NC0025721_Historical information_20071231

Michael F. Easley, Governor
January 10, 2007
Dear Mayor Draper:
Wkly & Mo. BODAugust
September
October
An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper
The year 2006 has seen a serious deterioration in compliance, with 7 months out of 12 having
problems severe enough to result in penalties. The reasons given are tabulated below:
Raleigh Regional Office
1628 Mail Service Center
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Phone [phone]
FAX [phone]
Alan W. Klimek, P.E., Director
Division of Water Quality
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
Surface Water Protection
Raleigh, NC 27699-1628
Subject: Compliance Evaluation Inspection
Weldon WWTP
NPDES Permit No. NC0025721
Halifax County
-NrrthCarolin
Naturally
Customer Service
1-877-623-6748
Explanation__________
Aerator down, bearings
May
June
Month
April
Wkly BOD
Wkly BOD High infl BOD, wet fields so high
solids inventory, heavy rain with
aerators off, poor settling in
clarifiers____________________
Ernesto rain, aerators off, poor
settling in clarifiers___________
Debris in reuse water for C12
clogged screen
High infl BOD, heavy wasting
resulted in pin floc_____________
Flow pacing valve not functioning
correctly_____________________
Poor settling
Manual feed until
problem corrected
Began polymer feed to
clarifiers, running
filtered and unfiltered
CODs
Returned to normal after
rain and began using new
digester
Returned to normal after
rain__________________
Eventually found reason
for clog, returned to
potable water for C12
Contacted C.D. Malone
Steps Taken______
Replaced bearings,
restarted
Spikes in Fecal
(did not trigger
enforcement)
3 Wkly BOD &
Mo. BOD
3 Wkly Fecal &
Mo. Fecal_____
2 Wkly BOD &
Mo. BOD
Parameter(s)
Wkly & Mo. TSS
The Honorable G. W. Draper, Mayor
Town of Weldon
109 Washington Ave.
P.O. Box 551
Weldon, NC 27890
On January 4, 2007, Mr. Myrl Nisely of the Raleigh Regional Office conducted a compliance
inspection of the Weldon WWTP facility with the help of ORC Donald Crowder. Attached is a
checklist for the inspection - please be sure to read the comment sections.
CO /1
0 u
111■ 11 dj r
Inspection of Halifax County ities 3/1/07 Page 2
O
O
o
• Proactive Maintenance/Troubleshooting/Responding to Equipment Malfunctions
Coming Changes as Presented by ORC Duncan
If thick sludge were observed building up in the outer ring, more than the skimmer could remove, a
proactive operator would find a way to either remove it by hand, or stir it up, or hose it for dilution or
otherwise return the consistency to what was intended.
The following logs and activities are planned in the near future. As part of Weldon’s Compliance
Action Plan, firm dates should be established for them to be implemented.
Particularly troubling was a lack of observing equipment and/or measurements enough to see trouble
developing, and the absence of timely action when breakdowns occur. The clarifier had stopped
turning on Saturday, said by Mr. Duncan to be loss of one phase of the motor. The vinyl curtain for
the outer ring had tom and the curtain was displaced in several locations. Thick dried sludge was in
the outer ring, apparently pressing on the vinyl causing the deformations. Unit outages such as this are
to be reported by telephone to the Weldon plant immediately as required by Part II, 30, of the IUP.
Apparently the operator was planning to somehow continue using the clarifier to allow Reser’s to run
the next day. Once Donald declared the unit inoperable, we left the plant but were alerted later that
Reser and Halifax County maintenance men had moved in to install a temporary gearbox and attempt
repairs on the curtain. By Wednesday morning the unit was able to operate.
Inattention was also inferred from pH charts that were not changed out after a 24 hour period. Some
continued to run for 36 or 48 hours. One of the pH charts has been running backward for
approximately two months.
In addition to the large tear in the vinyl wall, numerous other breaks and cracks were readily apparent.
These suggest a potential failure, so a proactive operator making regular rounds could have foreseen
future problems and taken steps to perform maintenance on an off day when Riser’s was not running.
o
o
o
o
In other words, there has been no database developed on which comparisons could be built, no
opportunity to observe trends or otherwise develop expertise on running the plant.
• Except for pH circular recording charts for influent and effluent, there were no operational or other
process control documents in use. Brandon was aware of the need for them, stating that he was
developing forms. Completely absent were
Influent flow records
pH logs for influent, Equalization Tanks (EQ), the Dissolved Air Flotation unit (DAF),
or final effluent. He was basically operating to a pH of 7.5 to 8 in the EQ tanks. If the
final effluent pH was out of line, adjustments would be made in EQ.
Documented operator rounds. There are no recorded observations such as colors, DAF
effectiveness, or final effluent appearance
Equipment maintenance logs
Process control measurements, laboratory analyses, results of jar tests, etc., used to
operate/adjust the DAF, for example when the dosages need to be changed for pH
adjustment chemicals, precipitants, flocculants, polymers, etc.
Data on operation of the BioTower, such as distributor arm speed and flow rates,
condition of the hanging strips during freezing weather, health of biomass, etc.
Clarifier blanket depths, settleability, effluent clarity, and other observations.
■ Inspection of Halifax County lities 3/1/07 Page 3
HCPU Reconnaissance Inspection Findings
Other Related Comments and Recommendations from DWQ Pretreatment Central Office Staff
• The most recent Consent Agreement between the Town and HCPU has expired. The Town has
offered HCPU at least two drafts of an extended CA, however HCPU has not accepted either one. If a
new CA cannot be agreed upon and signed by March 16, 2007, the Town must proceed with other
actions (issue administrative order, go back to IUP limits, or even termination of service).
• It is understood that HCPU is not reporting all pH limit violations documented by their continuous
recording pH meter. This is a violation of IUP Part II, 2., (a) and (g) and perhaps other paragraphs or
sections. The POTW must take appropriate enforcement as outlined in your Division approved ERP
for this reporting failure. Also for all limit violations at least back to 1/1/07, and perhaps beyond. In
general, the SIU must immediately begin either providing copies of their pH charts with their monthly
• Log sheets for nearly every piece of equipment on which time of visitation and operating data can
be recorded
• Rounds carried out every 30 minutes, unless the operator is working on a problem or carrying out
lab work to adjust polymer doses so that he is not available for a round at the regular time.
• pH adjustment of HCPU effluent will be made in a manhole discharging to the Weldon WWTP,
and the pH probe will be moved from the Parshall flume to that manhole.
• EQ blowers will be installed in the large tank for better mixing and aeration
• Hire two new employees. Be sure certification is at appropriate grade level, and submit a
designation form to Technical Assistance and Certification Unit (TACU).
Based on our site visit, the situation at HCPU is very serious. As stated above, the SIU is in SNC for
causing Pass-Through for October 2006 and perhaps other times. It is clear from our site visit that the
underlying cause of the Pass-through is severe neglect and mis-operation of HCPU’s pretreatment unit.
This is a violation of several Industrial User Pretreatment Permit (IUP) General Conditions listed
below. The Town must take appropriate enforcement action as outlined in your Division approved
ERP. Many of these violations should be considered SNC under Criteria 8. Additionally, the Town
must require HCPU to submittal a complete O&M manual to the Town for review and begin
observation and documentation of HCPU’s proper implementation of the O&M activities. Include a
schedule of these activities in your Corrective Action Plan.
• Part II #6 - Prevention of Adverse Impact
“The permittee shall take all responsible steps to minimize or prevent any discharge in
violation of this permit which has a likelihood of adversely affecting the POTW.”
• Part II #7 - Facilities Operation, Bypass
“The permittee shall at all times maintain in good working order and operate efficiently as
possible, all control facilities or systems installed or used by the permittee to achieve
compliance with the terms and conditions of this permit.”
• Part II #8 - Removed Substances
“Solids, sludges, etc., removed in the course of treatment shall be disposed of in a manner such
as to prevent any pollutants from such materials from entering the sewer system.”
• Part III, #5 - Certified Operator
“While on site, the ORC or backup operator must document proper operation, maintenance,
staffing, record keeping, reporting.”
Also see 15A NCAC 08G .0200 - establishes requirements for Certified Operators, especially
.0203(4) and .0204(5).
Inspection of Halifax County ies 3/1/07 Page 4
O
O
1.
2.
3.
• IUP Part III, 5, requires the HCPU ORC to hold a Grade 2 Certification. We assume this was Grade
2 for Biological treatment systems, due to the bio-tower. DWQ strongly recommends the POTW
require HCPU to have an ORC with both Biological and Physical/Chemical certifications as the DAF
and other physical chemical processes are critical to proper operation of HCPU's pretreatment unit.
However, if the POTW feels that more intensive training for the specific physical/chemical units
present at HCPU than is provided from the NC DWQ Physical/Chemical certification training, the
POTW should explore requiring other (or additional) training.
• Part II, 1, requires samples to be representative. Generally, please review all aspects of the SIU's
sampling procedures to confirm proper procedures. It is understood that both the POTW and SIU
samples are composited according to flow. Please evaluate the need for more frequent aliquots during
compositing (eg. every 15 minutes instead of every hour), and also the need for flow proportional
sampling.
In any case, there are some months, and multiple days where the numbers were exceeded by
Reser's. Please determine if Resers did any of the things the Agreement requires of them.
If they are not, or even if they are, the Town could put them in Reser's IUP as limits. Or you
could put a special condition in Resers IUP that requires them to report to HCPU and the Town
each time the criteria are exceeded, and include a description of what they did to comply with
• The Town's next Headworks Analysis (HWA) is due 8/1/07. Mr. Crowder is signed up to an HWA
workshop on 4/12/07. Regarding that HWA:
This new HWA will have to follow PERCS new requirements for BOD and TSS allowable
loads being based on Design criteria. This will considerably lower the WWTP allowable
loads. Weldon will likely have to reduce HCPU's current TSS limit, and will possibly not
be able to raise HCPUs’ BOD limit much if at all (only 14% left based on Design).
reports, or if the POTW wishes, simply provide a list of the max and min for the day, and all times the
pH was out of range. Note any violations are subject to the 24 hour reporting (Part II, 2, g).
o It is also understood that HCPU believes that pH slugs from Reser's are causing HCPU's
pH violations. As the wastewater goes through a 0.1 mg EQ basin, and then through the
DAF (which requires precise pH adjustment to work properly), this is either an incorrect
explanation or evidence that the DAF is not being operated properly at all. It is assumed
that severe pH swings out of the DAF would easily inhibit the bio-tower (part of O&M
discussed above). Do they ever look at the bio-slime under the micro-scope?
