NC0024538_Approval_20100608

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CDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director
Secretary
June 8, 2010
Mr. Brad Cornwell, Utilities Director
City of Shelby
P. O. Box 207
Shelby, 28151-0207
Subject: Renewal of Waiver
24/7 Operator Staffing Requirement
NPDES Permit NCO024538
City of Shelby—First Broad River WWTP
Cleveland County
Dear Mr. Cornwell:
Title 15A of the North Carolina Administrative Code, Subchapter 2H, Section .0124 enumerates specific
reliability measures that point source dischargers in North Carolina must implement in order to help
ensure that wastewater treatment plants are adequately operated and maintained and pose minimal risk
to the environment in the event that problems arise at a wastewater treatment plant (WWTP). 15A
NCAC 2H .0124 (4) states that mechanical facilities with a design capacity equal to or greater than 5.0
MGD must be continuously staffed, 24 hours a day, seven days per week, with a certified wastewater
treatment plant operator being a member of that staff during each shift. This requirement may be
waived by the Director of the Division of Water Quality if it can be demonstrated to his satisfaction that
the requirement is not warranted in a particular case.
The Division has reviewed the information provided by your staff regarding the SCADA system
(including telemetry, notification and remote operations capabilities) for the City of Shelby WWTP.
City of Shelby staff have demonstrated the system's ability to contact appropriate WWTP personnel in
the event of an emergency, and those personnel's ability to manage such situations, either through
remote analysis and operation of the WWTP or by their expeditious return to the WWTP. Based upon
the stated and demonstrated capabilities of the system, and the details of the City's response plan, the
Division is satisfied that if an emergency event occurs while the WWTP is unstaffed, proper personnel
can be notified in a time frame adequate to ensure a prompt response that will keep harm from occurring
to the WWTP infrastructure and/or the environment.
In light of the above findings and upon the recommendation of the staff of the Mooresville Regional
Office, the Division has determined that the City of Shelby— First Broad WWTP provides adequate
safeguards to ensure proper operation of the WWTP without requiring a certified operator to be on site
24 hours a day. Therefore, in accordance with the provisions of 15A 2H .0124 (4), the City of Shelby is
granted a waiver from the 24 hour per day staffing requirement at its wastewater treatment plant.
1617 Mail Service Center,Raleigh,North Carolina 27699-1617
Location:512 N.Salisbury St.Raleigh,North Carolina 27604 One
Phone:[phone]\FAX:[phone] Customer Service:1-877-623-6748 NorthCarolina
Internet:www.ncwaterqualtive Action
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An Equal Opportunity 1 Affirmative Action Employer

Mr. Brad Cornwell
City of Shelby WWTP 24/7 Staffing Waiver- ,
p. 2
This waiver shall be effective through the term of the current permit cycle (ending August 31, 2013) and
will be reviewed during the next permit renewal period. Please be aware that the Division reserves the
right to rescind this waiver and impose the staffing requirements as stated in 15A 2H .0124 if
circumstances warrant such action.
If you have any questions concerning this letter, please contact Bob Sledge at telephone number(919)
807-6398, or via e-mail at [e-mail].
Sincerely,
�1
oleen H. Sullins
cc: Central Files
NPDES Unit
ec: Technical Assistance & Certification Unit
Mooresville Regional Office/Surface Water Protection Section

Sledge, Bob
From: David Hux [[e-mail]]
Sent: Tuesday, July 14, 2009 5:10 PM
To: Sledge, Bob
Subject: City of Shelby- First Broad WWTP
Bob:
Good to speak with you. As per our conversation, you have requested some information regarding the SCADA
capabilities at the WWTP considering our exemption from the 24/7 Operator on-site requirements.
■ The First Broad WWTP is equipped with Allen Bradley Programmable Logic Controllers throughout the treatment
plant for automated control of the treatment plant. These PLCs control the function of the equipment and also
alert on-call staff of any alarms. As a back-up the main lift is also equipped with an autodailer that also alerts staff
if a problem occurs.
■ Even though we have been given the 24/7 exemption, on-call staff still visit the treatment plant every day of the
week including holidays. During the hours that staff is not on site, on-call staff carry pagers and cell phones in
order to be contacted in case of an emergency. Multiple staff members are notified in the event of a problem until
the alarm has been acknowledged; the Water Plant is also notified in the event of an alarm.
■ From any computer with internet access, staff can access the treatment plant and also make control changes
from any remote location. On-call staff and the ORC will periodically check the treatment plant via the internet
access while not on site.
■ Both the maintenance supervisor and ORC have less than a 10 minute response time to the plant. All on-call
personnel can be at the plant within 30 minutes and with the internet capabilities can check and dispatch closer
personnel if the need arises.
■ During periods of heavier flows (rain events) staff will come into the plant and operate until conditions are normal.
SCADA will notify on-call staff when flows indicate the plant is reaching rain event status.
Please let me know if you need additional information.
David Hux
Assistant Utilities Director
City of Shelby
PO Box 207
Shelby, NC 28151-0207
Phone: [phone]
Fax: [phone]