NC0024201_Renewal (Application)_20210202

ri
r o,51. 4
ROY COOPER , +
Governor ;
M
MICHAEL S.REGAN �,_
. Q"""` .
Secretory
1 S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
February 02, 2021
Roanoke Rapids SanitaryDistrict
Attn: R. Danieley Brown, Chief Executive Officer
PO Box 308
Roanoke Rapids, NC 27870
Subject: Permit Renewal
Application No. NC0024201
Roanoke River WWTP
Halifax County
Dear Applicant:
The Water Quality Permitting Section acknowledges the February 2, 2021 receipt of your permit renewal application and
supporting documentation. Your application will be assigned to a permit writer within the Section's NPDES WW permitting
branch. Per G.S. 150B-3 your current permit does not expire until permit decision on the application is made.
Continuation of the current permit is contingent on timely and sufficient application for renewal of the current permit. The
permit writer will contact you if additional information is required to complete your permit renewal. Please respond in a
timely manner to requests for additional information necessary to allow a complete review of the application and renewal
of the permit.
Information regarding the status of your renewal application can be found online using the Department of Environmental
Quality's Environmental Application Tracker at:
https://deq.nc.gov/permits-regulations/permit-guidance/environmental-application-tracker
If you have any additional questions about the permit, please contact the primary reviewer of the application using the
links available within the Application Tracker.
Sincerely,
JIB ,c?_. ,
Wren Th dford
Administrative Assistant
Water Quality Permitting Section
cc: Central Files w/application
ec: WQPS Laserfiche File w/application
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Ce k P.O.Box 308
9p1000 Jackson Street
�oRoanoke Rapids,NC 27870Roanoke Rapids Sanitary District [phone]
Fax: [phone]
D�5�4, www.rrsd.org
February 1,2021
Ms. Wren Thedford RECEIVED
NC DENR,Division of Water Quality,NPDES Unit
1617 Mail Service Center E B 0 2 2021
Raleigh,North Carolina,27699-1617
NCDEQ/DWPAPDES
RE: Renewal Request of NPDES Permit Number NC0024201
Roanoke River Waste Treatment Plant
Roanoke River Basin
Dear Ms. Thedford,
The Roanoke Rapids Sanitary District(RRSD)is permitted to discharge 8.34 million gallons per day
(mgd)of treated effluent to the Roanoke River under NPDES Permit No.NC0024201. The NPDES
permit is scheduled to expire on March 31,2022. The enclosed application is for renewal of the current
permit. In accordance with the requirements of federal(40 CFR 122)and state(15A NCAC 2H.0105(3))
regulations,we are submitting one signed copy and an electronic copy of the completed application
package and associated attachments and figures. The application package includes the following
information:
1. NPDES Permit Application—EPA Form 2A
2. EPA Form 2A Additional Information(Topographic Map,Process Flow Diagram,Process
Narrative,and Site Map)
3. EPA Form 2A Tables:A, B,C and F
4. Analysis in support of the Reduction of Monitoring Frequency for Exceptionally Performing
Facilities
5. Mercury Minimization Plan Summary
6. Biosolids Program Summary
In accordance with 15A NCAC 2B .0508(b)(1)and the October 2012 DWR Guidance Document for the
Reduction of Monitoring Frequency for Exceptionally Performing Facilities,the District respectfully
requests a continuation in reduction in frequency monitoring for carbonaceous biochemical oxygen
demand(CBOD5),ammonia,and fecal coliform.Effluent sampling results from the past three years
demonstrate that all state regulatory and guidance requirements have been met in support of this request.
A summary of the sampling data and analysis for the reduction of monitoring frequency is attached to this
application.
Additionally, RRSD respectfully requests that the following issues be addressed in this permit renewal:

• We request that Footnote 1 remain in the permit unaltered.
• Reduce the total nitrogen and total phosphorous monitoring frequency from monthly
sampling to once per quarter.Our facility does not discharge into nutrient sensitive waters.
• Reduce the chronic toxicity sampling(Ceriodaphnia)from quarterly to annually.We have
been conducting chronic toxicity testing since April 1993.All of our toxicity tests have
passed,including the second species testing with Fathead Minnow.
We request the following information as part of the draft permit preparation:
• A copy of the permit Fact Sheet.
• Documentation for any methodology,data,and assumptions used in any permit modification,
including Reasonable Potential Analyses,if applicable.
• A copy of any comments that are received from the public regarding this permit renewal,if
applicable.
We very much appreciate the time and effort of the NPDES Unit to consider our requests for this permit
renewal.Please do not hesitate to call me(252-537-9137).
Sincerely
w
R.Danieley Brown,P .
Chief Executive O cer
Roanoke Rapids Sanitary District
Attachments:
Topographic Map
Process Flow Diagram
Process Narrative
Site Map
Form 2A Tables:A,B,C,and F
RMF Analysis
MMP Summary
Biosolids Program Summary
cc: Steven Ellis,ORC
Michael Montebello,Supervisor,NPDES Municipal Permitting Unit
File
Ave*pcomon fiksypduponnlNooumorsloppYutioMnad_porn morel son_mwrlottr.doa
Page:2/2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
Form U.S.Environmental Protection Agency
2A 6'EPA Application for NPDES Permit to Discharge Wastewater
NPDES NEW AND EXISTING PUBLICLY OWNED TREATMENT WORKS
SECTION 1.BASIC APPLICATION INFORMATION FOR ALL APPLICANTS(40 CFR 122.21(j)(1)and(9))
1.1 Facility name
Roanoke River WWTP
Mailing address(street or P.O.box)
135 Aqueduct Road
City or town State ZIP code
0 Weldon NC 27890
Contact name(first and last) Title Phone number Email address
Steven Ellis ORC [phone] [e-mail]
Location address(street,route number,or other specific identifier) m Same as mailing address
10
LL
City or town State ZIP code
1.2 Is this application for a facility that has yet to commence discharge?
❑ Yes 3 See instructions on data submission ❑✓ No
requirements for new dischargers.
1.3 Is applicant different from entity listed under Item 1.1 above?
❑✓ Yes AD No 4 SKIP to Item 1.4.
Applicant name
Roanoke Rapids Sanitary District
Applicant address(street or P.O.box)
PO Box 308
City or town State ZIP code
0
Roanoke Rapids NC 27870
Contact name(first and last) Title Phone number Email address
n R.Danieley Brown CEO [phone] [e-mail]
1.4 Is the applicant the facility's owner,operator,or both?(Check only one response.)
❑✓ Owner ❑ Operator ❑ Both
1.5 To which entity should the NPDES permitting authority send correspondence?(Check only one response.)
CI Facility El Applicant
❑ Facility and applicant
(they are one and the same)
1.6 Indicate below any existing environmental permits.(Check all that apply and print or type the corresponding permit
number for each,1
Existing Environmental Permits
a ❑ NPDES(discharges to surface ❑ RCRA(hazardous waste) ❑ UIC(underground injection
water) control)
E NC0024201
c
❑ PSD(air emissions) ❑ Nonattainment program(CM) ❑ NESHAPs(CM)
c
w
rn
y ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section ❑✓ Other(specify)
404)
N CG 110000,W Q00019 89,W
EPA Form 3510-2A(Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
1.7 Provide the collection system information requested below for the treatment works.
Municipality Population Collection System Type Ownership Status
Served Served (indicate percentage)
100 %separate sanitary sewer 0 Own El Maintain
13 Town of Gaston 1,358 %combined storm and sanitary sewer ❑ Own 0 Maintain
rn 0 Unknown ❑ Own 0 Maintain
c 100 %separate sanitary sewer 0 Own ❑ Maintain
City of Roanoke 14,741 %combined storm and sanitary sewer ❑ Own ❑ Maintain
co
a Rapids 0 Unknown ❑ Own DI Maintain
a no %separate sanitary sewer 0 Own ❑ Maintain
v Unincorporated 966 %combined storm and sanitary sewer 0 Own ❑ Maintain
m Areas ❑ Unknown 0 Own 0 Maintain
E al %separate sanitary sewer ❑ Own 0 Maintain
co %combined storm and sanitary sewer ❑ Own ElMaintain
r_ ❑ Unknown ❑ Own ❑ Maintain
0 Total
07 Population 17,065
v Served
Separate Sanitary Sewer System Combined Storm and
Sanitary Sewer
Total percentage of each type of ° °/o
sewer line(in miles) 100 /°
z' 1.8 Is the treatment works located in Indian Country?
c
'
0 ❑ Yes ✓❑ No
V
c 1.9 Does the facility discharge to a receiving water that flows through Indian Country?
c ❑ Yes ❑✓ No
1.10 Provide design and actual flow rates in the designated spaces. Design Flow Rate
8.34 mgd
o
u Annual Average Flow Rates(Actual)
a It co
Two Years Ago Last Year This Year
C
TO
c o 3.34 mgd 3.24 mgd 3.58 mgd
a" Maximum Daily Flow Rates(Actual)
ci Two Years Ago Last Year This Year
9.02 mgd 11.42 mgd 12.4 mgd
u) 1.11 Provide the total number of effluent discharge points to waters of tle United States by type.
c Total Number of Effluent Discharge Points by Type
a o. Constructed
co EP 1- Treated Effluent Untreated Effluent Combined Sewer Bypasses Emergency
Iv t - Overflows Overflows
(.f
U)
0 1 1
EPA Form 3510-2A(Revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
Outfalls Other Than to Waters of the United States
1.12 Does the POTW discharge wastewater to basins,ponds,or other surface impoundments that do not have outlets for
discharge to waters of the United States?
❑ Yes ❑✓ No 4 SKIP to Item 1.14.
1.13 Provide the location of each surface impoundment and associated discharge information in the table below.
Surface Impoundment Location and Discharge Data
Average Daily Volume Continuous or Intermittent
Location Discharged to Surface
Impoundment (check one)
❑ Continuous
gpd ❑ Intermittent
❑ Continuous
gpd ❑ Intermittent
gpd 0 Continuous
❑ Intermittent
L 1.14 Is wastewater applied to land?
2 ❑ Yes ❑✓ No 4 SKIP to Item 1.16.
0 1.15 Provide the land application site and discharge data requested below.
a Land Application Site and Discharge Data _
Continuous or
Average Daily Volume
Location Size Intermittent
Applied (check one)
acresgpd ❑ Continuous
o ❑ Intermittent
acres gpd 0 Continuous
❑ Intermittent
acres d ❑ Continuous
gp ❑ Intermittent
a 1.16 Is effluent transported to another facility for treatment prior to discharge?
❑ Yes m No 4 SKIP to Item 1.21.
1.17 Describe the means by which the effluent is transported(e.g.,tank truck,pipe).
1.18 Is the effluent transported by a party other than the applicant?
❑ Yes ❑ No 4 SKIP to Item 1.20.
1.19 Provide information on the transporter below.
Transporter Data _
Entity name Mailing address(street or P.O.box)
City or town State ZIP code
Contact name(first and last) Title
Phone number Email address
EPA Form 3510-2A(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
1.20 In the table below,indicate the name,address,contact information,NPDES number,and average daily flow rate of the
receiving facility.
Receiving Facility Data
0 Facility name Mailing address(street or P.O.box)
City or town State ZIP code
0
V
o Contact name(first and last) Title
0
Phone number Email address
c0 NPDES number of receiving facility(if any) 0 None
Average daily flow rate mgd
1.21 Is the wastewater disposed of in a manner other than those already mentioned in Items 1.14 through 1.21 that do not
° have outlets to waters of the United States(e.g.,underground percolation,underground injection)?
L ❑ Yes ❑ No 4SKIP to Item 1.23.
0 1.22 Provide information in the table below on these other disposal methods.
41) Information on Other Disposal Methods
Disposal Location of Size of Annual Average Continuous or Intermittent
Method Daily Discharge
Description Disposal Site Disposal Site Volume (check one)
acresgpd ❑ Continuous
❑ Intermittent
❑ Continuous
acres gpd ❑ Intermittent
acresgpd ID Continuous
O Intermittent
1.23 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(n)?(Check all that apply.
w Consult with your NPDES permitting authority to determine what information needs to be submitted and when.)
o ❑ Discharges into marine waters(CWA ❑ Water quality related effluent limitation(CWA Section
Section 301(h)) 302(b)(2))
✓❑ Not applicable
1.24 Are any operational or maintenance aspects(related to wastewater treatment and effluent quality)of the treatment works
the responsibility of a contractor?
❑ Yes ❑✓ No+SKIP to Section 2.
1.25 Provide location and contact information for each contractor in addition to a description of the contractor's operational
and maintenance responsibilities.
Contractor Information
Contractor 1 Contractor 2 Contractor 3
0
Contractor name
a (company name)
€ Mailing address
(street or P.O.box)
City,state,and ZIP
code
0 Contact name(first and
v last)
Phone number
Email address
Operational and
maintenance
responsibilities of
contractor
EPA Form 3510.2A(Revised 3-19) Page 4