• The POTW should require HCPU to submit a plan for prevention of all these clarifier outages, and
problems with all other units as needed. You should also evaluate the need to require HCPU to
provide redundant units and/or equipment, or of modifying the IUP to establish requirements for
mandatory discharge shutdown if certain units/equipment are out for a specified time.
Also, we note HCPU had a Consent Order interim limit of 3000 Ibs/day, and the Town has
proposed to lower it to 2000 in this latest Order, exactly because of the County causing the
current pass-through. Even this new lower Order limit causes a 19% over allocation based
on Design.
• The 8/27/01 Agreement for Pretreatment between HCPU and Resers contains Design Criteria for the
HCPU pretreatment unit of BOD 6000 mg/1 or 9174 Ibs/day, TSS 3500 mg/1, and flow 0.2 mgd.
The Agreement expressed these numbers as "maximum average daily" values - please find out
whether they are meant to be monthly averages or a daily max designs.
• Inspection of Halifax County ities 3/1/07 Page 5
Summary
If you have any questions concerning this report please call Stephanie or Myrl at [phone].
Sincerely,
i?,
cc:
As stated above, our Reconnaissance Inspection indicated severe O&M problems at HCPU, including
several IUP violations. Your Compliance Action Plan must include steps to address improvement of
operating practices by HCPU as authorized by the Pretreatment Program, with a means of
documenting to DWQ appropriate follow-up by the Town. Because of the inter-relationship of your
NPDES violations and your Pretreatment Program, we request that you submit a copy of your Plan to
the PERCS Unit, in addition to RRO.
• Please consider contacting other POTWs with food processors or SIU DATs and bio-towers to
discuss your issues and seek their input, even possibly accompanying them on inspections.
Stephanie Brixey
RRO Pretreatment Coordinator
Myrl A. Nisely
Environmental Chemist
Donald Crowder, Town of Weldon
Leo Green, Green Engineering
Brandon Duncan, HCPU ORC
Jerry Rimmer, TACU
Dana Folley, PERCS Unit, Central Office
Vanessa Manual, NPDES Central Office
Central Files (SWP)
RRO/ SWP File
the Agreement. These may be ideas to consider now, or to consider for later if HCPU
violations continue after the end of the Consent Order.
• We noted that there were several days where the Town influent showed spikes that were not
associated with an HCPU spike. This could be due to improper sampling at either the SIU or POTW,
or could be due to slugs from another User.
sjfof Ji?:
. ■ TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/26/074/30/07
1
Develop process records system for the following:4/30/07 4/10/07
2
5/10/07 5/10/07
3 3.
4.
Develop Daily Operations Data Log for Pretreatment Facility 4/10/07 4/10/07
4
1
Finding
Number
Entity/
Contact
Person/
Phone
Number
1.
2.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
1.
2.
3.
4.
5.
6.
7.
8.
Develop Operation and Maintenance manuals for Influent
screens, DAF, Clarifier, Bio-tower, Self Priming Pumps,
Blowers, Recirculation Pumps and Effluent Pumps. Include in
manuals process control guides for total treatment interaction.
Influent Flow
Effluent Flow
Influent pH
DAF Flow Rate
Recirculation Flow Rate thru bio tower
Process pH
Effluent pH at discharge to Weldon system
All chemical feed-volumes and locations______________
Complete Consent Order process improvements to include:
Add diffused aeration/mixing to existing tanks.
Install EQ re-charge pumps at recirculation pump
station
Instrumentation and pump control improvements at
recirculation pump station
Pinch valve modifications
• TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/10/074/10/07
5
8/15/07 Controllin
6
4/26/074/30/07
7
2
Finding
Number
Entity/
Contact
Person/
Phone
Number
Provide Town of Weldon access to SCADA web site so that
continuous pH monitoring and recording is available from all
sampling locations.
Install SCADA RTU and caustic feed pump and piping at
pretreatment plant to monitor and control caustic feed into plant
effluent in response to demand at Weldon receiving manhole.
Frequency of all monitoring activities will be no less than once
per every two (2) hours during operation of pretreatment facility.
Monitoring reports will be available at all time for inspection by
the Town of Weldon and/or state DWQ representatives.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
g
Pretreat.
Plant eff.
through
caustic
feed at
eff.
parshall
flume.
AtoC
issued
5/7/07
Relocate ph probe from Wallace Fork pump station to Town of
Weldon receiving manhole. Integrate with County SCADA to
control caustic feed at pretreatment plant.
' TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/26/074/30/07
8
1/1/08 to
9
4/13/07
Complete Clarifier Repairs 4/14/07 4/14/07
10
Continue Sewer System Rehabilitation. +/- $65,000 annually.7/1/077/1/07
11
3
BOD-6000mg/l (9174 pounds)-daily max
TSS-3500 mg/l-daily max
Flow-200,000 gal/day (175,000gal/day presently)
Finding
Number
Entity/
Contact
Person/
Phone
Number
Revise Reser’s Pretreatment Permit to include specific limits for
their influent into the HCPU Pretreatment Facility. These limits
shall be in accordance with the Pre-treatment agreement
between Reser’s Fine Foods, Inc. and Halifax County dated
August 27, 2001. More specifically, these limits are:
Action
Target
Date
Action
Completion
Date
Town of
Weldon/
Donald
Crowder
1252-
536-
3478
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Reser’s
/Randy
Earle/
252-
536-
5760
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Added
Consent
Agreement
upon
HCPU’s
request for
extension.
Halifax County Public Utilities will be required to provide 24 hour
operation of pretreatment facility. HCPU will provide full
contingency of operators to adequately perform duties
throughout a 24-hour period. Each operating shift will have a
certified operator on duty. This operator should be certified for
both biological and physical/chemical treatment systems.
' TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
7/1/077/1/07
12
Next anticipated 9/1/07
13
Prepare Preventative Maintenance Checklist for all equipment.4/10/07 4/10/07
14
4/10/07 4/10/07
15
4
Develop a worksheet and document microscopic examination
of organisms in the Bio-Tower immediately.
Finding
Number
Entity/
Contact
Person/
Phone
Number
Continue Oil & Grease inspection program,
compliance inspection (11 establishments)
Improve reclaimed water feed to chlorine disinfection system at
wastewater treatment plant.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
10/23/07
through
10/30/07
’ TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
8/15/07
16
5
Coordinate Ph limits at Pretreatment facility and Town of
Weldon receiving manhole. Modify either Pretreatment Permit
or Town of Weldon Sewer Use Ordinance as necessary.
Finding
Number
Entity/
Contact
Person/
Phone
Number
Action
Target
Date
Action
Completion
Date
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
Adjustment
of pH at
eff. of
Pretreat.
Plant has
eliminated
low pHs.
f
2.
a.
3.
a.
b.
c.
d. Latitude/Longitude OK
e.
a.
b.
c.
Driving Directions OK on Existing Permit OR, if not, is
OK on Application Q, or provide Driving Directions (please be accurate):
USGS Quadrangle Map name and number OK on Existing Permit Q, OR, if not, is
OK on Application Q, or provide USGS Quadrangle Map name and number:
Stream Classification: C
River Basin and Sub basin No.: Roanoke River, 23-(26)
Describe receiving stream features and downstream uses: Flow varied by hydroelectric
generation
No.
County: Halifax
Permitee: Town of Weldon
Application/ Permit No.: NC0025721
Staff Report Prepared By: Mvrl Nisely
Date: 1/11/2007
To: NPDES Discharge Permitting Unit
Attn. NPDES Reviewer: Jim McKay
Receiving Stream OK on Existing Permit OR. if not, is
OK on Application [J, or provide Receiving Stream or affected waters:
NPDES REGIONAL WATER QUALITY
STAFF REPORT AND RECOMMENDATIONS
(This form is best filled out on computer, rather than hard copy)
Keeping BIMS Accurate: Is the following BIMS information (a. through e. below) correct?
Q Yes or No. If No, please either indicate that it is correct on the current application or the
existing permit or provide the details. If none can be supplied, please explain:
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing')
(If there is more than one discharge pipe, put the others on the last page of this form.)
Location OK on Existing Permit Q, OR, if not, is
OK on Application O, or if neither is right, provide Location: More accurate in d. below
b. Person contacted and telephone number: Donald Crowder 252-536-3478
c. Site visit conducted by: Myrl Nisely
d. Inspection Report Attached: [X] Yes or Q No.
Project Name:
SOC Priority Project? (Y/N) N If Yes, SOC No.
on Existing Permit Q, (check at http://www.topozone.com These are
often inaccurate) or is OK on Application Q, or provide Latitude: 36-25-24 Longitude: 77-
34-39
A. GENERAL INFORMATION
1. This application is (check all that apply): New [X] Renewal
Modification
Was a site visit conducted in order to prepare this report? [X] Yes or
Date of site visit: 1/4/2007
B. DESCRIPTION OF FACILITIES AND WASTE(S) (renewals and modifications only)
1.
2.
3.
4.
FORM: NPDES-RRO 06/03, 9/03 2
N^^REGIONAL WATER ITY
STAFF REPORT AND RECOMMENDATIONS
For NEW FACILITIES Proceed to Section C, Evaluation and Recommendations
(For renewals or modifications continue to section B)
Landfilled? Yes O No^ If yes, where?
Other?
Adequate Digester Capacity? Yes [X] No O Sludge Storage Capacity? Yes M No | |
Please comment on current operational practices: Historically strong, lots of extra process control
testing. However, may not be taking enough time to analyze and make us of the process data
generated.
5. Are there any issues related to compliance/enforcement that should be resolved before issuing this
permit? |X1 Yes or O No. If yes, please explain: Mayor is being asked for a corrective action plan to
maintain compliance.
Describe the existing treatment facility: Same as old permit but add new 285,000 gal aerated digester,
polymer addition to the clarifiers, and standby power generator.
Are there appropriately certified ORCs for the facilities? KI Yes or O No.
Operator in Charge: Donald Crowder Certificate # 11136 (Available in BIMS or Certification
Website)
Back- Operator in Charge: Russell Wheeler Certificate # 24059
Does the facility have operational or compliance problems? Please comment: Yes, in 2006. See
attached Compliance Evaluation Inspection report.
