct problems
leading to the referenced action issued via your correspondence(s) dated April 23, 2014 (2)
and April 22, 2014. Attached for your reference is our November 2013 DMR, its
accompanying remedial actions report and resulting NOTICE OF DEFICIENCY NOD-
2014-LM-0001. We also request the following additional information is favorably
considered regarding the noted violation(s) and in support of our assertion of compliance
conformance:
Mr. Danny Smith, Supervisor
North Carolina Division of Water Resources
1628 Mail Service Center
Raleigh, N. C. 27699-1628
NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
CERTIFIED MAIL 7010 3090 000 3778 0494
RETURN RECEIPT REQUESTED
ft0
P.O. Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870
[phone]
Fax: [phone]
www.rrsd.org
BACKGROUND: The Roanoke Rapids Sanitary District (District) expends significant funds and
resources to maintain NPDES compliance. In the early to mid-2000's District budgeted in excess
of $250,000 to replace one of two Rotary Distributors followed by another $250,000-plus the
next fiscal year. The existing Distributors, installed in the early 1980's, were deteriorating from
the inside out despite being regularly painted over the years. This third set of distributors was
different from the original set installed in the early 1960's and the second set, of the early
1980's, in two major ways. First, rather than carbon steel the new units were fabricated from
stainless to negate the need for external painting and slow the internal deterioration process
and secondly, rather than top load bearings the new stainless were fitted with bottom load
bearings. The bearing on the first installed Distributor failed and was replaced at a cost of
$11,500 after only a few years of service.
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This condition led to bulking sludge. Wastewater was basically leaving the primary clarifiers
and entering the Secondary System with no buffering from the Trickling Filters. This resulted in
an organic overload of the Secondary System. Microscopic examination did not reveal excess
filamentous growth. Five minute MLSS settleabilites ran in the 950-990 range. Normally this
would be in the 400-600 range. To help bring the F/M ratio back into balance the wasting was
stopped. This increased the solids inventory in the Secondary System above what is normally
needed to run the system.
The following year, the same failure occurred on the second installed Distributor. Hence,
remedial construction of the "new" Distributors was required. The District decided not to do
another bottom bearing repair. It was discovered the Distributors could be retrofitted with top
load bearings for around $175,000. It was decided to start with the second failed unit since the
first unit had already received a second lower bearing. Work actually began early even before
July 1st FY14. The Distributor was removed and sent to the fabrication shop on June 20th, 2013.
NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
Page:
2/6
The reinstall date was set for September 13th, 2013. This was good timing to get the first
retrofitted Distributor on line while conditions were suitable for zoogleal mass to restore
quicker. The second unit would be removed and retrofitted once the first unit recovered.
However, the unit was not installed until October 28, 2013 due to concealed damage; which had
to be repaired prior to other modifications being made. Further, the unit was discovered to
have been installed out of plumb and, at the manufacturer's recommendation, the Distributor
could not go on line because of possible damage. The installer did not return until mid­
December to re-plumb the Distributor. Finally on December 18th the distributor went on line.
This was three months longer than first anticipated. Unfortunately, the second Distributor
began to fail in November. Much effort was put into keeping it turning to maintain zoogleal
growth. There are three recirculation pumps available for Rotary Distributor/Trickling Filter
management. All three pumps were run constantly. Maintenance personnel increased oiling
and greasing schedule. The Distributors have a motion sensor on them and each time it stopped
the operation staff along with maintenance would push the Distributor to keep it turning.
Finally, a backhoe was used to pull the Distributor with a strap to keep it turning. The
Distributor failed. This occurred before a zoogleal mass was established on the newly installed
Distributor.
SUSPENDED SOLIDS MANAGEMENT: There is a polymer feed system set up ahead of the
Secondary Clarifiers. It is used periodically to control solids washout during high flows and to
help control alum sludge received from the water treatment plant. It has been on line
approximately 10 years. It is also used to help percent removal during wet weather events with
high flows that dilute influent solids to achieve better settling out effluent suspended solids.
This system has kept the wastewater plant compliant for solids reduction on numerous
ckjocunKnls and scttings'jdb'jny documcnt^npcks pcnrilVwvncdadinfb hr doc
NOTICE OF DEFICIENCY/NOT1CE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES#NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
Page:
3/6
Polymer used at this location is received in 55 gallon drums. It is a small area of operation
and can only accommodate a few barrels at the time. Operations were asked to monitor
inventory closely and keep it on hand at all times. However, during cold days polymer would
not be shipped due to fear of freezing the polymer and rendering it ineffective. This happened
on several occasions. In these cases staff would take empty 55 gallon barrels to the bulk
As evidenced by the DMR's, the polymer did a great job of controlling the bulking sludge.
