NC0024201_2024 Compliance Evaluation Inspection_20240301

March 1st, 2024

Thomas Wrenn
Roanoke Rapids Sanitary District
PO Box 308
Roanoke Rapids, NC 27870

Subject: Compliance Evaluation Inspection
Roanoke River WWTP
NPDES Permit NC0024201
Halifax County

Dear Mr. Wrenn:

On Wednesday, February 27th, 2023, Kevin Fowler conducted a compliance evaluation
inspection of the treatment systems located at Roanoke River WWTP. The purpose of this visit
was to conduct an inspection of the subject NPDES facility. During the inspection, the presence
and cooperation of Steven Lee Ellis, Operator in Responsible Charge (ORC), and Timothy Van
Skipper, Chief Operator, were helpful and appreciated.

The Roanoke River WWTP, located is at 135 Aqueduct Road, Weldon, North Carolina 27890 in
Halifax County. The plant has a Municipal Wastewater Discharge permit.

This NPDES compliance evaluation inspection consisted of the following:
 Review of the NPDES permit.
 Review of the owner/facility information.
 Review of January 2022 – January 2024 monitoring data.
 Review of January 2022 – January 2024 compliance history.
 On-site inspection of the treatment systems; and
 On-site inspection of discharge outfalls

DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Page 2 of 3
Roanoke River WWTP
Compliance Inspection 2024
2
Findings during the pre-inspection file review were:

1. Through NPDES permit NC0024201, Roanoke River WWTP. is authorized to discharge
treated wastewater to the Roanoke River classified C waters in the Roanoke River Basin.
The current NPDES permit was issued effective April 1, 2023, and will expire March 31,
2028. An application for renewal of this permit should be submitted no less than six months
before the expiration of the current permit.
2. The plant provides treatment and discharge of wastewater through outfall pipe 001 to the
Roanoke River. The plant is permitted to discharge at a rate of 8.34 MGD. The system
consists of: bar screen, grit chambers, equalization basin, dual primary clarifiers, dual
trickling filters, three aeration basins, dual final clarifiers, hypochlorite disinfection and
dichlorination system, dual secondary sludge thickeners, three aerobic digesters, sludge
storage tanks, and sludge drying beds.
3. For the review period January 2022 – January 2024, one violation was found for monitoring
frequency for Ammonia. No civil penalty assessment was issued for this violation.

Findings during the inspection were:

4. The operator’s log and supporting analytical documentation were consistent and up to date.
5. DMR reports from June 2023, and February 2023 were brought to be compared to laboratory
analytical results. No discrepancies were found.
6. The facility contains two back-up power generators not covered in the permit. The plant can
run on one of the generators and the other one is a backup. At time the time of the inspection
one of the generators was down for repairs. The generators are tested monthly.
7. At the time of the inspection, two aeration basins, one primary clarifier, and one secondary
clarifier were not in use due to low flow.
8. An effluent pump station is present that is not covered by the permit. Plant staff indicated
that the pump station is only used if the river level is too high for normal plant discharge.
9. EQ basin on site is only used for emergency storage in high flow events. The EQ basin was
empty at the time of the inspection. The basin contains dual pumps.
10. At the time of the inspection, the sludge blanket in one of the dual primary clarifiers was
more than ¼ of the sidewall depth. Plant staff indicated that sludge from the primary
clarifiers is pumped to the anerobic digesters three times a day. The high levels are only
temporary until pumped. The plant also typically only uses one of the dual primary clarifiers
at a time due to low flow. Plant staff indicated that the clarifier used switches monthly.
11. Dissolved oxygen levels in the aeration basin were at 0.56 mg/l. The low levels were
explained by plant staff to be necessary to prevent over nitrification. This would lead to
excess solids leaving the plant. Dissolved oxygen levels are typically higher around 1mg/l.
12. The effluent sampler is located after the dual secondary clarifiers but prior to disinfection.
The plant was told to do this in correspondence with DEQ in 1993. The correspondence
letter which was shown to the inspector during the inspection indicated that this would be the
most accurate sampling location given the plant’s design.
13. The right of way to Outfall 001 was well maintained. No evidence of solids or visible
environmental impacts were noted downstream of the effluent pipe.

DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Page 3 of 3
Roanoke River WWTP
Compliance Inspection 2024
3

If you have questions or comments about the inspection, this report or the requirements to take
corrective action (if applicable), please contact Kevin Fowler at 919-437-0047 or via email at
[e-mail]

Sincerely,

Vanessa Manuel
Water Quality Regional Assistant Supervisor
Raleigh Regional Office

Attachments: EPA Water Compliance Inspection Report

Cc: Laserfische
Steven Lee Ellis (ORC)
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NC0024201 24/02/28 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Roanoke River WWTP
135 Aqueduct Rd
Weldon NC 27890
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/02/28 23/04/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
01:45PM 24/02/28 28/03/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Steven L Ellis,PO Box 308 Ronok Rpd Afs NC 27870//252-536-4884/2525364885 Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Kevin Fowler DWR/RRO WQ/919-791-4200/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
03/01/2024
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
3/1/2024
NPDES yr/mo/day
24/02/28
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lab appeared to be in compliance at time of inspection. Enforcment and violation history was very
good.
NC0024201 17
Page#2
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Permit Expires March 31st, 2028.Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Page#3
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Plant has 2 different methods of grit removal. (Cyclone and Detritor)Comment:
Equalization Basins Yes No NA NE
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Page#4
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Equalization Basins Yes No NA NE
Rarely used. Only used in times of high flow as means of temporary storage. Empty at
time of inspection.
Comment:
Primary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the sludge blanket level acceptable?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Sludge blanket was 4' in a 14' high clarifier. However, plant has 2 clarifiers that can be
used. Plant also pumps sludge to digesters 3 times a day which lowers the blanket
level.
Comment:
Trickling Filter Yes No NA NE
Is the filter free of ponding?
Is the filter free of leaks at the center column of filter’s distribution arms?
Is the distribution of flow even from the distribution arms?
Is the filter free of uneven or discolored growth?
Is the filter free of sloughing of excessive growth?
Are the filter’s distribution arms orifices free of clogging?
Is the filter free of excessive filter flies, worms or snails?
2 Trickling Filters Present.Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Page#5
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Secondary Clarifier Yes No NA NE
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Plant contains 2 secondary clarifiers. Only one in use due to flow. Clarifiers are
rectangular in shape.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
4 Blowers Present. Only 1 or 2 needed to run process. DO level at time of inspection
was 0.56 mg/l. Plant staff indicated that the plant works best when ran at a lower DO.
DO is typically around 1mg/l.
Comment:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Chemical Feed Yes No NA NE
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
Page#6
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Chemical Feed Yes No NA NE
Disinfection-Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Duck weed growing in contact chamberComment:
De-chlorination Yes No NA NE
Type of system ?Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de-chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Sodium BisulfiteComment:
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Anaerobic Digester Yes No NA NE
Type of operation:Floating cover
Is the capacity adequate?
# Is gas stored on site?
Is the digester(s) free of tilting covers?
Is the gas burner operational?
Is the digester heated?
Is the temperature maintained constantly?
Is tankage available for properly waste sludge?
3 Digesters Present. (2 are heated) Gas is used to heat 2 of the digesters.Comment:
Page#7
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Drying Beds Yes No NA NE
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
# Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
# Is the sludge disposed of through county landfill?
# Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Drying beds not used except in extreme circumstance.Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Sampling takes place after secondary clarifier. This is because of guidance from DEQ
in 1993. Documentation provided at plant to prove this.
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Page#8
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Comment:
Solids Handling Equipment Yes No NA NE
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Granville Farm Contract.Comment:
Pump Station - Effluent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Only used if river level is to high.Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Page#9
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0
Permit:NC0024201
Inspection Date:02/28/2024
Owner - Facility:
Inspection Type:
Roanoke River WWTP
Compliance Evaluation
Standby Power Yes No NA NE
Is the generator fuel level monitored?
Diesel fuel supplied by Dixie Oil Company. Generators are ran monthly.Comment:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Most anlysis handled in house (lab #70). Metals, toxcicity, and nirite/nitrate are
handled by meritech (lab #165)
Comment:
Page#10
DocuSign Envelope ID: E3F4A767-CE57-4DFF-955B-CA038DB318F0