NC0024201_Renewal Application_20160923

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Roanoke rapids Sanitary District
September 21, 2016
Mr. Wren Thedford
NC DENR, Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina, 27699-1617
RE: Renewal Request of NPDES Permit Number NCO024201
Roanoke River Waste Treatment Plant
Roanoke River Basin
Dear Mr. Thedford,
P.O. Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870
[phone]
Fax: [phone]
www.rrsd.orQ
RECEIVEDIMCDEORWR
SEP 2 1 2016
V�Iater Quality
permitting Section
The Roanoke Rapids Sanitary District (RRSD) is permitted to discharge 8.34 million gallons per day
(mgd) of treated effluent to the Roanoke River under NPDES Permit No. NCO024201. The NPDES
permit is scheduled to expire on March 31, 2017. The enclosed application is for renewal of the current
permit. In accordance with the requirements of federal (40 CFR 122) and state (15A NCAC 2H .0105(3))
regulations, we are submitting three signed copies of the completed application package and associated
attachments and figures. The application package includes the following information:
1. NPDES Permit Application — EPA Form 2A
2. EPA Form 2A Additional Information (Topographic Map, Process Flow Diagram and Process
Narrative)
3. Priority Pollutant Scan Analyses (three scans) _
4. First Species Effluent Toxicity Tests
5. Second Species Toxicity Tests
6. Biosolids Management Description
7. Technical Memorandum in support of the Reduction of Monitoring Frequency for Exceptionally
Performing Facilities
8. Effluent and stream hardness data
9. Mercury Minimization Plan Summary
At the time of this application submittal, the required second species toxicity testing events have not yet
been completed. The June, July, and August tests have been completed and the results are included in our
application package. The remaining second species tests are currently scheduled to be completed in
September and October 2016., When the second species toxicity test results become available, they will
be forwarded to the Division of Water Resources (DWR) along with revisions to Part E of EPA Form 2A

to include these results. All of the second species toxicity tests will be submitted prior to the current
permit expiration date of March 17, 2017.
In accordance with 15A NCAC 2B .0508(b)(1) and the October 2012 DWR Guidance Document for the
Reduction of Monitoring Frequency for Exceptionally Performing Facilities, the District respectfully
requests a continuation in reduction in frequency monitoring for carbonaceous biochemical oxygen
demand (CBOD5), ammonia, and fecal coliform. Effluent sampling results from the past three years
demonstrate that all state regulatory and guidance requirements have been met in support of this request.
A summary of the sampling data and analysis for the reduction of monitoring frequency is attached to this
application.
Additionally, RRSD respectfully requests that the following issues be addressed in this permit renewal:
• We request that Influent Equalization / Sludge Storage tanks be added to the treatment
components list in. the supplement to the peri it ver sheet as per request by DWl? inspector
Autumn Romanski on 4/2/2015.
• We request that Footnote 1 remain in the permit unaltered.
We request that Footnote 2 — Monthly average effluent CBODs and TSS concentrations shall
not exceed 15% of the respective influent value (i.e., 85% removal is required) — be removed
from the permit. We believe that the additional percentage removal limitation is not
warranted as the facility continuously meets the monthly and weekly average permit limit.
If Footnote 2 is not removed, we request that the language be modified to make an exception
for low influent suspended solids and CBOD events. Our facility has difficulty meeting this
percent removal requirement when influent suspended solids and CBOD concentrations are
extremely low. Thus, we request that Footnote 2 be modified, as follows: Monthly average
effluent CBODS and TSS concentrations,shall not exceed 15% of the respective influent value
(i.e., 85% removal is required). This requirement shall be waived if influent TSS
concentrations are less than 150 mg/7 andlor influent CBOD is less than 100 mg/L.
Reduce the total nitrogen and total phosphorous monitoring frequency from monthly
sampling to once per quarter. Our facility does not discharge into nutrient sensitive waters.
Reduce the chronic toxicity sampling (Ceriodaphnia) from quarterly to annually. We have
been conducting chronic toxicity testing since April 1993. All of our toxicity tests have
passed, including the second species testing with Fathead Minnow.
• A reasonable potential analysis was conducted using data from our Long Term Monitoring
Plan (LMTP) and Priority Pollutant Analysis (PPA) scans. Reasonable potential of the
effluent to violate the new instream dissolved metals standards was not found. The District
has been collecting effluent and receiving stream hardness data, which is included in this
application.
We request the following information as part of the draft permit preparation:
• A copy of the permit Fact Sheet.
• Documentation for any methodology, data, and assumptions used in any permit modification,
including Reasonable Potential Analyses, if applicable.
• A copy of any comments that are received from the public regarding this permit renewal, if
applicable.
s:}wwtp common fileslnpdes p—itkao27 renewal applicationlrrsd_permit renewal 2-7—cover letterdoa Page: 2/3

We very much appreciate the time and effort of the NPDES Unit to consider our requests for this permit
renewal. Please do not hesitate to call myself (252-537-9137) or Mary Sadler with Hazen and Sawyer
(919-755-8560) if you have any questions.
Sincerely,
Roanoke Rapids Sanitary District
R. D ieley Brow, P.E.
Chief Executive fficer
Attachments:
Letter from Contract Laboratory
WET Test Results
Hardness Data
Biosolids Program Description
RMF Technical Memo
MMP Summary
cc: Steven Ellis, ORC
Gregg Camp, RRSD Wastewater Treatment Plant
Jeff Poupart, DWQ, Point Source Branch Chief
Tom Belnick, DWQ, NPDES Unit Supervisor
Mary Sadler, PE, Hazen and Sawyer
File
s:Xwwtp common fileslnpdes pennit-7mnewal epplimtionXmd,pe—t renewal-27c—rletter.doa
Page: 3/3

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke River V1#W R, NCO024201 Standard Renewal Roanoke
FORM
2A NPDES FORM 2A APPLICATION OVERVIEW
NPDES
APPLICATION OVERVIEW
Form 2A has been developed in a modular format and consists of a "Basic Application Information" packet
and a "Supplemental Application Information" packet. The Basic Application Information packet is divided
into two parts. All applicants must complete Parts A and C. Applicants with a design flow greater than or
equal to 0.1 mgd must also complete Part B. Some applicants must also complete the Supplemental
Application Information packet. The following items explain which parts of Form 2A you must complete.
BASIC APPLICATION INFORMATION:
A. Basic Application Information for all Applicants. All applicants must complete questions A.1 through A.8. A treatment works
that discharges effluent to surface waters of the United States must also answer questions A.9 through A.12.
B. Additional Application Information for Applicants with a Design Flow >_ 0.1 mgd. All treatment works that have design flows
greater than or equal to 0.1 million gallons per day must complete questions 13.1 through B.6.
C. Certification. All applicants must complete Part C (Certification).
SUPPLEMENTAL APPLICATION INFORMATION:
D. Expanded Effluent Testing Data. A treatment works that discharges effluent to surface waters of the United States and meets
one or more of the following criteria must complete Part D (Expanded Effluent Testing Data):
1. Has a design flow rate greater than or equal to 1 mgd,
2. Is required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to provide the information.
E. Toxicity Testing Data. A treatment works that meets one or more of the following criteria must complete Part E (Toxicity Testing
Data):
1. Has a design flow rate greater than or equal to 1 mgd,
2. Is required to have a pretreatment program (or has one in place), or
3. Is otherwise required by the permitting authority to submit results of toxicity testing.
F. Industrial User Discharges and RCRA/CERCLA Wastes. A treatment works that accepts process wastewater from any
significant industrial users (SI Us) or receives RCRA or CERCLA wastes must complete Part F (Industrial User Discharges
and RCRA/CERCLA Wastes). SIUs are defined as:
1. All industrial users subject to Categorical Pretreatment Standards under 40 Code of Federal Regulations (CFR) 403.6 and
40 CFR Chapter I, Subchapter N (see instructions); and
2. Any other industrial user that:
a. Discharges an average of 25,000 gallons per day or more of process wastewater to the treatment works (with certain
exclusions); or
b. Contributes a process wastestream that makes up 5 percent or more of the average dry weather hydraulic or organic
capacity of the treatment plant; or
C. Is designated as an SIU by the control authority.
G. Combined Sewer Systems. A treatment works that has a combined sewer system must complete Part G (Combined Sewer
Systems).
ALL APPLICANTS MUST COMPLETE PART C (CERTIFICATION)
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 1 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WWTP, NCO024201
Standard Renewal
Roanoke
BASIC APPLICATION INFORMATION
PART A. BASIC APPLICATION INFORMATION FOR ALL APPLICANTS:
All treatment works must complete questions A.1 through A.8 of this Basic Application Information Packet.
A.I. Facility Information.
Facility Name Roanoke River WWVTP
Mailing Address 135 Aqueduct Road
Weldon Forth Carolina 27890
Contact Person Steven L. Ellis
Title Operator in Responsible Charge
Telephone Number 252 536-4884
Facility Address 135 Aqueduct Road
(not P.O. Box) Weldon North Carolina 27890
A.2. Applicant Information. If the applicant is different from the above, provide the following:
Applicant Name Roanoke Rapids Sanitary District
Mailing Address 1000 Jackson Street PO Box 308
Roanoke Rapids, North Carolina 27870
Contact Person R. Danieley Brown
Title Chief Executive Officer
Telephone Number [phone]
Is the applicant the owner or operator (or both) of the treatment works?
® owner ® operator
Indicate whether correspondence regarding this permit
should be directed to the facility or the applicant.
❑ facility ® applicant
A.3. Existing Environmental Permits. Provide the permit number of any existing environmental permits that have been issued to the treatment works
(include state -issued permits).
NPDES NCO024201 Other Stormwater Permit — General NCG'I 10000
UIC Other Land Application Permit W00001989
RCRA Other Collection System Permit WQCS00027
PSD
A.4. Collection System Information. Provide information on municipalities and areas served by the facility. Provide the name and population of each
entity and, if known, provide information on the type of collection system (combined vs. separate) and its ownership (municipal, private, etc.).
Name Population Served Type of Collection System Ownership
Town of Gaston 1,092 Sanitary Seaver District
City of Roanoke Rapids 15,623 Sanitary Sewer District
Unincorporated Areas 966 Sanitary Sewer Halifax & Northampton County
Total population served 17.681
E Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 2 of 27

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke Rivet WWTP, NCO024201 Standard R� Roanoke
A.S. Indian Country.
- a. Is the treatment works located in Indian Country?
❑ Yes ® No
b. Does the treatment works discharge to a receiving water that is either in Indian Country or that is upstream from (and eventually flows
through) Indian Country?
❑ Yes ® No
A.S. Flow. Indicate the design flow rate of the treatment plant (i.e., the wastewater flow rate that the plant was built to handle). Also provide the
average daily flow rate and maximum daily flow rate for each of the last three years. Each year's data must be based on a 12 -month time period
with the 12th month of "this year" occurring no more than three months prior to this application submittal.
a. Design flow rate 8.33 mgd
Two Years Ago Last Year This Year
b. Annual average daily flow rate 3.0 P,IIGD 3.8 fIi63GD 4.1 MGD
C. , Maximum daily flow rate 15.2 IIIIGD 11.4 PAGD :12.7 MGD
A.7. Collection System. Indicate the type(s) of collection system(s) used by the treatment plant. Check all that apply. Also estimate the percent
contribution (by miles) of each.
® Separate sanitary sewer 100 %
❑ Combined storm and sanitary sewer NIA %
A.8. Discharges and Other Disposal Methods.
a. Does the treatment works discharge effluent to waters of the U.S.? ® Yes ❑ No
If yes, list how many of each of the following types of discharge points the treatment works uses:
i. Discharges of treated effluent
ii. Discharges of untreated or partially treated effluent
iii. Combined sewer overflow points
iv. Constructed emergency overflows (prior to the headworks)
V. Other NIA
b. Does the treatment works discharge effluent to basins, ponds, or other surface impoundments
that do not have outlets for discharge to waters of the U.S.? ❑ Yes
If yes, provide the following for each surface impoundment:
Location:
Annual average daily volume discharge to surface impoundment(s)
Is discharge ❑ continuous or ❑ intermittent?
C. Does the treatment works land -apply treated wastewater?
If yes, provide the following for each land application site:
Location:
Number of acres:
Annual average daily volume applied to site: u
Is land application ❑ continuous or ❑ intermittent?
d. Does the treatment works discharge or transport treated or untreated wastewater to another
treatment works?
NIA
raw
NIA mgd
❑ Yes Z No
mgd
❑ Yes ® No
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 3 of 27

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke Raver WlJVTP, NCO024201 Standard Renewal Roanoke
If yes, describe the mean(s) by which the wastewater from the treatment works is discharged or transported to the other treatment works
(e.g., tank truck, pipe).
If transport is by a party other than the applicant, provide:
Transporter Name N/A
If known, provide the NPDES permit number of the treatment works that receives this discharge N/A
Provide the average daily flow rate from the treatment works into the receiving facility. N/A mgd
e. Does the treatment works discharge or dispose of its wastewater in a manner not included
in A.8. through A.8.d above (e.g., underground percolation, well injection): ❑ Yes ® No
If yes, provide the following for each disposal method:
Description of method (including location and size of site(s) if applicable):
Annual daily volume disposed by this method: N/A
Is disposal through this method ❑ continuous or ❑ intermittent?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 4 of 27
Mailing Address
NIA
NIA
Contact Person
NIA
Title
N/A
Telephone Number
NIA
For each treatment works that receives this discharge, provide the following:
Name
N/A
Mailing Address
NIA.
N/A
Contact Person
NIA
Title
N/A
Telephone Number
N/A
If known, provide the NPDES permit number of the treatment works that receives this discharge N/A
Provide the average daily flow rate from the treatment works into the receiving facility. N/A mgd
e. Does the treatment works discharge or dispose of its wastewater in a manner not included
in A.8. through A.8.d above (e.g., underground percolation, well injection): ❑ Yes ® No
If yes, provide the following for each disposal method:
Description of method (including location and size of site(s) if applicable):
Annual daily volume disposed by this method: N/A
Is disposal through this method ❑ continuous or ❑ intermittent?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 4 of 27

