NC0025461_Report_20010601

NPDES DOCUMENT SCANNING; COVER SHEET
NC0025461
Bakersville WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Report
....)
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
June 1, 2001
Mims document is printed on reuse paper - ignore any
content on the reizerse side

Municipal Compliance Initiatives Program
PERFORMANCE EVALUATION
TOWN OF BAKERSVILLE
WASTEWATER TREATMENT PLANT
PREPARED BY
CONSTRUCTION GRANTS AND LOAN SECTION
DIVISION OF WATER QUALITY
JUKE 2001

i
TABLE OF CONTENTS
TOWN OF BAKERSVILLE
WASTEWATER TREATMENT PLANT
I. INTRODUCTION
II. EXISTING SYSTEM AND PERFORMANCE
Page
1
EXISTING SYSTEM 2
CURRENT NPDES PERMIT REQUIREMENTS 4
SUMMARY OF INFLUENT LOADING AND
EFFLUENT DISCHARGE CHARACTERISTICS 5
RECENT HISTORY 6
III. SYSTEM EVALUATION
INFILTRATION AND INFLOW 8
SUMMARY UNIT PROCESS AND
OPERATION AND MAINTENANCE EVALUATION 17
BUDGET AND USER CHARGE ANALYSIS 23
IV. CONCLUSIONS AND RECOMMENDATIONS
V. APPENDIX
SECTION 1: PROCESS EVALUATION
24
- Performance Graphs A-1
- Impact of Influent Concentrations on Effluent Concentrations A-2
- Flow Schematic A-3
- Summary Current Process Monitoring A-4
- Process Evaluation A-5
- Microscopic Examination A-10
- Recommended Process Monitoring A-11
-Summary of Existing Process Units A-12
SECTION 2: DESIGN EVALUATION
- Technical Design Evaluation A-14
- Variables Definitions A-29

SECTION 3: MISCELLANEOUS
- Process Monitoring Forms A-33
- Requirements fot Achieving Class "B"
Pathogen Requirements A-35 '
- Troubleshooting High Effluent BOD A+3S

INTRODUCTION
Portions of this report are based on data collected during the MCI audit, records
from the waste treatment facility, and data submitted to the state by the Operator in
Responsible Charge (ORC) for the town of Bakersville during the period between
October 1999 and March 2001 as summarized on page four (4). Other parts are based on
data collected on site at the time of the MCI audit. Finally, data from the State
Information Processing System (SIPS) was used to determine the Inflow for the
Inflow/Infiltration (I/I) evaluation.
During the review period, monthly influent BOD5 levels ranged from 76
milligrams per liter (mg/1) to 369 mg/1 over the eighteen (18) month period and averaged
200 mg/1 for the period. The design BOD5 level was assumed to be 225 mg/1 for the
plant. There have been no violations in effluent BOD5 levels that had averaged 6.1 mg/1.
Using the influent and effluent BOD5 values, the plant operated at a 97% efficiency level.
The influent Total Suspended Solids (TSS) ranged from 53 mg/1 to 829 mg/1. With
the design TSS assumed to be 200 mg/1, the monthly influent averages exceeded the
design value three (3) times. There were no effluent TSS violations during the review
period.
The facility consists of three (3) 0.025 Million Gallons per Day (MGD) treatment
trains, operating in parallel. The average monthly flow ranged from 0.0526 to 0.1102
MGD. Three (3) monthly violations for flow were recorded. The monthly average daily
flow value can be very deceiving. High daily flows and spike flows are averaged over
the month and do not reflect what is happening at the facility on a daily basis. Review of
daily records revealed that the plant does experience these flows. The records indicate
that Bakersville has an Inflow/ Infiltration (I/I) problem.

EXISTING SYSTEM
The Town of Bakersville owns and operates a wastewater treatment plant
which has a design capacity of 0.075 MGD. The facility consists of a bar screen,
equalization basin, flow splitter box, three aeration basins, three clarifiers, three
sludge holding tanks, chlorination, dechlorination, flow recorder, a settling well,
and standby power. The discharge is into the Cane River, Class C-Trout waters in
the French Broad River Basin.
Page four represents a summary of influent and effluent characteristics in
the self -monitoring reports for the last eighteen months and shows three (3)
violations for flow prior to being placed on SOC. Had the town not received the
SOC, it would have had eleven (11) violations during the review period.
The graphs on page A-1 present averages calculated by linear regression to
dampen the variations and more clearly show the trends, compared to the
permitted effluent limit adjusted to compensate for the amplitude of variation.
Based on SOC limits, the evaluation of submitted data indicates the
following :
1) Flow levels are running at about 53% of the limit and are erratic.
2) Biochemical Oxygen Demand (BOD) levels are fairly stable and
running at only 14% of the limit.
3) Total Suspended Solids (TSS) levels are stable and running at only
20% of the limit.
4) Fecal Coliform levels are somewhat erratic, but running at only 1% of
the limit.
Based on the original limits, the evaluation of submitted data indicates the
following :
1) Flow levels would be running at about 106% of the limit and are
erratic.
2) Biochemical Oxygen Demand (BOD) levels are fairly stable and
would be running at 20% of the limit.
3) Total Suspended Solids (TSS) levels are stable and would be running at
30% of the limit.
2

r � �
4) Fecal Coliform levels are somewhat erratic, but be running at 11% of
the limit.
Generally speaking, submitted Daily Monitoring Reports (DMR) indicate
that facility performance has been good.
The graphs on page A-2 for BOD and TSS compare the influent and
effluent concentrations as percent of 200 mg/1, which is a reasonable concentration
for domestic wastewater influent, and effluent concentrations as a percent of 30.0
mg/1 for BOD and 30 mg/1 for TSS, which are the permit limits.
3

TOWN OF BAKERSVILLE WASTEWATER TREATMENT PLANT
Current NPDES Permit Limits
Permit No. NC0025461
Limit Prior to SOC Limit
Flow, mgd .075
BOD, mg/1 30.0
RES/TSS, mg/1 30.0
Fecal Coliform, / 100 ml 200.0
Limit Since SOC (March 2000) Limit
Flow, mgd 0.15 ".
BOD, mg/1 45.0
RES/TSS, mg/1 45.0
Fecal Coliform, / 100 ml 400.0
Expiration Date 12/31 /01
-4