Lots of TSS numbers were single digit or low double digit. The few triple digit numbers would
ruin the TSS average. Three factors contributed to these high numbers; pump problems,
gumming or high flows from l&l. As mentioned earlier this polymer is only used (usually)
occasionally and only for a few days. During the period of Rotary Distributor bearing retrofitting
the polymer was used for one hundred and six days in a row. The average annual polymer cost
for the past five years was around $7,800.00. This year nearly $28,000, over triple the past five
year average, was spent on polymer.
occasions. The system is set up for infrequent use for short periods of time (days), as needed.
Polymer is a difficult chemical to work with. Moisture in the wrong location, from sweating to a
leaking valve causes polymer to gum up. To prevent this, operations was asked to monitor the
secondary clarifiers more often to make sure the polymer was still coagulating secondary solids.
This was a visual observation. Another way to check the feed is with a draw down tube located
on the pump. Mineral oil is added to the tube and a draw down is observed. If the draw down
slows down with the variable speed drive of the pump at the same speed this could indicate a
pump problem or a gumming problem. Feeding mineral oil this way not only checked the feed
system but also cleansed gumming of the pump. Operations was asked to perform this task
more and regularly. Operations were also trained to know where common gumming areas in
the system and how to clean them. During daily morning meetings the operators were
reminded of the criticality of this. The maintenance staff was also kept informed in these
morning meetings. Maintenance was asked to check the system each afternoon before leaving.
Operations and maintenance were kept informed on the status of the plant. They were also
instructed that if anything went awry with the system it took precedence over all other work
going on at the time. Maintenance was also put on call for weekend problems. Several things
were done to make the system more reliable. Hot water used in the correct location can help
with gumming. An on-line demand hot water unit was added. The bulk polymer storage tank
was cleaned. The polymer pump was relocated right next to the bulk polymer storage tank to
reduce the length of piping and elbows where gumming was occurring and a second mineral oil
flush system was added to be able to flush the entire suctions side of the pump. Suspect check
valves were replaced with ball valves. In addition, maintenance was instructed to keep all spare
parts for the feed pump and feed system in stock at all times. As one was used it was
immediately replaced.
c.'doainK’nls and scftingsVdbVuy doaimcnli'jipcks pcrnul\nos rKMbdinfo hr doc
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Demand for hypochlorite feed significantly increased in December. Feed rate was increased
by approximately 50%. Comparatively, in December 2012, the monthly pre-removal residual
was 576ug/l versus a pre-residual 667ug/l in December 2013. In December 2012 this resulted in
a monthly geometric mean of 7 fecal colonies. This compared to a monthly geometric mean in
NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDA TION FOR ENFORCEMENT
NPDES#NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014 -LV-0190
Case No. NOV-2014-LV-0191
Halifax County
Page'
4/6
This winter was unusually colder, overcast and wetter than past years. Effluent temperature
dropped onto Celsius single digits, something not seen in many years, if ever. Also daylight hours
were shorter. This made it more difficult and took longer to establish the zoogleal growth.
Finally around late February to early March the zoogleal mass began to appear on the first
installed retrofitted Distributor. The bulking sludge stopped and 5 minute settleabilites began
to return to normal. The zoogleal mass returned shortly after on the second retrofitted
Distributor. This came quicker because warmer ambient and wastewater temperatures and
longer daylight hours. Both filters now have well established zoogleal mass on them and the
plant has returned to expected operation.
polymer storage for the waste activated thickening process. Using a bypass pump the barrel
would be filled and transported across the plant and added to the secondary polymer feed
system to maintain control over the effluent TSS. Unfortunately the plan to establish zoogleal
growth on the first retrofitted Distributor before removing the second for retrofitting did not
work out. So it was removed anyway on 1-13-2014. This unit was reinstalled on 3-10-14.
However during installation a seal was inadvertently missed. The Distributor had to be
disassembled once again to install the seal. Finally on 3-24-2014, the Distributor went on line.
Even with the omission of the seal, the second Distributor rebuild took only a little over two
months versus six months for the first unit.