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke River WVVTP, NCO024201 I Standard Pi Roanoke
WASTEWATER DISCHARGES:
if you answered "Yes" to question A.8.a complete questions A.9 through A.12 once for each outfall (including bypass points) through
which effluent is discharged. Do not include information on combined sewer overflows in this section. If you answered "No" to question
A.8.a_ go to Part B, "Additional Application Information for Applicants with a Design Flow Greater than or Equal to 0.1 mgd."
A.9. Description of Outfall.
a. Outfall number
b. Location Weldon 27890
(City or town, if applicable) (Zip Code)
(County) (State)
360 26' 13" 770M'37"
(Latitude) (Longitude)
C. Distance from shore (if applicable) 11,11A ft.
d. Depth below surface (if applicable) N/A ft.
e. Average daily flow rate 4.1 (Year to Date) mgd
f. Does this outfall have either an intermittent or a periodic discharge? ® Yes ® No (go to A.9.g.)
If yes, provide the following information:
Number f times per year discharge occurs:
Average duration of each discharge:
Average flow per discharge:
Months in which discharge occurs:
g. Is outfall equipped with a diffuser?
N/A
N/A
N/A
mgd
N/A
® Yes ® No
A.10. Description of Receiving Waters.
a. Name of receiving water Roanoke River
b. Name of watershed (if known) Roanoke River and Tributaries
United States Soil Conservation Service 14 -digit watershed code (if known): 03010107070010
C. Name of State Management/River Basin (if known): Roanoke River Basin
United States Geological Survey 8 -digit hydrologic cataloging unit code (if known): 03010107
d. Critical low flow of receiving stream (if applicable) 1172 cfS (7Q10)
acute cls chronic cfs
e. Total hardness of receiving stream at critical low flow (if applicable): unknown mg/1 of CaCO3
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 5 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WWTP, NCO024201
Standard Rene'WB�
Roanoke
A.11. Description of Treatment
a. What level of treatment are provided? Check all that apply.
® Primary ® Secondary
❑ Advanced ❑ Other. Describe:
b. Indicate the following removal rates (as applicable):
Design BOD5 removal or Design CBOD5 removal 85
Design SS removal 85
Design P removal NIA %
Design N removal NIA %
Other N/A N/A %
C. What type of disinfection is used for the effluent from this outfall? If disinfection varies by season, please describe:
Sodium Hypochlorite
If disinfection is by chlorination is dechlorination used for this outfall? ® Yes ❑ No
Does the treatment plant have post aeration? ❑ Yes ® No
A.12. Effluent Testing Information. All Applicants that discharge to waters of the US must provide effluent testing data for the following
parameters. Provide the indicated effluent testing required by the permitting authority for each outfall through which effluent is
discharged. Do not include information on combined sewer overflows in this section. All information reported must be based on data
collected through analysis conducted using 40 CFR Part 136 methods. In addition, this data must comply with QA/QC requirements of
Part 136 appropriate QA1QC requirements for standard methods for analytes not addressed by 40 CFR Part 136. At a
40 CFR and other
minimum, effluent testing data must be based on at least three samples and must be no more than four and one-half years apart.
Ouffall number. 001 DMR Data from January 2014 — July 2016 used.
MAXIMUM DAILY VALUE
AVERAGE DAILY VALUE
PARAMETER
Value
Units
Value
Units
Number of Samples
pH (Minimum)
6.4
S.U.
-
pH (Maximum)
7.6
s.u.
Flow Rate
15.2
NIDD
3.93
MGD
>660
Temperature (Winter)
16.6
°C
13.36
®C
4660
Temperature (Summer)
27.4
°C
24.94
®C
4660
* For pH please report a minimum and a maximum dail value
MAXIMUM DAILY
AVERAGE DAILY DISCHARGE
DISCHARGE
ANALYTICAL
ML/MDL
POLLUTANT
METHOD
Number of
Conc.
Units
Conc.
Units
Samples
CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS
BIOCHEMICAL OXYGEN
BOD5
CBOD5
31.1
Mg/1
5.2
Mg/o
264
SM5210B
2 mg/l
DEMAND (Report one)
Coloni
FECAL COLIFORM
600
Colonies
6.4
es/10®
270
SM9222D
1/100rr10
/100mo
spa V
TOTAL SUSPENDED SOLIDS (TSS)
570
(t/j /(
19.0
1 Mg/I
1 660
SM2540
1 2.5 mg/I
END, OF PART A.
REFER TO THE APPLICATION' OVERVIEW (PAGE 1) TO DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST COMPLETE
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 6 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River V\APJTP,
Standard Renewal
Roanoke
BASICAPPLICATION INFORMATION
.PART B. ADDITIONAL APPLICATION INFORMATION FOR APPLICANTS WITH'A DESIGN FLOW GREATER THAN OR
EQUAL TO 0.1 MGD (100,000 gallons per day).
All applicants with a design flow rate z 0.1 mgd must answer questions B.1 through B.S. All others go to Part C (Certification).
B.I. Inflow and Infiltration. Estimate the average number of gallons per day that flow into the treatment works from inflow and/or infiltration.
2,147,000 gpd
Briefly explain any steps underway or planned to minimize inflow and infiltration.
Completion of O/F G Rehab (364 VF MH Lining, 14,666 LF Pipeline CIP, 1,753 LF Pipe Burst) and Sub Basins C & D Rehab (625 VF MH Lining,
27,279 LF Pipeline CIP, 630 LF Pipe Burst) projects.
Lower Roanoke O/F and Sub Basin A Sewer Rehab project const. permit pending (Rehabilitation of approximately 2,500 linear feet of 8 -inch, 1,300
linear feet of 12 -inch, 511 linear feet of 18 -inch, 1,023 linear feet of 21 -inch, and 6,400 linear feet of 30 -inch gravity sewer by CIPP;
relocation of 4,334 linear feet of 8 -inch and 38 linear feet of 12 -inch gravity sewer; cleaning and inspection of approximately 12,786 linear
feet of 8 -inch to 12 -inch gravity sewer; rehabilitation of 33 manholes, six (6) point repairs, and 45 sewer service laterals.).
B.2. Topographic Map. Attach to this application a topographic map of the area extending at least one mile beyond facility property boundaries. This
map must show the outline of the facility and the following information. (You may submit more than one map if one map does not show the entire
area.) See Attached Figure
a. The area surrounding the treatment plant, including all unit processes.
b. The major pipes or other structures through which wastewater enters the treatment works and the pipes or other structures through which
treated wastewater is discharged from the treatment plant. Include ouffalls from bypass piping, if applicable.
c. Each well where wastewater from the treatment plant is injected underground.
d. Wells, springs, other surface water bodies, and drinking water wells that are: 1) within % mile of the property boundaries of the treatment
works, and 2) listed in public record or otherwise known to the applicant.
e. Any areas where the sewage sludge produced by the treatment works is stored, treated, or disposed.
f. If the treatment works receives waste that is classified as hazardous under the Resource Conservation and Recovery Act (RCRA) by truck, rail,
or special pipe, show on the map where the hazardous waste enters the treatment works and where it is treated, stored, and/or disposed.
B.3. Process Flow Diagram or Schematic. Provide a diagram showing the processes of the treatment plant, including all bypass piping and all
backup power sources or redunancy in the system. Also provide a water balance showing all treatment units, including disinfection (e.g.,
The balance must show daily average flow rates at influent and discharge points and approximate daily flow
chlorination and dechlorination). water
rates between treatment units. Include a brief narrative description of the diagram. See Attached Figure
B.4. Operation/Maintenance Performed by Contractor(s).
Are any operational or maintenance aspects (related to wastewater treatment and effluent quality) of the treatment works the responsibility of a
contractor? El Yes ® No
If yes, list the name, address, telephone number, and status of each contractor and describe the contractor's responsibilities (attach additional
pages if necessary).
Name: N/A
Mailing Address: N/A
N/A
Telephone Number: N/A
Responsibilities of Contractor: N/A
B.S. Scheduled improvements and Schedules of Implementation. Provide information on any uncompleted implementation schedule or
uncompleted plans for improvements that will affect the wastewater treatment, effluent quality, or design capacity of the treatment works. If the
treatment works has several different implementation schedules or is planning several improvements, submit separate responses to question B.5
for each. (If none, go to question B.6.)
a. List the outfall number (assigned in question A.9) for each outfall that is covered by this implementation schedule.
N/A
the improvements or implementation schedule are required by local, State, or Federal agencies. N/A
b. Indicate whether planned
® Yes El No
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 7 of 27

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke River WWTP, 4* CO024201 Standard Renewal Roanoke
C. If the answer to B.5.b is "Yes," briefly describe, including new maximum daily inflow rate (if applicable).
NIA
d. Provide dates imposed by any compliance schedule or any actual dates of completion for the implementation steps listed below, as
applicable. For improvements planned independently of local, State, or Federal agencies, indicate planned or actual completion dates, as
applicable. Indicate dates as accurately as possible.
N/A Schedule Actual Completion
Implementation Stage MM/DD/YYYY MM/DD/YYYY
- Begin Construction
- End Construction / / I /
- Begin Discharge
- Attain Operational Level
e. Have appropriate permits/clearances concerning other Federal/State requirements been obtained? ❑ Yes ❑ No
Describe briefly: NIA
B.6. EFFLUENT TESTING DATA (GREATER THAN 0.1 MGD ONLY).
Applicants that discharge to waters of the US must provide effluent testing data for the following parameters. Provide the indicated
effluent testing required by the permitting authority for each outfall through which effluent is discharged. Do not include information
on combine sewer overflows in this section. All information reported must be based on data collected through analysis conducted
using 40 CFR Part 136 methods. In addition, this data must comply with QA/QC requirements of 40 CFR Part 136 and other appropriate
QA/QC requirements for standard methods for analytes not addressed by 40 CFR Part 136. At a minimum effluent testing data must be
based on at least three pollutant scans and must be no more than four and on -half years old.
Outfall Number: 001 DMR Data from January 2014 — July 2016, and PPA 2013,2014, & 2105 used.
MAXIMUM DAILY AVERAGE DAILY DISCHARGE
DISCHARGE ANALYTICAL MLIMDL
POLLUTANT Number of METHOD
Conc. Units Conc. Units Samples
CONVENTIONAL AND NON CONVENTIONAL COMPOUNDS
AMMONIA (as N) 15.1 Mg/I 4.0 mg/6 255 S119A500F 0.1mg/1
CHLORINE (TOTAL 43 U9/1 <10.8 U,q/I 6714 MACH 10014 <70uo/l
RESIDUAL, TRC)
DISSOLVED OXYGEN 9.8 Mgt] 5.9 Moll 647 SM4500-OG NA
TOTAL KJELDAHL 17.3 Moll 5.9 Moll 24 EPA 331.1 0.2rng/I
NITROGEN (TKN)
NITRATE PLUS NITRITE 32.2 MU/I 6.0 W19/I 34 EPA 353.2 0.1mg1l
NITROGEN
OIL and GREASE 6.0 Iing/l <5.0 Mon 3 EPA 16648 5mcr/i
PHOSPHORUS (Total) 3.6 Mg/l 1.0 GMg/I 33 EPA H200.7 0 02rng/I
TOTAL DISSOLVED SOLIDS 340 0 Moll 314.7 Moil 3 SM210mg/I
(TDS)
OTHER NA
END OF PART B.
REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST COMPLETE
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 8 of 27

FACILITY NAME AND PERMIT NUMBER:
Roanoke River WWTP, NCO024201
BASK: APPLICATIONI INFORMOON4
PERMIT ACTION REQUESTED: RIVER BASIN:
Standard Renewal I Roanoke
PART•,'C:, d. KTI_FICATION
All applicants must complete the Certification Section. Refer to instructions to determine who is an officer for the purposes of this
certification. All applicants must complete all applicable sections of Form 2A, as explained in the Application Overview. Indicate below which
parts of Form 2A you have completed and are submitting. By signing this certification statement, applicants confirm that they have reviewed
Form 2A and have completed all sections that apply to the facility for which this application is submitted.
Indicate which parts of Form 2A you have completed and are submitting:
® Basic Application Information packet Supplemental Application Information packet:
® Part D (Expanded Effluent Testing Data)
® Part E (Toxicity Testing: Biomonitoring Data)
® Part F (Industrial User Discharges and RCRAICERCLA Wastes)
❑ Part G (Combined Sewer Systems)
THE EOLL'-OWIING'CERTIFI -AT N,
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who
manage the system or those persons directly responsible for gathering the information, the information is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment
for knowing violations.
Name and official title
Signature
Telephone number
Date signed
Upon request of the permitting authority, you must sul
works or identify appropriate permitting requirements.
t(
any other information necessary to assure wastewater treatment practices at the treatment
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 9 of 27