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
SECTION 2.ADDITIONAL INFORMATION(40 CFR 122.21(j)(1)and(2))
c Outfalls to Waters of the United States
c 2.1 Does the treatment works have a design flow greater than or equal to 0.1 mgd?
a)
To
❑✓ Yes ❑ No 4 SKIP to Section 3.
a 2.2 Provide the treatment works'current average daily volume of inflow Average Daily Volume of Inflow and Infiltration
and infiltration. 1,860,000 gpd
tc
Indicate the steps the facility is taking to minimize inflow and infiltration.
RRSD manages and sources I/I by smoke testing,dye testing and CCTV inspection;rainwater catch pans installed as
needed;stream debris removal;and manhole metering and monitoring with hydraulic modeling.Ongoing SSES studies.
$7MM invested in SS rehab projects since 2017.
2.3 Have you attached a topographic map to this application that contains all the required information?(See instructions for
V g specific requirements.)
0
❑✓ Yes ❑ No
E 2.4 Have you attached a process flow diagram or schematic to this application that contains all the required information?
o `` (See instructions for specific requirements.)
o rn
LT_' o ❑✓ Yes ❑ No
2.5 Are improvements to the facility scheduled?
❑ Yes ❑✓ No 4 SKIP to Section 3.
Briefly list and describe the scheduled improvements.
0
1.
C
d
E
a 2.
0
to 3.
C,
N
U)
4.
•a
0 2.6 Provide scheduled or actual dates of completion for improvements.
a Scheduled or Actual Dates of Completion for Improvements
Affected Attainment of
d Scheduled Begin End Begin
Outfalls Operational
c Improvement Construction Construction Discharge
E (from above) (list outfall (MM/DD/YYYY) (MMIDD/YYYY) (MM/DD/YYYY) Level
number) (MM/DD/YYYY)
1.
v
to
2.
to
3.
4.
2.7 Have appropriate permits/clearances concerning other federal/state requirements been obtained?Briefly explain your
response.
❑ Yes ❑ No ❑ None required or applicable
Explanation:
EPA Form 3510-2A(Revised 3-19) Page 5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
SECTION 3.INFORMATION ON EFFLUENT DISCHARGES(40 CFR 122.21(j)(3)to(5))
3.1 Provide the following information for each outfall.(Attach additional sheets if you have more than three outfalls.)
Outfall Number 001 Outfall Number Outfall Number
State NC
ru County Halifax
3
0 City or town Weldon
g Distance from shore o ft. ft. ft.
a
Depth below surface 0 ft. ft. ft.
0
Average daily flow rate 3.58 mgd mgd mgd
Latitude 36° 26' 13" "
Longitude 77° 36' 37" °
3.2 Do any of the outfalls described under Item 3.1 have seasonal or periodic discharges?
❑ Yes ✓❑ No 4 SKIP to Item 3.4.
3.3 If so,provide the following information for each applicable outfall.
in Outfall Number Outfall Number Outfall Number
0
Number of times per year
discharge occurs
a Average duration of each
(specify e s
9 ( P fY units)
a Average flow of each
0 discharge mgd mgd mgd
Cn Months in which discharge
occurs
3.4 Are any of the outfalls listed under Item 3.1 equipped with a diffuser?
❑ Yes ❑✓ No 4 SKIP to Item 3.6.
(1) 3.5 Briefly describe the diffuser type at each applicable outfall.
O.
a)
Outfall Number Outfall Number Outfall Number
d
a
Does the treatment works discharge or plan to discharge wastewater to waters of the United States from one or more
a = 3.6 discharge points?
r ❑ Yes 0 No 4SKIPto Section 6.
EPA Form 3510-2A(Revised 3.19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
3.7 Provide the receiving water and related information(if known)for each outfall.
Outfall Number 001 Outfall Number Outfall Number
Receiving water name Roanoke River
Name of watershed,river,
0 or stream system Roanoke River and Tributaries
U.S.Soil Conservation
u, Service 14-digit watershed 03010107070010
o code
= Name of state
3 management/river basin Roanoke River Basin
rn
U.S.Geological Survey
4) 8-digit hydrologic 03010107
re cataloging unit code
Critical low flow(acute) 1172 cfs cfs cfs
Critical low flow(chronic) 1172 cfs cfs cfs
Total hardness at critical mg,L of mgfL of mg/L of
low flow unknown CaCO3 CaCO3 CaCO3
3.8 Provide the following information describing the treatment provided'or discharges from each outfall.
Outfall Number 001 Outfall Number Outfall Number
Highest Level of ID Primary ❑ Primary Cl Primary
Treatment(check all that ❑ Equivalent to ❑ Equivalent to ❑ Equivalent to
apply per outfall) secondary secondary secondary
0 Secondary ❑ Secondary ❑ Secondary
❑ Advanced ❑ Advanced 0 Advanced
❑ Other(specify) ❑ Other(specify) ❑ Other(specify)
0
0
Q. Design Removal Rates by
•
u Outfall
m 1
a)
2 BODs or CBODs 85 % % % 1
c
E
w TSS 85 % %
1
GI Not applicable ❑Not applicable ❑Not applicable
Phosphorus % %
0 Not applicable 0 Not applicable El Not applicable
Nitrogen % % %
Other(specify) la Not applicable ❑Not applicable ❑Not applicable
% % ok
EPA Form 3510-2A(Revised 3-19) Page 7

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
3.9 Describe the type of disinfection used for the effluent from each outfall in the table below.If disinfection varies by
season,describe below.
61
d
Sodium Hypochlorite(Chlorination)
c
0
U
o Outfall Number 001 Outfall Number Outfall Number
C Disinfection type
0 Chlorination/Dechlorination
CO
Seasons used
All
r Dechlorination used? ❑ Not applicable ❑ Not applicable ❑ Not applicable
❑✓ Yes ❑ Yes ❑ Yes
❑ No ❑ No ❑ No
3.10 Have you completed monitoring for all Table A parameters and attached the results to the application package?
✓❑ Yes ❑ No
3.11 Have you conducted any WET tests during the 4.5 years prior to the date of the application on any of the facility's
discharges or on any receiving water near the discharge points?
❑✓ Yes ❑ No 4 SKIP to Item 3.13.
3.12 Indicate the number of acute and chronic WET tests conducted since the last permit reissuance of the facility's
discharges by outfall number or of the receiving water near the discharge points.
Outfall Number 001 Outfall Number Outfall Number
Acute Chronic Acute Chronic Acute Chronic
Number of tests of discharge
water 16
Number of tests of receiving
water
3.13 Does the treatment works have a design flow greater than or equal to 0.1 mgd?
❑✓ Yes ❑ No 3 SKIP to Item 3.16.
0 3.14 Does the POTW use chlorine for disinfection,use chlorine elsewhere in the treatment process,or otherwise have
m reasonable potential to discharge chlorine in its effluent?
✓❑ Yes 4 Complete Table B,including chlorine. ❑ No 4 Complete Table B,omitting chlorine.
I-
3.15 Have you completed monitoring for all applicable Table B pollutants and attached the results to this application
package?
ID Yes ❑ No
3.16 Does one or more of the following conditions apply?
• The facility has a design flow greater than or equal to 1 mgd.
• The POTW has an approved pretreatment program or is required to develop such a program.
• The NPDES permitting authority has informed the POTW that it must sample for the parameters in Table C,must
sample other additional parameters(Table D),or submit the results of WET tests for acute or chronic toxicity for
each of its discharge outfalls(Table E).
Yes 4 Complete Tables C,D,and E as
❑ applicable. ❑ No-) SKIP to Section 4.
3.17 Have you completed monitoring for all applicable Table C pollutants and attached the results to this application
package?
❑,/ Yes ❑ No
3.18 Have you completed monitoring for all applicable Table D pollutants required by your NPDES permitting authority and
attached the results to this application package?
❑✓ Yes ❑ No additional sampling required by NPDES
permitting authority.
EPA Form 3510-2A(Revised 3-19) Page 8