DECEMBER VIOLATIONS - FECAL/TSS (0190): 12-31-2013 monthly TSS average 38.83 (Limit
value=30 mg/l). Fecal Coliform Weekly Geometric Mean 502 col/lOOml (Limit value
=400col/100ml). With only three required sampling days left in December the monthly TSS
average was 15.6 mg/l. That included one high TSS of 105.6 mg/l day. This was due to a
malfunction in the polymer feed system. Then on the 29th and 30th, 2.4 inches of rain fell. The
maximum flow for the two days was 16.2 and 16.1 MGD respectively with the daily totals being
9.1 and 9.3 respectively. The total plant capacity is 8.34 MGD. The polymer feed could not
control the washout of the finely dispersed bulking sludge at these high flows. As a result, the
two days TSS's were 103.1 and 396.2 mg/l respectively. However as the flow lowered to a
maximum of 8.0 MGD on the 31st, with a total of 5.3 MGD, the effluent TSS dropped to 11.4
mg/l. This demonstrates the ability of the polymer to control the bulking sludge under more
normal flow conditions. December received 8.1 inches of rain in the month. It did not take as
much precipitation to significantly increase flows. The monthly flow average was 4.0 MGD as
compared to the previous December of 2.8 MGD. The yearly average for 2013 was 3.5 MGD.
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FEBRUARY DEFICIENCY - TSS (0034): Date 2-1-14 weekly average 46.19 mg/l (limit value
45.0). February was a turning point month from all the issues that were experienced since
November 2013. The monthly average was 16.1 mg/l. Regardless, the deficiency experienced
the last week of January can directly be attributed to the combination of removal of the trickling
filter on January 13th, cold, wet, overcast days during the period and faulty polymer feed
equipment. Our most experienced operators were on duty negotiating these difficult conditions
during the final week of January and through their efforts we barely missed our permit limit for
the week.
SUMMARY: Since August of 1992, the Roanoke Rapids Sanitary District Wastewater
Treatment Plant's operation has had an excellent compliance record. Since this date through
JANUARY VIOLATIONS-TSS (0191): Date 1-4-14, weekly average 78.93 mg/l (limit value 45.0
mg/l); this week contains in its average three data points from the previous month. Two of
which caused the monthly non-compliance for December discussed above. It is not understood
how the same two data points can be used in compliance judgment to levy two different
violations. The District feels this is a case of double jeopardy and is incorrect. A weekly violation
should not result in a monthly violation since a monthly violation suggests a chronic condition;
while the results of the other four weeks in December were compliant. However, we recognize
a violation and have previously discussed our actions to correct the problem.
Date 1-18-14, weekly average 106.29 (limit value 45 mg/l); this week had some higher flows
along with issues associated with the polymer feed system. As the flow for the week decreased
and repairs to the polymer feed system were completed, TSS values trended down. If not for
the anomaly of 570.0 mg/l TSS on the 13th, the same day the trickling filter was taken off line,
the week may very well have been compliant.
Date 1-31-14, monthly average 47.08 mg/l (limit value 30 mg/l); this month had some slightly
higher flows but mostly there were polymer feed system problems. Without the anomalies of
570.0 mg/l, the highest TSS reported since 1992, on 1-13 and 152.0 mg/l on 1-27, the monthly
average may well have been compliant. Polymer feed parts were available for all issues as they
arose. However, this month had more than its share of gumming problems. This was the month
that most of the aforementioned improvements were made to the system.
NOTICE OF DEFICIENCY/NOTICE OF VIOLA TION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
Page:
5/6
December of 2013 of 197 fecal colonies. Even with the increased hypochlorite feed and extra
sampling and testing, some on the weekend, the weekly limit could not be met. Additionally,
Hypochlorite was increased to ensure compliance for the month. Comparing the subsequent
months as the bulking sludge subsided, fecal Coliform counts went down. This may only be a
coincidence or there may have been some other interference. Nitrites have been an issue in the
past. December nitrite was up some over November.
Enclosures
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The District has successfully conducted remedial construction activities, as evidenced by
our initial replacement of our Trickling Filters, without a Special Order by Consent but
now realizes it to be a useful tool for satisfactorily completing future activities. Should you
require additional information, please do not hesitate to contact me.
In addition to the cost to retrofit the two Rotary Distributors the District spent additional
money on extra sampling and testing, overtime, mineral oil, Distributor oil, pump parts, polymer
feed system improvements, polymer, electrical, disinfection chemicals, and change orders. In a
six month timeframe the District spent well in excess of $200,000 on one project to improve
plant operations in an attempt to maintain compliance.
Gene St. Clair, Chairman
Mack Wiggins
Gregg Camp
File
Page:
6/6
NOTICE OF DEF1CIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
October 315t of 2013 or 7969 days there have been only four daily (instantaneous) infractions;
one for a missed daily analysis for ammonia nitrogen, one for pH, and two for chlorine residual.