SEND COMPLETED FORMS TO:
NCDENR/ DWQ
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 10 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke Rifer VMITP, NCO024201
Standard Rerlewd
Roanoke
SUPPLEMENTAL APPLICATION INFORMATION
PART D. EXPANDED EFFLUENT TESTING DATA
Refer to the directions on the cover page to determine whether this section applies to the treatment works.
Effluent Testing: 1.0 mgd and Pretreatment Works. If the treatment works has a design flow greater than or equal to 1.0 mgd or it has (or is required
to have) a pretreatment program, or is otherwise required by the permitting authority to provide the data, then provide effluent testing data for the following
pollutants. Provide the indicated effluent testing information and any other information required by the permitting authority for each outfall through which
effluent is discharged. Do not include information on combined sewer overflows in this section. All information reported must be based on data collected
through analyses conducted using 40 CFR Part 136 methods. In addition, these data must comply with QA/QC requirements of 40 CFR Part 136 and
other appropriate QA/QC requirements for standard methods for analytes not addressed by 40 CFR Part 136. Indicate in the blank rows provided below
any data you may have on pollutants not specifically listed in this form. At a minimum, effluent testing data must be based on at least three pollutant
scans and must be no more than four and one-half years old.
Outfall number: 001 (Complete once for each outfall discharging effluent to waters of the United States.)
MAXIMUM DAILY DISCHARGE
AVERAGE DAILY DISCHARGE
ANALYTICAL
ML/MDL
Number
POLLUTANT
Conc.
Units
m7d
Units
Conc.
Units
Mass
Units
of
METHOD
Samples
METALS (TOTAL RECOVERABLE), CYANIDE, PHENOLS, AND HARDNESS.
ANTIMONY
6.025
M /L
g
<.813
Lbs/
Day
<.025
Mg/L
<.785
Lbs/
Day
3
EPA 200.8
.025
ARSENIC
<.010
Mg/L
<.325
pay
<.010
Mg/L
<.314
Day
3
EPA 200.8
.010
BERYLLIUM
<.005
Mg/L
<.163
pay
<.005
Mg/L
<.157
Day
3
EPA 200.8
.005
CADMIUM
6.002
M /L
g
<.065
Da /
y
<.002
Mg/L
<.063
pay
3
EPA 200.8
.002
CHROMIUM
6.005
Mg/L
< 162
Lbs!
Day
<.005
Mg/L
<,157
Lbs/
Day
3
EPA 200.8
.002
COPPER
.0'15
Mg/L488
pay
<.009
Mg/L
<.278
pay
3
EPA 200.8
.002
LEAD
6.010
Mg/L
6.325
Lbs/
Day
6.010
Mg/L
< 314
Lbs/
Day
3
EPA 200 8
.010
MERCURY
.0284
Ug/I
.0009
Lay
0155
Ug/L
.0005
Day
3
1631E
0.001
NICKEL
6.010
M rL
g'
6.325
Da/
y
<.010
Mg/L
<.314
Day
3
EPA 200 8
.010
SELENIUM
< 010
Mg1L
<.325
Lav
<.010
Mg/L
<.314
Day
3
EPA 200.8
010
SILVER
6.005
Mg/L
6.162
Lbs/
Day
<.005
M /�
9
6.157
Lbs/
Gay
3
EPA 200.8
.005
THALLIUM
6.020
Mg/L
< 065
Lbs/
Day
<.020
Mg/L
<.063
Lbs/
Day
3
EPA 200.8
.020
ZINC
.040
Mg/L
1.3
Day
.035
Mg/L
1.09
pay
3
EPA 200.8
0.10
CYANIDE
<.005
Mg/L
<.162
Lbs/
Day
< 005
Mg/L
<.137
Lbs/
Day
3
EPA 335 4
.005
TOTAL PHENOLIC
•018
Mg /L
.540
Lbs/
<.014
Mg/L
<.427
Lbs/
Day
3
EPA 420.1
.010
COMPOUNDS
Day
HARDNESS (as CaCO3)
84
MgPL
2662
Lay
73.33FMg/L
2305
Lay
3
SM 3240B
1
Use this space (or a separate sheet) to provide information on other metals requested by the permit writer
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 11 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke 'River kNWTP, NCO024201
Standard Renewal
Roanoke
Outfall number: 001 (Complete once for each outfall discharging effluent to waters of the United States.)
MAXIMUM DAILY DISCHARGE
AVERAGE DAILY DISCHARGE
ANALYTICAL
ML/MDL
Number
POLLUTANT
Conc.
Units
Mass
Units
Conc.
Units
Mass
Units
of
METHOD
Samples
VOLATILE ORGANIC COMPOUNDS Please See notes in Additional Information Section.
ACROLEIN
<600
Ug/L
<15.0
Day
<200
Ug/L
<6.07
Day
3
EPA 624
50
ACRYLONITRILE
<100
Ug/L
<3.0
Day
<40
Ug/L
<1.21
Day
3
EPA 624
10
BENZENE
<'10
Ug/L
<.30
Day
<4
<4
Ug/L
<0.12
Dy
3
EPA 624
1
BROMOFORM
<10
Ug/L
<.30
Day
<4
Ug/L
<0.12
Day
3
EPA 624
1
CARBON
<10
Ug/L
<.30
<4
Ugil-
<0.12
Day
3
EPA 624
1
TETRACHLORIDE
Day
CHLOROBENZENE
<10
Ug/L
<.30
Das!
Y
<ts
UgIL
Day
3
EPA 624
I
CHLORODIBROMO-
c10
Ug/L
< 30
Lbs!
<4
Ug/L
Lbsl3EPA
Dav
624
1
METHANE
Day
J12
CHLOROETHANE
<50
Ug/L
<;,6
Lbs!
Dao/
20
Ug,'L
Lbs!
Day
3
FPA 622?
5
2-CHLOROETHYLVINYL
<50
Ug/L
<1.5
Lbs/
<20
Ug/L
<0.61
Lbs/
Day
3
EPA 62�
5
ETHER
Day
CHLOROFORM
<10
Ug/L
<.30
Day <6.00
Ug
<0.21
Daly
3
EPA 524
5
DICHLOROBROMO-Lbs/
<`10
4Jg/L
<,30
<4
Ug/L
<0.12Day
Lbs/
3
EPA 62 I
1
METHANE
Day
1,1-DICHLOROETHANE
<10
Ug/L
<Lbs.30
Day /
<4
Ug/L
<0.12
Day
3
EPA 624
a
1,2-DICHLOROETHANE
<10
Ug/L
<,30
Day «
Ug1L
<o.a2
Day Day
624
1
TRANS-I,2-DICHLOR10-Lbs!
<°10
UgIL
<.30
<4
Ug/L
<0.12
Lbs/
3
EPA 624
a
ETHYLENE
Day
Day
1,1-DICHLORO-
<70
UgIL
<.30
Lbs!
<&
UgIL
<0.'12
Lbs!
Day
3
EPA 624
1
ETHYLENE
Day
1,2-DICHLOROPROPANE
<10
Ug/L
<.30
DaY!
«
Ug/L
<0.12
Day
3
EPA 624
1
1,3-DICHLORO-
<10
U /L
g
<.30
Lbc_/
<4
U /L
g
<0.12
Lbs/
Day
3
EPA 624
'I
PROPYLENE
Day
ETHYLBENZENE
<10
Ug/L
<.30
Das/
<$
UgIL
<0.'12
Day
3
EPA 624
a
METHYL BROMIDE
<50
Ug/L
<1.5
Day
<20
<20
Ug/L
<0.61
Dy
3
EPA 624
5
METHYL CHLORIDE
<50
Ug/L
<1.5
Das/
<18.7
Ug/L
<0.57
Day
3
EPA 624
5
METHYLENE CHLORIDE
<10
Ug/L
<.30
Da/
<4
Ug/L
<0, i2
Day
3
EPA 624
1
1,1,2,2-TETRA-
<•10
Ug/L
<.30
Lbs/
<4
Ug/L
<0.12
Lbs/
Day
3
EPA 624
a
CHLOROETHANE
Day
TETRACHLORO-
<10
U /L
g
<.30
Lbs/
Day
<4
Ug/L
<0.12
Lbs/
Day
3
EPA 624
a
ETHYLENE
TOLUENE
<10
Ug/L
<.30
Day «
Ug/L
<0.'i2
Day
3
EPA 624
a
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 12 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WNTP, NCO024201
Standard Renewal
Roanoke
Outfall number. 001 (Complete once for each outfall discharging effluent to waters of the United States.)
MAXIMUM DAILY DISCHARGE
AVERAGE
DAILY
DISCHARGE
POLLUTANT
ANALYTICAL
METHOD
MUMDL
Number
Conc.
Units
Mass
Units
Conc.
UnitsMass
Units
of
Samples
1,1,1-
<10
Ug/L
<.30
Lbsl
Day
<a
Ug/L
<0.12
Da/
y
3
EPA 624
1
TRICHLOROETHANE
1,1,2-
<10
Ug/L
<.30
Lbs/
Day
<4
Ug/L
<0.12
Lbs/
Day
3
EPA 624
1
TRICHLOROETHANE
TRICHLOROETHYLENE
<10
Ug/L
<.30
Day <4
UglL
<0.12
pay
3
EPA 624
1
VINYL CHLORIDE
<50
Ug/L
<1.5
Lbsl
Day
<20
Ug/L
<0.61
Lbs/
Day
3
EPA 624
5
Use this space (or a separate sheet) to provide information on other volatile organic compounds requested by the permit writer
ACID -EXTRACTABLE COMPOUNDS
P -CHLORO -M -CRESOL
<10
Ug/L
<.325
Da
<10
UglL
<.314
pay
3
EPA 625
10
2 -CHLOROPHENOL
<10
Ug/L
<.325
pay
<10
Ug/L
<.314
pay
3
EPA 625
10
2,4-DICHLOROPHENOL
<10
Ug/L
<.325
Da /
Y
<10
Ug/L
<.314
pay
3
EPA 625
10
2,4 -DIMETHYLPHENOL
<10
Ug/L
<.325
pay
<10
Ug/L
<.314
Day
3
EPA 625
10
4,6-DINITRO-0-CRESOL
<50
Ug/L
<1.63
pay
<50
Ug/L
<1.57
Lbsl Day
3
EPA 625
50
2,4-DINITROPHENOL
<50
Ug/L
<1.63
pay <50
Ug/L
<1.57
Day
3
EPA 625
50
2-NITROPHENOL
<10
Ug/L
<.325
pay <10
UglL
<.314
pay
3
EPA 625
10
4-NITROPHENOL
<60
Ug/L
<1.63
st
pay <50
Ug/L
<1.57
Day
3
EPA 625
50
PENTACHLOROPHENOL
<50
UglL
<1.63
Lbs/
Day
<50
Ug/L
<1 57
Lbs/
Day
3
EPA 625
50
PHENOL
<10
Ug/L
<.325
Lbs/
Day
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
2,4,6-
<10
UgIL
<.325
Lbs/
Day
<10
Ug/L
<.314
Lbs'
Day
3
EPA 625
10
TRICHLOROPHENOL
Use this space (or a separate sheet) to provide information on other acid -extractable compounds requested by the permit writer
BASE -NEUTRAL COMPOUNDS
ACENAPHTHENE
<10
Ug/L
<.325
Day <10
Ug/L
<.314
Day
3
EPA 625
10
ACENAPHTHYLENE
<10
Ug/L
<.325
Lbsl
Day
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
ANTHRACENE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
Day
3
EPA 625
10
BENZIDINE
<50
Ug/L
<1.63
Day
<60
Ug/L
<1.57
Day
3
EPA 625
50
BENZO(A)ANTHRACENE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
Day
3
EPA 625
10
BENZO(A)PYRENE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
day
3
EPA 625
10
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 13 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WWTP, NCO024201
Standard Renewal
Roanoke'
Outfall number: 001 (Complete once for each outfall discharging effluent to waters of the United States.)
MAXIMUM
DAILY DISCHARGE
AVERAGE
DAILY DISCHARGE
ANALYTICAL
ML/MDL
Number
POLLUTANT
Conc.
Units
Mass
Units
Conc.
Units
Mass
Units
of
METHOD
Samples
3,4 BENZO-
<10
Ug/L
<.325
Lbs/
<10
Ug/L
<.314
Lbs/
3
EPA 625
10
FLUORANTHENE
Day
Y
BENZO(GHI)PERYLENE
<10
Ug/L
<.325
aa/v
<10
Ug/L
<.314
pay
EPA
3
625
10
BENZO(1)
<10
Ug/L
<.325
Lbs/
<10
Ug/L
<.314
pal
3
EPA 625
10
FLUORANTHENE
Day
y
BIS (2-CHLOROETHOXY)
<10
Ug/L
<.325
Lbs<
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
METHANE
Day
BIS (2-CHLOROETHYL)-
<10
Ug/L
= 325
Lbs/
< 10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
ETHER
Day
BIS (2-CHLOROISO-
<10
Ug/L
<.326
Lbs/
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
PROPYL) ETHER
Day
BIS-ETHYLHEXYL 2)
<10
Ug/L
<.325
Lbs/
<10
Ug/L
<.31a
Lbs/
Day
3
EPA 625
10
PHTHALATE
Day
4-13ROMOPHENYL
<10
U lL
g
<.325
Lbs!
<10
UglL
<.314
Lbs/
Day
3
EPA 625
10
PHENYL ETHER
Day
BUTYL BENZYL
<10
UglL
<•325
Lbs/
<10
U g/L
<.314
Lbs/
Day
3
EPA 625
10
PHTHALATE
Day
2 -CHLORO-
<10
Ug/L
<.325
Lbsl
<10
Ug/L
<.314
Lbs/
Da
3
EPA 625
10
NAPHTHALENE
Day
4-CHLORPHENYL
<10
U /L
g
<.325
Lbs/
Day
<10
Ug/L
<.314
Lbs!
Day
3
EPA 625
10
PHENYL ETHER
CHRYSENE
<10
Ug/L
<.325
Lbs/
Day
<10
Ug/L
<.3`1E4
Lbs
Day
D ay
3
EPA 625
10
DI -N -BUTYL PHTHALATE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
Lay
3
EPA 625
10
DI-N-OCTYL PHTHALATE
<10
Ug/L
<.325
oay
<10
Ug/L
<.314
Day
3
EPA 625
10
DIBENZO(A,H)
<10
Ug/L
<.325
Lbs/
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
ANTHRACENE
Day
1,2 -DICHLOROBENZENE
<10
L19/1-<.325
LbDay
<10
Ug/L
<.314Y
Day'
3
EPA 625
10
1,3 -DICHLOROBENZENE
<10
Ug/L
<.325
pay
<10
Ug/L
<.3.14
pay
3
EPA 625
10
1,4 -DICHLOROBENZENE
<10
Ug/L
<.325
pay <bst
10
Ug/L
<.314
pay Day
625
10
3,3-DICHLORO-
<50
Ug/L
<1.63
Lbs/
Day
<50
U /L
g
<1.57
Lbs/
Day
3
EPA 625
50
BENZIDINE
DIETHYL PHTHALATE
<10
Ug/L
<.325
pay
<10
Ug/L
<.314
pay
3
EPA 625
10
DIMETHYL PHTHALATE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
pay
3
EPA 625
10
2,4-DINITROTOLUENE
<10
U /L
g
<.325
L bsl
Day
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
10
2,6-DINITROTOLUENE
<10
Ug/L
<.325
Lbs/
Day
<10
Ug/L
<.314
Lbs/
Day
3
EPA 625
'10
1,2 -DIPHENYL-
<10
Ug/L
<.325
Lbs/
<10
Ug/L
<.3'14
Lbs!
Day
3
EPA 625
10
HYDRAZINE
Day
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.
Page 14 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WWTP, NCO024201
Standard Renewal
Roanoke
for each outfall discharging effluent to waters of the United States.)
Outfall number: 001 (Complete once
MAXIMUM DAILY DISCHARGE
AVERAGE DAILY DISCHARGE
ANALYTICAL
ML/MDL
Number
POLLUTANTMETHOD
Conc.
Units
Mass
Units
Conc.
Units
Mass
Units
of
Samples
FLUORANTHENE
<10
Ug/L
<.325
LbsDay
y
<10
/L
U /L
Ug
<.314
Day
3
EPA 625
10
FLUORENE
<10
Ug/L
<.325
Da Y
<10
UglL
<.3'i4
Day
3
EPA 625
10
HEXACHLOROBENZENE
<10
Ug1L
<,325
Da/
Y
<10
Ug/L
<.314
Da/ 3
EPA 625
10
HEXACHLORO-
<10
Ug/L
<.325
Lt)slDay
<10
Ug/L
<.314
pay
3
EPA 625
10
BUTADIENE
HEXACHLOROCYCLO-
<50
iUg/L
<1.63
Da/
<50
Ug/L
<1.57
Luy
Da
3
EPA 625
50
PENTADIENE
y
HEXACHLOROETHANE
<10
Ug/L
<.325
Da/
Y
<10
Ug/L
<.3'14
Day
3
EPA 625
1®
INDENO(1,2,3-CD)
<10
Ug!L
<.325
<10
Ug/L
<.3'14
pay
3
EPA 625
10
PYRENE
Das/
ISOPHORONE
<10
Ug/L
<.325
Lbs!
Day
<10
Ug/L
< 3,14
Lbs/
Day
3
EPA 625
10
NAPHTHALENE
<10
Ug/L
<,325
Lbs/
Day
<10
Ug/L
st
<.31 ,
Lbs/
Day
3
EPA 625
10
<10
/L
U /L
Ug
<.325
Da/ <10
Ug/L
<.314
Day
3
EPA 625
10
N-NITROSODI-N-
<10
Ug/L
<.325
LbsDa/
<10
Ug/L
<.314
Day
3
EPA 625
10
PROPYLAMINE
y
N-NITROSODI-<10
U /L
g
<.325
Lbs/
<10
Ug/L
<,314
Lbs/
Day
3
EPA 625
10
METHYLAMINE
Day
N-NITROSODI-<10
Ug/L
<.325
Da/
Ug/L
<.314
Day
3
EPA 625
10
PHENYLAMINE
<10
y
PHENANTHRENE
<10
Ug/L
<.325
Lbs!
Day
<1G
Ug/L
< 314
Lbs/
Day
3
EPA 625
10
PYRENE
<10
Ug/L
<.325
Day
<10
Ug/L
<.314
Day
3
EPA 625
10
1,2,4-
<10
U !L
g
<,325
Lbs/
<10
Ug/L
<.314
Da!
y
3
EPA625
10
TRICHLOROBENZENE
Day
Use this space (or a separate sheet) to provide information on other base -neutral compounds requested by the permit wr3iter
Use this space (or a separate sheet) to provide information on other pollutants (e.g., pesticides) requested by the permit wri3ter
T_=
END OF PART D.33
REFER TO THE APPLICATION OVERVIEW ('PAGE 1) TO DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST C30MPLETE
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 15 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke Giver WWTP, NIIC0024201
Standard Renewal
Roanoke
SUPPLEMENTAL APPLICATION INFORMATION
PART E. TOXICITY TESTING DATA
POTWs meeting one or more of the following criteria must provide the results of whole effluent toxicity tests for acute or chronic toxicity for each of the facility's
discharge points: 1) POTWs with a design flow rate greater than or equal to 1.0 mgd; 2) POTWs with a pretreatment program (or those that are required to have
one under 40 CFR Part 403); or 3) POTWs required by the permitting authority to submit data for these parameters.
• At a minimum, these results must include quarterly testing for a 12 -month period within the past 1 year using multiple species (minimum of two
species), or the results from four tests performed at least annually in the four and one-half years prior to the application, provided the results show no
appreciable toxicity, and testing for acute and/or chronic toxicity, depending on the range of receiving water dilution. Do not include information on
combined sewer overflows in this section. All information reported must be based on data collected through analysis conducted using 40 CFR Part 136
methods. In addition, this data must comply with QA/QC requirements of 40 CFR Part 136 and other appropriate QA/QC requirements for standard
methods for analytes not addressed by 40 CFR Part 136.
• In addition, submit the results of any other whole effluent toxicity tests from the past four and one-half years. If a whole effluent toxicity test conducted
during the past four and one-half years revealed toxicity, provide any information on the cause of the toxicity or any results of a toxicity reduction
evaluation, if one was conducted.
• If you have already submitted any of the information requested in Part E, you need not submit it again. Rather, provide the information requested in
question EA for previously submitted information. If EPA methods were not used, report the reasons for using alternate methods. If test summaries
are available that contain all of the information requested below, they may be submitted in place of Part E.
If no biomonitoring data is required, do not complete Part E. Refer to the Application Overview for directions on which other sections of the form to complete.
See attached toxicity test results. Also, refer to EA for submittal details
E.I. Required Tests.
Indicate the number of whole effluent toxicity tests conducted in the past four and one-half years.
❑ chronic ❑ acute
E.2. Individual Test Data. Complete the following chart for each whole effluent toxicity test conducted in the last four and one-half years. Allow one
column per test (where each species constitutes a test). Copy this page if more than three tests are being reported.
Test number: Test number: Test number:
a. Test information.
Test Species & test method number
Age at initiation of test
Outfall number
Dates sample collected
Date test started
Duration
b. Give toxicity test methods followed.
Manual title
Edition number and year of publication
Page number(s)
c. Give the sample collection method(s) used. For multiple grab samples, indicate the number of grab samples used.
24 -Hour composite
Grab
d. Indicate where the sample was taken in relation to disinfection. (Check all that apply for each.
Before disinfection
After disinfection
After dechlorination
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 16 of 27