Summarize your BIMS review of monitoring data (Notice(s) of violation within the last permit cycle;
Current enforcement action(s)): Each of the months listed except November have received
enforcements.
Are they currently under SOC, O Currently under JOC, Currently under moratorium O? Have
all compliance dates/conditions in the existing permit, SOC, JOC, etc. been complied with? O Yes
or O No. If no, please explain:
Residuals Treatment: PSRP [X] (Process to Significantly Reduce Pathogens, Class B) or
PFRP Q (Process to Further Reduce Pathogens, Class A)?
Are they liquid or dewatered to a cake? Liquid
Land Applied? Yes K No O If so, list Non-Discharge Permit No. WQ0002368
Contractor Used: Synagro
1
C. EVALUATION AND RECOMMENDATIONS
3.
4.
Reason
5.
Reason
6.
FORM: NPDES-RRO 06/03, 9/03 3
REGION AL WATER ITY
STAFF REPORT AND RECOMMENDATIONS
List specific Permit requirements that you recommend to be removed from the permit when
issued. Make sure that you provide a reason for each condition:
Recommended Removal
List specific special requirements or compliance schedules that you recommend to be included in
the permit when issued. Make sure that you provide a reason for each special condition:
Recommended Addition
_______________Reason_______________
These components have been added since the
last permit____________________________
Get most accurate estimate of flows for near
future. Town engineer estimates capacity
can be increased from 1.2 MGD to 1.6 MGD
by using UV disinfection. Yet they did not
request an increase in permit flow limit.
Recommendation: O Hold, pending receipt and review of additional information by regional office;
Hold, pending review and approval of required additional information by NPDES permitting
office; 0 Issue; O Deny. If deny, please state reasons:
2. Provide any additional narrative regarding your review of the application: Question A(8)c. was
answered incorrectly. Sludge is land applied, but wastewater is not. This is done intermittently, now
about once per quarter.
List any items that you would like NPDES Unit to obtain through an additional information
request. Make sure that you provide a reason for each item:
Recommended Additional Information
Updated site map to show new digester, standby
generator and polymer addition_____________
Estimated flow from Hobgood (now tied in) and
Town of Halifax, to be added in 2007
1. Alternative Analysis Evaluation: has the facility evaluated the non-discharge options available? Give
regional perspective for each option evaluated:
Spray Irrigation: Not a reasonable alternative for this much flow
Connect to Regional Sewer System: No regional treatment plant exists
Subsurface: Flow too large
Other Disposal Options:
7. Signature of report preparer:
Date:
D. ADDITIONAL REGIONAL STAFF RE\ IEW ITEMS
If next page is not used, PLEASE set printer for pages 1 through 3 to avoid wasting paper.
Use this page for facilities with more than one Discharge Pipe
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a.
b.
c.
d.
e.
c.
Discharge Point: (Fill this section only if BIMS or Application Info is incorrect or missing)
a.
b.
c.
These are oftend.
FORM: NPDES-RRO 06/03, 9/03 4
Location OK on Application Q,
OK on Existing Permit O, or provide Location:
Stream Classification:
River Basin and Sub basin No.:
Describe receiving stream features and downstream uses:
These are often
Longitude:
Driving Directions OK on Application O,
OK on Existing Permit Q, or provide Driving Directions (please be accurate):
USGS Quadrangle Map name and number OK on Application Q,
OK on Existing Permit O, or provide USGS Quadrangle Map name and number:
Location OK on Application Q,
OK on Existing Permit Q, or provide Location:
Driving Directions OK on Application Q,
OK on Existing Permit Q, or provide Driving Directions (please be accurate):
USGS Quadrangle Map name and number OK on Application □,
OK on Existing Permit EZI, or provide USGS Quadrangle Map name and number:
a.
b.
Signature of WQS regional supervisor:
Latitude/Longitude OK on Application □, (check at http://topozone.com
inaccurate) OK on Existing Permit Q, or provide Latitude:
Latitude/Longitude OK on Application Q, (check at http://topozone.com
inaccurate) OK on Existing Permit Q, or provide Latitude: Longitude:
Reminder: attach inspection report if Yes was checked for 2 d.
lu a iu.
Receiving Stream OK on Application Q,
OK on Existing Permit O, or provide Receiving Stream or affected waters:
NFD REGIONAL WATER^MjTY
STAFF REPORT AND RECOMMENDATIONS
Michael F. Easley, Governor
January 10, 2007
Dear Mayor Draper:
Wkly & Mo. BODAugust
September
October
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
The year 2006 has seen a serious deterioration in compliance, with 7 months out of 12 having
problems severe enough to result in penalties. The reasons given are tabulated below:
Raleigh Regional Office
1628 Mail Service Center
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Phone [phone]
FAX [phone]
Alan W. Klimek, P.E., Director
Division of Water Quality
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
Subject: Compliance Evaluation Inspection
Weldon WWTP
NPDES Permit No. NC0025721
Halifax County
Surface Water Protection
Raleigh, NC 27699-1628
Ncr thCarolin
Naturally
Customer Service
1-877-623-6748
May
June
High infl BOD, heavy wasting
resulted in pin floc_____________
Flow pacing valve not functioning
correctly_____________________
Poor settling
Manual feed until
problem corrected
Began polymer feed to
clarifiers, running
filtered and unfiltered
CODs
Returned to normal after
rain__________________
Eventually found reason
for clog, returned to
potable water for C12
Contacted C.D. Malone
Month
April
Wkly BOD
Wkly BOD High infl BOD, wet fields so high
solids inventory, heavy rain with
aerators off, poor settling in
clarifiers____________________
Ernesto rain, aerators off, poor
settling in clarifiers____________
Debris in reuse water for C12
clogged screen
Explanation__________
Aerator down, bearings
Returned to normal after
rain and began using new
digester
Steps Taken______
Replaced bearings,
restarted
Spikes in Fecal
(did not trigger
enforcement)
3 Wkly BOD &
Mo. BOD
3 Wkly Fecal &
Mo. Fecal_____
2 Wkly BOD &
Mo. BOD
Parameter(s)
Wkly & Mo. TSS
The Honorable G. W. Draper, Mayor
Town of Weldon
109 Washington Ave.
P.O. Box 551
Weldon, NC 27890
On January 4, 2007, Mr. Myrl Nisely of the Raleigh Regional Office conducted a compliance
inspection of the Weldon WWTP facility with the help of ORC Donald Crowder. Attached is a
checklist for the inspection - please be sure to read the comment sections.
&
Jj r> 11—ZVMS-* o'dis”
Weldon WWTP CE1, January 9^007 Page 2 of 2
Other comments from this inspection:
If you have comments or questions, please contact Myrl Nisely at 919-791-4200.
Sincerely,
ATTACHMENT
November 2 Wkly BOD
Mo. BOD
cc: RRO SWP File w/ attachment
Central Files w/ attachment
• Several extra process control tests are being run to predict plant performance, especially CODs
to estimate BOD. Continue to monitor these results closely to catch a period of troublesome
performance so that corrective measures can be taken as soon as possible.
• Because the new permit will contain a Total Chlorine Residual in the ug/1 range, the facility is
urged to begin measuring and controlling to these levels to be sure the requirement can be met
when the permit goes into effect. Existing equipment, standards and technique may need to be
altered to read to the lower levels.
• Synagro has historically held the 503 test results run by them. It is recommended that a copy of
all test results be routinely mailed to the ORC.
High infl BOD, poor settling when
polymer feed not pumping right
Improve polymer feed to
clarifiers. Halifax
Pretreatment improved
We recognize that efforts to understand plant problems continue, especially to determine if loads from
Halifax County Public Utilities (HCPU) may have caused the BOD problems. Nevertheless, the
Town is directed to prepare a Corrective Action Plan for assuring future compliance, to be
submitted to this office by February 23, 2007.
Charles Wakild, P.E.
Surface Water Protection Supervisor
Raleigh Regional Office
• Maintenance of fine bubble diffuser aerators at the bottom of the newly installed 485,000
gallon digester was a concern to RRO when that design was reviewed. Where would all that
sludge be stored if the tank had to be emptied? A scheme has been designed to do this. Waste
sludge is held in the old (smaller) digester with frequent decanting to raise solids. When that
tank is nearly full, it is pumped to the new tank. The new tank aerates enough to pass 503
testing for land application before the next pumping from the small digester. So after
satisfactory testing, the contents are pumped to the concrete holding basin (volume 201,960
gallons). Synagro, Inc. comes about once per quarter to completely empty this basin plus any
volume in the new digester that has also met 503 tests. In this way, the volume to be removed
from the new tank for maintenance is orchestrated to avoid the buildup of unmanageable
volumes in case emergency work is needed on the aerators.
Permit: NC0025721
Inspection Date: 01/04/2007
Yes No NA NEPermit
■ O(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■ oIs the facility as described in the permit?
■ # Are there any special conditions for the permit?
■ Is access to the plant site restricted to the general public?
■ Is the inspector granted access to all areas for inspection?
Yes No NA NELaboratory
■ Are field parameters performed by certified personnel or laboratory?
■ Are all other parameters(excluding field parameters) performed by a certified lab?
■ 0# Is the facility using a contract lab?
■ 0Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■ Incubator (Fecal Coliform) set to 44.5 degrees Celsius*/- 0.2 degrees?
■ Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
Comment:
Yes No NA NERecord Keeping
■ OAre records kept and maintained as required by the permit?
■ Is all required information readily available, complete and current?
■ Are all records maintained for 3 years (lab. reg. required 5 years)?
■ Are analytical results consistent with data reported on DMRs?
■ Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
■ Are DMRs complete: do they include all permit parameters?
■ Has the facility submitted its annual compliance report to users and DWQ?
■ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
3Page #
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: In new permit description add the new digester, the system for adding
polymer to clarifier influent and the standby power generator.
Record Keeping Yes No NA NE
■ Is the ORC visitation log available and current?
■ Is the ORC certified at grade equal to or higher than the facility classification?
■ Is the backup operator certified at one grade less or greater than the facility classification?
■ Is a copy of the current NPDES permit available on site?
■ Facility has copy of previous year’s Annual Report on file for review?
Comment:
Operations & Maintenance Yes No NA NE
■ Is the plant generally clean with acceptable housekeeping?
Comment:
Yes No NA NEFlow Measurement - Effluent
■ O# Is flow meter used for reporting?
■ 0Is flow meter calibrated annually?
■ 0Is the flow meter operational?