DATE
TOWN OF BAKERSVILLE
SUMMARY OF INFLUENT LOADING
AND EFFLUENT DISCHARGE CHARACTERISTICS
FLOW BOD TSS NH3-N D.O.
MGD MG/L MG/L MG/L MG/L
INFLUENT
10-99
no data
256.4
112.7
no data
no data
11-99
no data
129.3
53.0
no data
no data
12-99
no data
159.4
142.5
no data
no data
01-00
no data
76.8
74.0
no data
no data
02-00
no data
149.1
249.8
no data
no data
03-00
no data
164.0
126.3
no data
no data
04-00
no data
109.0
98.8
no data
no data
05-00
no data
154.0
138.6
no data
no data
06-00
no data
98.3
94.8
no data
no data
07-00
no data
218.6
91.0
no data
no data
08-00
no data
202.3
74.2
no data
no data
09-00
no data
156.7
143.8
no data
no data
10-00
no data
154.0
178.0
no data
no data
11-00
no data
320.9
185.7
no data
no data
12-00
no data
275.4
161.5
no data
no data
01-01
no data
361.7
136.2
no data
no data
02-01
no data
369.3
220.8
no data
no data
03-01
no data
237.0
829.8
no data
no data
avg
199.6
172.8
FLOW
EFFLUENT
BOD TSS
NH3-N FECAL
10-99
0.0690
3.1
2.8
0.76
3.40
11-99
.0.0798
3.4
1.8
0.53
4.30
12-99
0.0648
3.3
1.7
1.18
1.20
01-00
0.0826
2.7
4.7
0.87
6.70
02-00
0.1102
6.9
8.6
1.35
14.60
03-00
.0.0867
2.6
7.7
1.17
1.50
04-00
0.1056
3.0
7.0
1.14
8.30
05-00
0.0849
6.6
7.8
2.75
14.70
06-00
0.0858
4.1
5.0
6.95
150.90
07-00
0.0870
18.4
17.5
3.55
95.10
08-00
0.0962
4.3
1.4
1.63
31.80
09-00
0.0666
4.0
4.2
0.34
49.00
10-00
0.0643
5.3
8.8
0.06
4.40
11-00
0.0540
6.4
6.2
1.04
2.50
12-00
0.0526
7.7
32.7
0.39
0.00
01-01
0.0870
8.2
12.8
1.49
2.60
02-01
0.0604
11.7
11.7
0.61
0.00
03-01
0.0895
7.4
19.5
1.01
1.80
avg.:
0.0793
6.1
9.0
1.526
21.822
5

RECENT HISTORY - TOWN OF BAKERSVILLE
The following is a list of documents currently residing in central files for the town
of Bakersville covering the last two years.
01/07/99 - Letter from Asheville Regional Office denying additional flow for CDGB
project and suggesting the town enter into a Special Order by Consent
(SOC).
01/11/99 - Letter from DWQ denying Remission of Civil Penalty in the amounts of
$1668.70, $3090.19 and $3090.19, cases LV 98-53, LV 98-153 and
LV 98-207.
01/19/99 - Acknowledgment of receipt of check in the amount of $2,603.58 for payment
of civil penalties, case LV 98-271.
02/24/99 - Acknowledgment by DWQ of receipt of Request for Remission of Civil
Penalty in the amount of $2,603.19, case LV 98-237.
02/26/99 - Transmittal of a Notice of Violation and Civil Penalty Assessment in the
amount of $1592.84 for three violations of exceeding NPDES permit limits
for Fecal Coliform.
03/25/99 - Notification that the Request for Remission of Civil Penalty for cases
LV 98-053, LV 98-153, and 98-207 had been placed on the April 8, 1999,
Environmental Management Commission's Committee of Civil Penalty
Remissions agenda.
03/26/99 - Letter from DWQ to Hobbs, Upchurch and Associates, consulting Engineers
for Bakersville, listing NPDES violations. The letter suggests that the
Engineers attempt to secure funding for sewer line improvements and
expansion of the wastewater treatment plant.
04/08/99 - Acknowledgment by DWQ of receipt of $1592.84 for payment of Civil
Penalty, case number LV 99-080.
04/19/99 - Engineers Certificate from McGill Associates for improvements at the
wastewater treatment plant.
04/23/99 - Transmittal of Notice of Violation and Assessment of Civil Penalty, case
number LV 99-13, in the amount of $1566.70 for one NPDES violation for
exceeding flow and two for exceeding the Fecal Coliform limit.
05/13/99 - Acknowledgment by DWQ of Request of Remission of Civil Penalty, cases
LV 99-114 and LV 99-131.
05/14/99 - Acknowledgment by DWQ for receipt of Application for a Special Order by
Consent (SOC).
-6

05/28/99 - Transmittal of Notice of Violation and Assessment of Civil Penalty, case
LV 99-210, in the amount of $1,416.79 for one violation for exceeding the
NPDES flow limit.
06/04/99 - Acknowledgment of a Technical Assistance visit by Asheville Regional
Office.
06/11/99 - Transmittal of Notice of Violation and Assessment of Civil Penalty, case
LV 99-224, in the amount of $1,416.79 for one violation for exceeding the
NPDES flow limit.
06/28/99 - Compliance Evaluation Inspection indicating that facility is in compliance.
07/01/99 - Acknowledgment of receipt of Request for Remission of Civil Penalty for
cases LV 99-224 and LV 99-210.
07/20/99 - Acknowledgment of a Technical Assistance visit by Asheville Regional
Office.
08/05/99 - Memorandum from DWQ Environmental Chemist to Asheville Regional
Office outlining the civil assessments against the town of Bakersville from
May 1998 through March 1999.
10/06/99 - Memorandum to Asheville Regional Office outlining the Insteam Assessment
for SOC Request by the town of Bakersville.
05/23/00 - Notification for DWQ Technical Assistance of Certification classifying
Bakersville as a Class 2 facility and informing the town they must have an
Operator in Responsible Charge/Back up Operator.
03/02/00 - Town received SOC.
06/07/00 - Compliance Evaluation Inspection indication that the facility is in compliance.
-7

