NC0021181_Approval_20051005

N!"DES DOCUWENT SCANNINL COVER SNEET
NPDES Permit:
NCO021181
Belmont WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Approval
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
October 5, 2005
Thig document is priaated on reu6e paper - igizore airy
coateat on the resrerse Bide

-- I 0"A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
October 5, 2005
Mr. David W. Isenhour
City of Belmont
P. O. Box 431
Belmont, NC 28012
Subject: Waiver of 24 hour/7 day Staffing Requirement
!� City of Belmont WWTP
NPDES Permit NCO021181
Gaston County
Dear Mr. Isenhour:
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
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.
Division staff have reviewed your correspondence of August 22, 2005, which requested a waiver
from the 24 hour a day staffing requirement. You noted the difficulties the City of Belmont has
experienced in hiring and retaining certified WWTP operators. As a response, the City has
proposed the installation of a SCADA system for monitoring and control of the various treatment
units within the WWTP. Upon its installation, your proposal states that the WWTP would
remain staffed around the clock, ideally with certified operators, but during times when its
numbers of certified operators were down, the WWTP may be operated by trainees on the night
and weekend shifts. A conversation between you and DWQ staff on September 30, 2005
provided more details about the proposed scope of the SCADA system, response time of
experienced public works personnel in the event of any emergency, and the City's commitment
to hire, train and retain certified WWTP operators.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Intemet:: h2o.enr state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
one
NCat'olina
Natmally

Mr. David Isenhour
City of Belmont 24 Hour Staffing Waiver
p. 2
After reviewing your monitoring plan and considering the recommendation of the staff of the
Mooresville Regional Office, the Division has determined that the system as described in your
August 22, 2005 letter should provide adequate safeguards to ensure proper operation of the
WWTP without requiring a certified operator to be on site 24 hours a day. Therefore,
conditional upon the full implementation of the SCADA system you have described, the
requirement for 24 hour per day staffing by certified operators at the subject WWTP is hereby
waived. Please keep the Mooresville Regional Office apprised of all developments regarding the
installation and activation of the SCADA system.
Though the request for a waiver has been granted, you are encouraged to keep up your efforts to
employ individuals in positions at the WWTP whose skill and experience match the
responsibility they and the City bear in the collection, treatment and discharge of wastewater.
The City's current policies and incentives for staff development give us confidence you will
succeed in this area.
An unfortunate aspect of the use of such systems is that they are best tested under the harsh
circumstances of real life situations. If such an incident should occur and your monitoring
system or response plan should be found to be inadequate in any way, the Division reserves the
right to demand changes be made to the system/response plan, or it may indeed reinstate the 24
hour staffing provision as stated in 15A NCAC 2H .0124 (4). Additionally, should data provided
by the City reveal the WWTP to be experiencing difficulty in maintaining consistent compliance
with the terms of its NPDES permit, the decision to waive the 24 hour staffing requirement may
have to be revisited. At a minimum, this decision will be reviewed when the NPDES permit
comes up for renewal.
Thank you for your cooperation in this matter and your commitment to the protection of North
Carolina's waters. If you have any questions regarding this matter, please contact Mr. Rex
Gleason in our Mooresville Regional Office at [phone] or Bob Sledge in our Raleigh
central office at [phone], extension 547.
Sincerely,
04A an W. Klimek, P.E.
cc: Mooresville Regional Office
Point Source Branch
Technical Assistance & Certification Unit
Central Files

