NC0037508_Staffing Requirement_20030826

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August 26, 2003
Mr. James D. Frye
Department of Public Utilities
County of Moore
1094 ADDOR ROAD
ABERDEEN, NC 28315
Michael F, Easley, Govemor
William G. Ross Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: Waiver of 24 hour/7 day Staffing Requirement
Moore County Regional WWTP
NPDES Permit NC0037508
Moore County
Dear Mr. Frye:
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.
I have reviewed your correspondence of December 5, 2002, which describes a proposed system
of monitoring various treatment units within the WWTP. It further describes how information
on WWTP operational status will be transmitted and observed, and what response will follow
should the telemetry indicate a malfunction in the treatment process. In addition, you state that
the WWTP would remain staffed around the clock, but perhaps not always by a certified
operator.
After reviewing your monitoring plan and considering the recommendation of the staff of the
Fayetteville Regional Office, I have determined that the system as described in your December 5,
2002 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 telemetry and response system you have described, I hereby waive the
requirement for 24 hour per day staffing by certified operators at the subject WWTP. Please
keep the Fayetteville Regional Office apprised of all developments regarding the installation and
activation of the system.
siegie
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617
[phone] Fax: [phone]
1 800 623-7748

An unfortunate aspectof 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, I reserve the right to
demand changes be made to the system/response plan or I may indeed reinstate the 24 hour
staffing provision as stated in 15A NCAC 2H .0124 (4).
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 Ms. Belinda
Henson in our Fayetteville Regional Office at [phone].
Sincerely,
Alan W. Klimek, P.E.
cc: CFa_yetteille-Regional Offid
Point Source Compliance/Enforcement Unit
Technical Assistance & Certification Unit
Central Files

Moore County WWTP-NC0037508-Telemetry Request
Subject: Moore County WWTP-NC0037508-Telemetry Request
Date: Fri, 15 Aug 2003 10:05:19 -0400
From: Belinda Henson <[e-mail]>
To: [e-mail]
CC: paul rawls <[e-mail]>, don register <[e-mail]>
Bob,
I am emailing you,a letter we had written which basically gives the go
ahead to allow the facility to use the Telemetry system instead of
operating the plant with 24 hour certified operators. I am also faxing
to you today the package request that the facility sent to us. If you
have any questions give me a call. Thanks for your assistance with
this.
Belinda
r
03-nc37508.moo.doc
Name: 03-nc37508.moo.doc
Type: Winword File (application/msword)
Encoding: base64
Download Status: Not downloaded with message
1 of 1 8/18/2003 8:52 AM

W A7 . Michael F. Easley, Govemor
Q 9 William G. Ross Jr., Secretary
QG North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
,< Coleen H. Sullins, Deputy Director
Division of Water Quality
August 6, 2003
James D. Frye -
Moore County Regional WWTP
1094 Addor Road
Aberdeen, NC 28315
SUBJECT: Response to Telemetry Request
Moore County Regional WWTP
NC0037508
Moore County
Dear Mr. Frye:
We received your request letter dated December 5, 2002 with the request to utilize a telemetry
system to monitor your wastewater treatment plant to eliminate the need for a certified operator at
the plant for 24 hours each day. Your plans include monitoring the following locations: raw
sewage pump station, first stage aeration return pumps, immediate clarifiers, blowers, second
stage aeration return pumps, and final clarifiers. As noted in your request the following items are
addressed: 1)the telemetry system will operate by radio signal with battery backup and the signal
will be received by Central Security Systems, Incorporated 2)a representative from the company
will contact Backup Operator first and if he cannot be reached then the Lead Mechanic will be
contacted 3)the staff to be called would be reached by home telephone, beeper or cell phone
4)the plant will be staffed at all times but not necessarily by a Certified Operator.
Our staff has reviewed the request and implementation of the telemetry system can be done as
soon as possible. If you or your staff have any questions please do not hesitate to contact me
[phone].
Sincerely,
CC: Dennis Brobst, Moore County Public Utilities
FRO Files
Ertl
NCDE1' R
N. C. Division of Water Quality
225 Green Street -Suite 714 Fayetteville, North Carolina 28301-50431 910- 486-1541/910-486-0707 Fax
Customer Service 1-877-623-6748