FACILITY NAME AND PERMIT NUMBER:
Roanoke River WWTP, NCO024201
PERMIT ACTION REQUESTED:
Standard Renewal
RIVER BASIN:
Roanoke
Test number: Test number: Test number:
e. Describe the point in the treatment process at which the sample was collected.
Sample was collected:
f. For each test, include whether the test was intended to assess chronic toxicity, acute toxicity, or both
Chronic toxicity
Acute toxicity
g. Provide the type of test performed.
Static
Static -renewal
Flow-through
h. Source of dilution water. If laboratory water, specify type; if receiving water, specify source.
Laboratory water
Receiving water
i. Type of dilution water. If salt water, specify "natural' or type of artificial sea salts or brine used;
Fresh water
Salt water
j. Give the percentage effluent used for all concentrations in the test series.
k. Parameters measured during the test. (State whether parameter meets test method specifications)
pH
Salinity
Temperature
Ammonia
Dissolved oxygen
I. Test Results.
Acute:
Percent survival in 100%
effluent
LC5o
95% C.I.
Control percent survival
Other (describe)
Page 17 of 27
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22.

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke Rives VVVVTP, NCO024201
Standard Renewal
Roanoke
Chronic:
NOEC
IC25
Control percent survival
Other (describe)
m. Quality Control/Quality Assurance.
Is reference toxicant data available?
Was reference toxicant test within
acceptable bounds?
What date was reference toxicant test
run (MM/DD/YYYY)?
Other (describe)
E.3. Toxicity Reduction Evaluation. Is the treatment works involved in a Toxicity Reduction Evaluation?
❑ Yes ® No If yes, describe:
E.4. Summary of Submitted Biomonitoring Test Information. If you have submitted biomonitoring test information, or information regarding the
cause of toxicity, within the past four and one-half years, provide the dates the information was submitted to the permitting authority and a summary
of the results.
Date submitted: 7/26/2016 (MM/DD/YYYY)
Date submitted: 6/17/2016 (MM/DD/YYYY)
Date submitted: 9/9/2016 (MM/DD/YYYY)
Summary of results: (see instructions)
WET testing results for Secondary Species were submitted in July WET testing results for Secondary and Primary
Species were submitted in August and September. September and October results for WET testing will be submitted upon
completion They will not be available until after submittal deadline for this application.
END OF, PART E.
REFER TO THE APPLICATION OVERVIEW (PAGE 1) TO' DETERMINE WHICH OTHER PARTS
OF FORM 2A YOU MUST COMPLETE.
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 18 of 27

FACILITY NAME AND PERMIT NUMBER: PERMIT ACTION REQUESTED: RIVER BASIN:
Roanoke River VVVVTP, NCO0 4201 Standard Renewal Roanoke
SUPPL-EIVIENTAL APPLICATION` IhIFQP.MA ION',
PART' F. INDUSTRIAL'USER;nISCH'AR'GES, AN6 RdfWCERCLA, WASTES
All treatment works receiving discharges from significant industrial users or which receive RCRA,CERCLA, or other remedial wastes must
complete part F.
GENERAL INFORMATION:
F.I. Pretreatment program. Does the treatment works have, or is subject to, an approved pretreatment program?
® Yes ❑ No
F.2. Number of Significant Industrial Users (SIUs) and Categorical Industrial Users (CIUs). Provide the number of each of the following types of
industrial users that discharge to the treatment works.
a. Number of non -categorical SIUs.
b. Number of CIUs.
2 (includes 1 pending Cateoorig
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Reser's Fine Foods
Mailing Address:
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Food processing
F.5. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Cold salads baked beans meat salads
Raw material(s): Meats. Potatoes Baked Beans Cabbage, Pasta. Salad Dressings
F.6. Flow Rate.
a. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
250.000 gpd V continuous or intermittent)
b. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
N/A gpd (N/A continuous or N/A intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ❑X Yes ❑ No
b. Categorical pretreatment standards ❑ Yes ® No
If subject to categorical pretreatment standards, which category and subcategory?
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 19 of 27

FACILITY NAME AND PERMIT NUMBER:
Roanoke River STP, NCO024201
PERMIT ACTION REQUESTED:
Standard Renev4
RIVER BASIN:
Roanoke
F.B. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
N/A
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes ® No (go to F.12)
F.10. Waste transport Method by which RCRA waste is received (check all that apply): N/A
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
NIA NIA. N/A
N/A N/A NIA
N/A N/A NIA
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) M No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
N/A
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
NIA
F.15. Waste Treatment.
a. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ® No
If yes, describe the treatment (provide information about the removal efficiency):
N/A
b. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
N/A
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 20 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WWTP, NCO024201
Standard Renewal
Roanoke
SUPPLEMENTAL APPLICATION INFORMATION
PART F.INDUSTRIAL USER DISCHARGES.AND�RCRAICERCLA WASTES
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the1riformation requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Dominion Rosemary Power Station
Mailing Address: '120 West 12'h St
Roanoke Rapids, NC 27870
F.4. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Power Generation
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Steam
Raw material(s): N/A
F.6. Flow Rate.
C. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
85.000 gpd ( continuous or X intermittent)
d. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
N/A gpd (N/A continuous or N/A intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
J
a. Local limits ® Yes 0 No
b. Categorical pretreatment standards ® Yes 0 No
If subject to categorical pretreatment standards, which category and subcategory?
Pending Categorical Status 40 CFR 423.17
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 21 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke RiverVVVVTP, NCO024201
Standard 'Renewei
Roanoke
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
N/A
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes R No (go to F.12)
F.10. Waste transport Method by which RCRA waste is received (check all that apply): NIA
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
N/A N/A N/A
N/A N/A N/A
N/A N/A N/A
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) 0 No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
N/A
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
N/A
F.15. Waste Treatment
C. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ® No
If yes, describe the treatment (provide information about the removal efficiency):
N/A
d. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
N/A
FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke Riser WVVTP, NCO024201
Standard Renewal
Roanoke
SUPPLEMENTAL APPLICATION yINFORMATION'
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 22 of 27