Mr. David Isenhour
City of Belmont 24 Hour Staffing Waiver
p. 2
After reviewing your monitoring plan and considering the recommendation of the staff of -the
Mooresville Regional Office, the Division has determined that the system as described in your
August 22, 2005 letter should provide adequate safeguards to ensure proper operation of the
WWTP without requiring a certified operator to be on site 24 hours a day. Therefore,
conditional upon the full implementation of the SCADA system you have described, the
requirement for 24 hour per day staffing by certified operators at the subject WWTP is hereby
waived. Please keep the Mooresville Regional Office apprised of all developments regarding the
installation and activation of the SCADA system.
Though the request for a waiver has been granted, you are encouraged to keep *up your efforts to
employ individuals in positions at the WWTP whose skill and experience match the -
responsibility they and the City bear in the collection, treatment and discharge of wastewater.
The City's current policies and incentives for staff development give us confidence you will
succeed in this area.
An unfortunate aspect of the use of such systems is that they are best tested under the harsh
circumstances of real life situations. If such an incident should occur and your monitoring
.system or response plan should be found to be inadequate in any way, the Division reserves the
right to demand changes be made to the system/response plan, or it may indeed reinstate the 24
hour staffing provision as stated in 15A NCAC 2H .0124 (4). Additionally, should data provided -
by the City reveal the WWTP to be experiencing difficulty in maintaining consistent compliance
with the terms of its NPDES permit, the decision to waive the 24 hour staffing requirement may
have to be revisited. At a minimum, this decision will be reviewed when the NPDES permit
comes up for renewal.
Thank you for your cooperation in this matter and your commitment to the protection of North
Carolina's waters. If you have any questions regarding this matter, please contact Mr. Rex
Gleason in our Mooresville Regional Office at [phone] or Bob Sledge in our Raleigh
central office at [phone], extension 547.
Sincerely,
IV A an W. Klimek, P.E..
cc: Mooresville Regional Office
Point Source Branch
Technical Assistance & Certification Unit
Central Files

10410/2005 14:37
97048250514
PAGE 02
City of Belmont
Memorandum
To: Pat Waiters - Wastewater Plant Superintendent
From: David Isenhour - Director of Public Works
Date: October 5, 2005
Re: Walve!r of 24 hour/ 7 day Staffing NPDES Permit
115 N. MAIN STREET
POST OFFICE BOX 431
BELMONT, N.C. 28012
PHONE [phone]
Attached vrith this memo is a copy of the letter I received today from the Ralei h office
of NCDENR . As you will see, the a g
y aregreeing to allow the �xy of Belmont and our
Wastewater Plant an opportunity to proceed with a waiver of our 24 7 day
requirements. This is exceptional news and it will offer us some t staffing
in
opportunities, especially for our current working staff. Please read all of the States
requuremen.ts and let's make sure that we abide by their newly approved standards. I
want us to pay particular attention to the condition of "full implementation of the
SCADA system" before we allow any untrained employees to be on staff. The State also
is encouraging us to keep up our efforts to employee certified operators. By allowing us
the benefit of hiring trainees for nights and weekends, and by allowing us the use of
better teclutology, we should see an improvement in trainees reachin their
Wastewater I certifications. g
Our first stti:p is to move forward with installing the SCA,DA system. I believe you
already have the necessary information from Nix-Pursur Company. Barry is depending
on us getting this new system installed as soon as possible. He will help us in securing
the funds for this purchase and will bring this information to the attention of Council.
We are very fortunate that the State is allowing us to move in this direction and xt' a
solution that the City of Belmont has long been looking for. Now that the opportunity
has been awarded to us, we need to make sure we abide by all recommendations in
order to mainWn this special waiver. Thanks and please share this great news to all the
employees.
Cc: Barry Webb - City Manager
Mozelle Liingafeldt - Human Resources