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Resources believes in Recognizing Excellence

, Moore County Request
Subject: Moore County Request
Date: Mon, 23 Dec 2002 11:06:05 -0500
From: Don Register <[e-mail]>
To: Paul Rawls <[e-mail]>
CC: Belinda Henson <[e-mail]>
Belinda and myself have discussed the proposal from Moore County to use
a telemetry system to monitor their treatment plant and also to satisfy
the regulation. I had one question relating to the primary pump
station that was satisfied by talking with ORC D.Frye. The facility has
30-30 limits and a good compliance record.(see attached) We recommend
through you to Training and Certification that their proposal be
accepted.
1 of 1 12/23/2002 11:06 AM

•
Department of Public 'Utilities
Wastewater Treatment Plant
1094 Addor Road
Aberdeen, NC 28315 '
Telephone: [phone]
Facsimile: [phone]
aaotty a/ aawe
December 5, 2002
Mr. Paul Rawls
NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301
Reference: Certified Operators & Telemetry
::Mr.' Rawls:
Upon completing the DMR for the month of September, Ms. Lillian Stephens
discovered we did not have a certified operator on the plant for the entire 24-
hour coverage for several days. On October 16, 2002, Ms.Lillian Stephens
and: I notified the Fayetteville Regional office of our situation. We did have
:coverage for all shifts, however, our operators were not certified. We spoke
with:Ms. Henson and she informed us of the requirement in the 15A
NCAC2H.0100 regulation that states any "mechanical facility with a design
capacity equal to or greater than 5.0 mgd, continuous operation, 24 hours,
seven'days per week, with each shift. staffed by at least one certified
wastewater operator shall be provided on or before October 1, 1993, unless
the applicant can demonstrate to the satisfaction of the Director that this
requirement is unwarranted for a particular case; and...." Ms. Henson and
Mr. Register spoke with you and informed us that we would need to either
monitor by using telemetry the things we felt would maintain compliance, or
have certified operators 24/7.
Ms.. Stephens and I spoke with the Director of Public Utilities for Moore
County, Mr. Dennis Brobst and determined we would try to obtain both
situations. Our operator trainees are currently attending school toprepare
for the Grade I WW license exam.
I contacted Central Security Systems, Incorporated. to evaluate the feasibility
of monitoring locations I feel would keep us compliant. Mr. Dick Harpster
was able to monitor all the locations I felt were necessary. I have enclosed a

December 5, 2002
Page 2
diagram of the plant with numbers that correspond with the items to be
monitored.
Our plan is to monitor the following locations:
• Raw Sewage Pump Station. The wet well will be monitored by a high
wet well alarm and the pump motor will be monitored to insure that at
least one pump is running at all times. (see # 1)
• First Stage Aeration Return Pumps. The pumps will be monitored to
insure that at least one pump is running at all times. (see # 2)
• Immediate Clarifiers. We will insure that both clarifier motors are
running. Notification will be given if even one of them fails to run.
(see # 3)
• Blowers. We will insure that at least one blower is running at all times.
(see # 4)
• Second Stage Aeration Return Pumps. The pumps will be monitored
to insure that at least one pump is running at all times. (see # 5)
• Final Clarifiers. We will insure that both clarifier motors are running.
Notification will be given if even one of them fails to run. (see # 6)
A five-minute delay will be built into all alarms to insure that there was an
actual failure and not just a power interruption.
The signal will be a radio signal with battery backup and therefore will not be
dependent on the telephone lines.
The signal is received at Central Security Systems, Incorporated. A
representative then calls the primary Backup ORC who can be on site within
ten minutes. If the primary Backup ORC is unreachable, then the ORC will
be contacted. In the event neither of the above two can be reached, the
Lead Mechanic will be contacted. The above three personnel can be
reached by home telephone, beeper or cell phone.
The plant will still be staffed by an Operator at all times; however, this may
not always be a Certified Operator. All Operators are trained for
approximately one month on the day shift before being moved to another
shift.