Both of which would not have been infractions had the State previously raised the limit to
50ug/l. Since this date through October 31st of 2013 or 1132 weeks, there have been only six
weekly infractions; four for TSS and two for CBOD. Since this date through October 31st of 2013
or 262 months there has been only four infractions; one for TSS, one for CBOD, and two for
percent removal. There was two times each of six years running where no infractions occurred.
This excellent record is due to the support and guidance of administration and the dedication of
staff. This support, guidance and dedication did not wane during the difficult months of
November 2013 through February 2014. The District saw the need to make improvements and
as usual appropriated funds to make this happen. The wastewater plant became a victim of bad
luck (mechanical failure) and one of the worst stretches of bad weather not seen in years.
Very truly yours,
R. Danieley Br^wn, P.E.
Chief Executive Officer
Roanoke Rapids Sanitary District
Fax:
June 6. 2014
Re:
NC DENR Raleigh Regional Office
Dear Sir:
Mr. Danny Smith, Supervisor
North Carolina Division of Water Resources
1628 Mail Service Center
Raleigh, N. C. 27699-1628
BACKGROUND: The Roanoke Rapids Sanitary District (District) expends significant funds and
resources to maintain NPDES compliance. In the early to mid-2000's District budgeted in excess
of $250,000 to replace one of two Rotary Distributors followed by another $250,000-plus the
next fiscal year. The existing Distributors, installed in the early 1980's, were deteriorating from
the inside out despite being regularly painted over the years. This third set of distributors was
different from the original set installed in the early 1960's and the second set, of the early
1980's, in two major ways. First, rather than carbon steel the new units were fabricated from
stainless to negate the need for external painting and slow the internal deterioration process
and secondly, rather than top load bearings the new stainless were fitted with bottom load
bearings. The bearing on the first installed Distributor failed and was replaced at a cost of
$11,500 after only a few years of service.
Please be advised that all known remedial actions have been taken to correct problems
leading to the referenced action issued via your correspondence(s) dated April 23, 2014 (2)
and April 22, 2014. Attached for your reference is our November 2013 DMR. its
accompanying remedial actions report and resulting NOTICE OF DEFICIENCY NOD-
2014-LM-0001. We also request the following additional information is favorably
considered regarding the noted violation(s) and in support of our assertion of compliance
conformance:
NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
CERTIFIED MAIL 7010 3090 000 3778 0494
RETURN RECEIPT REQUESTED
P.O. Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870
[phone]
[phone]
www.rrsd.org
c:\documenls and scttings\rdb\niy documenLs\npdcs pcniut\novnodadinfo llr.doc
This condition led to bulking sludge. Wastewater was basically leaving the primary clarifiers
and entering the Secondary System with no buffering from the Trickling Filters. This resulted in
an organic overload of the Secondary System. Microscopic examination did not reveal excess
filamentous growth. Five minute MISS settleabilites ran in the 950-990 range. Normally this
would be in the 400-600 range. To help bring the F/M ratio back into balance the wasting was
stopped. This increased the solids inventory in the Secondary System above what is normally
needed to run the system.
Page:
2/6
SUSPENDED SOLIDS MANAGEMENT: There is a polymer feed system set up ahead of the
Secondary Clarifiers. It is used periodically to control solids washout during high flows and to
help control alum sludge received from the water treatment plant. It has been on line
approximately 10 years. It is also used to help percent removal during wet weather events with
high flows that dilute influent solids to achieve better settling out effluent suspended solids.
This system has kept the wastewater plant compliant for solids reduction on numerous
The following year, the same failure occurred on the second installed Distributor. Hence,
remedial construction of the "new" Distributors was required. The District decided not to do
another bottom bearing repair. It was discovered the Distributors could be retrofitted with top
load bearings for around $175,000. It was decided to start with the second failed unit since the
first unit had already received a second lower bearing. Work actually began early even before
July 1st FY14. The Distributor was removed and sent to the fabrication shop on June 20th, 2013.
The reinstall date was set for September 13th, 2013. This was good timing to get the first
retrofitted Distributor on line while conditions were suitable for zoogleal mass to restore
quicker. The second unit would be removed and retrofitted once the first unit recovered.
However, the unit was not installed until October 28, 2013 due to concealed damage; which had
to be repaired prior to other modifications being made. Further, the unit was discovered to
have been installed out of plumb and, at the manufacturer's recommendation, the Distributor
could not go on line because of possible damage. The installer did not return until mid­
December to re-plumb the Distributor. Finally on December 18,h the distributor went on line.
This was three months longer than first anticipated. Unfortunately, the second Distributor
began to fail in November. Much effort was put into keeping it turning to maintain zoogleal
growth. There are three recirculation pumps available for Rotary Distributor/Trickling Filter
management. All three pumps were run constantly. Maintenance personnel increased oiling
and greasing schedule. The Distributors have a motion sensor on them and each time it stopped
the operation staff along with maintenance would push the Distributor to keep it turning.