■ (If units are separated) Does the chart recorder match the flow meter?
Comment:Meter calibration 7/20/06
Yes No NA NEAerobic Digester
■ oIs the capacity adequate?
■ Is the mixing adequate?
■ Is the site free of excessive foaming in the tank?
■ # Is the odor acceptable?
■ 0# Is tankage available for properly waste sludge?
Drying Beds Yes No NA NE
■ Is there adequate drying bed space?
Page #4
Permit: NC0025721
Inspection Date: 01/04/2007
Owner-Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: New aerated tank is working well. Waste sludge goes first to old (small)
digester, where water is decanted. When nearly full, this tank is pumped to the new
one. Aeration provides the vector reductions necessary to meet 503 regs, with testing
done by Synagro. The tank is then discharged to the concrete aerated holding tank
from which land application is done about once a quarter. By keeping this procedure
moving often enough, the volume in the new tank is kept low enough that the final
sludge holding tank can empty the new tank. This will become important when
maintenance is needed on the aerators in the new tank.
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settieable Solids, pH, DO, Sludge ■
Judge, and other that are applicable?
Yes No NA NEDrying Beds
■ Is the sludge distribution on drying beds appropriate?
■ Are the drying beds free of vegetation?
■ # Is the site free of dry sludge remaining in beds?
■ Is the site free of stockpiled sludge?
■ oIs the filtrate from sludge drying beds returned to the front of the plant?
■ # Is the sludge disposed of through county landfill?
■ # Is the sludge land applied?
■ (Vacuum filters) Is polymer mixing adequate?
Yes No NA NESolids Handling Equipment
■ Is the equipment operational?
■ Is the chemical feed equipment operational?
■ Is storage adequate?
■ Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■ oIs the site free of sludge buildup on belts and/or rollers of filter press?
■ Is the site free of excessive moisture in belt filter press sludge cake?
■ The facility has an approved sludge management plan?
Comment:
Yes No NA NEBar Screens
Type of bar screen
a.Manual
b.Mechanical
■ Are the bars adequately screening debris?
■ Is the screen free of excessive debris?
■ Is disposal of screening in compliance?
■ Is the unit in good condition?
Comment:
Yes No NA NEOxidation Ditches
5Page #
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: Workers were moving a layer of sludge into windrows for pickup by
Synagro at the time of this inpsection. Beds are normally empty except for small
amount of clarifier scum.
Oxidation Ditches Yes No NA NE
Are the aerators operational?■
Are the aerators free of excessive solids build up?■
# Is the foam the proper color for the treatment process?■
Does the foam cover less than 25% of the basin’s surface?■
Is the DO level acceptable?■
Are settleometer results acceptable (> 30 minutes)?■ O
Is the DO level acceptable?(1.0 to 3.0 mg/l)■
■ o
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?■ o
Is the site free of excessive buildup of solids in center well of circular clarifier?■
Are weirs level?■
Is the site free of weir blockage?■
Is the site free of evidence of short-circuiting?■ 0
Is scum removal adequate?■
Is the site free of excessive floating sludge?■
Is the drive unit operational?■ o
Is the return rate acceptable (low turbulence)?■
Is the overflow clear of excessive solids/pin floc?■
■
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?■ D
Are cylinders protected from direct sunlight?■
Is there adequate reserve supply of disinfectant?■ 0
Is the level of chlorine residual acceptable?■
Is the contact chamber free of growth, or sludge buildup?■
Page #6
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes)
Comment:
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
Comment: Scum removed is sent to the drying beds. Blankets were 1.5 - 2 ft out of
to redSuce'TSSdePth Lat6ly h3Ve added Po|ymer to the splitter box feeding the clarifiers
Yes No NA NEDis infection-Gas
■ Is there chlorine residual prior to de-chlorination?
■ Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
■ If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-..)
If yes, then when was the RMP last updated?
Yes No NA NEDe-chlorination
GasType of system ?
■ Is the feed ratio proportional to chlorine amount (1 to 1)?
■ Is storage appropriate for cylinders?
■ o# Is de-chlorination substance stored away from chlorine containers?
■ Are the tablets the proper size and type?
■ oAre tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Yes No NA NEInfluent Sampling
■ # Is composite sampling flow proportional?
■ Is sample collected above side streams?
■ Is proper volume collected?
■ 0Is the tubing clean?
■ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■ Is sampling performed according to the permit?
Yes No NA NEEffluent Sampling
Page #7
Permit: NC0025721
Inspection Date: 01/04/2007
Owner-Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: Unique system brings both effluent and influent into the lab, where
mechanical dippers sample in proportion to the flow. There is no tubing to be
periodically replaced. Influent refrigerator T = 2.9 deg. C
Comment: Chlorine is < 2500 lb. Attempts to use final effluent as carrier of the
chlorine ran into trouble when small worms clogged a screen in the line. This occurs
sporadically, or perhaps seasonally. The plant switched back to potable water to regain
needed control of the chlorine doseage.
Comment: The ORC was encouraged to begin adjusting to a lower Total Chlorine
Residual in preparation for the new permit. A limit in the range of 17 to 28 ug/l will be in
that permit.
Effluent Sampling Yes No NA NE
■ Is composite sampling flow proportional?
■ oIs sample collected below all treatment units?
■ Is proper volume collected?
■ Is the tubing clean?
■ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■ Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: 2.7 degrees C
Effluent Pipe Yes No NA NE
■ OIs right of way to the outfall properly maintained?
■ Are the receiving water free of foam other than trace amounts and other debris?
■ 0If effluent (diffuser pipes are required) are they operating properly?
Comment:
Standby Power Yes No NA NE
■ Is automatically activated standby power available?
■ Is the generator tested by interrupting primary power source?
■ Is the generator tested under load?
■ Was generator tested & operational during the inspection?
■ Do the generator(s) have adequate capacity to operate the entire wastewater site?
■ Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■ Is the generator fuel level monitored?
Comment:
Page #8
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
r
Michael F. Easley, Governor
January 10, 2007
Dear Mayor Draper:
August Wkly & Mo. BOD
September
October
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
The year 2006 has seen a serious deterioration in compliance, with 7 months out of 12 having
problems severe enough to result in penalties. The reasons given are tabulated below:
Raleigh Regional Office
1628 Mail Service Center
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Phone [phone]
FAX [phone]
Alan W. Klimek, P.E., Director
Division of Water Quality
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
Surface Water Protection
Raleigh, NC 27699-1628
Subject: Compliance Evaluation Inspection
Weldon WWTP
NPDES Pemiit No. NC0025721
Halifax County
Manual feed until
problem corrected
Began polymer feed to
clarifiers, running
filtered and unfiltered
CODs
Month
April
May
June
Wkly BOD
Wkly BOD
High infl BOD, heavy wasting
resulted in pin floc_____________
Flow pacing valve not functioning
correctly_____________________
Poor settling
High infl BOD, wet fields so high
solids inventory, heavy rain with
aerators off, poor settling in
clarifiers____________________
Ernesto rain, aerators off, poor
settling in clarifiers___________
Debris in reuse water for C12
clogged screen
Explanation__________
Aerator down, bearings
Returned to normal after
rain__________________
Eventually found reason
for clog, returned to
potable water for C12
Contacted C.D. Malone
Returned to normal after
rain and began using new
digester
Steps Taken______
Replaced bearings,
restarted
Spikes in Fecal
(did not trigger
enforcement)
3 Wkly BOD &
Mo. BOD
3 Wkly Fecal &
Mo. Fecal_____
2 Wkly BOD &
Mo. BOD
Parameter(s)
Wkly & Mo. TSS
The Honorable G. W. Draper, Mayor
Town of Weldon
109 Washington Ave.
P.O. Box 551
Weldon, NC 27890
A7 h r
Of c
-NOTthCarolin
Jvaturally
Customer Service
1-877-623-6748
On January 4, 2007, Mr. Myrl Nisely of the Raleigh Regional Office conducted a compliance
inspection of the Weldon WWTP facility with the help of ORC Donald Crowder. Attached is a
checklist for the inspection - please be sure to read the comment sections.
£2/1)11 |(Q
Weldon WWTP CEI, January 9, 2007 Page 2 of 2
Other comments from this inspection:
If you have comments or questions, please contact Myrl Nisely at 919-791-4200.
Sincerely,
ATTACHMENT
cc: RRO SWP File w/ attachment
Central Files w/ attachment
• Because the new permit will contain a Total Chlorine Residual in the ug/1 range, the facility is
urged to begin measuring and controlling to these levels to be sure the requirement can be met
when the permit goes into effect. Existing equipment, standards and technique may need to be
altered to read to the lower levels.
• Several extra process control tests are being run to predict plant performance, especially CODs
to estimate BOD. Continue to monitor these results closely to catch a period of troublesome
performance so that corrective measures can be taken as soon as possible.
• Synagro has historically held the 503 test results run by them. It is recommended that a copy of
all test results be routinely mailed to the ORC.
• Maintenance of fine bubble diffuser aerators at the bottom of the newly installed 485,000
gallon digester was a concern to RRO when that design was reviewed. Where would all that
sludge be stored if the tank had to be emptied? A scheme has been designed to do this. Waste
sludge is held in the old (smaller) digester with frequent decanting to raise solids. When that
tank is nearly full, it is pumped to the new tank. The new tank aerates enough to pass 503
testing for land application before the next pumping from the small digester. So after
satisfactory testing, the contents are pumped to the concrete holding basin (volume 201,960
gallons). Synagro, Inc. comes about once per quarter to completely empty this basin plus any
volume in the new digester that has also met 503 tests. In this way, the volume to be removed
from the new tank for maintenance is orchestrated to avoid the buildup of unmanageable
volumes in case emergency work is needed on the aerators.
High infl BOD, poor settling when
polymer feed not pumping right
Improve polymer feed to
clarifiers. Halifax
Pretreatment improved
November 2 Wkly BOD
Mo. BOD
We recognize that efforts to understand plant problems continue, especially to determine if loads from
Halifax County Public Utilities (HCPU) may have caused the BOD problems. Nevertheless, the
Town is directed to prepare a Corrective Action Plan for assuring future compliance, to be
submitted to this office by February 23, 2007.
Charles Wakild, P.E.