INFILTRATION/INFLOW EVALUATION
Infiltration and inflow (I/I) are groundwater and rainwater respectively, entering a
sewer system through cracked and broken pipes, storm drains and various types of direct
connections. Sewer systems can be expected to fail in time, but because they are
underground, signs of deterioration are not readily apparent until there is a major failure.
Pipe failures start with cracking, lateral deflection, crown sag and offset joints as well as
deteriorated mortar and exposed reinforcing. Besides failure, systems are also affected
by storm drains and other tie-ins. Proper sewer evaluation and maintenance help
municipalities identify the condition of their sewer system and eliminate potential sources
of trouble. If these sources can be eliminated in a timely manner, problems such as
overloaded treatment plants, pump stations, and collection lines can be avoided.
Infiltration is generally considered to be a result of groundwater intrusion into the
system. During high groundwater conditions, portions of a system may be inundated,
allowing groundwater to enter through cracks, holes and bad joints. This is referred to as
wet weather infiltration. Even during dry conditions when the groundwater table is low,
portions of a system can be inundated. Extraneous flow during these conditions is dry
weather infiltration. As high groundwater conditions can be expected for several
consecutive months, a wastewater treatment plant must have the capability to treat the
flow expected during these times. This includes the ability to handle peak flows as well
as having adequate hydraulic detention capabilities.
Inflow is rainfall related. The increase in flow from a ram event may last for
several hours or for several days depending upon the storm event, sources of inflow, or
the size and condition of the collection system. Inflow can adversely affect the system in
two ways. The peak flow associated with a storm event can overload the collection
system and plant causing overflows, spills or washouts. Also, the treatment plant must
be designed to have sufficient tank volume, aeration, etc. to handle the extraneous flow
associated with inflow on a daily and monthly basis.
Average Daily Expected Flow
The theoretical flow generally consists of domestic, commercial, and industrial
wastewater. In calculating flow, data from water records were utilized. The average
daily expected flow value was computed by subtracting a fifteen (15) percent
consumptive loss from the total water sold to the customers in town. There are
approximately 170 customers who are provided central collection and treatment service.
8

All customers are either residential or light commercial. According to the water and
sewer records analyzed and telephone conversations with the town's personnel, the
average theoretical flow to the treatment plant should be approximately 26,000 to 56,000
gallons per day (gpd).
The town of Bakersville operates three (3) parallel wastewater treatment plants on
one (1) site with a permitted flow of 75,000 gpd. The average flow for the observed
period was 79,300 gpd. A difference between the average expected theoretical flow and
the average daily flow recorded at the treatment plant suggests that there are
inflow/infiltration problems and/or discrepancies in the metering/recording/billing
process.
Dry Weather Infiltration
According to EPA guidelines, infiltration is considered excessive if it exceeds 3,000
gallons per day per inch mile of pipe. Bakersville has approximately 30.93 inch miles of
pipe in its collection system. To meet EPA's criteria, infiltration into the system would
be in excess of 140,000 gallons per day.
Dry weather infiltration is that flow entering the system during periods of dry
weather, when the ground water table is low, generally five (5) days or more following a
rainfall event. For this evaluation, the month of January 2001 was utilized because there
were only two rainfall events during the month and only 0.06 inch of rain during the time
selected analysis period. Comparing the flow from the Daily Monitoring Reports (DMR)
as shown on pages ten (10) and eleven (11) to the expected daily flows indicates that a
dry weather infiltration rate is less than 4,000 gallons per day (GPD) or approximately
130 gallons per inch mile of pipe.
Wet Weather Infiltration
Wet weather infiltration was estimated based on a review of the plant's daily
monitoring records compared with available rainfall records and a projection of average
daily expected flow at the plant. It is ideal to estimate wet weather infiltration during
periods of high groundwater. Records for late April, early May, 2000, were utilized (see
pages twelve (12) and thirteen (13)). An examination of records during periods of
extended rainfalls and when the water table would be expected to be high indicated that
wet weather infiltration at Bakersfield's treatment plant was approximately 44,600
gallons per day. Bakersville's waste treatment plant is permitted for 75,000 gallons per
day.
9

r
4rorn Jan. Wa.Gr Town of Bakersviile
Sr dOf\ Dry Weather Infiltration -January 2001
Day
Plant
Flow
Expected
Flow
(MGD)
Difference
(MGD)
Rainfall
(IN)
Dry Weather
Infiltration
(MGD)
Difference
(MGD)
Avg.Dry
Infiltration
Inflow
(MGD)
(MGD)
January 1
0.050
,_0.047
0.003
0.00
0.003
0.003
0.003
2
0.050
0.047
0.003
0.00
0.003
0.003
0.003
3
0.046
0.047
-0.001
0.06
-0.001
-0.001
-0.001
4
0.063
0.047
0.016
0.00
0.016
0.016
0.016
5
0.053
0.047
0.006
0.00
0.006
0.006
0.006
6
0.048
0.047
0.001
0.00
0.001
0.001
0.001
7
0.048
0.047
0.001
0.00
0.001
0.001
0.001
8
0.048
0.047
0.001
0.00
0.001
0.001
0.001
9
0.053
0.047
0.006
0.00
0.006
0.006
0.006
10
0.047
0.047
-0.000
0.00
-0.000
-0.000
-0.000
11
0.057
0.047
0.010
0.00
0.010
0.010
0.010
12
0.055
0.047
0.008
0.00
0.008
0.008
0.008
13
0.049
0.047
0.002
0.00
0.002
0.002
0.002
14
0.049
0.047
0.002
0.00
0.002
0.002
0.002
15
0.049
0.047
0.002
0.00
0.002
0.002
0.002
16
0.049
0.047
0.002
0.00
0.002
0.002
0.002
17
0.058
0.047
0.011
0.00
0.011
0.011
0.011
_ 18
0.054
0.047
0.007
0.00
0.007
0.007
0.007
19
0.093
0.047
0.046
2.30 , -
0.046
C0.004 )
4-- - _-- -
Average
Dry Weather
Infiltration,
MGD •
20
0.108
0.047
0.061
0.00
0.061
-
21
0.108
0.047
0.061
0.00
0.061
22
0.108
0.047
0.061
0.00
0.061
23
0.074
0.047
0.027
0.00
0.027
24
0.060
0.047
0.013
0.00
0.013
25
0.057
0.047
0.010
0.00
0.010
26
0.078 ,
0.047
0.031
0.00
0.031
27
0.045
0.045
0.047
-0.002
0.00
-0.002
28
0.047
-0.002
0.00
-0.002
29
0.045
0.047
-0.002
0.00
-0.002
30
0.061
0.047
0.014
_
0.00
0.014
31
0.054
0.047
0.007
0.00
0.007