Finally, a backhoe was used to pull the Distributor with a strap to keep it turning. The
Distributor failed. This occurred before a zoogleal mass was established on the newly installed
Distributor.
NOTICE OF DEFICIENCY^^ICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-019I
Halifax Count}'
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3/6
Polymer used at this location is received in 55 gallon drums. It is a small area of operation
and can only accommodate a few barrels at the time. Operations were asked to monitor
inventory closely and keep it on hand at all times. However, during cold days polymer would
not be shipped due to fear of freezing the polymer and rendering it ineffective. This happened
on several occasions. In these cases staff would take empty 55 gallon barrels to the bulk
As evidenced by the DMR's, the polymer did a great job of controlling the bulking sludge.
Lots of TSS numbers were single digit or low double digit. The few triple digit numbers would
ruin the TSS average. Three factors contributed to these high numbers; pump problems,
gumming or high flows from l&l. As mentioned earlier this polymer is only used (usually)
occasionally and only for a few days. During the period of Rotary Distributor bearing retrofitting
the polymer was used for one hundred and six days in a row. The average annual polymer cost
for the past five years was around $7,800.00. This year nearly $28,000, over triple the past five
year average, was spent on polymer.
occasions. The system is set up for infrequent use for short periods of time (days), as needed.
Polymer is a difficult chemical to work with. Moisture in the wrong location, from sweating to a
leaking valve causes polymer to gum up. To prevent this, operations was asked to monitor the
secondary clarifiers more often to make sure the polymer was still coagulating secondary solids.
This was a visual observation. Another way to check the feed is with a draw down tube located
on the pump. Mineral oil is added to the tube and a draw down is observed. If the draw down
slows down with the variable speed drive of the pump at the same speed this could indicate a
pump problem or a gumming problem. Feeding mineral oil this way not only checked the feed
system but also cleansed gumming of the pump. Operations was asked to perform this task
more and regularly. Operations were also trained to know where common gumming areas in
the system and how to clean them. During daily morning meetings the operators were
reminded of the criticality of this. The maintenance staff was also kept informed in these
morning meetings. Maintenance was asked to check the system each afternoon before leaving.
Operations and maintenance were kept informed on the status of the plant. They were also
instructed that if anything went awry with the system it took precedence over all other work
going on at the time. Maintenance was also put on call for weekend problems. Several things
were done to make the system more reliable. Hot water used in the correct location can help
with gumming. An on-line demand hot water unit was added. The bulk polymer storage tank
was cleaned. The polymer pump was relocated right next to the bulk polymer storage tank to
reduce the length of piping and elbows where gumming was occurring and a second mineral oil
flush system was added to be able to flush the entire suctions side of the pump. Suspect check
valves were replaced with ball valves. In addition, maintenance was instructed to keep all spare
parts for the feed pump and feed system in stock at all times. As one was used it was
immediately replaced.
NOTICE OF DEFICIENCY/^^CE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
c.\documcnts ;u»d scttingsXrdb'jnv documcnts\npdcs pemiilXnov nodadinfo It r doc
Demand for hypochlorite feed significantly increased in December. Feed rate was increased
by approximately 50%. Comparatively, in December 2012, the monthly pre-removal residual
was 576ug/l versus a pre-residual 667ug/l in December 2013. In December 2012 this resulted in
a monthly geometric mean of 7 fecal colonies. This compared to a monthly geometric mean in
Page:
4/6
This winter was unusually colder, overcast and wetter than past years. Effluent temperature
dropped onto Celsius single digits, something not seen in many years, if ever. Also daylight hours
were shorter. This made it more difficult and took longer to establish the zoogleal growth.
Finally around late February to early March the zoogleal mass began to appear on the first
installed retrofitted Distributor. The bulking sludge stopped and 5 minute settleabilites began
to return to normal. The zoogleal mass returned shortly after on the second retrofitted
Distributor. This came quicker because warmer ambient and wastewater temperatures and
longer daylight hours. Both filters now have well established zoogleal mass on them and the
plant has returned to expected operation.