Susan,
S'
9l Via
I spoke with David Isenhour of the City of Belmont on Friday. He offered some points of
clarification as to what Belmont was proposing with regard to the request for a waiver of the 24
hour staffing requirement at the WWTP.
The SCADA system they are anticipating would computerize all their treatment units at the
WWTP so they could be monitored and controlled from a central command location. The
treatment units would also be monitored by video. They are looking at a system that will cover
both the WWTP and the collection system, with the SCADA monitoring lift stations and
controlling pumps, but its expense will require that it be phased in, first at the WWTP and later
to the collection system. There is money available to begin the design, purchase and installation
of the SCADA "immediately." It's been allocated for improvements in the offices at the
WWTP, but with our approval of their proposal, public works would go to the city manager to
have him reassign the funds for this project.
As for what their response/contingency plan is in the event of an emergency:
All of the WWTP staff know to contact the ORC, Pat Waiters, who is on call on a 24/7 basis if
there is any type of emergency at the WWTP. He lives approximately 20 — 25 minutes away.
Additionally, their back-up operator (Grade IV) and their lab supervisior, Sandra Edwards, is on
call and lives about 10 minutes away.
Belmont has public works staff on duty 24 hours a day. All their collection system operators
have either grade I or 11 collection system certification. Its ORC, Gary Gallagher lives less than
5 minutes from the WWTP.
Emergency numbers and the Nextel numbers of public works staff have been given to the
Belmont police department in the event that they get first notification of any problems with the
wastewater infrastructure.
It is City policy to have certified operators employed in the WWTP positions. They've had
trouble competing with Charlotte and Gastonia in hiring and keeping certified operators. When
they hire someone as a trainee, they have one year to get their grade I certification and two years
to obtain their grade II certification. As an incentive for development in the field, they provide a
5% pay increase for each certification they achieve.
They need the letter from us to present to the city manager, so he'll know we're satisfied with the
plan. Then he'll approve the funding.
I

imap://bob.sledge%40dwq.denr.ncmail.net @ cros.ncmail.net:143/fet...
Subject: Re: City of Belmont 24/7 Staffing Request
From: Jerry Rimmer <[e-mail]>
Date: Wed, 28 Sep 2005 10:19:59 -0400
To: Bob Sledge <bob. sledge@ ncmail.net>
Bob,
I apologies. I thought I had responded, but evidently I failed to follow up. TACU
staff has discussed this issue. Belmont has a designated ORC and backup ORC which
are actively certified. Even though they are a WW-4 facility, all they need to do is
hire a WW-1 operator (or higher) for each shift. Or hire an operator and get him
trained (at Community College ongoing programs or statewide schools twice each year)
and pass the exam available each quarter.
We agree that until the SCADA system is installed, Belmont should man the facility
with certified operators. There must be certified operators or contractors available
in the Charlotte area for the interim. They could have hired an uncertified operator
and completed his training and exam by now. Certified operators are not that
expensive compared to non -certified employees.
Maybe a temporary waiver to allow them to train and certify a new employee would
suffice. Until the SCADA system is in place why can't they continue to cover the
shifts as they are doing now? If this is too expensive maybe they will make an
effort to hire an operator.
Jerry
Bob Sledge wrote:
Jerry,
About a month ago I faxed y'all a copy of a request from the City of Belmont for a
waiver to the requirement to have the facility staffed by certified operators
around the clock. We probably need to give them a response soon, but we didn't
want to prepare one without getting TAAC's opinion and recommendation regarding
this request.
Have you or anyone on the crew had the opportunity to look over their letter and
come to any sort of conclusion as to whether what they propose is sufficient to
justify the waiver? Do you have concerns you'd like for me to address in a
response or suggestions for conditions we'd need to include any waiver based upon
the information they provided?
Just to let you know what we're thinking, I believe what they're proposing is
adequate, but I wouldn't recommend granting the waiver until the SCADA system is
actually installed. I'd further like them to document who will be notified in the
event problems occur at the WWTP and what an anticipated response time by
experience personnel would be. Hopefully, they'll hire and retain enough qualified
staff or will get folks certified so this isn't really an issue. I believe MRO is
in agreement with that line of thinking.
Thanks for your help.
Bob
1 of 1 9/28/2005 10:35 AM

