NC0020737_Permit (Modification)_20040629

MPDCS DOCYNEMT SCAMMIMC COVER SHEET
NPDES Permit: NC0020737
Kings Mountain WWTP
Document Type: Permit Issuance
Wasteload Allocation
i Authorization to Construct (AtC)
Permit Modification
Correspondence
201 Facilities Plan
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: June 29, 2004
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contest oa the reverse Bide

O�O� wAr��pG Michael F. Easley,Governor
Stale of North Carolina
i
.'� William G. Ross,Jr.,Secretary
C r Department of Environment and Natural Resources
Alan W.Klimek, P.E., Director
Division of Water Quality
June 29, 2004
Walter C. 011is
Water Resource Director
City of Kings Mountain
P.O. Box 429
Kings Mountain, NC 28086
Subject: Exemption Request: 24 Hour Staffing
City of Kings Mountain
NPDES NCO020737
Cleveland County
Dear Mr. 011is:
This letter is in response to your letter of April 8, 2004 concerning your request for a
variance of the 15A NCAC 2H .0124 (Reliability) that requires 24 hour staffing at your W WTP
by certified operators. Your request for a variance of the regulation has been reviewed by the
staff of the Water Quality Section's Operations Branch and granted with the following
conditions:
I. The facility shall operate and maintain the telemetry monitoring system, consisting of
monitoring for: total power failure, high level alarm at the influent pump station,
operational status of three (3) aerators, operational status of secondary clarifier drive units,
low flow alarm on RAS line, operational status of chlorine and dechlorination pumps.
2. The facility shall perform regular maintenance on the disinfection system components and
have documentation of all preventative and corrective maintenance events.
3. The facility shall maintain all current systems and operating strategies as outlined in your
letter of December 28, 1993.
4. In case of power failure or an alarm situation, an appropriate certified operator must be
dispatched immediately to the treatment plant.
5. Failure of the monitoring system to detect a malfunction, the failure of the monitoring
system in reporting a malfunction, or the failure of an appropriate certified operator in
responding to a problem must be documented and reported to the Mooresville Regional
Office by phone within 24 hours and in writing within five (5) working days. Failure of a
monitoring device or failure to respond to a problem will not be a mitigating factor in any
enforcement action.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 -TELEPHONE [phone]/FAX [phone]
VISIT W Or!THE WEB AT hRn://h2o.enr.state.nc.us/NP DES

Mr. 011is
City of Kings Mountain
NC0020737
June 29, 2004
Page 2
6. The City shall provide in writing to the Mooresville Regional Office, within ten (10)
working days of receipt of this variance, the notification procedure and notification
schedule of how contacts will be made when problems are reported and shall notify the
Mooresville Regional Office of any changes in this schedule.
7. This variance shall be in effect until August 31, 2008 and will be reviewed with the
renewal of the NPDES permit for this facility. A request for renewal of this variance
should be submitted with the permit renewal request and shall include the operational
history of the system, the frequency of malfunctions along with any actions taken to
resolve any such malfunctions.
8. The variance may be rescinded at the discretion of the Director in the event that the
compliance status or the conditions at the facility change or that the system in place does
not prove to Provide adequate reliability or adequate notification.
The Division appreciates the efforts that the City-of Kings Mountain has made to provide
reliable and efficient wastewater treatment and we look forward to your continued cooperation.
If you have any questions or need any further assistance in this matter, please contact Rex
Gleason, Regional Water Quality Supervisor of,the Mooresville Regional Office at (704) 663-
1699.
Sincere/�
lan W. Klimek, P.E.
Director, Division of Water Quality
cc: Mooresville Regional Office
Technical Assistance & Certification
Central Files
NPDES Unit File

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THE CITY OF KINnS�hA60UNTAINj
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f r ? P.O.BOX 429 . KINGS MOUNCAIIN I ORAi FRA409ININ 704-734-0333
D' q - QUALITY
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April 8, 2004 D
APR 16 2004
N.C. Department of Environment and Natural Resources DIV. OF WATER QUALITY
D ' 'on of Water Quality DIRECTOR'S OFFICE
17 Mail Service Center
Raleigh, N. C. 27699-1617
Atm. Mr Alan W. Klimek, P.E,1 Director
As instructed by Mooresville Regional Office, this letter is directed to your attention.
The Pilot Creek WWT facility of the City of Kings Mountain, NPDES Permit No.
NC0020737, asked for, and was granted a waiver from the requirement for 24/7 staffing
requirement by letter dated March 14, 1994. (Copy enclosed.)
Due primarily to changes in personnel at the facility over the years, the requirement for
renewal of this waiver was forgotten. I know that this is the responsibility of the City, not
DWQ. However, we now find ourselves in the position of begging renewal of that which
should have been renewed in 1998/99 and again in 2003/04.
Other than failure to renew, changes in personnel, and reduction in flow due to recent
cuts by our textile clients and thus our income, all the other factors which led to our
requesting and being granted this waiver have remained the same. The phone dialer still
calls the people if there is a need, and continues to call others if they forget to turn it off
when they arrive.
I have included an up-dated list of personnel who are on the call out list, but other things
remain the same.
Please forgive our failure to renew this waiver. Rather, consider the fact that we have
had no problems resulting from not having personnel on hand 24/7, and also be aware
that in preparation of next years budget I have been asked to cut at least one existing
position at this facility. (They were not referring to the open ORC position.) If we had to
meet the 24/7 staffing requirement, this would double our personnel costs, funds for
which would be better spent elsewhere.
CJ` The Historical City