DECEMBER VIOLATIONS - FECAL/TSS (0190): 12-31-2013 monthly TSS average 38.83 (Limit
value=30 mg/l). Fecal Coliform Weekly Geometric Mean 502 col/lOOml (Limit value
=400col/100ml). With only three required sampling days left in December the monthly TSS
average was 15.6 mg/l. That included one high TSS of 105.6 mg/l day. This was due to a
malfunction in the polymer feed system. Then on the 29th and 30th, 2.4 inches of rain fell. The
maximum flow for the two days was 16.2 and 16.1 MGD respectively with the daily totals being
9.1 and 9.3 respectively. The total plant capacity is 8.34 MGD. The polymer feed could not
control the washout of the finely dispersed bulking sludge at these high flows. As a result, the
two days TSS's were 103.1 and 396.2 mg/l respectively. However as the flow lowered to a
maximum of 8.0 MGD on the 31st, with a total of 5.3 MGD, the effluent TSS dropped to 11.4
mg/l. This demonstrates the ability of the polymer to control the bulking sludge under more
normal flow conditions. December received 8.1 inches of rain in the month. It did not take as
much precipitation to significantly increase flows. The monthly flow average was 4.0 MGD as
compared to the previous December of 2.8 MGD. The yearly average for 2013 was 3.5 MGD.
polymer storage for the waste activated thickening process. Using a bypass pump the barrel
would be filled and transported across the plant and added to the secondary polymer feed
system to maintain control over the effluent TSS. Unfortunately the plan to establish zoogleal
growth on the first retrofitted Distributor before removing the second for retrofitting did not
work out. So it was removed anyway on 1-13-2014. This unit was reinstalled on 3-10-14.
However during installation a seal was inadvertently missed. The Distributor had to be
disassembled once again to install the seal. Finally on 3-24-2014, the Distributor went on line.
Even with the omission of the seal, the second Distributor rebuild took only a little over two
months versus six months for the first unit.
NOTICE OF DEFICIENCY^^ICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-I.V-0190
Case No. NOV-2014-LV-0191
Halifax County
c:\doauiKnls and sctungs'nfc'anv dociimenls\npdcs pcnnittan nodadinfo Ur doc
December of 2013 of 197 fecal colonies. Even with the increased hypochlorite feed and extra
sampling and testing, some on the weekend, the weekly limit could not be met. Additionally,
Hypochlorite was increased to ensure compliance for the month. Comparing the subsequent
months as the bulking sludge subsided, fecal Coliform counts went down. This may only be a
coincidence or there may have been some other interference. Nitrites have been an issue in the
past. December nitrite was up some over November.
JANUARY VIOLATIONS - TSS (0191): Date 1-4-14, weekly average 78.93 mg/l (limit value 45.0
mg/l); this week contains in its average three data points from the previous month. Two of
which caused the monthly non-compliance for December discussed above. It is not understood
how the same two data points can be used in compliance judgment to levy two different
violations. The District feels this is a case of double jeopardy and is incorrect. A weekly violation
should not result in a monthly violation since a monthly violation suggests a chronic condition;
while the results of the other four weeks in December were compliant. However, we recognize
a violation and have previously discussed our actions to correct the problem.
Date 1-18-14, weekly average 106.29 (limit value 45 mg/l); this week had some higher flows
along with issues associated with the polymer feed system. As the flow for the week decreased
and repairs to the polymer feed system were completed, TSS values trended down. If not for
the anomaly of 570.0 mg/l TSS on the 13th, the same day the trickling filter was taken off line,
the week may very well have been compliant.
Date 1-31-14, monthly average 47.08 mg/l (limit value 30 mg/l); this month had some slightly
higher flows but mostly there were polymer feed system problems. Without the anomalies of
570.0 mg/l, the highest TSS reported since 1992, on 1-13 and 152.0 mg/l on 1-27, the monthly
average may well have been compliant. Polymer feed parts were available for all issues as they
arose. However, this month had more than its share of gumming problems. This was the month
that most of the aforementioned improvements were made to the system.
FEBRUARY DEFICIENCY - TSS (0034): Date 2-1-14 weekly average 46.19 mg/l (limit value
45.0). February was a turning point month from all the issues that were experienced since
November 2013. The monthly average was 16.1 mg/l. Regardless, the deficiency experienced
the last week of January can directly be attributed to the combination of removal of the trickling
filter on January 13th, cold, wet, overcast days during the period and faulty polymer feed
equipment. Our most experienced operators were on duty negotiating these difficult conditions
during the final week of January and through their efforts we barely missed our permit limit for
the week.
SUMMARY: Since August of 1992, the Roanoke Rapids Sanitary District Wastewater
Treatment Plant's operation has had an excellent compliance record. Since this date through
Page.