Surface Water Protection Supervisor
Raleigh Regional Office
EPA
NPDES
3l NC0025721
21| I I I I I I
Entry Time/Date Permit Effective Date
03/06/0109:35 AM 07/01/04Weldon WWTP
Exit Time/Date Permit Expiration DateUS Hwy 301
Weldon NC 27890 07/05/3103:00 PM 07/01/04
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)Other Facility Data
Donald L Crowder/ORC/252-536-3478/
Name, Address of Responsible Official/Title/Phone and Fax Number
George W Draper,PO Box 551 Weldon NC 27890/Mayor/919-536-4836/
Permit Operations & Maintenance
Sludge Handling Disposal Facility Site Review
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Myrl Wisely PRO WQ//919-791-4200/
1/^7
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page #1
Self-Monitoring Program
Laboratory
United States Environmental Protection Agency
Washington, D.C. 20460
yr/mo/day
07/01/04
Contacted
No
m Records/Reports
Effluent/Receiving Waters
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
QA
72 Ld
Facility Self-Monitoring Evaluation Rating70U
Inspection Type
18lil
Fac Type
2°U
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
■ Flow Measurement
J17
Inspector
19LU12L
Inspection Work Days
671 I 69
Bl71 u
_______________________________________________Section B: Facility Data______
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Transaction Code
1 [NJ 2^
Water Compliance Inspection Report
Section A: National Data System Coding (i.e., PCS)
Remarks
I I I I I I I I I I I I I I I I | | | | | | | | | | | | | | | | | | | | | | | [^
J11
----------------------------Reserved------------------------
73l I I74 75l I I I I I I I80
Yes No NA NEPermit
■ (If the present permit expires in 6 months or less). Has the permittee submitted a new application?
■ Is the facility as described in the permit?
■ # Are there any special conditions for the permit?
■ Is access to the plant site restricted to the general public?
■ 0Is the inspector granted access to all areas for inspection?
Yes No NA NELaboratory
■ Are field parameters performed by certified personnel or laboratory?
■ Are all other parameters(excluding field parameters) performed by a certified lab?
■ # Is the facility using a contract lab?
■ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■ Incubator (Fecal Coliform) set to 44.5 degrees Celsius*/- 0.2 degrees?
■ Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
Comment:
Record Keeping Yes No NA NE
■ Are records kept and maintained as required by the permit?
■ Is all required information readily available, complete and current?
■ Are all records maintained for 3 years (lab. reg. required 5 years)?
■ Are analytical results consistent with data reported on DMRs?
■ Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
■ Are DMRs complete: do they include all permit parameters?
■ Has the facility submitted its annual compliance report to users and DWQ?
■ (If the facility is - or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Page #3
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Permit: NC0025721
Inspection Date: 01/04/2007
Comment: In new permit description add the new digester, the system for adding
polymer to clarifier influent and the standby power generator.
1
Permit: NC0025721
Inspection Date: 01/04/2007
Yes No NA NERecord Keeping
■ Is the ORC visitation log available and current?
■ Is the ORC certified at grade equal to or higher than the facility classification?
■ Is the backup operator certified at one grade less or greater than the facility classification?
■ Is a copy of the current NPDES permit available on site?
■ Facility has copy of previous year's Annual Report on file for review?
Comment:
Yes No NA NEOperations & Maintenance
■ Is the plant generally clean with acceptable housekeeping?
Comment:
Yes No NA NEFlow Measurement - Effluent
■ # Is flow meter used for reporting?
■ Is flow meter calibrated annually?
■ Is the flow meter operational?
■ (If units are separated) Does the chart recorder match the flow meter?
Comment:Meter calibration 7/20/06
Yes No NA NEAerobic Digester
■ Is the capacity adequate?
■ 0Is the mixing adequate?
■ Is the site free of excessive foaming in the tank?
■ # Is the odor acceptable?
■ 0# Is tankage available for properly waste sludge?
Yes No NA NEDrying Beds
■ 0Is there adequate drying bed space?
Page #4
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: New aerated tank is working well. Waste sludge goes first to old (small)
digester, where water is decanted. When nearly full, this tank is pumped to the new
one. Aeration provides the vector reductions necessary to meet 503 regs, with testing
done by Synagro. The tank is then discharged to the concrete aerated holding tank
from which land application is done about once a quarter. By keeping this procedure
moving often enough, the volume in the new tank is kept low enough that the final
sludge holding tank can empty the new tank. This will become important when
maintenance is needed on the aerators in the new tank.
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■
Judge, and other that are applicable?
1
Yes No NA NEDrying Beds
■ Is the sludge distribution on drying beds appropriate?
■ Are the drying beds free of vegetation?
■ # Is the site free of dry sludge remaining in beds?
■ Is the site free of stockpiled sludge?
■ Is the filtrate from sludge drying beds returned to the front of the plant?
■ o# Is the sludge disposed of through county landfill?
■ # Is the sludge land applied?
■ (Vacuum filters) Is polymer mixing adequate?
Yes No NA NESolids Handling Equipment
■ Is the equipment operational?
■ Is the chemical feed equipment operational?
■ Is storage adequate?
■ Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■ Is the site free of sludge buildup on belts and/or rollers of filter press?
■ Is the site free of excessive moisture in belt filter press sludge cake?
■ The facility has an approved sludge management plan?
Comment:
Yes No NA NEBar Screens
Type of bar screen
a.Manual
b.Mechanical
■ Are the bars adequately screening debris?
■ Is the screen free of excessive debris?
■ Is disposal of screening in compliance?
■ Is the unit in good condition?
Comment:
Yes No NA NEOxidation Ditches
Page #5
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: Workers were moving a layer of sludge into windrows for pickup by
Synagro at the time of this inpsection. Beds are normally empty except for small
amount of clarifier scum.
Oxidation Ditches Yes No NA NE
■ Are the aerators operational?
■ Are the aerators free of excessive solids build up?
■ # Is the foam the proper color for the treatment process?
■ Does the foam cover less than 25% of the basin's surface?
■ Is the DO level acceptable?
■ Are settleometer results acceptable (> 30 minutes)?
■ Is the DO level acceptable?(1.0 to 3.0 mg/1)
■ Are settelometer results acceptable?(400 to 800 ml/1 in 30 minutes)
Comment:
Yes No NA NESecondary Clarifier
■ Is the clarifier free of black and odorous wastewater?
■ Is the site free of excessive buildup of solids in center well of circular clarifier?
■ Are weirs level?
■ Is the site free of weir blockage?
■ Is the site free of evidence of short-circuiting?
■ Is scum removal adequate?
■ Is the site free of excessive floating sludge?
■ Is the drive unit operational?
■ Is the return rate acceptable (low turbulence)?
■ Is the overflow clear of excessive solids/pin floc?
■ Is the sludge blanket level acceptable? (Approximately 'A of the sidewall depth)
Yes No NA NEDisinfection-Gas
■ Are cylinders secured adequately?
■ Are cylinders protected from direct sunlight?
■ OIs there adequate reserve supply of disinfectant?
■ Is the level of chlorine residual acceptable?
■ Is the contact chamber free of growth, or sludge buildup?
Page #6
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Comment: Scum removed is sent to the drying beds. Blankets were 1.5 - 2 ft out of
12 ft.sidewall depth. Lately have added polymer to the splitter box feeding the clarifiers
to reduce TSS.
Disinfection-Gas Yes No NA NE
■ Is there chlorine residual prior to de-chlorination?
■ Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
■ If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-..)
If yes, then when was the RMP last updated?
De-chlorination Yes No NA NE
Type of system ?Gas
■ Is the feed ratio proportional to chlorine amount (1 to 1)?
■ Is storage appropriate for cylinders?
■ # Is de-chlorination substance stored away from chlorine containers?
■ Are the tablets the proper size and type?
■ Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?■
Is sample collected above side streams?■
■ 0Is proper volume collected?
■ Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?■
Is sampling performed according to the permit?■ o
Effluent Sampling Yes No NA NE
Page #7
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
Permit: NC0025721
Inspection Date: 01/04/2007
Comment: The ORC was encouraged to begin adjusting to a lower Total Chlorine
Residual in preparation for the new permit. A limit in the range of 17 to 28 ug/l will be in
that permit.
Comment: Chlorine is < 2500 lb. Attempts to use final effluent as carrier of the
chlorine ran into trouble when small worms clogged a screen in the line. This occurs
sporadically, or perhaps seasonally. The plant switched back to potable water to regain
needed control of the chlorine doseage.
Comment: Unique system brings both effluent and influent into the lab, where
mechanical dippers sample in proportion to the flow. There is no tubing to be
periodically replaced. Influent refrigerator T = 2.9 deg. C
Yes No NA NEEffluent Sampling
■ Is composite sampling flow proportional?
■ Is sample collected below all treatment units?
■ Is proper volume collected?
■ Is the tubing clean?
■ Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■ Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
2.7 degrees CComment:
Yes No NA NEEffluent Pipe
■ Is right of way to the outfall properly maintained?
■ Are the receiving water free of foam other than trace amounts and other debris?
■ If effluent (diffuser pipes are required) are they operating properly?
Comment:
Yes No NA NEStandby Power
■ Is automatically activated standby power available?
■ Is the generator tested by interrupting primary power source?
■ Is the generator tested under load?
■ Was generator tested & operational during the inspection?
■ Do the generator(s) have adequate capacity to operate the entire wastewater site?
■ Is there an emergency agreement with a fuel vendor for extended run on back-up power?
■ OIs the generator fuel level monitored?
Comment:
Page #8
Permit: NC0025721
Inspection Date: 01/04/2007
Owner - Facility: Weldon WWTP
Inspection Type: Compliance Evaluation
L.
Dear Mayor Draper:
Background
Raleigh Regional Office
1628 Mail Service Center
Surface Water Protection
Raleigh, NC 27699-1628
..One NpfthCarolin
Naturally
Phone [phone] Customer Service
FAX [phone]
nSr'JnanSanCC tasPect,on Halifax County Public Utilities
(HPCU) Pretreatment Plant March 6, 2007
Significant Industrial User to Weldon WWTP
NPDES Permit NC0025721
Halifax County
co IfS11
=-~:~ g==s=.:S=-=—--
North Carolina Division of Water Quality
Internet: www.ncwaterquality.org
Observations
* “S’ (K??) , the compliance
SSfSSS 2',’ zs‘^r, b”'
Mr. G.W. Draper, Mayor
Town of Weldon
P.O. Box 551
Weldon, NC 27890
Subject:
Michael F. Easley, Governor
North Carolina Department of Environment andSra^RwourcM
si ' AIan W‘ KJ‘rnek’ p-E., Director
. Division of Wate«- Quality
----------------7_____
March 15, 2007 ------------ ---------
Page 2Inspection of Halifax County Public Utilities 3/1/07
• Except for pH circular recording charts for influent and effluent, there were no operational or other
o
o
o
• Proactive Maintenance/Troubleshooting/Responding to Equipment Malfunctions
Coming Changes as Presented by ORC Duncan
Inattention was also inferred from pH charts that were not changed out after a 24 hour period. Some
continued to run for 36 or 48 hours. One of the pH charts has been running backward for
approximately two months.