I have enclosed several items referring to this situation, which have been written from
the City to DWQ or from DWQ to the City in the past, for your information. Some of
these may contain references to matters other than the one at hand, and some may not be
the full communication but only pertinent portions.
Thank you for your patience and assistance in this matter. If you need additional
information or have further questions, please let us know. Feel free to call the plant
directly at 704-739-7131, or call me at 704-734-4531. I can generally be reached more
quickly by cell phone at 704-473-0047.
Sincerely:
Gf)a'z Gz�—xzl:v
Walter C. 011is
Water Resource Director
City of Kings Mountain

Mr. Klimek.
I cannot put my hands on a copy of the letter I wrote requesting the waiver, dated
December 28, 1993. This does not really surprise me, since every time I really get
comfortable with a computer, they tell me it is outdated or over-full, and replace it.
I will keep looking.
In the letter dated March 25, 1994, only the last two names on the list are still
unchanged, and due to Mr. VanDyke's age we do not call him until a person sees the
need for his expertise. .
The present listing would be:
ORC
Donnie Spencer—Maint. Op.
Lee Bailey - Chief Operator
Kay Barker— Operator
Pump Maint. Stand-by Person
Walt 011is — Water Res. Dir.
Police Dept.
The ORC position will be filled soon, we hope.
Thank you again.
Walt 011is

April 24, 1995
Training and Certification Unit
Attn. Dwight Lancaster
P.O. Box 29535
Raleigh, NC 27626-0535
Re: Certified Operator requirement:
Dear Mr. Lancaster:
Received your request for input concerning the requirement for Certified Operators at Wastewater
Treatment Plants today.
There are two Regulations which this could possibly concern, and as I am not certain from the letter
which you intend to address, I will comment on both. (These may be two parts of the same
Regulation.)
First, as to the requirement for an Operator with the same Grade of Certification as the Plant, I have
no problem with this and do not believe it is creating, or about to create a problem of legitimate
concern.
Second, and more complicated, the requirement for a Certified operator on site 24-hours per day.
The DEM held a Public Hearing on this in late 1993, at which there was only one person who
desired to speak against. I was the one. Several representatives of environmental groups spoke. My
concerns are still the same that they were then.
We have been granted a variance from this requirement due to the amount of monitoring equipment
we have installed, however I object to the re-opening of this matter in any form due to the fact that
any change which occurs seems to cost me money or paperwork.
I do not find a problem hiring certified operators except occasionally with proper grade. Our
objection was, and is, with having to keep an operator on site who would only amount to a glorified
watchman, due to several factors.
-91. This would require us to hire several additional people to cover the additional hours. We would
start out with one person on second shift and one on third. Then there is the matter of weekends,
and holidays, and vacations, and sick and --------- Then DEM or OSHA would require that we have
more than one person on duty due to safety. Soon, our off-hours payroll would exceed that for our
working people.
42-But bearing on the last part of the above, these operators are, in effect, non-working people.
Only the Chief Operator or someone under her direct orders, is allowed to make changes which will

affect operations. Also, we do not want people operating mechanical equipment, working with
chemicals, or much of the other work at the plant, at night when the chances for an accident or
miss-adjustment are multiplied. The only thing this leaves is lab work or guard duty. We do the
first during the day, under supervision, and accomplish the later more efficiently with electronics.
#3. The only plants I can easily understand having a need for operators on duty 24-hours - 7 days
are those where solids handling, operation complexity, or sheer size demand it. This should be
decided on a case-by-case basis and not by an arbitrary, shot-gun type regulation. Both DEM and
the owners of any WWTP know when they have reached that point. To base this on an arbitrary
size number, alone, could very well create an artificial shortage of Certified Operators in some
areas.
I will close before I get wound-up since the is cutting very close to one of my pet peeves.
If I may be of assistance, or if you have any questions I may be able to help with, please feel free to
write or call.
Sincerely;
Walt 011is
Water Resource Dir.
City of Kings Mountain