mailbox:///Cl/Documents%20and%20Settings/Bob_Sledge/Applicati...
Subject: Re: [Fwd: City of Belmont's Request for Waiver of Requirement for 24/7 Staffing with
Certified Operators]
From: Susan Wilson <[e-mail]>
Date: Mon, 29 Aug 2005 16:25:08 -0400
To: Rex Gleason <[e-mail]>
CC: Richard Bridgeman <[e-mail]>, Bob Sledge <Bob. Sledge @ncmail.net>
Thanks for the info. I'm passing to Bob S as he will be looking over their request
and we'll be discussing.
Rex Gleason wrote:
Susan,
Here are comments provided by Richard re. Belmont's request to modify WWTP
operational hours. I concur with Richard's assessment and recommendation.
Rex
Subject:
City of Belmont's Request for Waiver of Requirement for 24/7 Staffing with
Certified Operators
From:
Richard Bridgeman <[e-mail]>
Date:
Mon, 29 Aug 2005 14:06:52 -0400
To:
Rex Gleason <[e-mail]>
To:
Rex Gleason <[e-mail]>
Citing difficulties in maintaining an adequate staff of properly certified
operators, sufficient to operate on a 24/7 basis, as per 15A NCAC 02H .0124(4), the
City has requested a waiver from the requirement to have at least one certified
wastewater operator per each shift.
Following is a summary of facts and/or supposition surrounding the City's request:
* For mechanical facilities with a design capacity equal to or
greater than 5.0 mgd, 15A NCAC 02H .0124(4), in part, requires
that each shift be staffed by at least one certified wastewater
operator.
* In part, 15A NCAC 08G .0202 _only_ requires that a classified
water pollution control system have one designated ORC and one or
more Back-up ORC's of the appropriate type and grade for the system.
* The City's WWTP has funding for 10 (possibly 11, according to how
one interprets the waiver request) positions. Seven positions are
currently filled with certified operators, but the City is having
difficulty finding additional certified operators to fill the
remaining positions.
* The waiver request suggests that the City is willing to install an
electronic SCADA system, but only if DWQ agrees to allow the City
to use uncertified operators.
* The waiver request does not discuss how the SCADA system would be
set up and how quickly staff could be mobilized in the event of an
operational problem.
* The City suggests that finding certified operators is made more
difficult because the nearby larger communities, such as Charlotte
and Gastonia, are able to offer higher pay scales.
1 of 2 9/28/2005 8:40 AM

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Following are the writer's comments and conclusions:
* 15A 02H .0124(4) provides for a waiver of the rule.
* Perhaps a partial waiver related to shift staffing can also be given.
* The City of Statesville's two WWTP's are operated on a 24/7 basis,
even though the facilities are not subject to the requirements of
15A 0211 .0124(4). The facilities may or may not be staffed by
certified operators during the night and weekend shifts. Neither
facility has a SCADA system, although the Fourth Creek facility
does have telemetry. The SWP staff has been given no reason to
think that the facilities receive inadequate care during the 2nd
and 3rd shifts.
* To maintain its WWTP staff, the City needs to realize that it has
to successfully compete with larger, better funded communities.
* Perhaps the Technical Assistance and Certification Unit can
provide the City of Belmont a list of area certified operators.
* 15A NCAC 08G .0602 (Temporary Certificates) does not seem to apply
in this case.
* Provided that the City installs and properly operates an approved
SCADA system, and provided that the City gives intensive
supervision to the trainees, and provided that the partially
trained staff who would work the night and weekend shifts actively
work toward successfully sitting for certification, the writer has
no objection to granting a _temporary_ waiver. In the interim,
compliance with the relevant rules is expected.
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City of Belmont
Ms. Susan Wilson
Supervisor of Western NPDES Programs
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
-JAV- bT
10z44�-
AUG 2 5 2005
- 115N. MAIN STREET
POST OFFICE BOX 431
BELMONT, N.C. 28012
PHONE [phone]
August 22, 2005
Re: Permit # NPDES NCO021181 - City of Belmont - Request to Modify Operational Hours
Dear Ms. Wilson:
Thank you for taking time to discuss with me some of our operational concerns pertaining to the
City of Belmont and our wastewater plant. As you requested, I have listed below several items of
immediate concerns which we would like for you and your staff to review. These concerns result
primarily in the City of Belmont being unable to adequately meet personnel staffing for nights
and week -end shifts through qualified and certified operators. Currently, we are approved for
ten (10) certified or semi -trained plant positions. We currently have seven positions filled with
qualified operators but are having difficulty in finding additional personnel to fill our remaining
three (3) open positions. This is causing some hardships on our first and second shift employees
through excessive amounts of overtime and shift changes in order for them to keep the plant
operational on a 24 - 7 basis.
We hope you will take into consideration the following thoughts and ideas for which our staff
and City officials are requesting in order to modify our current operational procedures. Once
you have had a chance to review our concerns, we certainly welcome a meeting so that we can
determine a better plan on operating our wastewater plant on a more improved and professional
schedule. Our main goal is to ease the responsibilities of our current wastewater staff while at the
same time, allowing us to move forward until we have adequately trained and certified our new
employees.
PROSPOSED THOUGHTS AND IDEAS:
•A We are currently permitted for 5 MGD within the Catawba River Basin. Requesting a
reduction in our daily gallons would be one option as it would require less certified
operators. With our current growth in residential additions, we do not feel comfortable
seeking a reduction of our permit for fear of not being re -approved should future needs
be requested. In short, our 5 MGD should remain as permitted by the State unless of
course, we could receive assurance from the State otherwise.
4 The City has spent hundreds of dollars each month advertising for certified operators in
hopes of filling these open positions. Our City elected officials recently approved adding
another new position to help offset our existing work load as well as approving
additional funds to aid in searching for new personnel. To date, we have not been
successful in finding approved or qualified personnel to fill not only the new position,
but existing positions as well.