December 5, 2002
Page 3
I feel if the above conditions are met, plant compliance will be maintained. If
you have any questions, please call me at [phone].
Thanks for your help and cooperation.
Sincerely,
likhw,
James D. Frye,
Plant Superintendent
cc: Dennis Brobst, Moore County Public Utilities Director
Lillian Faye Stephens, Chemist/Pretreatment Coordinator

REGIONAL
INTERCEPTOR
POST
AERATION
CASCADE
CHLORINE
CONTACT
BASIN
FINAL
CLARIFIERS
SECOND STAGE
AC RAT ION
BASINS
• • •
• • •
• • •
• • •
CHEMICAL UNIT
is
•,
•
•1
Q
• • •
• • •
• • •
• • •
• FIRST STAGE
AERATION
BASINS
INTERMEDIATE
CLARIFIERS
DIGESTERS • SOLIDS
HANDLING UNIT
•
•
•
131
O
•2
OPERATIONS
emir.
•
PRIMARY
CLARIFIERS
•GRIT\
R EMOv
UNIT
WATER 1 }
STORAGE a l }1
STORAGE
UNIT
L
Maintenance Shop

PERMIT NUMBER: NC0037508
FACILITY NAME: Moore County Public Utilities - Moore County WWTP
CITY: Pinebluff
OUTFALL: 001
EFFLUENT
COUNTY: Moore
PERIOD ENDING MONTH: 10 - 2002
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 1 OF 4
00010
deg c
Temperature,
Water Deg.
Centigrade
00300
mg/1
DO, Oxygen,
Dissolved
00310
lbs/day
BOD, 5-Day (20
Deg. C)
00310
mg/1
BOD, 5-Day (20
Deg. C)
00340
mg/1 -
COD, Oxygen
Demand, Chem.
(High Level)
00400
su
pH
00500
mg/1
Solids, Total
00530
lbs/day
Solids, Total
Suspended
11 01
19.203333
8.703667
1,676
30 .
6.811111
6.74 - 7.12
1,676
12 - 01
18.058065
9.187097
1.676
30
9.088889
6.91 - 7.6
1,676
1 - 02
15.209677
10.329677
1,676
30
8.963636
6.92 - 7.27
1,676
2 02
15.453571
11.2225
1.676
30
11.64
6.56 - 7.35
1,676
3 - 02
16.777419
10.219032
1,676
30
11.405
6.71 - 7.45
1,676
4 - 02
19.6
9.196667
1,676
22
8.745455
6.82 - 7.24
1,676
5 02
21.970968
9.506129
1,676
22
8.195238
7.04 - 7.45
1,676
6 - 02
24.676667 ,
8.66
1,676
22
5.447619
6.78 - 7.28
1,676
7 02
26.306452
8.660968
1,676
22
3.927273
6.95 - 7.18
1,676
8 02
26.5
8.465161
1.676
22
3.957143
6.44 - 7.29
1,676
9 - 02
25.353333
8.478667
1,676
22
4.97619
6.82 - 7.36
1,676
10 - 02
23.432258
8.887097
1,676
22
6.617391
6.93 - 7.41
1,676

PERMIT NUMBER: NC0037508
FACILITY NAME: Moore County Public Utilities - Moore County WWTP
CITY: Pinebluff COUNTY: Moore
PERIOD ENDING MONTH: 10 - 2002
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 2 OF 4
00530
mg/1
Solids, Total
Suspended
00545
ml/1
Solids,
Settleable
00600
mg/1
Nitrogen, Total
(as N)
00610
mg/1
Nitrogen,
Ammonia Total
(as N)
00665
mg/1
Phosphorus,
Total (as P)
00720
ug/1
Cyanide, Total
(as Cn)
01027
ug/1
Cadmium, Total
(as Cd)
01034
ug/1
Chromium, Total
(as Cr)
11 -01
30
'
10.611111
18
0
3.5
12-01
30
12.666667
18
0.028889
3.6
1-02
s0
13.363636
18
0
2.7
2-02
30
18.1
17
.0
3.2
3 - 02
30
19.05
17
0
3.8
4 - 02
30
17
11.5
16
0
2.9
5-02
30
17
13.714286
17
0
2.9
6 - 02
30
17
10.333333
18
0
3.3
7-02
30
17
8.636364
17
0
3.2
8-02
30
17
8.095238
19
0
0.38
9-02
30
17
12.714286
21.2
0
3.3
10 - 02
30
17
15.478261
20
0
3.3