PART F. INDUSTRIAL USER: DISCHARGES AN11 RCRA/CERCLA, WASTES,
SIGNIFICANT INDUSTRIAL USER INFORMATION:
Supply the following information for each SIU. If more than one SIU discharges to the treatment works, copy questions F.3 through F.8 and
provide the information requested for each SIU.
F.3. Significant Industrial User Information. Provide the name and address of each SIU discharging to the treatment works. Submit additional pages
as necessary.
Name: Kennametal Inc.
Mailing Address: 100 Kennametal Rd.
Weldon NC 27890
FA. Industrial Processes. Describe all the industrial processes that affect or contribute to the SIU's discharge.
Cutting and machine tool accessory manufacturing _
F.S. Principal Product(s) and Raw Material(s). Describe all of the principal processes and raw materials that affect or contribute to the SIU's
discharge.
Principal product(s): Machine Tools
Raw material(s): Tungsten Carbide Powder Ceramic Powder
F.6. Flow Rate.
e. Process wastewater flow rate. Indicate the average daily volume of process wastewater discharge into the collection system in gallons per
day (gpd) and whether the discharge is continuous or intermittent.
30.000 gpd ( continuous or X intermittent)
f. Non -process wastewater flow rate. Indicate the average daily volume of non -process wastewater flow discharged into the collection system
in gallons per day (gpd) and whether the discharge is continuous or intermittent.
30.000 gpd (X continuous or intermittent)
F.7. Pretreatment Standards. Indicate whether the SIU is subject to the following:
a. Local limits ® Yes ❑ No
b. Categorical pretreatment standards ® Yes ❑ No
If subject to categorical pretreatment standards, which category and subcategory?
40 CFR 471 Subpart J ---
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 23 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River VWVTP, NCO024201
Standard Renewal
Roanoke
F.8. Problems at the Treatment Works Attributed to Waste Discharge by the SIU. Has the SIU caused or contributed to any problems (e.g.,
upsets, interference) at the treatment works in the past three years?
❑ Yes ® No If yes, describe each episode.
N/A
RCRA HAZARDOUS WASTE RECEIVED BY TRUCK, RAIL, OR DEDICATED PIPELINE:
F.9. RCRA Waste. Does the treatment works receive or has it in the past three years received RCRA hazardous waste by truck, rail or dedicated pipe?
❑ Yes ® No (go to F.12)
F.10. Waste transport Method by which RCRA waste is received (check all that apply): N/A
❑ Truck ❑ Rail ❑ Dedicated Pipe
F.11. Waste Description. Give EPA hazardous waste number and amount (volume or mass, specify units).
EPA Hazardous Waste Number Amount Units
N/A N/A N/A
N/A N/A N/A
N/A N/A NIA
CERCLA (SUPERFUND) WASTEWATER, RCRA REMEDIATION/CORRECTIVE ACTION
WASTEWATER, AND OTHER REMEDIAL ACTIVITY WASTEWATER:
F.12. Remediation Waste. Does the treatment works currently (or has it been notified that it will) receive waste from remedial activities?
❑ Yes (complete F.13 through F.15.) ® No
F.13. Waste Origin. Describe the site and type of facility at which the CERCLA/RCRA/or other remedial waste originates (or is excepted to origniate in
the next five years).
N/A
F.14. Pollutants. List the hazardous constituents that are received (or are expected to be received). Include data on volume and concentration, if
known. (Attach additional sheets if necessary.)
N/A
F.15. Waste Treatment
e. Is this waste treated (or will be treated) prior to entering the treatment works?
❑ Yes ® No
If yes, describe the treatment (provide information about the removal efficiency):
N/A
f. Is the discharge (or will the discharge be) continuous or intermittent?
❑ Continuous ❑ Intermittent If intermittent, describe discharge schedule.
N/A
END1 OF PART F.
REFER TO THE' APPLICATION' OVERVIEW`(PAG'E 1'): TO.DETERMINE`W Mt. OTHERPARTS-
_OFFORM' 2A YOU. MUST COMPLETE
EPA Form 3510-2A (Rev. 1-99). Replaces EPA fors 7550-6 & 7550-22. Page 24 of 27

.Roanoke River WWTP, NCO024201 Standard ReneWa� Roanoke
SUPPLEMENTAL APPLICATION INFORMATION
PART. G. COMBINED SEWER SYSTEMS
If the treatment works has a combined sewer system, complete Part G.
G.I. System Map. Provide a map indicating the following: (may be included with Basic Application Information) NIA
a. All CSO discharge points.
b. Sensitive use areas potentially affected by CSOs (e.g., beaches, drinking water supplies, shellfish beds, sensitive aquatic ecosystems, and
outstanding natural resource waters).
C. Waters that support threatened and endangered species potentially affected by CSOs.
G.2. System Diagram. Provide a diagram, either in the map provided in G.1 or on a separate drawing, of the combined sewer collection system that
includes the following information. NIA
a. Location of major sewer trunk lines, both combined and separate sanitary.
b. Locations of points where separate sanitary sewers feed into the combined sewer system.
C. Locations of in-line and off-line storage structures.
d. Locations of flow -regulating devices.
e. Locations of pump stations.
CSO OUTFALLS:
Complete questions G.3 through G.6 once for each CSO discharge point.
G.3. Description of Outfall. NIA
a. Ouffall number
b. Location
(City or town, if applicable) (Zip Code)
(County) (State)
(Latitude) (Longitude)
C. Distance from shore (if applicable)
ft.
d. Depth below surface (if applicable) ft.
e. Which of the following were monitored during the last year for this CSO?
❑ Rainfall ❑ CSO pollutant concentrations
❑ CSO flow volume ❑ Receiving water quality
f. How many storm events were monitored during the last year?
G.4. CSO Events. NIA
a. Give the number of CSO events in the last year.
events (❑ actual or ❑ approx.)
b. Give the average duration per CSO event.
hours (❑ actual or ❑ approx.)
❑ CSO frequency
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 25 of 27

FACILITY NAME AND PERMIT NUMBER:
PERMIT ACTION REQUESTED:
RIVER BASIN:
Roanoke River WIVTP, NCO024201
Standard Renewaa
Roanoke
C. Give the average volume per CSO event.
million gallons (® actual or ® approx.)
d. Give the minimum rainfall that caused a CSO event in the last year
Inches of rainfall
G.S. Description of Receiving Waters. NIA
a. Name of receiving water:
b. Name of watershed/river/stream system:
United State Soil Conservation Service 14 -digit watershed code (if known):
C. Name of State Management/River Basin:
United States Geological Survey 8 -digit hydrologic cataloging unit code (if known):
G.6. CSO Operations. NIA
Describe any known water quality impacts on the receiving water caused by this CSO (e.g., permanent or intermittent beach closings, permanent or
intermittent shell fish bed closings, fish kills, fish advisories, other recreational loss, or violation of any applicable State water quality standard).
END OF PART G.
REFER TO THE APPLICATION OVERVIEW (PAG'E 1) TO DETERMINE WHICH' OTHER PARTS'
OF FORM 2A YOU MUST COMPLETE.
EPA Form 3510-2A (Rev. 1-99). Replaces EPA forms 7550-6 & 7550-22. Page 26 of 27

Additional information, if provided, will appear on the following pages.
Please note that for the 2013 Priority Pollutant Scan, Volatile Organic Compounds Section, the
sample analyzed with EPA 624 had to be diluted by a factor of 10 due to foaming. Due to the
dilution, the results could not be reported less than the normal detection level, but less than 10
times the detection level, thus increasing the maximum daily discharge concentrations, daily
maximum masses, the average daily concentrations, and the average daily masses. Attached is a
letter to support this information from the contract laboratory.
_ r
Attached -Figures:
Topographic Map
Plant Site. Plan
Plant Flow Schematic
Process Narrative
Attachments:
A: Letter from Contract Laboratory re: 2013 PPA
B: Whole Effluent Toxicity Results
C: Hardness Testing Data
D: Biosolids Program Description
E: Technical Memo in support of RMF
F: Mercury Minimization Plan Summary
NPDES FORM 2A Additional Information

Attached Figures

'Q%\ q% Outfall 0011_�
'K r
17,
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jr dr- M—At
fir
a r* r
4b
Weldo
t
Roanoke Rapids Sanitary District — NC0024201
Facility
14;Mw
USGS Quad Name: Weldon Lat: 36026'10" Location
Receiving Stream: Roanoke River Long: 77036'04"
Stream Class: C Not to Scale
Subbasin: Roanoke — 030208

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WASTEWATER TREATMENT PLANT
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35. C&1V0Y 5!INGE 1NMSE✓mS fi & ¢2
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47. SWOGE am DUN PUMPS
48. GENEMTOR
49. CC
50. UCC
61. TRxm SR1L PR01Em
52. SDMT IER PUMP MEN
PLANT SITE PIAN
ROANOKE RAPIDS SANITARY DISTRICT
WASTEWATER TREATMENT PLANT
MS

r --.T ------- INFLUENT EWAIJUMIN--------------------
11,34 MGD
---------r-------iB.34MGD i i O2 DRAINAGE
BEDS —� I I PT. 3
I I
—t
DIGESTER
SUPERNATANT I I I BLOWERS PT. 2
CREEK OUTFALL CHOCKOYOTIE I I� ��BAR USCR@NJ GRAVITY
oIv1R�oN ° Q'
RIVER L BOX MECHANICAL GRIT INFLUENT PRWARY 17.34 MGD 1PoCQING P 834 MGD AERATION FINAL CHLORINARONJ L,11 142 ®DISCHARGE TO
PUMP STATION TANKS CIARFIERS DEp1LIXiWAiIOONN ROANOKE RIVER
BAR SCREEN CHAMBERS 4 PUMPS ClARD1ERS FlLIERS 4 PUMPS I METERING i Q8 4 MGD
cwt I I j AFF
FED J I I I I FLOOD
j PT. 1 I - STORM WATER RATION FEED 3 I r PUMP WATER FILTER PUMP STATION
RECIRCULATION OVERFLOW TO
L� DIVERSION TO j PU3 PM�I�ON ROANOKE RIVER 3 PUMPS
ROANOKE RIVER
GRAVITY 0 3 MGD EACH
j OVERFLOW TO
OTTE PUMPED TO PUMPED
cm CRREE YO11E
DISCHARGE TO
PRIMARY SLUDGE Q - 00088 WIENOKE RIVER
tvNETJ d > 25,000 CFS
WAS 9=0,044
L----------- -----------
Fp UMP UST�ON tt
SUPERNATANT s
z
r WAS DRUM
I THICKENER 3
L— —�� , PT.5
I�
LAME SLUDGE LAND APPLJCARON
WAS L RAM1Y STABLIZAWN � HOLDING
THICKENERS FACLIIY TANKS LL SLUDGE DR11NG BEDS-DRANA �O
-----J
PT.4 SUPERNATANT O SUPERNATANT 0 ----1 ------�
I
SLUDGEI LEGEND
PRIMARY 2 PHMARY 1 SECONDARY DIGESTED I
PUMP STATION ANAEROBIC ANAEROBIC --- DICESIED SLUDGE -----------J NORMAL O ERARORI
DIGESTERS DIGESTER
---- INRETRMITIENT OPERATION
PT. SAMPLING POINT

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

Attachment A

MER-
`` ENVIRONMENTAL LABORATORIES'.
A Division of Wafer Technology and Controls, Inc. ;
September 1, 2016
Ms. Isabelle W, ilcoxon
Roanoke Rapids SD WW fP
135 Aquaduct Road
Weldon, NC 27870
RE: Volatile Data Detection Limits - July. 9; •2413 Eflluefii`§ample
Dear Ms. Wilcoxon:
Due t6 considerable foaming (indicating presence of surfactants) bf the above referenced : - -
sample (Meritech Work Order # 07091395) we were unable -to achieve lower detection*
limits for the Method 624 -organic' analysis. This volatile sample required x10 dilution. ,
Foaming makes the purge and trap volatile analysis impossible because it damages the
trap and transfers water and foam into the instrument plumbing.
If you have any questions concerning this matter, please give me: a call. We appreciate
your business and look forward to working -with you iz3 the future.
Sincerely,
Kris Pawlak
Laboratory Manager
Meritech, Inc--
Ph:
nc_ Ph: 336 342-4748 .
Fax: [phone]
642 Tamco Road - P.O. Box 27 • Reidsville, NC 27320
[phone] ° [phone] Fax