EPA Identification Number NPDES Permit Number Facil ty Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
3.19 Has the POTW conducted either(1)minimum of four quarterly WET tests for one year preceding this permit application
or(2)at least four annual WET tests in the past 4.5 years?
El Yes ❑ No 4 Complete tests and Table E and SKIP to
Item 3.26.
3.20 Have you previously submitted the results of the above tests to your NPDES permitting authority?
El Yes 0 No 4 Provide results in Table E and SKIP to
Item 3.26.
3.21 Indicate the dates the data were submitted to your NPDES permitting authority and provide a summary of the results.
Date(s)Submitted Summary of Results
(MM/DD/YYYY)
Results were submitted with eDMR data quarterly as required by the
permit.Also as required,second species testing was conducted and
05/07/2020 submitted on 5/9/2017,8/6/2018,11/6/2019,and 5/7/2020 with regular
}—. toxicity testing results on eDMR.All four 2nd species WET tests had a
results of greater than 4.4%while all quarterly tests had a result of Pass.
3.22 Regardless of how you provided your WET testing data to the NPDES permitting authority,did any of the tests result in
1-4 toxicity?
35' ❑ Yes ❑✓ No 4 SKIP to Item 3.26.
3.23 Describe the cause(s)of the toxicity:
c
CD
w
3.24 Has the treatment works conducted a toxicity reduction evaluation?
❑ Yes ❑ No 4 SKIP to Item 3.26.
3.25 Provide details of any toxicity reduction evaluations conducted.
3.26 Have you completed Table E for all applicable outfalls and attached the results to the application package?
❑ Yes 0Not applicable because previously submitted
information to the NPDES I rmittin. authori .
SECTION 4.INC USTRIAL DISCHARGES AND HAZARDOUS WASTES(40 CFR 122.21(j)(6)and(7))
4.1 Does the POTW receive discharges from Sills or NSCIUs?
❑✓ Yes ❑ No 4 SKIP to Item 4.7.
4.2 Indicate the number of Sills and NSCIUs that discharge to the POTW.
Number of Sills Number of NSCIUs
3 0
4.3 Does the POTW have an approved pretreatment program?
❑✓ Yes ❑ No
(73
4.4 Have you submitted either of the following to the NPDES permitting authority that contains information substantially
to
identical to that required in Table F:(1)a pretreatment program annual report submitted within one year of the
application or(2)a pretreatment program?
s
0 Yes ❑ No 4 SKIP to Item 4.6.
i 4.5 Identify the title and date of the annual report or pretreatment program referenced in Item 4.4.SKIP to Item 4.7.
Pretreatment Annual Report submitted to NCDWR 1/29/2021 01/29/2021
-o
---
4.6 Have you completed and attached Table F to this application package?
❑✓ Yes ❑ No
EPA Form 3510-2A(Revised 3-19) Page 9

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
4.7 Does the POTW receive,or has it been notified that it will receive,by truck,rail,or dedicated pipe,any wastes that are
regulated as RCRA hazardous wastes pursuant to 40 CFR 261?
❑ Yes ❑� No 4 SKIP to Item 4.9.
4.8 If yes,provide the following information.
Annual
Hazardous Waste Waste Transport Method Amount of Units
Number (check all that apply) Waste
Received
❑ Truck ❑ Rail
❑ Dedicated pipe ❑ Other(specify)
0
❑ Truck ❑ Rail
❑ Dedicated pipe ❑ Other(specify)
0
0
❑ Truck ❑ Rail
❑ Dedicated pipe ❑ Other(specify)
-0
A 4.9 Does the POTW receive,or has it been notified that it will receive,wastewaters that originate from remedial activities,
including those undertaken pursuant to CERCLA and Sections 3004(7)or 3008(h)of RCRA?
to
❑ Yes ❑✓ No 4 SKIP to Section 5.
b 4.10 Does the POTW receive(or expect to receive)less than 15 kilograms per month of non-acute hazardous wastes as
specified in 40 CFR 261.30(d)and 261.33(e)?
❑ Yes-4 SKIP to Section 5. ❑ No
4.11 Have you reported the following information in an attachment to this application:identification and description of the
site(s)or facility(ies)at which the wastewater originates;the identities of the wastewater's hazardous constituents;and
the extent of treatment,if any,the wastewater receives or will receive before entering the POTW?
❑ Yes ❑ No
SECTION 5.COMBINED SEWER OVERFLOWS(40 CFR 122.21(j)(8))
5.1 Does the treatment works have a combined sewer system?
❑ Yes ElNo+SKIP to Section 6.
R
5.2 Have you attached a CSO system map to this application?(See instructions for map requirements.)
1O ❑ Yes ❑ No
R
5.3 Have you attached a CSO system diagram to this application?(See instructions for diagram requirements.)
❑ Yes ❑ No
EPA Form 3510.2A(Revised 3-19) Page 10