0.12
0.1
2
0.08
0
0.06
0.04
TOWN OF BAKERSVILLE
Dry Weather Infiltration -January 2001
r
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Date
2.6
2.4
2.2
2
1.8
1.6
1.4
1.2
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0.8
0.6
0.4
0.2
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Rainfall - Inches
u ACTUAL FLOW - MGD
o EXPECTED FLOW - MGD
A RAINFALL -IN

rtko bolt, Town of Bakersville
0 Wet Weather Infiltration - April/May 2000
,I
Day
Plant
Flow
(MGD)
Expected
Flow
(MGD)
Difference
(MGD)
Rainfall
(IN)
Wet Weather
Infiltration
(MGD)
Avg.Wet
Infiltration
Inflow
(MGD)
(MGD)
April 25
0.079
0.026
0.053
0.30
26
0.089
0.026
0.063
0.20
27
0.083
0.026
0.057
0.00
28
0.076
0.026
0.050
0.00
29
0.105
0.026
0.079
0.00
30
0.105
0.026
0.079
0.00
May 1
0.105
0.027
0.078
0.00
2
0.091
0.027
0.064
0.00
3
0.080
0.027
0.053
0.00
0.0530
4
0.076
0.027
0.049
0.00
0.0490
5
0.075
0.027
0.048
0.00
0.0480
6
0.068
0.027
0.041
0.00
0.0410
7
0.068
0.027
0.041
0.00
0.0410
8
0.068
0.027
0.041
0.00
0.0410
9
0.074
0.027
0.047
0.00
0.0470
10
0.072
0.027
0.045
0.00
0.0450
11
0.072
0.027
0.045
0.00
0.0450
12
0.070
0.027
0.043
0.00
0.0430
13
0.074
0.027
0.047
0.00
0.0470
14
0.074
0.027
0.047
0.00
0.0470
15
0.074
0.027
0.047
0.00
0.0470
16
0.067
0.027
0.040
0.00
0.0400
17
0.069
0.027
0.042
0.00
0.0420
18
0.078
0.027
0.051
0.00
0.0510
19
0.064
0.027
0.037
0.00
0.0370
20
0.063
0.027
0.036
0.00
0.0360
21
0.063
0.027
0.036
0.00
0.0360
22
0.086
0.027
0.059
0.00
0.0590
23
0.069
0.027
0.042
0.00
0.0420
24
0.112
0.027
0.085
2.00>
0.04461905-,
<Avg Wet Infiltration
25
0.246
0.027
0.219
2.25
26
0.118
0.027
0.091
0.00
27
0.096
0.027
0.069
0.00
28
0.096
0.027.
0.069
0.00

0.3
0.25
0.2
0
2
0.15
0
u_
0.1
0.05
TOWN OF BAKERSVILLE
Wet Weather Inflow - May/June 2000
2.6
— 2.4
— 2.2
■
-- 2
— 1.8
1.6
1.4
1.2
O O O O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 OO O O
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5 6 7 8 9 1011 1213141516171819202122232425262728293031 1 2 3 4 5 6
Date
Rainfall - Inches
ACTUAL FLOW - MGD
o EXPECTED FLOW - MGD
A RAINFALL - IN

Based on the size and amount of pipe in Bakersville's collection system,
infiltration is not excessive. Its wet weather infiltration rate of 44,600 gallons per day
would equate to approximately 1440 gallons per day per diameter inch mile. Worthy to
note, though, is the fact that present wet weather infiltration accounts for almost 60
percent of the facility's design flow.
Inflow
In order to estimate the amount of inflow entering Bakersville's system, the
plant's daily monitoring records and twenty-four hour flow charts were reviewed and
compared with available rainfall data. Rainfall events following dry periods were noted
and the corresponding daily monitoring records examined. Rapid increases and decreases
in flow were considered to be indicative of rainfall induced inflow. Increased flow which
remained over a sustained time was assumed to be rainfall -induced infiltration. From the
available records, it appears that an increase of approximately 123,000 gallons per inch of
rain can be attributed to the flow into the plant (see pages fifteen (15) and sixteen (16)).
- 14-

Wet
Towr, of Bakersville
Weather Inflow - May/June 2000
Day
Plant
Flow
Expected
Flow
(MGD)
Difference
(MGD)
Rainfall
(IN)
Wet Weather
Infiltration
(MGD)
0.0480
Avg.Wet
Infiltration
Inflow
Inflow
(MGD)
(MGD)
(MGD)
May 5
0.075
0.027
0.048
0.00
6
0.068
0.027
0.041
0.00
0.0410
7
0.068
0.027
0.041
0.00
0.0410
8
0.068
0.027
0.041
0.00
0.0410
9
0.074
0.027
0.047
0.00
0.0470
10
0.072
0.027
0.045
0.00
0.0450
11
0.072
0.027
0.045
0.00
0.0450
12
0.070
0.027
0.043
0.00
0.0430
13
0.074
0.027
0.047
0.00
0.0470
14
0.074
0.027
0.047
0.00
0.0470
15
0.074
0.027
0.047
0.00
0.0470
16
0.067
0.027
0.040
0.00
0.0400
17
0.069
0.027
0.042
0.00
0.0420
18
0.078
0.027
0.051
0.00
0.0510
19
0.064
0.027
0.037
0.00
0.0370
20
0.063
0.027
0.036
0.00
0.0360
21
0.063
0.027
0.036
0.00
0.0360
22
0.063
0.027
0.036
0.00
0.0360
23
0.069
0.027
0.042
_ 0.00
0.0420 -
,
24
0.112
0.027
0.085
2.0V
0.0427 -
0.0473
25
0.246
0.027
0.219 -
2.25--'
0.0377
0.1813
I
26
0.118
0.027
0.091
• 0.00
0.0377
0.0533
i
27
0.096
0.027
0.069
0.00
0.0377
0.0313
28
0.096
0.027
0.069
0.00
0.0377
0.0313
29
0.096
0.027
0.069
0.00
0.0377
0.0313
!
30
0.099
0.027
0.072
0.00
0.0377
0.0343
,
31
0.094
0.027
0.067
0.00
0.0377
0.0293
1
0.085
0.030 •
0.055
0.00
0.0377
0.0173
,
2
0.091
0.030
0.061
0.00
0.0377
0.0233
3
0.082
0.030
0.052
0.00
0.0377
0.0143
4
0.082
0.030
0.052
0.00
0.0377
• 0.0143
1
5
0.082
0.030
0.052
0.20
0.0377
0.0143
/
6
0.070
0.030.
0.040
0.00
0.5229
< Total Inflow
4.2500
<Total Rain
0.1230
<MG/ln_Rain