5/6
NOTICE OF DEFICIENCY^fecE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
»
Enclosures
Cc:
cAdocumenis and scttingsVdbVnv documents\npdcs pcmuttaot nodadinfo ltr.doc
In addition to the cost to retrofit the two Rotary Distributors the District spent additional
money on extra sampling and testing, overtime, mineral oil. Distributor oil, pump parts, polymer
feed system improvements, polymer, electrical, disinfection chemicals, and change orders. In a
six month timeframe the District spent well in excess of $200,000 on one project to improve
plant operations in an attempt to maintain compliance.
The District has successfully conducted remedial construction activities, as evidenced by
our initial replacement of our Trickling Filters, without a Special Order by Consent but
now realizes it to be a useful tool for satisfactorily completing future activities. Should you
require additional information, please do not hesitate to contact me.
Gene St. Clair, Chairman
Mack Wiggins
Gregg Camp
File
Page:
6/6
October 31st of 2013 or 7969 days there have been only four daily (instantaneous) infractions;
one for a missed daily analysis for ammonia nitrogen, one for pH, and two for chlorine residual.
Both of which would not have been infractions had the State previously raised the limit to
50ug/l. Since this date through October 31st of 2013 or 1132 weeks, there have been only six
weekly infractions; four for TSS and two for CBOD. Since this date through October 31st of 2013
or 262 months there has been only four infractions; one for TSS, one for CBOD, and two for
percent removal. There was two times each of six years running where no infractions occurred.
This excellent record is due to the support and guidance of administration and the dedication of
staff. This support, guidance and dedication did not wane during the difficult months of
November 2013 through February 2014. The District saw the need to make improvements and
as usual appropriated funds to make this happen. The wastewater plant became a victim of bad
luck (mechanical failure) and one of the worst stretches of bad weather not seen in years.
Very truly yours,
ZruXyg
R. Danieley Br^wn, P.E.
Chief Executive Officer
NO TICE OF DEFICIENCY^^ICE OF VIOLATION AND
RECOMMENDA TION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD-2014-LV-0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
April 23,2014
Subject:
Dear Mr. Brown, CEO PE:
Limit ValueDate
45 mg/101/04/14
106.29 mg/101/18/14 45 mg/1
30 mg/1 47.08 mg/101/31/14
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Solids, Total Suspended -
Concentration
Pat McCrory
Governor
1628 Mail Service Center
Location: 3800 Barrett Drive
John E. Skvarla, III
Secretary
Weekly
Average
Exceeded
R Danieley Brown, CEO PE
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids NC 27870
NOTICE OF VIOLATION AND RECOMMENDATION FOR
ENFORCEMENT
Permit No. NC0024201
Roanoke River WWTP
Case No. NOV-2014-LV-0191
Halifax County
CERTIFIED MAIL 7012 1640 0001 9606 3448
RETURN RECEIPT REQUESTED
The Division of Water Resources has reviewed Roanoke River WWTP's monitoring report for
January 2014 and we noted the following violation(s) had been reported:
Parameter/Outfall Limit Type
Weekly
Average
Exceeded
Reported Value
78.93 mg/1
HCDEHR
North Carolina Department of Environment and Natural Resources
Monthly
Average
Exceeded
A Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the subject
NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five
thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1. If you wish to provide additional information regarding the noted violation, please
submit it within 10 days of receipt of this Notice. Your response should be mailed to Danny
Smith at the below listed letterhead address. A review of your response will be considered in the
----------------- - " NorthCarolina
North Carolina Division of Water Resources 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone] J dtlirully
Internet: www.ncwaterqualitv.org Location: 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
2 '
inceiely,
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water Resources may pursue enforcement actions for this and any additional
violations. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities, you may wish to
consider applying for a Special Order by Consent. You may contact this office for additional
information.
enforcement/assessment decision process along with any information provided on the Discharge
Monitoring Report.
If you have any questions regarding this notice or need additional information, please contact
Mack Wiggins at 919-791-4200.
xc: Central Files
RRO SWP files
Danny Smith, Supervisor
Division or Water Resources, NCDENR
Waste Water Treatment Plant
135 Aqueduct Rd.Weldon, NC 27890 [phone] Fax [phone]
The Roanoke Rapids Sanitary District Wastewater Plant (WWTP) has a monthly Total Suspended
Solids (TSS) limit of 30 milligrams per liter (mg/l) and an 85 % removal requirement. The WWTP
was noncompliant for November 2013 with a 34.7 TSS and an 82.2 % removal.
The WWTP is experiencing bulking sludge. Microscopic examination reveals no filamentous
organisms. The sludge is finely dispersed and will not settle and therefore easily washes out
with effluent flow. Laboratory comparison of data from this year to last at the same time
shows nearly a 50% increase in food to microorganism (F/M) ratio. Literature states a 10%
increase in F/M ratio can cause bulking sludge.