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
5.4 For each CSO outfall,provide the following information.(Attach additional sheets as necessary.)
CSO Outfall Number CSO Outfall Number CSO Outfall Number
City or town
O --
n- State and ZIP code
0
O County
to
0
Latitudeo
„ '" .,
(i) Longitude '" '" -,
o
Distance from shore ft. ft. ft.
Depth below surface ft. ft. ft.
5.5 Did the POTW monitor any of the following items in the past year for its CSO outfalls?
CSO Outfall Number CSO Outfall Number CSO Outfall Number
Rainfall 0 Yes 0 No ❑ Yes ❑No ❑Yes ❑No
co
c
O CSO flow volume 0 Yes 0 No 0 Yes 0 No 0 Yes ❑No
c
CSO pollutant ❑Yes ❑No 0 Yes 0 No El Yes 0 No
o concentrations ,
co
C-' Receiving water quality 0 Yes 0 No 0 Yes 0 No D Yes ❑No
CSO frequency ❑Yes ❑No 0 Yes 0 No D Yes ❑No
Number of storm events ❑Yes 0 No 0 Yes 0 No ❑ Yes 0 No
5.6 Provide the following information for each of your CSO outfalls.
CSO Outfall Number CSO Outfall Number CSO Outfall Number
r Number of CSO events in events events events
to
the past year
to
1 n.
Average duration per hours hours hours
c event 0 Actual or 0 Estimated ❑Actual or❑Estimated 0 Actual or 0 Estimated
CD
LIJ
o Average volume per event million gallons million gallons million gallons
c`"i ❑Actual or❑Estimated ❑Actual or❑Estimated ❑Actual or❑ Estimated
Minimum rainfall causing inches of rainfall inches of rainfall inches of rainfall
a CSO event in last year ❑Actual or❑Estimated ❑Actual or❑Estimated ❑Actual or❑ Estimated
EPA Form 3510-2A(Revised 3-19) Page 11
I

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
NC0024201 Roanoke River Wastewater OMB No.2040-0004
5.7 Provide the information in the table below for each of your CSO outfalls.
CSO Outfall Number CSO Outfall Number CSO Outfall Number
Receiving water name
Name of watershed/
stream system
U.S.Soil Conservation ❑Unknown 0 Unknown 0 Unknown
Service 14-digit
watershed code
'> (if known)
Name of state
management/river basin
U.S.Geological Survey ❑Unknown 0 Unknown ❑Unknown
8-Digit Hydrologic Unit
Code(if known)
Description of known
water quality impacts on
receiving stream by CSO
(see instructions for
exam a les
SECTION 6.CHECKLIST AND CERTIFICATION STATEMENT(40 CFR 122,22(a)and(d))
6.1 In Column 1 below,mark the sections of Form 2A that you have completed and are submitting with your application.For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to provide attachments.
Column 1 Column 2
❑ Section is Basic Application ❑ wl variance request(s) ❑ wl additional attachments
Information for All Applicants
❑ Section 2:Additional ❑✓ wl topographic map ✓❑ wl process flow diagram
Information ❑✓ w/additional attachments
❑✓ wl Table A ❑ w/Table D
❑ Section 3:Information on ❑✓ wl Table B ❑ wl Table E
Effluent Discharges
E ❑✓ w/Table C ❑ wl additional attachments
Section 4:Industrial ❑ wl SIU and NSCIU attachments ✓❑ wI Table F
❑✓ Discharges and Hazardous
Wastes ❑ w/additional attachments
o
❑ Section 5:Combined Sewer ❑ w/CSO map ❑ wl additional attachments
Overflows ❑ w/CSO system diagram
Section 6:Checklist and
Certification Statement ❑✓ w/attachments
6.2 Certification Statement
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted.Based on my inquiry of the person or persons who manage the system,or those persons directly responsible
for gathering the information,the information submitted is,to the best of my knowledge and belief,true,accurate,and
complete.l am aware that there are significant penalties for submitting false information,including the possibility of fine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
R.Danleley Brown CEO
Signatur .�� Date signed
t� l �1�12/
EPA Form 3510-2A(Revised 3-19) Page 12

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03105/19
NC0024201 Roanoke River Wastewater ©I 001 OMB No.2040-0004
TABLE A.EFFLUENT PARAMETERS FOR ALL POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of Method' (include
Value Units Value Units Samples units)
Biochemical oxygen demand LI ML
0 BOD5 or m CB0D5 35.6 mg/L 7.5 mg/L 312 SM5210B 2 m MDL
(report one)
Fecal coliform >792 colonies/100mL 12 colonies/100mL 314 SM9222D 1 El MDL
Design flow rate 12.4 MGD 3.39 MGD 748
pH(minimum) 6.2 SU
pH(maximum) 7.6 SU
Temperature(winter) 26.8 degrees C 17.1 degrees C 494
Temperature(summer) 27.9 degrees C 25.6 degrees C 254
0 ML
Total suspended solids(TSS) 109.3 mg/L 15.5 mg/L 748 SM2540 2.5 MDL
1 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2A(Revised 3-19) Page 13

This page intentionally left blank.

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0024201 Roanoke River Wastewater MI001 OMB No.2040-0004
TABLE B. EFFLUENT PARAMETERS FOR ALL POTWS WITH A FLOW EQUAL TO OR GREATER THAN 0.1 MOD
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Number of
Value Units Value Units Samples Methods (include units)
0 ML
Ammonia(as N) 8.8 mg/L 2.3 mg/L 318 SM4500F 0.1mg/I 0 MDL
Chlorine 20.0 ug/L <10.2 ug/L 748 HACH 10014 l0ug/I 0 ML
(total residual,TRC)20 ML
MDL
Dissolved oxygen 9.4 mg/L 5.7 mg/L 748 SM4500-0G NA O MDL
ML
Nitrate/nitrite 28.9 mg/L 5.6 mg/L 58 EPA 353.2 0.1mg/I io MDL
ML
Kjeldahl nitrogen 12.3 mg/L 4.5 mg/L 37 EPA 351.1 0.2mg/I 0 MDL
ML
Oil and grease <5 mg/L <5 mg/L 3 EPA 16648 5mg/I ©MDL
0 ML
Phosphorus 2.1 mg/L 1.0 mg/L 37 EPA 200.7 0.02mg/I MDL
ML
Total dissolved solids 362 mg/L 267 mg/L 3 SM2540C 10mg/I 0 MDL
I Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
2 Facilities that do not use chlorine for disinfection,do not use chlorine elsewhere in the treatment process,and have no reasonable potential to discharge chlorine in their effluent are not
required to report data for chlorine.
EPA Form 3510-2A(Revised 3-19) Page 15

This page intentionally left blank.