0.3
0.25
0.2
0
0
0.15
0
0.1
0.05
0
TOWN OF BAKERSVILLE
Wet Weather Infiltration - April/Mayl 2000
INN
-
I
.-1
'
-
,
II
o
1
,, ,
, , ,
is
�o
00
4
Q00
A
0Q0o0
<LO<
0044
Akt-
AAA
®
AAAAAA�
ii
1
e
IA
26 27 2829 30 1 2 3 4 5 6 7 8 9 1011 12 1314 15 16 171819 20 2122 23 24 25 2627 28
Date
2.6
2.4
2.2
2
1.8
1.6
1.4
1.2
1
0.8
0.6
0.4
0.2
0
Rainfall - Inches
a ACTUAL FLOW - MGD
o EXPECTED FLOW - MGD
A RAINFALL - IN

SUMMARY UNIT PROCESS EVALUATION
AND OPERATION AND MAINTENANCE
The purpose of this section is to review each unit within a treatment facility and
identify problems associated with them. The MCI team found that, overall,
Bakersville's wastewater treatment plant is experiencing some problems.
Equalization Basin/Influent Pump Station
Wastewater is pumped into Bakersville's wastewater treatment plant from an
onsite equalization basin. The pumps in the basin are rated at eighty (80) gallons per
minute (gpm). However, analysis of the existing head conditions on the pumps indicate
that they are pumping at a higher rate, about one hundred seventeen (117) gpm. The two
(2) pump independently of each other into a splitter box. Therefore when both are
pumping, their combined flow is about two hundred, thirty-four (234) gpm. Even though
varying amounts of flow are returned to the equalization basin, the plant can not
hydraulically handle the flow from these pumps. When a substantial rainfall event
occurs, the operator has to continually adjust the weirs in the splitter box to prevent an
overflow of the three treatment plants. Wastewater treatment plants are generally
designed to operate at flows two and one-half (2 '/2) times their designed flow for short
periods of times. That flow would be approximately 130 gpm in Bakersville's case. An
Operation and Maintenance (O&M) manual for this type of plant indicates that it is
designed to treat short, high flow situations at approximately one and one half (1 '/2)
times (approximately 78 gpm) of the designed flow. Therefore it is easy to understand
why problems are occurring.
The station appeared to be maintained well with only one maintenance item noted.
That was the equalization basin had a considerable concentration of plastics, rags, large
solids, etc. floating on its surface. The equalization basin serves as inlet structure and is
equipped with a basket strainer/bar screen at its entrance. The strainer/screen does not
have a top on it and when the liquid level in the basin submerges the screen, the solids
simply float out.
The treatment facility is not equipped with a grit chamber. Grit entering a
wastewater treatment system not only reduces the life of mechanical devices within a
facility, but once into the system, it occupies space originally designed for treatment of
wastewater. If not properly removed, the grit passes through the influent pumps and
settles in the downstream treatment tanks. The usual method of its grit removal is to
dewater (pump out) the tank(s) and remove it by hand. This procedure not only costs both
time and capital, but in addition, the unit(s) taken out of service can not be utilized to
treat wastewater, possibly jeopardizing the town's NPDES discharge limits.
-17-

Splitter Box
Flow is split and discharged into the three (3) aeration basins by means of a
splitter box. After rainfall events, the operator has a difficult time preventing the plant
form overflowing. Flow is regulated to the basins by three (3) adjustable rectangular
weirs controlled by three (3) rising stem wheels. The height of each of the weirs controls
both the amount of wastewater entering each of the plants and the amount returned to the
equalization basin. The amount of liquid returned to the equalization basin is controlled
by a fixed rectangular weir located at the face of the splitter box. As the three (3)
adjustable rectangular weirs are raised, the water level in the splitter box rises and more
wastewater flows over the fixed weir. Another problem noted with the flow splitter box
was that under normal flow conditions, the flow split into the treatment plants is difficult
to control. The independent force mains from the influent pumps enter the box in the
bottom of the structure. There is no baffle to break up the flow from the pump
discharge(s). When the pumps are operating separately, the water boils on the respective
side of the box in which the discharge is located. With a raised water level at the boil, the
gates near the discharge receive more flow. Only when both pumps operating
simultaneous is the flow evenly split.
The facility can be operated at high flows. Extended aeration plants are designed
to hold wastewater in its basin(s) for a period of twenty-four (24) hours. However, under
proper condition, treatment can be obtained in as little as eighteen (18) hours. Possible
problems that might make it more difficult for Bakersville's plant to operate with less
than twenty-four (24) hours treatment are the type of and depth of its clarifiers and the
small sludge holding tanks. To counteract these problems, the operator is holding the
solids in the aeration basin rather than wasting them to the sludge holding tanks. By
doing this, more problems can be encountered. At current and design conditions, the
combined blower capacity is marginal for treatment and airlift pump operation and
certainly is inadequate at the higher solids loading. Another problem that might be
anticipated is when heavy hydraulic loadings, associated with rain fall events occur, and
the solids in the basin are at high levels, the solids can more readily be washed from the
plant. Also the clarifiers are relatively shallow and solids can easily be washed from the
plant with heavy hydraulic loading.
Process Testing
In order to obtain peak performance of a wastewater treatment plant, an operator
must know certain mathematical values associated with the plant. These values change
as the influent wastewater changes and as daily operational activities are performed at the
plant. Among these are the Food to Mass Ratio (F/M), Sludge Retention Time (SRT),
Settleability, and solids to be wasted. Simply explained the F/M is a ratio of the amount
- 18-