The WWTP has two Trickling Filters that buffers flow from the Primary Clarifiers before reaching
the Activated Sludge System. With the lower plant flows of recent one Filter with recirculation
will accomplish the buffering needed. The Filters had both Rotary Distributors replaced in the
mid to late nineties. Unlike the Distributors of the past these Distributors were built with
bottom load bearings rather than top load bearings. The WWTP has experienced much trouble
with this style of Distributor. In 2012 funding was budgeted to have both Distributors rebuilt in
2013 and retrofitted with top load bearings. The first Distributor was in the process of being
machined for retrofitting when the bearing of the Distributor still in service failed. The lack of
no buffering led to the organic over load and the resulting bulking sludge.
The bulking sludge caused three extremely high TSS results that led to the noncompliance. The
numbers were 176.0,142.0 and 186.1 mg/l. Without these anomalies the monthly average
would be 14.7 and the percent removal 93.4. The first high number was due to a pump failure
which was feeding polymer to aid in solids settling. The other two high numbers was a result of
high flow wash out due to 2.4 inches of rain in two days.
To control the loss effluent solids the WWTP did the following. Approximately $77,500 was
spent to rebuild the first distributor. It is back on line but will take some time before zoogleal
mass can be established and buffering begins. Around $5500.00 was spent on polymer to aid
settling. Over $1000.00 of spare pump parts were on hand to be able to repair the polymer
pump as quickly as possible. Extra maintenance was done to the on line Distributor to keep it in
operation. The wasting was halted to bring the F/M ratio back in balance. Extra sampling and
Waste Water Treatment Plant
135 Aqueduct Rd.Weldon, NC 27890 [phone] Fax [phone]
testing was done to improve the TSS weekly and monthly averages. And during high flow day's
equalization tanks were used to store flow to minimize solids wash out.
The WWTP spent approximately $84,000.00 and put in a great deal of effort to obtain
compliance.
\A vfr
*
Waste Water Treatment Plant
(252) 536-4884135 Aqueduct Rd.Weldon, NC 27890 Fax [phone]
The WWTP is experiencing bulking sludge. Microscopic examination reveals no filamentous
organisms. The sludge is finely dispersed and will not settle and therefore easily washes out
with effluent flow. Laboratory comparison of data from this year to last at the same time
shows nearly a 50% increase in food to microorganism (F/M) ratio. Literature states a 10%
increase in F/M ratio can cause bulking sludge.
The bulking sludge caused three extremely high TSS results that led to the noncompliance. The
numbers were 176.0,142.0 and 186.1 mg/l. Without these anomalies the monthly average
would be 14.7 and the percent removal 93.4. The first high number was due to a pump failure
which was feeding polymer to aid in solids settling. The other two high numbers was a result of
high flow wash out due to 2.4 inches of rain in two days.
To control the loss effluent solids the WWTP did the following. Approximately $77,500 was
spent to rebuild the first distributor. It is back on line but will take some time before zoogleal
mass can be established and buffering begins. Around $5500.00 was spent on polymer to aid
settling. Over $1000.00 of spare pump parts were on hand to be able to repair the polymer
pump as quickly as possible. Extra maintenance was done to the on line Distributor to keep it in
operation. The wasting was halted to bring the F/M ratio back in balance. Extra sampling and
The Roanoke Rapids Sanitary District Wastewater Plant (WWTP) has a monthly Total Suspended
Solids (TSS) limit of 30 milligrams per liter (mg/l) and an 85 % removal requirement. The WWTP
was noncompliant for November 2013 with a 34.7 TSS and an 82.2 % removal.
The WWTP has two Trickling Filters that buffers flow from the Primary Clarifiers before reaching
the Activated Sludge System. With the lower plant flows of recent one Filter with recirculation
will accomplish the buffering needed. The Filters had both Rotary Distributors replaced in the
mid to late nineties. Unlike the Distributors of the past these Distributors were built with
bottom load bearings rather than top load bearings. The WWTP has experienced much trouble
with this style of Distributor. In 2012 funding was budgeted to have both Distributors rebuilt in
2013 and retrofitted with top load bearings. The first Distributor was in the process of being
machined for retrofitting when the bearing of the Distributor still in service failed. The lack of
no buffering led to the organic over load and the resulting bulking sludge.
[phone]
equalization tanks
Waste Water Treatment Plant
135 Aqueduct Rd. Weldon, NC 27890
in a great deal of effort to obtain
testing was done to improve the TSS weekly and monthly averages. And during high flow day’s
equalization tanks were used to store flow to minimize solids wash out. V
The WWTP spent approximately $84,000.00 and put
compliance.
11 "