The following logs and activities are planned in the near future. As part of Weldon’s Compliance
Action Plan, firm dates should be established for them to be implemented.
o
o
Influent flow records
pH logs for influent, Equalization Tanks (EQ), the Dissolved Air Flotation unit (DAF),
or final effluent. He was basically operating to a pH of 7.5 to 8 in the EQ tanks. If the
final effluent pH was out of line, adjustments would be made in EQ.
Documented operator rounds. There are no recorded observations such as colors, DAF
effectiveness, or final effluent appearance
Equipment maintenance logs
Process control measurements, laboratory analyses, results of jar tests, etc., used to
operate/adjust the DAF, for example when the dosages need to be changed for pH
adjustment chemicals, precipitants, flocculants, polymers, etc.
Data on operation of the BioTower, such as distributor arm speed and flow rates,
condition of the hanging strips during freezing weather, health of biomass, etc.
Clarifier blanket depths, settleability, effluent clarity, and other observations.
Particularly troubling was a lack of observing equipment and/or measurements enough to see trouble
developing, and the absence of timely action when breakdowns occur. The clarifier had stopped
turning on Saturday, said by Mr. Duncan to be loss of one phase of the motor. The vinyl curtain for
the outer ring had tom and the curtain was displaced in several locations. Thick dried sludge was in
the outer ring, apparently pressing on the vinyl causing the deformations. Unit outages such as this are
to be reported by telephone to the Weldon plant immediately as required by Part II, 30, of the IUP.
Apparently the operator was planning to somehow continue using the clarifier to allow Reser’s to run
the next day. Once Donald declared the unit inoperable, we left the plant but were alerted later that
Reser and Halifax County maintenance men had moved in to install a temporary gearbox and attempt
repairs on the curtain. By Wednesday morning the unit was able to operate.
In addition to the large tear in the vinyl wall, numerous other breaks and cracks were readily apparent.
These suggest a potential failure, so a proactive operator making regular rounds could have foreseen
future problems and taken steps to perform maintenance on an off day when Riser’s was not running.
If thick sludge were observed building up in the outer ring, more than the skimmer could remove, a
proactive operator would find a way to either remove it by hand, or stir it up, or hose it for dilution or
otherwise return the consistency to what was intended.
process control documents in use. Brandon was aware of the need for them, stating that he was
developing forms. Completely absent were
o
o
In other words, there has been no database developed on which comparisons could be built, no
opportunity to observe trends or otherwise develop expertise on running the plant.
' Inspection of Halifax Coun:k Utilities 3/1/07 Page 3
Based on our site visit, the situation at HCPU is very serious. As stated above, the SIU is in SNC for
causing Pass-Through for October 2006 and perhaps other times. It is clear from our site visit that the
underlying cause of the Pass-through is severe neglect and mis-operation of HCPU’s pretreatment unit
This is a violation of several Industrial User Pretreatment Permit (IUP) General Conditions listed
A, mUSt take aPProPriate enforcement action as outlined in your Division approved
ERP. Many of these violations should be considered SNC under Criteria 8. Additionally, the Town
must require HCPU to submittal a complete O&M manual to the Town for review and begin
observahon and documentation of HCPU’s proper implementation of the O&M activities. Include a
schedule of these activities in your Corrective Action Plan.
• Part II #6 - Prevention of Adverse Impact
The permittee shall take all responsible steps to minimize or prevent any discharge in
violation of this permit which has a likelihood of adversely affecting the POTW.”
• Part II #7 - Facilities Operation, Bypass
The permittee shall at all times maintain in good working order and operate efficiently as
possible, all control facilities or systems installed or used by the permittee to achieve
compliance with the terms and conditions of this permit.”
• Part II #8 - Removed Substances
“Solids, sludges, etc., removed in the course of treatment shall be disposed of in a manner such
as to prevent any pollutants from such materials from entering the sewer system.”
• Part HI, #5 — Certified Operator
’SOTiile on site, the ORC or backup operator must document proper operation, maintenance
staffing, record keeping, reporting.”
0203(4) 1 0?04(5)08G 020° ~ establishes reTuirements for Certified Operators, especially
Other Related Comments and Recommendations from DWQ Pretreatment Central Office Staff
• The most recent Consent Agreement between the Town and HCPU has expired. The Town has
ottered HCPU at least two drafts of an extended CA, however HCPU has not accepted either one If a
new CA cannot be agreed upon and signed by March 16, 2007, the Town must proceed with other
actions (issue administrative order, go back to IUP limits, or even termination of service).
• It is understood that HCPU is not reporting all pH limit violations documented by their continuous
recording pH meter This is a violation of IUP Part II, 2., (a) and (g) and perhaps other paragraphs or
sections. 1 he POTW must take appropnate enforcement as outlined in your Division approved ERP
for this reporting failure. Also for all limit violations at least back to 1/1/07, and perhaps beyond. In
general, the SIU must immediately begin either providing copies of their pH charts with their monthly
• b^mcorded °f equipment On which time of visitation and operating data can
• i R°unds carried out every 30 minutes, unless the operator is working on a problem or carrying out
lab work to adjust polymer doses so that he is not available for a round at the regular time.
• pH adjustment of HCPU effluent will be made in a manhole discharging to the Weldon WWTP
and the pH probe will be moved from the Parshall flume to that manhole.
• EQ blowers will be installed in the large tank for better mixing and aeration
• Hire two new employees. Be sure certification is at appropriate grade level, and submit a
designation form to Technical Assistance and Certification Unit (TACU).
HCPU Reconnaissance Inspection Findings
Inspection of Halifax County Public Utilities 3/1/07
O
O
2.
• Part n, 1, requires samples to be representative. Generally, please review all aspects of the SIU's
sampling procedures to confirm proper procedures. It is understood that both the POTW and SIU
samples are composited according to flow. Please evaluate the need for more frequent aliquots during
compositing (eg. every 15 minutes instead of every hour), and also the need for flow proportional
sampling.
Page 4
• IUP Part DI, 5, requires the HCPU ORC to hold a Grade 2 Certification. We assume this was Grade
2 for Biological treatment systems, due to the bio-tower. DWQ strongly recommends the POTW
require HCPU to have an ORC with both Biological and Physical/Chemical certifications as the DAP
and other physical chemical processes are critical to proper operation of HCPU's pretreatment unit.
However, if the POTW feels that more intensive training for the specific physical/chemical units
present at HCPU than is provided from the NC DWQ Physical/Chemical certification training, the
POTW should explore requiring other (or additional) training.
• The Town’s next Headworks Analysis (HWA) is due 8/1/07. Mr. Crowder is signed up to an HWA
workshop on 4/12/07. Regarding that HWA:
This new HWA will have to follow PERCS new requirements for BOD and TSS allowable
loads being based on Design criteria. This will considerably lower the WWTP allowable
loads. Weldon will likely have to reduce HCPU's current TSS limit, and will possibly not
be able to raise HCPUs’ BOD limit much if at all (only 14% left based on Design).
Also, we note HCPU had a Consent Order interim limit of 3000 Ibs/day, and the Town has
proposed to lower it to 2000 in this latest Order, exactly because of the County causing the
current pass-through. Even this new lower Order limit causes a 19% over allocation based
on Design.
• The 8/27/01 Agreement for Pretreatment between HCPU and Resers contains Design Criteria for the
HCPU pretreatment unit of BOD 6000 mg/1 or 9174 Ibs/day, TSS 3500 mg/1, and flow 0.2 mgd.
1. The Agreement expressed these numbers as "maximum average daily" values - please find out
whether they are meant to be monthly averages or a daily max designs.
In any case, there are some months, and multiple days where the numbers were exceeded by
Reser's. Please determine if Resers did any of the things the Agreement requires of them.
3. If they are not, or even if they are, the Town could put them in Reser's IUP as limits. Or you
could put a special condition in Resers IUP that requires them to report to HCPU and the Town
each time the criteria are exceeded, and include a description of what they did to comply with
reports, or if the POTW wishes, simply provide a list of the max and min for the day, and all times the
pH was out of range. Note any violations are subject to the 24 hour reporting (Part II, 2, g).
o It is also understood that HCPU believes that pH slugs from Reser's are causing HCPU's
pH violations. As the wastewater goes through a 0.1 mg EQ basin, and then through the
DAF (which requires precise pH adjustment to work properly), this is either an incorrect
explanation or evidence that the DAF is not being operated properly at all. It is assumed
that severe pH swings out of the DAF would easily inhibit the bio-tower (part of O&M
discussed above). Do they ever look at the bio-slime under the micro-scope?
• The POTW should require HCPU to submit a plan for prevention of all these clarifier outages, and
problems with all other units as needed. You should also evaluate the need to require HCPU to
provide redundant units and/or equipment, or of modifying the IUP to establish requirements for
mandatory discharge shutdown if certain units/equipment are out for a specified time.
ic Utilities 3/1/07
Page 5
Stephanie or Myrl at [phone].
Sincerely,
cc:
k/aij
Myrl R. Nisely
Environmental Chemist
If you have any questions concerning this report please call
Stephanie Brixey
RRO Pretreatment Coordinator
Donald Crowder, Town of Weldon
Leo Green, Green Engineering
Brandon Duncan, HCPU ORC
Jerry Rimmer, TACU
Dana Folley, PERCS Unit, Central Office
Vanessa Manual, NPDES Central Office
Central Files (SWP)
RRO/ SWP File
Summary
the PERCS Unit, in addition to RRO. 9 Y b C°Py °f your Plan t0
1 Inspection of Halifax Coui
the Agreement These may be ideas to consider now, or to consider for later if HCPU
vtolations continue after the end of the Consent Order.
“°"d “'■<»""» or could bo due ro slug, tai, ,„oi|,er u™” lh« S"J «
Michael F. Easley, Governor
March 15, 2007
Dear Mayor Draper:
Background
Observations
eno/ —imho/
North Carolina Division of Water Quality
Internet: www.ncwaterquality.org
In recent days, Pretreatment personnel Dana Folley and Stephanie Brixey have reviewed and analyzed,
with ORC Donald Crowder, HCPU effluent quality data as it relates to upsets in the Weldon plant.