. •
of food present in wastewater to the number of bacteria. As with any environment, a
balance of food and the number of those that consume it must be maintained. If too
much food is present, it is not utilized and part of it passes from the system. Too little
food, the organisms die of starvation and the system becomes much less efficient.. With
Bakersville's BOD5 (food) of 200 mg/1 and an average of 79,300 gallons per day influent
flow, the F/M in all three (3) basins is above the acceptable design range. The reason for
the high F/M is that the solids level in the basins is probably too high.
The SRT is the theoretical time that food and bacteria (solids) remain in an
aeration basin for treatment. If the solids remain too briefly there are problems. If they
remain too long, another set of problems develop. The average time that they should
remain in a facility such as Bakersville's is 20 to 30 days. The SRT at the time of the
MCI for Bakersville's plant was about 21 days. This value is probably misleading in this
case. The SRT is calculated using the level of solids in the Mixed Liquor Suspended
Solids and Mixed Liquor Suspended Volitile Solids. When both are high, the value of
the SRT remains low. Solids (floc) remaining in a system for too long are broken or
sheared by the action of the aeration into smaller particles. The smaller the floc, the
harder it is to settle and remove from the effluent. If solids remain too long, they can
completely oxidize and become an ash that floats on the surface of clarifiers. Ash is
almost impossible to settle in the clarifier and passes easily into the effluent.
The Settleability test mimics the Mixed Liquor Suspended Solids (MLSS) ability
to settle in a clarifier(s). The test can be performed by placing 1,000 ml of MLSS into a
graduated cylinder. The solids are allowed to settle for 30 minutes. The level of settled
solids are recorded every five minutes for the duration of the test. Using the level of
settling after 30 minutes, a Sludge Volume Index (SVI) is computed. The SVI for all
aeration basins exceeded the acceptable design value. The settleability test suggested that
there were too many solids in the aeration system, a common problem with many
wastewater treatment plants. Knowledge of the level of solids in a plant is essential for
an operator to determine process values. When the plant was first visited, the operators
had to rely on results from a certified lab that may not be made available to them for
several days. By the time the results are obtained the solids levels could change. It is
suggested the town purchase a centrifuge to allow the operator to determine the level of
solids in the facility as necessary.
Knowing the values for influent BOD5, influent flow and MLSS concentrations,
the operator can compute the volume of sludge to be wasted daily. Solids management is
probably the most important aspect of wastewater treatment. Manipulation of the solids
regulates the F/M, SRT, and in most cases, the settleability. One thing that should be
noted with process control parameters is their values should be used collectively and an
operator should not rely on just one entity to operate the facility.
- 19 -

Aeration Basins
The three (3) aeration basins do not provide the capacity required for Bakersville's
average daily flow of 79,300 gallons per day as designed. However, the facility should
function at these flows. Extended aeration treatment plants are normally designed to treat
the wastewater for a period of twenty-four (24) hours, but can provide proper treatment in
as few as eighteen (18) hours.
Calculations in the Appendix indicate that with two blowers per basin there is
marginal air for the treatment facility for biological survival in the aeration tanks,
treatment of sludge in the holding tanks and to operate the various air lift pumps of the
facility. These calculations could not be substantiated because at the time the audit was
performed, a rain event had occurred. The ORC had to turn the blowers off in an effort
to maintain solids in the plant. The organisms in the plant continue to use the available
oxygen in the plant after blower shutdown. Therefore an accurate oxygen profile could
not be performed at the facility at that time, but as a rule, a level of approximately 2.0
mg/1 DO is suggested. Another item that should be addressed concerning blowers is the
mixing of solids within the aeration basin and digester. Twenty-five (25) to thirty (30)
Cubic Feet per Minute (cfm) per 1000 cubic feet basin volume is required to keep the
solids in suspension. One blower produces 100 cfm. As with the biological treatment,
there is insufficient air to keep solids properly suspended.
The Mixed Liquor Suspended Solids were higher than suggested for the type of
treatment plant that Bakersville has. Some plants operate at higher MLSS levels than
design materials suggest. That level is within a range of 1,500 to 5,000 mg/1 with
approximately 2,500 mg/1 generally accepted as the level that most plants operate.
Aeration Basin "1" had approximately 4,800 mg/1, Basin "2" approximately 4,100 mg/1
and Basin "3" approximately 4,800 mg/1. Using these numbers, approximately 86 dry
pounds of solids or approximately 1,100 gallons of Return Activatited Sludge (RAS)
should have been wasted from the aeration basins at the concentrations that they were
being returned at the time of the audit. When excess solids, Waste Activated Sludge
(WAS), are removed from the system, they should not be removed during one wasting
session. Rather, solids should be removed daily and the digester supernated as needed
until the proper level of solids remains in the aeration basin(s). As wasting is
accomplished, volumes of solids to be wasted daily should be calculated as the MLSS
concentrations in the aeration basin (s) change. Records of the MLSS concentrations
should be retained as the solids are being wasted. In conjunction, plant performance
should be noted. The Operator In Responsible Charge (ORC) will then know what level
the plant performs most efficiently.
; f 1 vh
- 20 -

Clarifiers
According to calculations, the clarifiers are sized to handle current average daily
flow and designed flow. At combined pumped flows, the calculations indicate that the
clarifiers can not handle the spike flows.
The Returned Activated Sludge (RAS) are the solids that settle in the
clarifier(s). Normally the desired RAS concentration returned to aeration
basins is 7,000 to 8,000 mg/1. Balcersville's RAS concentration in the three (3) clarifiers
was approximately 11,000, 5,400, and 11,900 mg/1 respectively . Normally during an
audit, a columnar sample of each clarifier is taken with a "sludge judge" to determine its
"sludge blanket" level. A sludge blanket should form with a definite strata between the
settled solids and the supernatant (clear water at or near the surface of the clarifier). In
the type of clarifier at Bakersville, the sludge blanket should be maintained three (3) to
four (4) feet deep. This sample was not taken at the time of the audit due to the unsettled,
stirred condition of the plant. In a settled condition, the ORC should check the clarifiers
to ascertain the blanket level. In addition to checking the sludge blanket, the bottom of
the clarifiers should be checked to determine if any black solids are present. They have
presented problems in other clarifiers of similar design. A possible reason that the black
solids could be in the bottom of the clarifier is that the RAS rate is too high. If the rate is
too high, short circuiting between the inlet of the clarifier and the air lift pumps can
occur. If this is happening, MLSS from the aeration basin is drawn directly to the air lift
intake and it, along with only clarifier solids, are being returned.
The black solids can cause problems with plant efficiency. When settled solids
turn black, they are septic. Certain organisms in a zero oxygen environment cause
fermentation of the solids. As a result, methane and carbon dioxide gases are released
into the water. Before the solids become septic, they are usually in a zone above the
black solids where the oxygen level is low (less than 0.5mg/1). If these solids are not
returned to an area of higher oxygen levels (aeration basins), another type of bacteria that
thrives in low oxygen environments digest the solids and as a byproduct of their
respiration nitrogen gas is produced. This process is called Denitrification. The gases
produced by either/or Fermentation and Denitrification become entrained in the solids
and cause them to float to the surface of the clarifier and ultimately portions can enter the
effluent.
Chlorine Contact Chamber
The chlorine contact chamber is a converted 3,500 gallon septic tank that has
serpentine walls. At design and average daily flows, the detention time is sufficient to
accomplish fecal coliform kill. At combined pump flows it is not. Thirty minutes
-21 -