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EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
NC0024201 Roanoke River Wastewater 0 001 OMB No.2040 0004
TABLE C. EFFLUENT PARAMETERS FOR SELECTED POTWS
Maximum Daily Discharge Average Daily Discharge Analytical ML or MDL
Pollutant Value Units Value Units Number of Method' (include units)
Samples
ci ML
1,2-diphenylhydrazine <10 ug/L <10 ug/L 3 EPA 625 loug/L O MDL
ML
Fluoranthene <10 ug/L <10 ug/L 3 EPA 625 loug/L 0 MDL
0 ML
Fluorene <10 ug/L <10 ug/L 3 EPA 625 loug/L 0 MDL
ML
Hexachlorobenzene <10 ug/L <10 ug/L 3 EPA 625 loug/L 0 MDL
0 ML
Hexachlorobutadiene <10 ug/L <10 ug/L 3 EPA 625 loug/L p MDL
Hexachlorocyclo-pentadiene <50 ug/L <50 ug/L 3 EPA 625 5Oug/L 0 MDL
ML
Hexachloroethane <10 ug/L <10 ug/L 3 FPA 625 loug/L m MDL
0 ML
Indeno(1,2,3-cd)pyrene <10 ug/L <10 ug/L 3 EPA 625 loug/L MDL
ML
Isophorone <10 ug/L <10 ug/L 3 EPA 625 loug/L ©MDL
ML
Naphthalene <10 ug/L <10 ug/L 3 EPA 625 loug/L 0 MDL
ML
Nitrobenzene <10 ug/L <10 ug/L 3 EPA 625 10ug/L 0 MDL
ML
N-nitrosodi-n-propylamine <10 ug/L <10 ug/L 3 EPA 625 loug/L 0 MDL
0 ML
N-nitrosodimethylamine <10 ug/L <10 ug/L 3 EPA 625 loug/L O MDL
ML
N-nitrosodiphenylamine <10 ug/L <10 ug/L 3 EPA 625 10ug/L 0 MDL
0 ML
Phenanthrene <10 ug/L <10 ug/L 3 EPA 625 loug/L O MDL
0 ML
Pyrene <10 ug/L <10 ug/L 3 EPA 625 loug/L ❑O MDL
ML
1,2,4-trichlorobenzene <10 ug/L <10 ug/L 3 EPA 625 lOug/L 0 MDL
'Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR Chapter I,Subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2A(Revised 3-19) Page 21

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This page intentionally left blank.

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater Treatment OMB No.2040-0004
TABLE F.INDUSTRIAL DISCHARGE INFORMATION
Response space is provided for three SIUs.Copy the table to report information for additional SIUs.
SIU 001 SIU 002 SIU 003
Name of SIU
Reser's Fine Foods Dominion Rosemary Power Station Kennametal Inc.
Mailing address(street or P.O. box) 11251 Hwy 903 120 West 12th St 100 Kenna metal Rd.
City,state,and ZIP code Halifax,NC 27839 Roanoke Rapids,NC 27870 Weldon,NC 27890
Description of all industrial processes that affect
or contribute to the discharge. Food processing Power Generation Cutting and machine tool accessory
manufacturing
List the principal products and raw materials that Meats,Potatoes,Baked Beans,Cabbage, N/A Tungsten Carbide Powder,Ceramic
affect or contribute to the SIU's discharge.
Pasta,Salad Dressings Powder
Indicate the average daily volume of wastewater
discharged by the SIU. 250000 gpd 8500o gpd 60000 gpd
How much of the average daily volume is
attributable to process flow? 250000 gpd 85000 gpd 30000 gpd
How much of the average daily volume is
attributable to non-process flow? gpd gpd 30000 gpd
Is the SIU subject to local limits?
❑✓ Yes ❑ No 0 Yes 0 No ✓❑ Yes ❑ No
Is the SIU subject to categorical standards?
❑ Yes D No ❑✓ Yes ❑ No ✓❑ Yes ❑ No
EPA Forth 3510-2A(Revised 3-19) Page 29

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05/19
NC0024201 Roanoke River Wastewater Treatment OMB No.2040-0004
TABLE F.INDUSTRIAL DISCHARGE INFORMATION
Response space is provided for three Sills.Copy the table to report information for additional SIUs.
SIU SIU_ SIU
Under what categories and subcategories is the
SIU subject? 40 CFR 423.17 40 CFR 471 Subpart J
Has the POTW experienced problems(e.g.,
upsets,pass-through interferences)in the past 4.5 ❑ Yes El No ❑ Yes ❑✓ No ❑ Yes ❑✓ No
years that are attributable to the SIU?
If yes,describe.
EPA Form 3510-2A(Revised 3-19) Page 30

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Process Narrative
Influent flow enters the Roanoke River Waste Treatment Plant via two outfalls:The Roanoke
River Outfall and Chockoyotte Creek Outfall. Both outfalls combine in a collection box prior to
mechanical screening and grit removal. Influent flow may be routed to influent equalization,
when necessary. The influent wastewater is lifted via an influent pump station to primary
clarifiers. Primary clarified effluent gravity flows to trickling filters. Trickling filter effluent is
pumped to aeration basins for further secondary treatment. The mixed liquor then flows to
final clarifiers. Clarified effluent is then chlorinated and dechlorinated. Effluent flow is
measured prior to discharge to the Roanoke River. An effluent flood pump station is used to
pump effluent to the river when gravity flow may not be achieved.

CP�KE R cn MEM Reduced Monitoring Frequency
4�� Analysis
Date:
1/15/2021
From:
Steven L. Ellis, ORC
Re:
Reduced Monitoring Frequency for Exceptionally Performing Facilities
Roanoke River Wastewater Treatment Plant
NPDES Permit NC0024201
In support of the National Pollutant Discharge Elimination System(NPDES) permit renewal, a monitoring
frequency reduction analysis was conducted on the Roanoke River Wastewater Treatment Plant(WWTP)
Discharge Monitoring Report(DMR)data between January 2018 and December 2020. The monitoring
frequency reduction analysis was performed in accordance with the Division of Water Resources (DWR)
guidance document, Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally
Performing Facilities(October 2012).
The Roanoke River WWTP received a reduction in monitoring frequency for CBOD5, ammonia, and fecal
coliform in the 2013 NPDES permit renewal and continued with reduced monitoring in the 2018 NPDES
permit renewal. Table 1 provides a summary of DMR data from January 2018 and December 2020 that
supports a continued reduction in the monitoring frequency for CBOD5, ammonia, and fecal coliform. The
three-year arithmetic mean of effluent data is less than 50 percent of the monthly permit limit for CBOD5
and fecal coliform. Less than 15 of the daily effluent sampling results are over 200 percent of the monthly
average limit for CBOD5. Less than 20 of the effluent sampling results are over 200 percent of the weekly
average limit for fecal coliform. The Roanoke Rapids WWTP does not have a permit limit for ammonia;
however, the three-year average effluent ammonia discharge is 2 3 mg/L with a maximum discharge of
8.8 mg/L. Even though comparisons cannot be provided for the effluent ammonia with respect to a permit
limit, the high-quality effluent supports a continued reduction in the monitoring frequency for ammonia.
The Excel Spreadsheet, NPDES Permit NC0024201 RMF2018-2020.xls, contains the data for the
monitoring reduction frequency analysis. This spreadsheet will be transmitted to DWR upon request.
Per DWR guidance, the following criteria has also been met by Roanoke Rapids Sanitary District:
• The District and Roanoke River WWTP employees have not been convicted of any
criminal violations of the Clean Water Act(CWA).
• The Roanoke River WWTP is not currently under a Special Order of Consent(SOC).
• The Roanoke River WWTP is not on EPA's Quarterly Noncompliance Report for either
CBOD5, ammonia, or fecal coliform.
The Roanoke River WWTP has met the requirements to be categorized as an Exceptionally Performing