There are clear periods of time when peak loads from HCPU correlate with limit violations at Weldon,
especially October 2006. This puts HCPU in Significant Non-Compliance (SNC) for Pass-Through -
SNC criteria #3. The Town must take all necessary enforcement actions as specified in your Division
approved Enforcement Response Plan (ERP), and provide documentation of the public notice as soon
as possible.
It was agreed that Stephanie, Donald and Myrl Nisely would visit the HCPU plant unannounced to
obtain a better understanding of the operational controls and practices used by HCPU. On Tuesday,
March 6, 2007 they met with ORC Brandon Duncan. The findings are being relayed to you for
possible inclusion in the Compliance Action Plan.
Raleigh Regional Office
1628 Mail Service Center
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Surface Water Protection
Raleigh, NC 27699-1628
Reconnaissance Inspection of Halifax County Public Utilities
(HPCU) Pretreatment Plant March 6, 2007
Significant Industrial User to Weldon WWTP
NPDES Permit NC0025721
Halifax County
As already communicated to you by the Raleigh Regional Office of DWQ (RRO), the compliance
record of the Weldon WWTP for 2006 and January 2007 is unacceptable with limit violations 8 out of
13 months. The Town has been instructed to submit a Compliance Action Plan to RRO for bringing
the plant into compliance. We expect the plan by March 30.
• Mr. Duncan had a general knowledge of what pH conditions should be for good treatment in the
various units, but had only vague operating guidelines. Mr. Duncan did not have an overall
Operating & Maintenance (O&M) manual for the plant to guide how to make adjustments or how
changes in one process would impact downstream processes. He did have maintenance manuals for
some of the individual units such as the DAE, the BioTower and the clarifier. However, these One
manuals do not cover operational activities. r
4
•-*- I ■
o 1
4«c
North Carol in
____________________ Naturally
Phone [phone] Customer Service
FAX [phone]
Mr. G.W. Draper, Mayor
Town of Weldon
P.O. Box 551
Weldon, NC 27890
Subject:
Weldon WWTP CEI, January 9 17 Page 2 of 2
Other comments from this inspection:
If you have comments or questions, please contact Myrl Nisely at 919-791-4200.
Sincerely,
o,ii e,
ATTACHMENT
November 2 Wkly BOD &
Mo. BOD
cc: RRO SWP File w/ attachment
Central Files w/ attachment
• Several extra process control tests are being run to predict plant performance, especially CODs
to estimate BOD. Continue to monitor these results closely to catch a period of troublesome
performance so that corrective measures can be taken as soon as possible.
• Because the new permit will contain a Total Chlorine Residual in the ug/1 range, the facility is
urged to begin measuring and controlling to these levels to be sure the requirement can be met
when the permit goes into effect. Existing equipment, standards and technique may need to be
altered to read to the lower levels.
• Synagro has historically held the 503 test results run by them. It is recommended that a copy of
all test results be routinely mailed to the ORC.
• Maintenance of fine bubble diffuser aerators at the bottom of the newly installed 485,000
gallon digester was a concern to RRO when that design was reviewed. Where would all that
sludge be stored if the tank had to be emptied? A scheme has been designed to do this. Waste
sludge is held in the old (smaller) digester with frequent decanting to raise solids. When that
tank is nearly full, it is pumped to the new tank. The new tank aerates enough to pass 503
testing for land application before the next pumping from the small digester. So after
satisfactory testing, the contents are pumped to the concrete holding basin (volume 201,960
gallons). Synagro, Inc. comes about once per quarter to completely empty this basin plus any
volume in the new digester that has also met 503 tests. In this way, the volume to be removed
from the new tank for maintenance is orchestrated to avoid the buildup of unmanageable
volumes in case emergency work is needed on the aerators.
High infl BOD, poor settling when
polymer feed not pumping right
Charles Wakild, P.E.
Surface Water Protection Supervisor
Raleigh Regional Office
Improve polymer feed to
clarifiers. Halifax
Pretreatment improved
We recognize that efforts to understand plant problems continue, especially to determine if loads from
Halifax County Public Utilities (HCPU) may have caused the BOD problems. Nevertheless, the
Town is directed to prepare a Corrective Action Plan for assuring future compliance, to be
submitted to this office by February 23, 2007.
March 13,2007
Ml I b m
Dear Mr. Delk:
NEAL C. PHILLIPS
TOWN ADMINISTRATOR
KAY TRIPP
CLERK
THOMAS H. WELLMAN
TOWN ATTORNEY
The Consent Agreement will be required to be signed on or before March 16, 2007.
Failure to sign the Consent Agreement will result in either reverting back to the original
pretreatment permit limits or termination of service.
Subject: Consent Agreement and Compliance Schedule Extension
Number 03-001
Halifax County Public Utilities
Halifax County, NC
DOCK M. BROWN
MICH.AEL D. HARGROVE
JULIA M. MEACHAM
HATTIE A. SQUIRE
-ANDY WHITBY
The lown of Weldon is in receipt of Green Engineering’s request on Halifax County
Public Utilities behalf of a 30 day extension of the unsigned Consent Agreement. The
1 own of Weldon feels that Halifax County Public Utilities has not exhausted all potential
disposal sites and therefore grants Halifax County a 15 day extension.
Mr. Matthew Delk, Manager
County of Halifax
PO Box 38
Halifax, NC 27839
nf MWbnn
109 WASHINGTON AVENUE
P.O. BOX 551
WELDON, N.C. 27890
PH. 252'536-4836
i
G. W. GOHNNY) DRAPER, JR.
MAYOR
h <
li 1
COMMISSIONER:
Respectfully,
Donald L. Crowder
Public Utilities Director
Town of Weldon
Mr. Matthew Delk
March 13,2007
Page 2
Cc: Mr. G.W. Draper, Jr., Mayor
Mr. Neal C. Phillips, Town Administrator
Mr. Myrl Nisely, N.CDENR, DWQ, RRO
Ms. Stephanie Brixey, NCDENR, DWQ, RRO
Mr. Leo Green, Green Engineering
Mr. Frank Ralph, Public Utilities Director, Halifax County
Should you have any questions or comments concerning this mater, please contact me at
[phone] or d 1 crowder@nco 1.net.
n ITOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/30/07
1
Develop process records system for the following:4/30/07
2
5/10/07
3 3.
4.
4/10/07Develop Daily Operations Data Log for Pretreatment Facility
4
1
Finding
Number
Entity/
Contact
Person/
Phone
Number
Develop Operation and Maintenance manuals for Influent
screens, DAF, Clarifier, Bio-tower, Self Priming Pumps,
Blowers, Recirculation Pumps and Effluent Pumps. Include in
manuals process control guides for total treatment interaction.
1.
2.
3.
4.
5.
6.
7.
8.
1.
2.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Influent Flow
Effluent Flow
Influent pH
DAF Flow Rate
Recirculation Flow Rate thru bio tower
Process pH
Effluent pH at discharge to Weldon system
All chemical feed-volumes and locations______________
Complete Consent Order process improvements to include:
Add diffused aeration/mixing to existing tanks.
Install EQ re-charge pumps at recirculation pump
station
Instrumentation and pump control improvements at
recirculation pump station
Pinch valve modifications
tirl'
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/10/07
5
8/15/07
6
4/30/07
7
4/30/07
8
2
Frequency of all monitoring activities will be no less than once
per every two (2) hours during operation of pretreatment facility.
Monitoring reports will be available at all time for inspection by
the Town of Weldon and/or state DWQ representatives.
Finding
Number
Entity/
Contact
Person/
Phone
Number
Relocate pH probe from Wallace Fork pump station to Town of
Weldon receiving manhole. Integrate with County SCADA to
control caustic feed at pretreatment plant.
Install SCADA RTU and caustic feed pump and piping at
pretreatment plant to monitor and control caustic feed into plant
effluent in response to demand at Weldon receiving manhole.
Provide Town of Weldon access to SCADA web site so that
continuous pH monitoring and recording is available from all
sampling locations.
Halifax County Public Utilities will be required to provide 24 hour
operation of pretreatment facility. HCPU will provide full
contingency of operators to adequately perform duties
throughout a 24-hour period. Each operating shift will have a
certified operator on duty. This operator should be certified for
both biological and physical/chemical treatment systems.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
1/1/08
9
Complete Clarifier Repairs 4/14/07
10
Continue Sewer System Rehabilitation. +/- $65,000 annually.7/1/07
11
7/1/07
12
3
Improve reclaimed water feed to chlorine disinfection system at
wastewater treatment plant.
Finding
Number
Entity/
Contact
Person/
Phone
Number
Revise Reser’s Pretreatment Permit to include specific limits for
their influent into the HCPU Pretreatment Facility. These limits
shall be in accordance with the Pre-treatment agreement
between Reser’s Fine Foods, Inc. and Halifax County dated
August 27, 2001. More specifically, these limits are:
BOD-6000mg/l (9174 pounds)-daily max
TSS-3500 mg/l-daily max
Flow-200,000 gal/day (175,000gal/day presently)
Action
Target
Date
Action
Completion
Date
Reser’s
/Randy
Earle/
252-
536-
5760
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Town of
Weldon/
Donald
Crowder
1252-
536-
3478
Town of
Weldon/
Donald
Crowder
1252-
536-
3478
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
9/1/07
13
Prepare Preventative Maintenance Checklist for all equipment.4/10/07
14
4/10/07
15
8/15/07
16
4
Coordinate pH limits at Pretreatment facility and Town of
Weldon receiving manhole. Modify either Pretreatment Permit
or Town of Weldon Sewer Use Ordinance as necessary.
Develop a worksheet and document microscopic examination
of organisms in the Bio-Tower immediately.