detention is suggested for design purposes. It is suggested that the chamber be inspected
periodically to determine if solids have built up in the basin. If so, they can be removed
relatively easily, preventing higher solids and BOD5 levels.
Dechlorination Chamber
Like the chlorine contact chamber, the dechlorination chamber is a 3,500 gallon
converted septic tank. Its function is to provide a chamber in which any residual chlorine
is neutralized prior to the effluent being discharged into the receiving stream. This
chamber can also collect solids. It should be checked for solids as the cholrination
chamber.
Stillling Well
The final unit in the treatment train is a stilling well. This chamber provides a
small area where solids in the effluent have a final chance to settle out.
Digester/Sludge Holding Tank
A digester/sludge holding tank is located on the end of each treatment module.
Two (2) of the treatment trains has a tank having a capacity of approximately 3,000
gallons, the final train has one with approximately 1000 gallons. The sludge is stored in
the digesters until it is deposited into a tanker truck. The sludge is then hauled offsite for
disposal.
Calculations indicate that the two digester/sludge holding tanks have
approximately 16 days solids detention, if they are thickened to two and one-half (2T/2)
percent. Based on theoretical sludge production, the entire contents of the digesters
should be removed at least twice a month. The reason that the sludge should be hauled
twice a month is that the calculations are based on the assumption that the solids be
concentrated to two and one-half (21/2) percent. That concentration probably will not be
obtained consistently and any concentration less than that shortens the detention time of
the tanks. For example, there is approximately two and one-half (2 1/2) days holding
capacity if the theoretical sludge to be wasted is wasted at the same concentration as that
of the RAS that was being returned at the time of the MCI audit. Record keeping is
important in solids handling at the treatment facility. The dates of removal, quantity of
liquid removed, the percent solids, any laboratory test on the biosolids removed and any
requirements outlined in the town's permit should also be kept as a permanent record.
Requirements for sludge disposal is also included in the Appendix of this report.
- 22 -

BUDGET AND USER CHARGE ANALYSIS
A review of the town of Bakersville's user charge rates and budget was conducted.
The purpose was to determine whether or not the user charge system has an adequate
financial management system which accurately accounts for revenues and expenditures
for operation, maintenance and replacement for the wastewater treatment system.
Based on the user charge rates and a review of the water rates and treatment plant
monitoring records, approximately $110,000.00 was budgeted in fiscal year 2001 with
the sewer department to receive $68,678.00. Of that more than thirty-five (35) percent or
almost $25,000 was budgeted to retire bond payments. It does not appear that the
remainder is sufficient to support the entire sewer infrastructure. Further, to provide
major replacement/repair of equipment, for sewer rehabilitation or funds, for any major
sewer related undertaking, the town will need additional funds. The town should perform
an analysis to determine the potential of the system to generate revenue and compare that
to the total cost of operation of the wastewater facility and maintain the system. This
should be done on a regular basis.
Federal and State funds for infrastructure(e.g. wastewater treatment facilities) have
become limited. It is suggested that the town continue to use wastewater user charges
revenue exclusively to operate, maintain, and replace the system as required.
- 23 -

Jul-20-01 09:52A BAKERSVILLE TOWN HALL
1 704 688 2745 P_02
TOWN OF BAKERSVILLE
rirSAGES
MONTH II YEAR
JANUARY 2000
FEBRUARY 2000
MARCH 2000
APRIL 2000
MAY 2000
JUNE 2000
JULY 2000
AUGUST 2000
SEPTEMBER 2000
OCTOBER 2000
NOVEMBER 2000
DECEMBER 2000
JANUARY 2001
FEBRUARY 2001
MARCH 2001
.AMMO( N
958,614—�� gooGPQ
1,180,946-A4,190 GPQ `' 4 '8;3
966,50031, i gocP� `a4��o3
925,650 30, 955 Gt-- 2G6 vie
1,001,018 3z, ZA 27 44."
1,058,461 as, z`a°c"°�'�.. �g1aD
960,890 31, uvt. c Pow �• yc� 3 p
1,569,892 5©,L4o6i°�—
1,140,212 38 bc�a G� _ _ __ .j �'61b
1,096,141 35",aGocP4 301054
977,603 1a, roo 6Pc `.---- 2d7 i
956,208 358" 6Pg ZG 11
1,727.618 6 ta3•4 j_5S73" Pa.
1,129,808 qa, 3 5o. --'-"" 3
986,438 31, gz.J �r---- 1°31 1

CONCLUSIONS AND RECOMMENDATIONS
A Municipal Compliance Initiative (MCI) audit was performed for the town of
Bakersville to evaluate its wastewater system. The evaluation included (1) a
determination of the status of the wastewater treatment plant's current NPDES permit
requirements. A comparison, expressed as percent of limit, was made for Flow, BOD5,
TSS, and Fecal Coliform; (2) a table top Inflow/Infiltration (UI) analysis. The analysis
was based on available records rather than conducting field work; (3) an evaluation of
both the physical condition and equipment to determine the plant's ability to meet the
requirements of the NPDES permit; (4) a review of the sewer budget and the town's user
charge to determine their adequacies; (5) an analysis of the performance of the treatment
facility at current and design conditions, and (6) staffing requirements for the facility.
Based on these analyses the following conclusions and recommendations are made:
1. Bakersville's primary problem appears to emanate from Inflow/Infiltration (UI).
To combat UI, an equalization basin with pumps that serve as influent pumps to
the wastewater treatment plant was constructed in the 1990's. When a significant
rainfall event occurs, the influent pumps hydraulically overload the treatment
facility, causing it not to function properly. The high flows disturb the solids in the
plant and they are "washed" from the plant into the receiving stream. With the
present UI problem observed at the time of the audit, there is little that can be done
with hydraulic overloading. After a 1.8 inch rain, the three treatment trains were
only inches from overflowing while the liquid depth in the equalization basin
increased. It is strongly suggested that Bakersville locate and repair the source(s)
of the UI . Calculations indicate that wet weather infiltration is a problem but
something the facility should be able to handle. Inflow on the other hand appears
to be the major problem. The calculations indicate that under certain condition as
much as 123,000 gallons of ground or rain water enter the system for each inch of
rain.
2. Grit is a problem for virtually every wastewater treatment plant. If not removed, it
generates a myriad of problems in the facility. Its abrasive properties diminish the
service life of all mechanical equipment with which it comes in contact. When it
does collect in the treatment units, it is a very labor intensive task to remove.
Further, it occupies space dedicated for waste treatment. The town should
investigate the possibilities of installing a grit chamber to insure that the maximum
quantity of grit is removed.
3. A strainer basket/bar screen was designed at the influent of the equalization basin to
- 24 -