OKE k
/ Reduced Monitoring Frequency
7-1- D,S��`L Analysis
Facility per DWR guidance and is eligible for a continued reduction in the monitoring frequency of CBOD5,
ammonia, and fecal coliform bacteria.
Table 1: Summary of Monitoring Frequency Reduction Analysis for Roanoke River WWTP
Approval Criteria',2 CBODS Ammonia TSS Fecal coliform
3-year average 7.5 mg/L 2.3 mg/L 15.5 mg/L 12/100mL
Number of data points 312 318 748 314
Monthly Average Permit limit 25.0 mg/L No limit 30.0 mg/L 200/100mL
Weekly Average Permit limit 37.5 mg/L No limit 45.0 mg/L 400/100mL
Percent of permit limit 30% — 51.6% 6%
Number of daily samples over 0 __ 4 1
200%of monthly average limit
Number of samples over 200%of — -- 1 0
weekly average limit
Non-monthly average violations in 0 0 0 0
2020
Data in compliance with DWR
Guidance for Monitoring Frequency Yes Yes 3 No Yes
Reduction?
'Per Division of Water Resources Guidance Regarding the Reduction of Monitoring Frequencies in NPDES
Permits for Exceptionally Performing Facilities dated October 2012.
2 Analysis is representative of data from January 2018 and December 2020.
3 Maximum discharged effluent ammonia concentration of 8.8 mg/L over data period.

Mercury Minimization Plan
NPDES Permit Renewal Summary Report
The Roanoke Rapids Sanitary District (District) Wastewater Treatment Plant (WWTP) NPDES
Permit (permit), issued in 2013 contained a requirement for the development of a Mercury
Minimization Plan (MMP). The MMP's purpose was to help reduce amounts of mercury received
by the WWTP and receiving stream,the Roanoke River. The MMP focuses on best management
practices (BMP's) to accomplish mercury reduction. The WWTP does not have a mercury limit
nor a monitoring requirement in its current permit. Mercury testing has been necessitated by
current permit due to the Priority Pollutant Analysis (PPA) Scan and due to the Long Term
Monitoring Plan (LTMP) requirement of the Industrial Pretreatment Program. As a result of a
detectable level of mercury in the WWTP effluent and flows exceeding two million gallons a day
(MGD), a MMP was required. The MMP contains needfulness mercury testing as well. The
permit required the development of a MMP within 180 days of the 2012 permit issuance and
subsequent implementation within two years. These requirements were met. In addition, a
requirement of the MMP is a summary report describing activities during the current permit
period for submittal with the next NPDES permit renewal application.
Other than permit renewal summary report requirement the MMP addresses four basic areas:
evaluation of non-domestic sources, control measures, tracking and monitoring, and
implementation of control measures.
Evaluation of non-domestic users
In order for WWTP personnel to establish and evaluate the potential sources contributing
mercury to the treatment system, information gathering was conducted. This was accomplished
primarily through conference and workshop attendance and extensive website research.
A target list of non-domestic users was developed. The list focused chiefly on significant and non-
significant industrial users, medical and dental facilities. Industrial users' permit required
mercury monitoring data was reviewed. This information was correlated with influent and
effluent data at the WWTP. Additionally,industrial users were instructed to do an internal review
of chemicals used in their process and evaluate for mercury presence. If amounts were

discovered above industrial level averages, alternative use chemicals were requested. Another
means of industrial user oversight is through the pretreatment program annual facility
inspection. Inspections offer opportunity to discuss mercury issues such as chemical usage and
proper disposal. Further, industry slug spill plans required by the pretreatment program control
the accidental release of mercury to the POTW.
As well as industrial users, medical and dental facilities were surveyed. Contact lists were in part
established through the use of the telephone directory yellow pages and a list of dentists who
are members of the American Dental Association. Surveys were both written form and
telephone. The surveys served several purposes: one) awareness of the problems with mercury
introduction into the WWTP;two) education on identifying mercury on location and;three) best
management practices for use and disposal.
The District continuously evaluates potential non-domestic sources of mercury contribution to
the WWTP. When an existing facility makes a customer service request, office staff notify the
WWTP if there may be a need to investigate potential contaminants. Also, the District is a
member of the City of Roanoke Rapids' Development Review Committee and reviews a new
facility's construction building plans as a condition of being issued a City building permit. This
review provides a means to examine potential contaminants.
Control Measures
Pollution Prevention: An internal review of chemicals and equipment that may contain mercury
was completed at the WWTP. Alternate chemicals and equipment containing lesser or no
amount of mercury have been evaluated for use. This internal review has been successful in
accomplishing mercury reduction throughout the plant site.
Housekeeping, Spill Control and Collection, and Education: Employees at the WWTP have been
informed of the MMP. Awareness has been raised on the importance of mercury control
procedures to minimize the possibility of any spill or release. In addition, identification of
possible mercury containing items has been recognized. Employees are informed on the use of
labels, Safety Data Sheets (SDS), suppliers, manufacturers and website for information on
mercury presence. The WWTP has a stormwater permit. This permit requires the development
of a stormwater pollution prevention plan (SPPP). The goal of the SPPP is to prevent the
accidental release of contaminants from leaving the plant site. Mercury is one of the
contaminants which must be controlled. Annual training includes spill containment, clean up
and proper disposal.
The WWTP had hundreds of compact florescent lamps (CFL's), florescent tube lamps, and metal
halide lamps. The first two are inside bulb use with the latter being mainly outside use.
Recycling of these mercury containing lamps had been occurring since the early 2000's. When
low level mercury containing lamps became available they were installed as the regular lamps