Attachment B

I
,----_6'ff1uent Toxicity Report Forma -Chronic Fathead Minnow Multi -Concentration Test
Facility: •Roanoke Rapids Sanitary District NPDES # NC00 24201
Laboratory: Meritech, Inc.
x
Signature of Operator in sponsib C arge
X
Signature of Laboratory Supervisor
MAIL ORIGINAL TO: Environmental Sciences Branch
Division of Water Quality
NC DENR
1621 Mail Service Center
Raleigh, NC 27699-1621
Pipe #:
Comments
Date:8/24/2016
County: Halifax
rest Initiation Date/Time
0.275
8/16/2016
10
6:00 PM
10
Avg Wt/Surv. Control 0.749
Test Organisms
0.454
0.535
2
3
4
0.55 Surviving #
E Cultured In -House
% Eff. Repl.
Control Surviving #
1
/ 6.54
% Survival 100.0
10
10
%Survival 97.5
yl Outside Supplier
10
9
10
10
Original #
10
10
10
10
0.644
Avg Wt (mg) 0.728
Hatch Date: 8/15/16
/ 24.9
24.1
0.760
0.646
Wt/original (mg)
0.733
0.772
10
Original #
Wt/original (mg)
10
10
1 10
S #
Avg Wt (mg) 0.721
0.755
0.788
0.661
0.681
I % Survival 97.5
Hatch Time: 3:00 PM
9
10
10 1
10
LIN wing
Original #
10
10
10
10
/ 7.63
Wt/original (mg)
0.454
0.535
0.684
0.896
Avg Wt (mg) 0.642
0.55 Surviving #
7.93
/ 6.74
7.90
/ 6.54
% Survival 100.0
10
10
10
10
Original #
WUoriginal (mg)
10
10
10
10
Avg Wt (mg) 0.691
0.690
0.742
0.689
0.644
1.1 Surviving #
24.2
/ 24.9
24.1
/ 25.3
% Survival 100.0
10
10 1
10
10
Original #
Wt/original (mg)
10
10
1 10
10
Avg Wt (mg) 0.721
0.755
0.788
0.661
0.681
2.2 Surviving #
% Survival 100.0
10
10
10
10
Original #
Wt/original (mg)
10
10
10
10
Avg Wt (mg) 0.730
0.763
0.777
0.703
0.676
4.4 Surviving #
% Survival 97.5
10
9
10
10
Original #
Wt/original (mg)
10
10
10
10
Avg Wt (mg) 0.770
0.698
0.756
0.870
0.757
Water Quality Data
Day
6
Control
pH (SU) Init/Fin
DO (mg/L•) Init/Fin
Temp (C) Init/Fin
High Concentration
pH (SU) Init/Fin
DO (mg/L) [nit/Fin
Temp (C) ]nit/Fin
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlorine(mg/L)
Temp. at Receipt (°C)
8.10
/ 7.59
7.88
/ 7.37
8.01
/ 7.63
1 8.37 / 7.85
1 8.10
/ 7.65
7.93
! 7.68
8.01
/ 7.80
7.93
/ 6.74
7.90
/ 6.54
7.92
/ 6.95
7.97 / 7.58
8.10
/ 6.98
7.90
1 7.10
7.98
/ 7.06
25.3
/ 25.1
24.8
/ 25.0
24.6
/ 25.2
124.2 / 24.8
24.2
/ 24.9
24.1
/ 25.3
124.1
/ 24.3
2 3 4 5 6
7.83
/ 7.63
7.87
/ 7.41
7.80
/ 7.60 1
7.99
/ 7.80
7.98
92
106
104
77
109
7 91
/ 7.01
7.91
/ 6.40
7.99
/ 6.88 17.96
<0.1
/ 7.56
8.11
/ 7.16
7.93
/ 6.93
8.05
/ 7.16
25.0
/ 24.7
24.8
/ 25.0
24.6
/ 24.2 125.2
/ 24.7
24.3
/ 24.8
24.2
/ 24.8
24.2
/ 24.3
1 9 3
8/15/2016
8/17/2016
8/18/2016
Normal
IM"
FI
24.3
23.6
23.7
92
106
104
77
109
95
657
772
691
<0.1
<0.1
<0.1
0.5
0.9
1.1
Dilution H2O Batch # 1063 1064 10651 1066
Hardness (mg/L) 48 44 44 46
Alkalinity (mg/L) 47 46 4751
Conductivity (umhos/cm) 197 175 186 195
1 ninin c,,- nr c ia1nn1
i•
hl;
Overall Result
ChV >4.4
Stats
Survival
Growth
Normal
IM"
FI
Hom. Var.
ri1
NOEC
4.4
4.4
LOEC
>4.4
>4.4
ChV
>4.4
>4.4
Method
Steel's
Dunnett's
Overall Result
ChV >4.4
Stats
Survival
Growth
Conc.
Critical Calculated
Critical Calculated
0.275
10 18
241 1.2788
0.55
10 20
2.41 0.5459
1.1
10 20
10 20
10 18
2.41 0.0972
2 41 -0.0299
1 2.41 -0.6357'
2.2
4.4

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50
Date: 08/24/16
Facility: ROANOKE RAPIDS SANITARY NPDES#: NCO024201 Pipe##: 001 County: HALIFAX
Laboratory Performing Test: MERITECH LABS, INC.
Comments:
X
Signature of Operator in Responsible Charge
Signature o L oratory�Supervisor * PASSED: 1.100 Reduction
Work Order: Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
14
iortn Caro.Lina uerioaapnnia
Chronic Pass/Fail Reproduction Toxicity Test
1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 24121123124120124126122122123121122
Adult (L) ive (D) ead IL IL IL IL L L IL L IL L IL L
Chronic Test Results
Calculated t = 0.330
Tabular t = 2.508
Reduction = 1.10
Mortality
Avg.Reprod.
0.00
22.67
Control
Control
0.00
22.42
Treatment 2
Treatment 2
REATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV
7.366. PASS FAIL
## Young Produced 23 27124120 22 20 24 21 23 21 21 23 . control orgs ECheck
producing 3rd
broodEOne
Adult (L)ive (D)ead L L �L]L L L L L L L L L 11 100.
1st sample 1st sample 2nd sample Complete This For Either Test
pH Test Start Date: 08/17/16
Control 8.09 8.14 8.06 8.00 8.17 7.91 Collecate
Sample 1: D
1: 08/15/16 Sample 2: 08/17/16
Treatment 2 7.99 8.12 7.90 7.98 7.93 7.95 Sample Type/Duration 2nd
1st P/F
s s s Grab. Comp. Duration D
t e t e t e I S S
a n a n a n Sample 1 X 24.3 hrs L A A
r d r d r d U M M
t t t Sample 2 X 23.6 hrs T P P
1st sample 1st sample 2nd sample
D.O. Hardness (mg/1) 46 ::::::....
Control 8.03 7.58 8.08 7.39 8.13 7.60
Spec. Cond.(pmhos) 168 657 772
Treatment 2 8.16 7.63 8.15 7.47 8.11 7.62
Chlorine (mg/1) ........ <0.1 c0 .1
LC50/Acute Toxicity Test Sample temp. at receipt (°C) ,,,,.... 0.5 0.9
(Mortality expressed as ., combining replicates)
Note: Please
Concentration Complete This
Section Also
Mortality
start/end start/end
0 0 P6 1-0 0 0 0 00
a *- .
0 0 0 *6 91
IC50 = . Method of Determination
9596 Con i ence Limits Moving Average Probit
-- . Spearman Karber _ Other
EControl
I
High
Conc.
-oH D. 0.
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Copied from DWQ form AT -1 (3/87) rev. 11/95 (DUBIA ver. 4.41)

- head Minnow Test
Date:8/4/2016
Effluent Toxicity Report Form -Chronic Fat
Facility: Roanoke Rapids Sanitary District
NPDES # NC00 24201 Pipe #: County: Halifax
Comments
Laboratory: Meritech, Inc.
I x
Signature o Operator in Re onsible QfArge
X
Signature of Laboratory Supervisor
MAIL ORIGINAL TO: Environmental Sciences Branch
Division of Water Quality
NC DE NR
1621 IVIail Service Center
Raleigh, NC 27699-1621t,�1
Test Initiation Date/Time
% Eft. ng #
Control Surviving #
I Original #
WUoriginal (mg)
7/26/2016
7/28/2016
5:32 PM
3
4
Avg WUSurv. Control 0.742
/o Survival 100.0
° �_�
Avg Wt (mg) 0.742
% Survival 100.0
Test organisms
(_ Cultured In -House
Outside Supplier
PP
!-hatch Date: 7/25/16
Hatch Time: 3:00 pm ct
1
2
10
10
10
10
10
10
10
10
0.713
0.722
0.751
0.780
10
10
10
10
` 0.275 Surviving #
10���
7/28/2016
Normal
10
Irl
Original #
10
23.6
110
0.689
Avg Wt (mg) 0.703
WUoriginal (mg)
0.7527
85
660
591
700
0.55 j Surviving #
910
<0.1
10
10
% Survival 97.5
I Original #
10
10
0.637
10
0.514
10
0.722
Avg Wt (mg) 0.661
Wt/original (mg)
0.772
1.1 Surviving #
10
10
10
10
% Survival 100.0
Original #
10
10
10
0.815
10
0.698
Avg Wt (mg) 0.749
Wt/original (mg)
0.781
0.701
2.2 Surviving #
10
10
10
10
%Survival 100.0
I Original #
10
1010
0.654
-6,758
10
0.793
Avg Wt (mg) 0.731
WUoriginal (mg)
0.717
4.4 Surviving #
10
10
10
10
% Survival 100.0
Original #
10
10
10
0.693
10
0.729
Avg Wt (mg) 0.749
WUoriginal (mg)
0.880
0.695
Water Quality Data
Day
3
4 5 6
Control 0 1 2
pH (SU) Init/Fin 8.19 / 7.81 7.91 / 7.65 7.92 / 7.64 7.8�7.75 86 / 7.78 7.94 / 7.71 7.96 / 7.59DO (mgJL) 1niUFin 7.72 / 7.49 7.63 16.79 7.90/ 6.81 7.960 I, 6.92 7.61 ! 7.35 8.03 / 7.23Temp (C) 1niUFin 24.4 / 24.2 24.3 / 24.6 25.2 / 24.5 24.4.6 / 24.7 24.8 / 24.6 24.6 / 24.5
n s 4 5 6
High Concentration
pH (SU) InitlFin
DO (mg/L) Init/Fin
Temp (C) Init/Fin
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlodne(mg/L)
Temp. at Receipt (°C)
o
7.76 / 7.73 7.91 / 7.65 7.90 / 7.57 7.87 / 7.63 7.84 / 7.77 7.93 17.77 7.95 / 7.62
7.54 / 7.42 7.73 / 6.68 7.83 / 6.64 7.81 / 6.71 7.59 / 6.70 7.14 / 7.57 8.07 / 7.20
24.6 1 24.6 24.3 1 24.9 25.0 / 24.9 25.3 1 24.5 25.1 / 24.5 24.4 / 24.0 24.3 / 24.0
2 3
7/25/2016
7/27/2016
7/28/2016
Normal
n
Irl
24.4
23.2
23.6
110
90
90
100
80
85
660
591
700
<0.1
<0.1
<0.1
0.5
0.7
1.0
Dilution H2O Batch # 1050 1051 10621 1053 1054
Hardness (mg/L) 40 46 42 42 42
Alkalinity (mg/L) 49 49 49 48 49
Conductivity (umhos/cm) 195 174 180 159 181
Overall Result
ChV >4.4
Stats
Survival
Growth
Normal
n
Irl
Hom. Var.
if -1
1171
NOEC
4.4
4.4
LOEC
>4.4
>4.4
ChV
>4.4
>4.4
Method
Steel's
Dunnett's
Overall Result
ChV >4.4
Stats
Survival
Growth
Conc.
Critical Calculated
critical Calculated
0.275
10 18
2.41 0.7712
0.55
10 16
2.41 1.6075
1.1
10 18
2.41 -0.1452
2.2
10 18
2.41 0.2203
4.4
10 18
2.41 -0.1552

-Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 08/03/16
Facility: ROANOKE RAPIDS SANITARY NPDES#: NCO024201 Pipe#: T0001 County; HALIFAX
Laboratory Performing Test: MERITECH LABS, INC. Comments:n1 � �J nn
Signature o Oper or Responsible Charge
X !�
Signature of Laborator'Y-��vi
ersor * PASSEDl ="14 0'S a"Rediuction
Work Order: Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Water Quality
N.C. DENR
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
iortn Carol3.na uerioaapnnia
Chronic Pass/Fail Reproduction Toxicity Test
'_ONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 1118119116118120121118119128124119122
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL IL IL IL IL
effluent 6: 1.16
CREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced 1124'25125128120124124126116115123126
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL ID IL IL IL
Chronic Test Results
Calculated t = -•1.906
Tabular t = 2.508
Reduction = -14.05
6 Mortality
Avg.Reprod.
0.00
20.17
Control
Control
8.33
23.00
Treatment 2
Treatment 2
Control CV
16.0806 PASS FAIL
control orgs pChec
producing 3rdbrood k One
100%
1st sample 1st sample 2nd sample Complete This For Either Test
PH Test Start Date: 07/27/16
Control 7.89 8.03 7.85 7.85 8.05 7.78 Collection (Start) Date
Sample 1: 07/25/16 Sample 2: 07/27/16
Treatment 2 7.83 8.12 7.95 7.89 7.90 7.77 Sample Type/Duration 2nd
1st PIF
s s s Grab Comp. Duration D
t e t e t e I S S
a n a n a n Sample 1 X 24.4 hrs L A A
r d r d r d U M M
t t t Sample 2 X 24.8 hrs T P P
1st sample 1st sample 2nd sample
D.O. Hardness (mg/1) 46 ,....,>. .,.......
Control 7.95 7.41 7.97 7.47 7.72 7.72
Spec. Cond.(gmhos) 154 660 591
Treatment 2 7.99 7.45 7.84 7.40 7.76 7.69
Chlorine(mg/1) ,.,...,. <0.1 <0.1
LC50/Acute Toxicity Test Sample temp, at receipt (°C) :o;seo;oo 0.5 0.7
(Mortality expressed as s, combining replicates)
Pl
Note.• ease
Concentration Complete This
Section Also
Mortality
start/end start/end
12C50 = % Method of Determination
956 Confidence Limits Moving Average_ Probit _
-- o Spearman Karber _ Other
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Copied from DWQ form AT -1 (3/87) rev. 11/95 (DUBIA ver. 4.41)
Control
High
Conc.
PH D. 0.
o
o
0
0
Note.• ease
Concentration Complete This
Section Also
Mortality
start/end start/end
12C50 = % Method of Determination
956 Confidence Limits Moving Average_ Probit _
-- o Spearman Karber _ Other
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Copied from DWQ form AT -1 (3/87) rev. 11/95 (DUBIA ver. 4.41)
Control
High
Conc.
PH D. 0.