PERMIT NUMBER: NC0037508
FACILITY NAME: Moore County Public Utilities - Moore County WWTP
CITY: Pinebluff COUNTY: Moore
PERIOD ENDING MONTH: 10 - 2002
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 3 OF 4
01042
ug/1
Copper, Total
(as Cu)
01051
ug/1
Lead, Total (as
Pb).
01067
ug/1
Nickel, Total
(as Ni)
01077
ug/1
Silver, Total
(as Ag)
01092
ug/1
Zinc, Total (as
Zn)
01147
ug/1
Selenium, Total
(as Se)
31616
#/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
31616
mpn/100m1
Coliform, Fecal
MF, M-FC
Broth,44.5C
11 -01
2.576521
12-01
21.5
4.4
48
11.577449
1 - 02
14
-
0
35
8.047165
2-02
25.5
0
43.5
8.04102
3-02
19.5
0
48.5
5.901763
4-02
16
0
33
12.452465
5-02
15
0
64.5
14.069504
6-02
47.45
24
81
6.982582
7-02
17.5
0
64
2.590619
8-02
20
2
49
3.332665
9-02
20
0
44
4.289165
10-02
25
0
41
10.224719

PERMIT NUMBER: NC0037508
PERIOD ENDING MONTH: 10 - 2002 DMR 12 Month Calculated
FACILITY NAME: Moore County Public Utilities - Moore County WWTP PAGE 4 OF 4
CITY: Pinebluff
COUNTY: Moore
REGION: Fayetteville
50050
mgd
Flow, in
conduit or thru
treatment plant
50060
ug/1
Chlorine, Total
Residual
71900
ug/1
Mercury, Total
(as Hg)
TGP3B
pass/fail
P/F STATRE 7Day
Chr Ceriodaphnia
THP3B
percent
CHV STATRE 7Day
CHR Ceriodaphnia
11 - 01
6.7
4.315167
12-01
6.7
4.090613
140
1
1-02
6.7
4.500419
245.238095
2-02
6.7
4.553321
172
3-02
6.7
4.404871
136
1
4-02
6.7
.
4.3623
90
5-02
6.7
4.15529
171.363636
6-02
6.7
4.052033
129
1
7-02
6.7
4.062581
123.636364
.
8-02
6.7
3.81471
105.454545
9-02
6.7
4.111133
122
1
10 - 02
6.7
4.635419
126.956522

•
Department of Public:Utilities
Wastewater Treatment Plant
i 094 Addor Road
Aberdeen, NC 28315 '
NI;
4` ss:
\f&aRTh,
WaevAty Q/lio aleei
December 5, 2002
Mr: Paul Rawls
NCDENR
225 Green Street, Suite 714
Fayetteville, NC 28301
Reference: Certified Operators & Telemetry
Mr. Rawls:
Telephone: [phone]
Facsimile: [phone]
'EC 6 2OrT7
Upon completing the DMR for themonth of September, Ms. Lillian Stephens
discovered we did not have a certified operator on the plant for the entire 24-
hour coverage for several days. On October 16, 2002, Ms. Lillian Stephens
and I notified the Fayetteville Regional office of our situation. We did have
coverage for all shifts, however, our operators were not certified. We spoke
with Ms. Henson and she informed us of the requirement in the 15A
NCAC2H.0100 regulation that states any "mechanical facility with a design
capacity equal to or greater than 5.0 mgd, continuous operation, 24 hours,
seven days per week, with each shift staffed by at least one certified
wastewater operator shall be provided on or before October 1, 1993, unless
the applicantcan demonstrate to the satisfaction of the Director that this
requirement is unwarranted for a particular case; and...." Ms. Henson and
Mr. Register spoke with you and informed us that we would need to either
monitor by using telemetry the things we felt would maintain compliance, or
have certified operators 2417.
Ms. Stephens and I spoke with the Director of Public Utilities for Moore
County, Mr. Dennis Brobst and determined we would try to obtain both
situations. Our operator trainees are currently attending school to prepare
for the Grade I WW license exam..
I contacted Central Security Systems, Incorporated to evaluate the feasibility
of monitoring locations I feel would keep us compliant. Mr. Dick Harpster
was able to monitor all the locations I felt were necessary. I have enclosed a
10E-d 010/E00'd 819-1 -0IOdd VIVll;ol sou-9i-Dnv