❖ The City would very much like for the State to approve an electronic SCADA system for
which we plan to purchase this year, providing we would be allowed to operate our
wastewater plant during the night and week -end shifts, along with approved newly
hired trainees. Currently we are having to staff with operators requiring a Wastewater I
or II certification. With current State testing, it is taking approximately 6 months for a
trainee to be State certified and that's counting on the trainee passing all current exams.
The City is willing to appropriate the necessary funds this year for an approved SCADA
system but we certain would like some assurance that the system would be approved
by the State as an operational device to supplement having to have certified operators
during the third and week -end shifts. Please keep in mind that we would still maintain
an active employee on all shifts at all times. They would be listed as trainees and not
ORCs.
❖ The City of Belmont believes that we have been an excellent example of a permit holder
and that our record of compliance stands on its own. We have been very active with all
Stage requirements as well as with all inspector request or written reports. We believe
that the State too, is aware of the reductions in annual State certifications as fewer and
fewer certified wastewater holders are renewing their annual certifications. In short, the
demand for finding certified wastewater applicants is proving to be more difficult as
each year approaches.
❖ The City of Belmont, through its Human Resource Department, furnished and approved
a complete pay -scale review of all departments as recently as 2002. At that time, the pay
scale for wastewater operators was revised and adjusted to meet the current pay ranges
for that period. Surrounded by larger cities such as Charlotte and Gastonia, we have
found that the applicants who have responded to our employment ads already exceed
what our current pay step and grades offer. The City would certainly be willing to adjust
the pay scale to meet the requirements but it would need some type of written
suggestions from State officials showing that we are "outside of pay range" for our
particular region. Again, any suggestions from the State level would be greatly
appreciated.
In conclusion, the City of Belmont is respectfully asking that you consider our current staffing
situation as well as our night and week -end operational scheduling. We would be grateful for
your consideration in our asking for reduced employees and shifts, providing that we meet your
criteria as it relates to automation and future compliance standards. We certainly hope to meet
with you very soon in order for us to report back to our City officials by the October 2005 council
meeting.
Sincerel Yours;
David W. Isenhour
Director of Public Works
Cc: Barry Webb - City Manager
Patrick Waiters - Wastewater Plant Superintendent
Mozelle Lingafeldt - Human Resource Officer