burned out. Again the low level lamps were recycled as well. With light-emitting diode (LED)
lamps; which contain no mercury, now on the market, the WWTP has replaced all mercury
containing lamps with LED lamps.
As equipment is upgraded or added, mercury free devices and accessories are sought. One
example would be mercury-containing level indicating or actuating float switches. Many tanks,
pumps, and mixers use these switches. As existing switches have been removed,they have
been sent to a recycler. New equipment added to plant processes are required to be controlled
with mercury free devices. All float switches have been replaced with mercury free swtiches.
Laboratory Practices: The WWTP laboratory has thoroughly reviewed chemicals and equipment
for mercury presence. Two tests being performed incorporated the use of mercury. Ammonia
Nitrogen is permit required and Chemical Oxygen Demand (COD) is for process control. The
permit required test required a dry chemical in its procedure which contained mercury. To
eliminate mercury, an alternative Selective Electrode Method test procedure is now performed.
The process control test required the use of a vial that has a liquid in it which contained
mercury. The lab switched to a vial that has no mercury for process control testing. However,
mercury containing vials are still used annually for blind studies to maintain certification and
quarterly as quality assurance/control. A recycling kit was obtained from the supplier for these
used vials. When the kit reaches capacity it is recycled. Mercury containing thermometers
used throughout the lab and various locations around the plant site have been replaced with
alcohol filled thermometers. Because of the small amount of mercury used in the lab a spill
recovery/cleanup kit is reserved.
Public Outreach: The District has been active in making available educational information
regarding issues with mercury. The system annual performance report describes and addresses
the goals and requirements of the MMP. The annual consumer confidence report; a synopsis of
the system annual performance report posted on the District's website, includes an attached
MMP and the Mercury Minimization Plan Implementation (MMPI) document. This document is
a brief overview of the MMP. It discusses problems with mercury in the environment,the MMP
goals, identification of sources of mercury, proper disposal, and web links where additional
information can be obtained. The WWTP conducts tours of the facility throughout the year.
These tours provide an excellent opportunity to educate the general public. Mercury awareness
is a part of this education opportunity. In addition, District personnel have on occasion had
opportunity to speak at various functions and locations. This provides opportunity for educating
about mercury issues.
The summary of the MMP for permit renewal can also be posted on the District's website as
further means to keep the public informed of the efforts being made to control mercury issues.

Tracking and Monitoring
In order to assess the implementation of control measures the WWTP will make evaluations of
several areas. Continue to review water customers and new construction projects. The District
Pretreatment Program continues its industrial waste surveys everyfive years. This will include
g Y
industrial, medical and dental facilities, and any other potential source identified as a mercury
contributor to the WWTP. The pretreatment program will continue to be an integral part of the
MMP. The annual industry pretreatment inspection will be a valuable tool for discussing mercury
issues and as a reminder to be vigilant about assessing bulk use chemicals.
Influent and effluent mercury is monitored quarterly as a requirement of the pretreatment
program LTMP.
The WWTP produces a solids by-product or biosolids. Biosolids are land applied to various land
parcels in the area. In order to monitor and control the various constituents, including mercury;
land applied testing of the biosolids is conducted regularly.
Implementation of Control Measures
Employee training will continue in an effort to identify internal mercury and mercury containing
devices and its proper disposal. This applies to the WWTP lab, programs, and plant operations.
The pretreatment program will be instrumental in working with industries through the permitting
process and annual inspections. Industries are required to give previous notice of any significant
process or chemical change. This allows time to evaluate affects to the WWTP before change is
initiated. The pretreatment program will continue annual surveys as a means to identify mercury
sources and promote awareness. The lab will continue to identify, evaluate and monitor side
streams in an effort to maintain oversight of mercury introduction into the WWTP. The lab data
collected from non-domestic users will continue to be evaluated for its effect on WWTP influent,
effluent and biosolids mercury concentration.
Public awareness and education continues to be a large part of the MMP and its application
towards mercury reduction. Avenues used include annual performance reports, consumer
confidence reports, website postings, public service announcements with newspaper and radio,
bill inserts, plant tours, and public forums.
The District's sewer use ordinance (SUO), a general ordinance which limits or prohibits the
introduction of substances into the WWTP system, protects the WWTP, its employees, public
health and the environment. Mercury is limited by the SUO.

EPA Dental Office Category Rule
One of the most important things to happen regarding mercury and the Mercury Minimization Plan
during the current permit cycle was the implementation of the EPA's Dental Office Category Rule.The
rule, which went into effect July 14, 2020, requires all Dental facilities that place or remove amalgam
fillings to install an amalgam separator and develop a Best Management Practices Plan.The facilities
covered under the rule have to submit a one-time compliance report to the control authority, in this
case,the Sanitary District.To date,the District has sent copies of the compliance report to all area
dentist offices and orthodontists.We have received 70%of the forms back completed.The Dental Office
Category Rule was aimed at controlling the controllable 2%of the mercury in wastewater plant influent.
Dental offices that place or remove amalgam fillings are the largest single source of influent mercury.
The rule is setup by EPA to be a self-implementing rule and puts the burden of compliance on the dental
facilities. It is the District's obligation to accept the one-time compliance reports and review them.The
District will continue to reach out to area dentist offices regarding the rule and continue to accept the
compliance reports and make all necessary efforts to enforce compliance to the rule.The District will
also continue to screen new commercial and industrial accounts for dental offices and request
compliance forms from new sources.

Biosolids Program
Roanoke Rapids Sanitary District
NPDES Permit No. NC0024201
Land Application Permit No. WQ0001989
Synagro Technologies, Inc. manages Land application of residuals. The Roanoke
Rapids Sanitary District holds the land application permit and provides a licensed ORC
and back-up ORC as required. Synagro Technologies, Inc. provides transport and
application equipment and personnel. District personnel perform all treatment of
residuals.
At present, the District has permitted approximately 1,535 acres of farmland for residual
application including 91 acres owned by the District. Approximately 3.1 million gallons
of -4% solids is applied to an estimated 300 acres per year. Soil pH is adjusted to
achieve a soil pH as specified by permit conditions.
The last plant addition, which provided treatment capacity, occurred in 1983; however,
several upgrades have been added since that date specifically for the solids program.
A system to thicken WAS from the 0.5% solids range to the 3-4% solids range was
accomplished by the addition of two gravity thickeners and a drum concentrator. The
drum concentrator has since been replaced with a gravity belt thickener. Pathogen
reduction and Vector Attraction Reduction for WAS was accomplished by adding a lime
stabilization, mixing, and holding system to maintain proper pH control. Primary solids
are treated through three anaerobic digesters to meet 38% Volatile Solids Reduction
and Fecal destruction for VAR and PSRP with solids stored for liquid application.
Storage of treated solids was provided by the addition of an above ground 1.0 MG tank
for primary storage and by retrofitting two abandoned clarifiers adding 0.375 MG each
to provide a total of 1.75 MG for emergency storage. Sand drying beds are also
available to store solids in the event that liquid storage is unavailable.
The alkaline stabilization process and anaerobic digested primary sludge meets all
requirements for pathogen and vector attraction reduction for Class B biosolids.