.44
December 5, 2002
Page 2
diagram of the plant with numbers that correspond with the items to be
monitored.
Our plan is to monitor the following locations:
• Raw Sewage Pump Station. The wet well will be monitored by a high
wet well alarm and the pump motor will be monitored to insure that at
least one pump is running at all times. (see # 1)
• First Stage Aeration Return Pumps. The pumps will be monitored to
insure that at least one pump is running at all times. (see # 2)
• Immediate Clarifiers. We will insure that both clarifier motors are
running. Notification will be given if even one of them fails to run.
(see # 3)
• Blowers_ We will insure that at least one blower is running at all times.
(see # 4)
• Second Stage Aeration Return Pumps. The pumps will be monitored
to insure that at least one pump is running at all times. (see # 5)
• Final Clarifiers. We will insure that both clarifiermotors are running.
Notification will be given if even one of them fails to run. (see # 6)
A five-minute delay will be built into all alarms to insure that there was an
actual failure and not just a power interruption.
The signal will be a radio signal with battery backup and therefore will not be
dependent on the telephone lines.
The signal is received at Central Security Systems, Incorporated. A
representative then calls the primary Backup ORC who can be on site within
ten minutes. If the primary Backup ORC is unreachable, then the ORC will
be contacted. In the event neither of the above two can be reached, the
Lead Mechanic will be contacted. The above three personnel can be
reached by home telephone, beeper or cell phone.
The plant will still be staffed by an Operator at all times; however, this may
not always be a Certified Operator. All Operators are trained for
approximately one month on the day shift before being moved to another
shift.
20E-d 010/P00 d 82S-1 -WOdd YIV11:01 son-9l-9f1V

December 5, 2002
Page 3
I feel if the above conditions are met, plant compliance will be maintained. If
you have any questions, please call me at [phone].
Thanks for your help and cooperation.
Sincerely,
James D. Frye,
Plant Superintendent
cc: Dennis Brobst, Moore County Public Utilities Director
Lillian Faye Stephens, Chemist/Pretreatment Coordinator
IOE-d 010/900 d 819-1 -MVOad YVVZ1:01 EOOZ-91-9f1V

REGIONAL.
INTERCEPTOR
POST
A [RATION
CASCADE
CHLORINE
anima'
BASIN
FINAL
CUU1FlERS
• V 4.
•
SECOND STAGE
AERATION
.D4s ibis
• .• •
•
•
• •
• • •
• • •
CH( MICAL UHT
■
•
•
0
W
Y
SHIMMY EOIAT [-
CLARIFIERS
•
• • •
• • •
• • •
FIRST STAGE
AEI/ ATIOH
SAS IIdS
RIMESTERS • SOLIDS
HANDLING UNIT
•
�•
PRIMARY
CLARIFIERS
0
e
.2
OPERATIONS I'
UNIT
•
•
GAIT
RCMDY L•
U WIT
MIATER.
STORAGE 11
STORAGE
UNIT
MaIntenl4nce Shop

'i oot ; ' uunry rcequesr
r?
Subject: Moore County Request
Date: Mon, 23 Dec 2002 11:06:05 -0500
From: Don Register <[e-mail]>
To: Paul Rawls <[e-mail]>
CC: Belinda Henson <[e-mail]>
Belinda and myeelf have discussed'the proposal from Moore County to use
a telemetry system to monitor their treatment plant and also to satisfy
the.r.egu_ation. 1 had one question relating to the primary pump
station that was satisfied by talking with ORC D.Frye. The facility has
30-30 limits and a good compliance record.(see attached)' We recommend
through you to. Training and Certification that their proposal be.
.accepted.
10E-d Dlo/Zoo d 819-1 V W O1 b00t-91-9flV