March 25 , 1994
Mooresville Regional Office
NC DEHNR DEM
Attn . Mr . Rex Gleason
Subject : Notification Procedure
Telemetry Monitoring System
Dear Mr . Gleason :
As required by condition #6 of the March 14 letter from the
Raleigh office granting the City of Kings Mountain ' s request
for variance from the 24 hour staffing requirement , following
is the schedule and methodology used for after-hours calls .
The alarm system is activated 24 hours per day on weekends
and holidays , even though personnel are present . Monday --
Friday the system is activated 4 : OOpm until 7 : 30am.
When an alarm is triggered, the Dial-a-log telephone dialer
calls the plant normal line first to achieve faster response
in the event personnel are still present . If no answer on
site , the sequence is as follows :
Kim Moss ORC tJ� j v a);2,'7(--
Kenny Downey Op
Lewis Messick Op '? "J tiFy- / � /o Ji�r
Tracy Meade Op p), o
Jim VanDyke Chief Mechanic
Walt 011is Water/wastewater Dir .
The person receiving the call indicates response by dialing
8 on their telephone , which allows approx . 15 min. to reach
the plant and disarm the system. If this is not done , the
system begins at the top of the list again until someone has
corrected the problem and reset the alarm system.
We will notify your office of changes in procedure or
personnel , as required.
If you need additional information, please call .
Sincerely;
Walt 011is
Water/wastewater Dir .
City of Kings Mountain

itTate of North Carolina
Department of Environment, I
Health and Natural Resourcesff4*40
Division of Environmental Management
James B. Hunt, Jr.; Governor
Jonathan B. Howes,Secretary ID F_
A. Preston Howard,Jr., P.E., Director
March 14, 1994
Walt 011is,Water/Wastewater Director
City of Kings Mountain
P.O. Box 429 , . 1
Kings Mountain, NC 28086 �1 �2��a ZN Ylo u71/� Qy S
v�•00- Subject: Exemption.Request- 24 Hour Staffing 9
---C:u of uiros Mo:r t* m
NPDES NCO020737
Cleveland County 7.
n,,,�61 °
Dear Mr. 011is: f�{�"
This letter is in r our letter of December 28, 199 concerning your request
for a variance of the ew regulation that requimE 4-hour-sta€firrg coverage at your.W WTP
by certified operators. Your request has been reviewed by the staff of the Water Quality
Section's Operations Branch. Your request for a variance of the regulation is,hereby
granted with the following conditions:
1. The facility shall operate and maintain the telemetry monitoring system,consisting of .
monitoring for. total power failure,high level alarm at the influent pump station,
"operational status of three (3) aerators,operational status of secondary clarifier drive
`::units;low flow alarm on RAS line,operational status of chlorine and dechlorination
pumps
r
2=.The facility shall'perforri regular maintenance on the disinfection system components
and have documentattori of all preventative and corrective maintenance events.
3 The,facility shall maintain all current systems and operating strategies as outlined in your..
_.letter of December.28, 1993. -
4 In case of a power failure or an alarm situation, an appropriate certified operator must be
dispatched immediately to the treatment plant.
5.Failure of the monitoring system to detect a malfunction, the failure of the monitoring
_system in reporting a malfunction,or the failure of an appropriate certified operator in
responding to a problem must be documented and reported to the Mooresville Regional
Office by phone within 24 hours and in writing within five (5) worldng days. Failure of
a monitoring device or failure to respond to a problem will not be a mitigating factor in
any,enforcement action.
6.The City shall provide in writing to the Mooresville Regional Office, within ten (10)
working days of receipt of this variance, the notification procedure and notification
schedule of how contacts will be made when problems are reported and shall notify the
Mooresville Regional Office of any charges in this schedule. „
P.O.Box 29535,Rdelgh,North Carolina 27626-0535 Telephone [phone] FAX [phone]
- An Equal Opportunity Affirmative Action Employer W%recycled/10%post-consumer paper, _, .

7.This variance shall be in effect until cember 31, 1998 d will be reviewed with the
�tfYh renewal of,the NPDES permit for this A reque for renewal of this"variance
should lie"submitted with the permit renewal request. This request should include:the
operational history of the system, frequency of malfunctions and actions taken to resolve
any such malfunctions.
8.The variance may be rescinded at the discretion of the Director in the event that the
compliance status or the conditions at the facility change or that the system in place does
not prove to provide adequate reliability or adequate notification.
The Division appreciates the efforts that the City of Kings Mountain has made to
provide reliable and efficient wastewater treatment and we look forward to your continued
cooperation. If you have any questions or need any, further assistance in this matter,please
contact Rex Gleason,Regional Water Quality Supervisor,of the Mooresville Regional
Office at [phone] or-DwighrL-ancaster—WastewaterTlm*Genseltant at-(919)-.733-
r-0026-
Sincerely,
A. Preston Howard, Jr., PE.'
11.cc: Mooresville Regional Office -
Faeiiities-Assessment-Unit— rrc.4 nzc d 41a,t3)4."^ f Ceer/i fic&4,
Central Files.. .
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