Continue Oil & Grease inspection program. Next anticipated
compliance inspection (11 establishments)
Finding
Number
Entity/
Contact
Person/
Phone
Number
Action
Target
Date
Action
Completion
Date
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
COMMISSIONER:
DOCK M. BROWN
MICHAEL D. HARGROVE
JULIA M. MEACHAM
HATTIE A. SQUIRE
ANDY WHITBY
March 23, 2007
Dear Mr. Ralph:
MAR 2 7 2007
G. W. (JOHNNY) DRAPER, JR.
MAYOR
NEAL C. PHILLIPS
TOWN ADMINISTRATOR
THOMAS H. WELLMAN
TOWN ATTORNEY
KAY TRIPP
CLERK
Halifax County Public Utilities has been found to be in violation of Part I., F of their
Wastewater Discharge Permit (#0002) and Consent Agreement issued by the Town of
Weldon for the month of February 2007. The violations are summarized as follows:
Mr. Frank Ralph
Director of Public Utilities
Halifax County Public Utilities
Post Office Box 70
Halifax, North Carolina 27839
'Snfott nf JUelftun
109 WASHINGTON AVENUE
P.O.BOX 551
WELDON. N.C. 27890
PH. 252-536-4836
Parameter
Oil & Grease
Technical
Review
Criterion
Exceeded
Yes
Subject: NOTICE OF VIOLATION
Halifax County Public Utilities
Pretreatment Facility
Pretreatment Permit Number NC00257210002
Sample
Date
2/8/07
Town/Self
Monitoring
POTW
Daily
Limit
(lbs) or
mg/1
100 mg/1
Technical
Review
Criterion
140 mg/l
Results
(lbs) or
mg/l
208
cc: Mr. G. W. Draper, Jr., Mayor
Mr. Neal Phillips, Town Administrator
Mr. Myrl Nisely, DWQ, RRO
Mr. Matthew Delk, Manager, Halifax County
Ms. Stephanie Brixey, DWQ, RRO
Ms. Dana Folley, PRECS, DWQ, RRO
Town of Weldon Commissioners
Halifax County Commissioners
Mr. Randy Earle, Reser's Fine Foods, Inc.
The appeal of civil penalties is provided for in section 9.02(c) of the Town’s Sewer Use
Ordinance. If you wish to appeal this penalty assessment, written demand identifying the
specific issues to be contested must be made to the Director within 30 days of the receipt
of this letter. Unless such demand is made, this decision shall be final and binding. Please
contact the Town of Weldon if you have any questions.
If Halifax County Public Utilities fails to return to compliance, then additional actions,
including increased penalties or issuance of an enforceable order, will be completed in
accordance with the Town's Enforcement Response Plan. Please be aware that the Town's
Sewer Use Ordinance gives the Director the authority to assess penalties of up to
$25,000.00 per day violation.
Mr. Ralph
March 23, 2007
page 2
Sincerely,
Donald L. Crowder
Public Utilities Director
Town of Weldon
In accordance with the Town’s Enforcement Response Plan, the Town of Weldon hereby
assesses Halifax County Public Utilities a $300.00 penalty. $300.00 per violation for one
Technical Review Criteria (TRC) Oil and Grease; for failure to comply with Part I,
industrial User (IU) Specific Conditions, Item F (1) Effluent Limits and Monitoring
Requirements (Daily Sampling) of the Pretreatment Permit. Payment of the penalty and a
report containing the probable cause of the violation plans to prevent from happening
again and plans to return to compliance must be submitted to this office within 30 days
of this notice.
COMMISSIONER;
April 23. 2007
2 6 2007
10;
Dear Mr. Nisely:
G. W. (JOHNNY) DRAPER. JR.
MAYOR
NEAL C. PHILLIPS
TOWN ADMINISTRATOR
KAY TRIPP
CLERK
THOMAS H. WELLMAN
TOWN ATTORNEY
List below are actions already taken by the Town of Weldon to meet and maintain
compliance with our NPDES permit:
DOCK M. BROWN
MICHAEL D. HARGROVE
JULIA M. MEACHAM
HATTIE A. SQUIRE
ANDY WHITBY
Subject: Corrective Action Plan
Weldon, NC
NPDES # NC0025721
During our unannounced inspection of the Halifax County Pretreatment Facility on March 6,
2007 it was found that the clarifier at the facility was inoperative, which violated Halifax
County Public Utilities’ SIU pennit. It was during this inspection, the Town of Weldon
ordered Elalifax County to “cease and desist" all discharges from the facilities until
permanent repairs could be made. Temporary repairs were made overnight to the clarifier
which allowed Halifax County to begin discharging again.
On March 9. 2007 Halifax County notified the Town that the clarifier had failed again and
that the facility had shut down. The town instructed Halifax County that the repairs they were
proposing to make had to work or the facility would be shut down until permanent repairs
could be made. Repairs were made on March 10. 2007 and the town was satisfied that the
repairs would work until permanent (new parts) repairs could be made.
Mr. Myrl Nisely
NC Dept, of Environment
and Natural Resources
Division of Water Quality
1628 Mail Service Center
Raleigh. NC 27699-1628
II V ET:
(Tofan of JKelbon
109 WASHINGTON AVENUE
P.O. BOX 551
WELDON. N.C. 27890
PH. 252-536-4836
Enclosed for your review and processing is the required Correction Action Plan for the Town
of Weldon. This plan addresses actions taken or to be taken by the Town to bring our
Wastewater Treatment Plant back into compliance.
Sincerely,
i
On March 16. 2007 I talked with Mr. C.D. Malone concerning the non-compliance issue the
town had been experiencing. Mr. Malone advised that he would be available to meet with me
to analysis and discuss the problems occurring at the wastewater treatment plant. We agreed
to meet on March 26. 2007.
Based off samples collected on March 14. 2007 and with guidance from the DWQ and the
PERCS Unit the town served a “Cease Discharge Order” to Halifax County Public Utilities
Pretreatment Facility on Friday March 16, 2007 for violating their SIU permit and causing
the town to violate our NPDES permit. Halifax County was advised that when they could
provide the town with five (5) days of analytical data that showed compliance, they would be
allowed to resume discharge to the town.
On March 28, 2007, Mr. C.D. Malone came by the wastewater treatment plant. Upon
reviewing the plant, process control and analytical data, Mr. Malone recommended that the
town continue operating the plant in the manner we are.
The town plans to continue to strongly enforce the Industrial Users Permit and Sewer Use
Ordinance.
The Town of Weldon will submit quarterly reports updating NCDENR on Action
Completion Dates.
Should you have any questions or comments concerning this matter, please contact me at
[phone] or dlcrowderffincol.net
Donald L. Crowder
Public Utilities Director
Town of Weldon
Cc: Mr. G.W. Draper, Mayor
Mr. Neal C. Phillips. Town Administrator
Mr. Nisely
April 23. 2007
Page 2
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/30/07
1
Develop process records system for the following:4/30/07 4/10/07
2
5/10/07
3 3.
4.
4/10/07 4/10/07Develop Daily Operations Data Log for Pretreatment Facility
4
I
Finding
Number
Entity/
Contact
Person/
Phone
Number
1.
2.
3.
4.
5.
6.
7.
8.
1.
2.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Develop Operation and Maintenance manuals for Influent
screens, DAF, Clarifier, Bio-tower, Self Priming Pumps,
Blowers, Recirculation Pumps and Effluent Pumps. Include in
manuals process control guides for total treatment interaction.
Influent Flow
Effluent Flow
Influent pH
DAF Flow Rate
Recirculation Flow Rate thru bio tower
Process pH
Effluent pH at discharge to Weldon system
All chemical feed-volumes and locations______________
Complete Consent Order process improvements to include:
Add diffused aeration/mixing to existing tanks.
Install EQ re-charge pumps at recirculation pump
station
Instrumentation and pump control improvements at
recirculation pump station
Pinch valve modifications
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
4/10/074/10/07
5
8/15/07
6
4/30/07
7
4/30/07
8
2
Finding
Number
Entity/
Contact
Person/
Phone
Number
Frequency of all monitoring activities will be no less than once
per every two (2) hours during operation of pretreatment facility.
Monitoring reports will be available at all time for inspection by
the Town of Weldon and/or state DWQ representatives.
Relocate ph probe from Wallace Fork pump station to Town of
Weldon receiving manhole. Integrate with County SCADA to
control caustic feed at pretreatment plant.
Install SCADA RTU and caustic feed pump and piping at
pretreatment plant to monitor and control caustic feed into plant
effluent in response to demand at Weldon receiving manhole.
Action
Target
Date
Action
Completion
Date
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Provide Town of Weldon access to SCADA web site so that
continuous pH monitoring and recording is available from all
sampling locations.
Kok CPxL
Halifax County Public Utilities will be required to provide 24 hour
operation of pretreatment facility. HCPU will provide full
contingency of operators to adequately perform duties
throughout a 24-hour period. Each operating shift will have a
certified operator on duty. This operator should be certified for
both biological and physical/chemical treatment systems.
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
1/1/08
9
4/14/07Complete Clarifier Repairs 4/14/07
10
Continue Sewer System Rehabilitation. +/- $65,000 annually.7/1/07
11
7/1/07
12
3
Improve reclaimed water feed to chlorine disinfection system at
wastewater treatment plant.
Finding
Number
Entity/
Contact
Person/
Phone
Number
Revise Reser's Pretreatment Permit to include specific limits for
their influent into the HCPU Pretreatment Facility. These limits
shall be in accordance with the Pre-treatment agreement
between Reser’s Fine Foods, Inc. and Halifax County dated
August 27, 2001. More specifically, these limits are:
BOD-6000mg/l (9174 pounds)-daily max
TSS-3500 mg/l-daily max
Flow-200,000 gal/day (175,000gal/day presently)
Action
Target
Date
Action
Completion
Date
Reser’s
/Randy
Earle/
252-
536-
5760
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
TOWN OF WELDON
CORRECTIVE ACTION PLAN
Wastewater Collection System
Corrective Action Planned
9/1/07Next anticipated
13
Prepare Preventative Maintenance Checklist for all equipment.4/10/07 4/10/07
14
4/10/074/10/07
15
8/15/07
16
4
Finding
Number
Continue Oil & Grease inspection program,
compliance inspection (11 establishments)
Develop a worksheet and document microscopic examination
of organisms in the Bio-Tower immediately.
Coordinate Ph limits at Pretreatment facility and Town of
Weldon receiving manhole. Modify either Pretreatment Permit
or Town of Weldon Sewer Use Ordinance as necessary.
Entity/
Contact
Person/
Phone
Number
Action
Target
Date
Action
Completion
Date
Town of
Weldon/
Donald
Crowder
/252-
536-
3478
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Halifax
County
Public
Utilities/
Frank
Ralph/
252-
583-
1451
Town of
Weldon/
Donald
Crowder
/252-
536-
3478