remove large solids, grease balls and plastics from the waste stream. During rainfall
events, the depth in the equalization basin increases and submerges the screen. The
strainer basket/bar screen does not have a top and the materials caught on it simply float
or are washed into the equalization basin. The floatables have to be removed by
skimming them from the surface with a net. This is an added maintenance problem. It is
suggested that some type of cover be installed on the device.
4. The splitter box will split flow but is totally dependant upon constant adjustment by the
operator. The flow split is obtained by observation and is just a guess. To compound the
problem, the quantity of wastewater introduced into each of the three (3) plants is
dependent upon the pumping sequence of the influent pumps. A possible solution that
could reduce operator involvement is to install baffles or flow diffusers in the box,
distributing the flow more evenly to the effluent weirs of the box.
5. It is important that the essential equipment and supplies be available to perform the
necessary sampling, testing, monitoring and maintenance. It is recommended that the
town purchase, if it is not already in its inventory, a "sludge judge" for measuring sludge
depths in the clarifier, a centrifuge to determine the solids levels in the plants, a Dissolved
Oxygen (DO), and pH meter, and graduated cylinders for running settleability tests. The
sludge depths in the clarifiers should be measured and recorded every day. Generally, the
blanket should not exceed three to four feet in this particular type of facility. The ORC
should note that different types of plants operate more efficiently at different blanket
levels. The DO should be checked and recorded daily for the aeration basins, clarifiers
and effluent. The pH should be checked and recorded daily for the influent, aeration
basins, and clarifiers. A minimum of one settleability test per week per basin should be
performed and the results recorded. A schedule of process monitoring should be
implemented and maintained similar to the one outlined in the appendix.
6. When aeration basins are hydraulically overloaded, it can be difficult to maintain proper
operational levels such as MLSS, DO, proper air for mixing the solids in the basins, SVI,
Sludge Age, etc. These properties however must be monitored, recorded, adjusted as
necessary to insure the optimum operation of the facility. The blower capacity at the
facility is marginal. There are air leaks in the units that should be repaired. Due to
oxygen depletion, the work should be planned to minimize the time that the blowers
would be off line.
7. Solids management is one of the most important factors in the operation of a waste
treatment facility. Plant performance and effluent quality are directly affected by the
level of solids and the time they are exposed to treatment. A waste treatment plant is a
living ecosystem. As with any living system, it must have certain elements to survive.
Among these are oxygen and food. The blowers at the plant provide the oxygen.
Calculations indicate that the existing blowers are marginal in two (2) of the units and
insufficient in the other. As food (generally BOD5) enters the plant, bacteria attach to it
and form floc. Floc is the solids found in a waste treatment plant. The plant is designed
- 25 -

to detain these particles within the system for proper treatment. Solids should be
maintained within an optimum range for a particular plant design. That level for
Bakersville should be around 2500 mg/1. The solids level in the aeration basins are well
above this level, ranging from 4,100 to 4,800 mg/1. Levels this high are usually
associated with old, slow settling sludge. This was confirmed through process tests
performed during the audit. Loss of solids over the effluent weirs can readily occur under
these conditions. It is suggested that the solids should slowly be reduced to design
standards. The facility should be carefully monitored and records kept to determine at
what level the plant has its best performance.
8. The clarifiers meet the necessary design and average daily flows requirements for
Bakersville's wastewater characteristics. Problems begin to appear when excess flow
passes through the units. The settled solids are disturbed and flow over the effluent
weirs. A second concern with the clarifiers is the clarifier air lift pumps. The pumps
purpose is to return solids at a controlled rate to the aeration basins and may not be
performing properly. The concentration of solids in the RAS is much higher than is
generally expected. The air lift pumps should be removed and checked to insure that they
are operating properly and are set at the proper depths. The clarifiers should then be
cleaned of compacted or black solids in the hopper bottom and the RAS return rate
adjusted to maintain the optimum sludge blanket level.
9. The digester/sludge holding tanks for the facility have a capacity of sixteen (16) days, if
the solids can be thickened to two and one-half (21) percent. It should be pointed out
that many digester/ sludge holding tanks can not obtain the concentration due to the
settling characteristics of the sludge. Lesser concentrations would, of course, shorten the
holding capacity, in days, of the tanks. Bakersville should develop a schedule to remove
the sludge from the digester/sludge holding tanks at least twice a month.
10. Based on records supplied by the town, the collection system does not have excess inflow
or infiltration according to EPA guidelines. However, their guidelines are just that,
guidelines and the flows entering the Bakersville's waste treatment facility due to
Inflow/Infiltration are too high. They completely upset the facility and presents the real
possibility of plant overflows, The town should be cognizant of the fact that
inflow/infiltration in collection systems never improves without repairs or replacement of
pipes and manholes. Rather, as time progresses, the system gets worse. The town
should also be aware that this plant nor any other plant of its size can handle the influent
hydraulic over loading that is occurring. Building a larger plant does not solve the
problem either; it only serves to create an entirely different set of problems. Therefore it
is suggested the town concentrate its efforts and monies into correcting the
inflow/infiltration problem.
11. Records indicate that for the size of the sewer system of the town of Bakersville the
revenue budgeted to it is probably insufficient for its operation and maintenance. It is
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suggested that the town perform an analysis of the actual costs for operating and
maintaining its sewer system. From these results it should make whatever provisions
necessary to properly maintain that system.
12. According to EPA guide lines 1.4 man years (2800 hours) should be dedicated to the
operation of the plant. These hours are explicitly for just the plant and does not include
any work on the collection system. According to the contract operators, approximately
0.52 man years are being dedicated to Bakersville's Wastewater Treatment Plant.
Therefore it is suggested that additional hours be scheduled for the plant and its
operation.
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