Effluent Toxicity Report Form -Chronic Fathead Minnow Multi -Concentration Test
Facility: Roanoke Rapids Sanitary District NPDES # NC00 24201 Pipe #:
Laboratory: Meritech, Inc. Comri
x
Signature of Operator in ResponsibleChargeA,
x e-
Signature of Laboratory Supervisor 1
MAIL ORIGINAL TO: Environmental Sciences Branch
Division of Water Quality
NC DENR
1621 Mail Service Center
Raleigh, NC 27699-1621
Test Initiation Date/Time 6/28/2016 4:00 PM Avg Wt/Surv. Control 0.516
% Eff. Repl.
1
2
3
4
Control Surviving #10
18.00
10
10
10
Original #
10
10
10
10
Wt/original (mg)
0.592
0.446 1
0.518
0.509
0.275 Surviving #
10
10
10
10
17.26
Original #
10
10
10
10
/ 24.4
Wt/original (mg)
0.616
0.560
0.570
0.610
/ 25.4
0.55 Surviving #
10
10
10
10
Original #
10
10
10
10
Wt/original (mg)
0.583
0.532
0.537
0.639
1.1 Surviving #
10
10
10
10
Original #
10
10
10
10
Wt/original (mg)
0.630
0.544
0.568
0.590
2.2 Surviving ,#
10
10
10
10
Original #
10
10
10
10
Wt/original (mg)
0.630
0.704
0.593
0.613
4.4 Surviving #
10
10 j
10
10
Original #
10
10
10
10
Wt/original (mg)
0.565
0.642
0.766
0.653
Water Quality Data
Day
Control
0
1
2
3
pH (SU) Init/Fin
DO (mg/L) Init/Fin
Temp (C) Init/Fin
% Survival 1 100.0
Avg Wt (mg)0:516
% Survival 100.0
Avg Wt (mg) 0.589
% Survival 100.0
Avg Wt (mg) 0.573
% Survival 100.0
Avg Wt (mg) 0.583
% Survival 100.0
Avg Wt (mg) 0.635
% Survival 100.0
Avg Wt (mg)F 0.657
4 5 6
Date:7/7/2016
County: Halifax
Test Organisms
( Cultured In -House
Outside Supplier
Hatch Date: 6/27/16
Hatch Time: 3:00 PM
7.85
/ 7:69
8.09
/ 7.78
8.05
/ 7.90
18.00
/ 7.90
18.21
/ 7.83 1
8.08
/ 7.83
8.08
/ 7.74
8.10
/ 6.95
7.96
/ 7.00
7.80
/ 7.89
821
/ 7.29
7.85
1 7.03
7.89
17.26
7.98
/ 7.09
24.3
/ 25.9
24.1
/ 24.4
24.9
/ 24.9
24.3
/ 24.5
24.7
/ 25.4
24.2
125.2
24.2
/ 24.5
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlorine(mg/L)
Temp. at Receipt (°C)
1 2 3
6/27/2016
High Concentration
0
1
2
3
4
5
6
-
pH (SU) Init/Fin
7.84 / 7.68
7.99 / 7.67
8.05 / 7.98
8.10 / 7.91
1 8.15 1 7.87
I 7.99 / 7.84
8.04 / 7.74
<0.1
DO (mg/L) Init/Fin
8.12 / 6.85
7.97 1 6.62
7.80 / 7.95
8.32 V 7.25
7.88 / 7.11
7.83 / 7.08
7.94 / 6.96
Temp (C) Init/Fin
24.4 / 25.7
24.3 / -25.1
24.3 / 25.4
25.0 / 24.6
24.7 / 25.7
25.0 / 25.2
24.5 / 25.6
Sample
Collection Start Date
Grab
Composite (Duration)
Hardness (mg/L)
Alkalinity (mg/L)
Conductivity (umhos/cm)
Chlorine(mg/L)
Temp. at Receipt (°C)
1 2 3
6/27/2016
1 6/29/2016
6/30/2016
Normal
Critical Calculated
11-11
23.2
23.8
23.8
94
112
144
115
153
180
560
630
750
<0.1
<0.1
<0.1
0.9
1.1
0.9
Dilution H2O Batch # 1039 1040 1041 1042
Hardness (mg/L) 46 44 42 -47o-
Alkalinity
0
Alkalinity (mg/L) 44 47 51 42
Conductivity (umhos/cm) 170 179 182 172
Overall Result
ChV >4.4
Stats
Survival
Growth
Normal
Critical Calculated
11-11
Horn. Var.
10 18
I "I
NOEC
4.4
4.4
LOEC
>4.4
>4.4
ChV
>4.4
>4.4
Method
Steel's
Dunnett's
Overall Result
ChV >4.4
Stats
Survival
Growth
Conc.
Critical Calculated
Critical Calculated -
0.275
10 18
2.41 -1.9113
0.55
10 18
2.41 -1.4844
1.1
10 18
10 18
2.41 -1.7537
2.41 -3.1198
2.2
4.4
10 18
2.41 -3.6847"

Attachment C

Attachment C
Date
Effluent
Influent Upstream
Downgtream
9/8/2013
92
10/7/2013
76
92
11/4/2013
1G0
11/6/2013
52
68
12/2/2013
116
1/6/2014
64•
96
2/3/2014
72
32
36
2/10/2014
56
72
43
3/3/2014
64
4/7/2014
60
4/8/2014
56
48
5/5/2014
104
6/2/2014
128
7/7/2014
1�2
7/8/2014
62.
36
48
8/4/2014
68
36
40
9/8/2014
64
10/6/2014
60
X0/13/2014
128
36
36
X0/20/2014
68
40
3
11/3/2014
68
12/1/2014
68
1/5/2015
52
28
32
1/7/2015T
76
32
32
RRSD WWTP
HARDNESS M9 L
Date
Effluent
Influent Upstream
Downstream
2/2/2015
44
3/2/2015
44
4/6/2015
76
4/21/2015
40
32
5/4/2015
96
6/1/2015
148
7/1/2015
32
36
7/6/2015
56
8/3/2015
144
9/1/2015
108
10/7/2015
40
44•
-.0/12/2015
76
11/2/2015
76
12/7/2015
14.2
1/4/2016
62.
1/6/2016
36
40
2/1/2016
52
3/9/2016
8$
4/4/2016
128
4/5/2016
40
3
5/2/2016
90
6/6/2016
72
7/11/2016
112
28
32
8/1/2016
76

Attachment D

Attachment D.
Biosolids Program
Roanoke Rapids Sanitary District
NPDES Permit No. NC0024201
Land Application Permit No. WQ0001989
Synagro Technologies, Inc. manages Land application of residuals. The Roanoke
Rapids Sanitary District holds the land application permit and provides a licensed ORC
and back-up ORC as required. Synagro Technologies, Inc. provides transport and
application equipment and personnel. District personnel perform all treatment of
residuals.
At present, the District has permitted approximately 1,986 acres of farmland for residual
application including 91 acres owned by the District. Approximately 3.1 million gallons
of -4% solids is applied to an estimated 300 acres per year. Soil pH is adjusted to
achieve a soil pH as specified by permit conditions.
The last plant addition, which provided treatment capacity, occurred in 1983; however,
several upgrades have been added since that date specifically for the solids .program.
A system to thicken WAS from the 0.5% solids range to the 3-4% solids range was
accomplished by the addition of two gravity thickeners and a drum concentrator. The
drum concentrator has since been replaced with a gravity belt thickener. Pathogen
reduction and Vector Attraction Reduction for WAS was accomplished by adding a lime
stabilization, mixing, and holding system to maintain proper pH control. Primary solids
are treated through three anaerobic digesters to meet 38% Volatile Solids Reduction
and Fecal destruction for VAR and PSRP with solids stored for liquid application.
Storage of treated solids was provided by the addition of an above ground 1.0 MG tank
for primary storage and by retrofitting two abandoned clarifiers adding 0.375 MG each
to provide a total of 1.75 MG for emergency storage. Sand drying beds are also
available to store solids in the event that liquid storage is unavailable.
The alkaline stabilization .process and anaerobic digested .primary sludge meets all
requirements for pathogen and vector attraction reduction for Class B biosolids.

Attachment E

" T j
TECHNICAL MEMORANDUM
To: Copies:
Steven Ellis File
Gregg Camp
Isabelle Wilcoxin
Roanoke Rapids Sanitary District
From:
Tim Devine, PE / Mary Sadler, PE
Date:
September 15, 2016
Subject:
Reduction of Monitoring Frequency for Exceptionally Performing Facilities
Roanoke River Wastewater Treatment Plant
NPDES Permit NCO024201
In support of the National Pollutant Discharge Elimination System (NPDES) permit renewal, a monitoring
frequency reduction analysis was conducted on the Roanoke River Wastewater Treatment Plant (WWTP)
Discharge Monitoring Report (DMR) data between August 2013 and August 2016. The monitoring
frequency reduction analysis was performed in accordance with the Division of Water Resources (DWR)
guidance document, Reduction of Monitoring Frequencies in NPDES Permits for Exceptionally Performing
Facilities (October 2012).
The Roanoke River WWTP received a reduction in monitoring frequency for CBODs, ammonia, and fecal
coliform in the 2013 NPDES permit renewal. Table 1 provides a summary of DMR data from August 2013
through August 2016 that supports a continued reduction in the monitoring frequency for CBODs,
ammonia, and fecal coliform. The three-year arithmetic mean of effluent data is less than 50 percent of the
monthly permit limit for CBODs and fecal coliform. Less than 15 of the daily effluent sampling results are
over 200 percent of the monthly average limit for CBODs. Less than 20 of the effluent sampling results are
over 200 percent of the weekly average limit for fecal coliform. The Roanoke Rapids WWTP does not
have a permit limit for ammonia; however, the 3 -year average effluent ammonia discharge is 3.9 mg/L with
a maximum discharge of 18 mg/L. Even though comparisons cannot be provided for the effluent ammonia
with respect to a permit limit, the high quality effluent supports a continued reduction in the monitoring
frequency for ammonia. The Excel Spreadsheet, NPDES Permit NCO024201 MRF.xIs, contains the data
for the monitoring reduction frequency analysis. This spreadsheet will be transmitted to DWR upon
request.
Per DWR guidance, the following criteria has also been met by Roanoke Rapids Sanitary District:
• The Roanoke River WWTP received two Notices of Violation (NOV) and two Notices of
Deficiency between November 2013 and February 2014 for fecal coliform and total
suspended solids (TSS). The violations were due to a mechanical failure by the trickling
filter rotary distributors despite an ongoing maintenance schedule. The NOV did not
Hazen and Sawyer • 4011 WestChase Blvd, Suite 600 • Raleigh, NC 27607 Page: 1/3

Hazen
result in any civil penalty assessments. The correspondence from the District responding
to the NOV is provided in Attachment 1.
The District and Roanoke River WWTP employees have not been convicted of any
criminal violations of the Clean Water Act (CWA).
The Roanoke River WWTP is not currently under a Special Order of Consent (SOC).
The Roanoke River WWTP is not on EPA's Quarterly Noncompliance Report for either
CBOD5, ammonia, or fecal coliform.
The Roanoke River WWTP has met the requirements to be categorized as an Exceptionally Performing
Facility per DWR guidance and is eligible for a continued reduction in the monitoring frequency of CBOD5,
ammonia, and fecal coliform bacteria.
Table 1: Summary of Monitoring Frequency Reduction Analysis for Roanoke River WWTP
Approval Criteria 1,2 CBODs Ammonia TSS Fecal coliform
3 -year average _ _ _ 5.4 mg/L 3.9 mg/L— 20.1 mg/L _ 38 / 100mL
Number of data points 304 312 -- — 767 —_ _ 317
Monthly Average Permit limit 25.0 mg/L No limit 30.0 mg/L — 200 / 100mL
Weekly Average Permit limit _ 37.5 mg/L No limit — 45.0 mg/L 4001 100mL
Percent of permit limit --- — -- 22% ---- 67% — 19% --^
Number of daily samples over 0 __ 49 ----
200% of monthly average limit
Number of samples over 200% of ____ _--_ 6
weekly average limit
Non -monthly average violations in 0 0 0 0
2016 ---- -----
Data in compliance with DWR Yes
Guidance for Monitoring Frequency Yes Yes 3 No
Reduction? _
1 Per Division of Water Resources Guidance Regarding the Reduction of Monitoring Frequencies in NPDES
Permits for Exceptionally Performing Facilities dated October 2012.
2 Analysis is representative of data from August 2013 through August 2016.
3 Maximum discharged effluent ammonia concentration of 18 mg/L over data period.
Page: 2/3

ATTACHMENT I
Roanoke Rapids Sanitary District Response to Notice of Deficiency / Notice of Violation:
NOD -2014 -LV -0034, Case No.'s NOV-2014-LV-0190 and NOV-2014-LV-0191
Page: 313

P.O. Box 308
pKE R 1000 Jackson Street
qA�� Roanoke Rapids, NC 27870
Roanoke Rapids •Sanitary District [phone]
u
Fax: [phone]
y `G ornw.rrsgd.oa-g
June 6, 2014
CERTIFIED MAIL 7010 3090 000 3778 0494
RETURN RECEIPT REQUESTED
Mr. Danny Smith, Supervisor
North Carolina Division of Water Resources
1628 Mail Service Center
Raleigh, N. C. 27699-1628
Re: NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River WWTP
NOD -2014 -LV -0034
Case No. NOV-2014-LV-0190
Case No.-NOV-2014-LV-0191
Halifax County
Dear Sir:
Please be advised that all known remedial actions have been taken to correct problems
leading to the referenced action issued via your correspondence(s) dated April 23, 2014 (2)
and April 22, 2014. Attached for your reference is our November 2013 DMR, its -
accompanying remedial actions report and resulting NOTICE OF DEFICIENCY NOD -
2014 -LM -0001. We also request the following additional information is favorably
considered regarding the noted violation(s) and in support of our assertion of compliance
conformance:
BACKGROUND: The Roanoke Rapids Sanitary District (District) expends significant funds and
resources to maintain NPDES compliance. In the early to mid -2000's District budgeted in excess
of $250,000 to replace one of two Rotary Distributors followed by another $250,000 -plus the
next fiscal year. The existing Distributors, installed in the early 1980's, were deteriorating from
the inside out despite being regularly painted over the years. This third set of distributors was
different from the original set installed in the early 1960's and the second set, of the early
1980's, in two major ways. First, rather than carbon steel the new units were fabricated from
stainless to negate the need for external painting and slow the internal deterioration process
and secondly, rather than top load bearings the new stainless were fitted with bottom load
bearings. The bearing on the first installed Distributor failed and was replaced at a cost of
$11,500 after only a few years of service.

NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECONMIENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River V rl?
NOD -2014 -LV -0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
The following year, the same failure occurred on the second installed Distributor. Hence,
remedial construction of the "new" Distributors was required. The District decided not to do
another bottom bearing repair. It was discovered the Distributors could be retrofitted with top
load bearings for around $175,000. It was decided to start with the second failed unit since the
first unit had already received a second lower bearing. Work actually began early even before
July 11 FY14. The Distributor was removed and sent to the fabrication shop on June 20th, 2013.
The reinstall date was set for September 13th, 2013. This was good timing to get the first
retrofitted Distributor on line while conditions were suitable for zoogleal mass to restore
quicker. The second unit would be removed and retrofitted once the first unit recovered.
However, the unit was not installed until October 28, 2013 due to concealed damage; which had
to be repaired prior to other modifications being made. Further, the unit was discovered to
have been installed out of plumb and, at the manufacturer's recommendation, the Distributor
could not go on line because of possible damage. The installer did not return until mid-
December to re -plumb the Distributor. Finally on December 18th the distributor went on line.
This was three months longer than first anticipated. Unfortunately, the second Distributor
began to fail in November. Much effort was put into keeping it turning to maintain zoogleal
growth. There are three recirculation pumps available for Rotary Distributor/Trickling Filter
management. All three pumps were run constantly. Maintenance personnel increased oiling
and greasing schedule. The Distributors have a motion sensor on them and each time it stopped
the operation staff along with maintenance would push the Distributor to keep it turning.
Finally, a backhoe was used to pull the Distributor with a strap to keep it turning. The
Distributor failed. This occurred before a zoogleal mass was established on the newly installed
Distributor.
This condition led to bulking sludge. Wastewater was basically leaving the primary clarifiers
and entering the Secondary System with no buffering from the Trickling Filters. This resulted in
an organic overload of the Secondary System. Microscopic examination did not reveal excess
filamentous growth. Five minute MLSS settleabilites ran in the 950-990 range. Normally this
would be in the 400-600 range. To help bring the F/M ratio back into balance the wasting was
stopped. This increased the solids inventory in the Secondary System above what is normally
needed to run the system.
SUSPENDED SOLIDS MANAGEMENT: There is a polymer feed system set up ahead of the
Secondary Clarifiers. It is used periodically to control solids washout during high flows and to
help control alum sludge received from the water treatment plant. It has been on line
approximately 10 years. It is also used to help percent removal during wet weather events with
high flows that dilute influent solids to achieve better settling out effluent suspended solids.
This system has kept the wastewater plant compliant for solids reduction on numerous
o.\31181-raWl 181a9mglamodedmfo In dm Page:
2/6

NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River W WTP
NOD -2014 -LV -0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
occasions. The system is set up for infrequent use for short periods of time (days), as needed.
Polymer is a difficult chemical to work with. Moisture in the wrong location, from sweating to a
leaking valve causes polymer to gum up. To prevent this, operations was asked to monitor the
secondary clarifiers more often to make sure the polymer was still coagulating secondary solids.
This was a visual observation. Another way to check the feed is with a draw down tube located
on the pump. Mineral oil is added to the tube and a draw down is observed. If the draw down
slows down with the variable speed drive of the pump at the same speed this could indicate a
pump problem or a gumming problem. Feeding mineral oil this way not only checked the feed
system but also cleansed gumming of the pump. Operations was asked to perform this task
more and regularly. Operations were also trained to know where common gumming areas in
the system and how to clean them. During daily morning meetings the operators were
reminded of the criticality of this. The maintenance staff was also kept informed in these
morning meetings. Maintenance was asked to check the system each afternoon before leaving.
Operations and maintenance were kept informed on the status of the plant. They were also
instructed that if anything went awry with the system it took precedence over all other work
going on at the time. Maintenance was also put on call for weekend problems. Several things
were done to make the system more reliable. Hot water used in the correct location can help
with gumming. An on-line demand hot water unit was added. The bulk polymer storage tank
was cleaned. The polymer pump was relocated right next to the bulk polymer storage tank to
reduce the length of piping and elbows where gumming was occurring and a second mineral oil
flush system was added to be able to flush the entire suctions side of the pump. Suspect check
valves were replaced with ball valves. In addition, maintenance was instructed to keep all spare
parts for the feed pump and feed system in stock at all times. As one was used it was
immediately replaced.
As evidenced by the DMR's, the polymer did a great job of controlling the bulking sludge.
Lots of TSS numbers were single digit or low double digit. The few triple digit numbers would
ruin the TSS average. Three factors contributed to these high numbers; pump problems,
gumming or high flows from I&I. As mentioned earlier this polymer is only used (usually)
occasionally and only for a few days. During the period of Rotary Distributor bearing retrofitting
the polymer was used for one hundred and six days in a row. The average annual polymer cost
for the past five years was around $7,800.00. This year nearly $28,000, over triple the past five
year average, was spent on polymer.
Polymer used at this location is received in 55 gallon drums. It is a small area of operation
and can only accommodate a few barrels at the time. Operations were asked to monitor
inventory closely and keep it on hand at all times. However, during cold days polymer would
not be shipped due to fear of freezing the polymer and rendering it ineffective. This happened
on several occasions. In these cases staff would take empty 55 gallon barrels to the bulk
0.131181_,ael 181-009�.B.—odad-f.Itr dm
Page:
3/6

NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River W WTP
NOD -2014 -LV -0034
I Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
polymer storage for the waste activated thickening process. Using a bypass pump the barrel
I would be filled and transported across the plant and added to the secondary polymer feed
system to maintain control over the effluent TSS. Unfortunately the plan to establish zoogleal
growth on the first retrofitted Distributor before removing the second for retrofitting did not
I work out. So it was removed anyway on 1-13-2014. This unit was reinstalled on 3-10-14.
However during installation a seal was inadvertently missed. The Distributor had to be
Idisassembled once again to install the seal. Finally on 3-24-2014, the Distributor went on line.
Even with the omission of'the seal, the second Distributor rebuild took only a little over two
months versus six months for the first unit.
This winter was unusually colder, overcast and wetter than past years. Effluent temperature
dropped onto Celsius single digits, something not seen in many years, if ever. Also daylight hours
Iwere shorter. This made it more difficult and took longer to establish the zoogleal growth.
Finally around late February to early March the zoogleal mass began to appear on the first
installed retrofitted Distributor. The bulking sludge stopped and 5 minute settleabilites began
to return to normal. The zoogleal mass returned shortly after on the second retrofitted
Distributor. This came quicker because warmer ambient and, wastewater temperatures and
alonger daylight hours. Both filters now have well established zoogleal mass on them and the
plant has returned to expected operation.
DECEMBER VIOLATIONS —FECAL/TSS(0190): 12-31-2013 monthly TSS average 38.83 (Limit
value=30 mg/1), Fecal Coliform Weekly Geometric Mean 502 col/100ml (Limit value
=400col/100m1). With only three required sampling days left in December the monthly TSS
average was 15.6 mg/I. That included one high TSS of 105.6 mg/I day. This was due to a
malfunction in the polymer feed system. Then on the 29th and 30th, 2.4 inches of rain fell. The
maximum flow for the two days was 16.2 and 16.1 MGD respectively with the daily totals being
9.1 and 9.3 respectively. The total plant capacity is 8.34 MGD. The polymer feed could not
control the washout of the finely dispersed bulking sludge at these high flows. As a result, the
two days TSS's were 103.1 and 396.2 mg/I respectively. However as the flow lowered to a
maximum of 8.0 MGD on the 31St, with a total of 5.3 MGD, the effluent TSS dropped to 11.4
mg/I. This demonstrates the ability of the polymer to control the bulking sludge under more
normal flow conditions. December received 8.1 inches of rain in the month. It did not take as
much precipitation to significantly increase flows. The monthly flow average was 4.0 MGD as
compared to the previous December of 2.8 MGD. The yearly average for 2013 was 3.5 MGD.
Demand for hypochlorite feed significantly increased in December. Feed rate was increased
by approximately 50%. Comparatively, in December 2012, the monthly pre -removal residual
was 576ug/I versus a pre -residual 667ug/1 in December 2013. In December 2012 this resulted in
a monthly geometric mean of 7 fecal colonies. This compared to a monthly geometric mean in
0.X3118] -re ajjsj_0091-&o-.&dmfoltrd- Page:
4/6

NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES #NC0024201
Roanoke River V VTP
NOD -2014 -LV -0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
December of 2013 of 197 fecal colonies. Even with the increased hypochlorite feed and extra
sampling and testing, some on the weekend, the weekly limit could not be met. Additionally,
Hypochlorite was increased to ensure compliance for the month. Comparing the subsequent
months as the bulking sludge subsided, fecal Coliform counts went down. This may only be a
coincidence or there may have been some other interference. Nitrites have been an issue in the
past. December nitrite was up some over November.
JANUARY VIOLATIONS —TSS (0191): Date 1-4-14, weekly average 78.93 mg/I (limit value 45.0
mg/1); this week contains in its average three data points from the previous month. Two of
which caused the monthly non-compliance for December discussed above. It is not understood
how the same two data points can be used in compliance judgment to levy two different
violations. The District feels this is a case of double jeopardy and is incorrect. A weekly violation
should not result in a monthly violation since a monthly violation suggests a chronic condition;
while the results of the other four weeks in December were compliant. However, we recognize
a violation and have previously discussed our actions to correct the problem.
Date 1-18-14, weekly average 106.29 (limit value 45 mg/1); this week had some higher flows
along with issues associated with the polymer feed system. As the flow for the week decreased
and repairs to the polymer feed system were completed, TSS values trended down. If not for
the anomaly of 570.0 mg/I TSS on the 13th, the same day the trickling filter was taken off line,
the week may very well have been compliant.
Date 1-31-14, monthly average 47.08 mg/I (limit value 30 mg/1); this month had some slightly
higher flows but mostly there were polymer feed system problems. Without the anomalies of
570.0 mg/I, the highest TSS reported since 1992, on 1-13 and 152.0 mg/I on 1-27, the monthly
average may well have been compliant. Polymer feed parts were available for all issues as they
arose. However, this month had more than its share of gumming problems. This was the month
that most of the aforementioned improvements were made to the system.
FEBRUARY DEFICIENCY — TSS (0034): Date 2-1-14 weekly average 46.19 mg/I (limit value
45.0). February was a turning point month from all the issues that were experienced since
November 2013. The monthly average was 16.1 mg/I. Regardless, the deficiency experienced
the last week of January can directly be attributed to the combination of removal of the trickling
filter on January 13th, cold, wet, overcast days during the period and faulty polymer feed
equipment. Our most experienced operators were on duty negotiating these difficult conditions
during the final week of January and through their efforts we barely missed our permit limit for
the week.
SUMMARY: Since August of 1992, the Roanoke Rapids Sanitary District Wastewater
Treatment Plant's operation has had an excellent compliance record. Since this date through
031181-,dG1181-0091=8k—d-didoltr dm Page:
5/6

NOTICE OF DEFICIENCY/NOTICE OF VIOLATION AND
RECOMMENDATION FOR ENFORCEMENT
NPDES 9NCO024201
Roanoke River W W'IP
NOD -2014 -LV -0034
Case No. NOV-2014-LV-0190
Case No. NOV-2014-LV-0191
Halifax County
October 31St of 2013 or 7969 days there have been only four daily (instantaneous) infractions;
one for a missed daily analysis for ammonia nitrogen, one for pH, and two for chlorine residual.
Both of which would not have been infractions had the State previously raised the limit to
50ug/I. Since this date through October 311 of 2013 or 1132 weeks, there have been only six
weekly infractions; four for TSS and two for CBOD. Since this date through October 31St of 2013
or 262 months there has been only four infractions; one for TSS, one for CBOD, and two for
percent removal. There was two times each of six years running where no infractions occurred.
This excellent record is due to the support and guidance of administration and the dedication of
staff. This support, guidance and dedication did not wane during the difficult months of
November 2013 through February 2014. The District saw the need to make improvements and
as usual appropriated funds to make this happen. The wastewater plant became a victim of bad
luck (mechanical failure) and one of the worst stretches of bad weather not seen in years.
In addition to the cost to retrofit the two Rotary Distributors the District spent additional
money on extra sampling and testing, overtime, mineral oil, Distributor oil, pump parts, polymer
feed system improvements, polymer, electrical, disinfection chemicals, and change orders. In a
six month timeframe the District spent well in excess of $200,000 on one project to improve
plant operations in an attempt to maintain compliance.
The District has successfully conducted remedial construction activities, as evidenced by
our initial replacement of our Trickling Filters, without a Special Order by Consent but
now realizes it to be a useful tool for satisfactorily completing future activities. Should you
require additional information, please do not hesitate to contact me.
Very truly yours,
R. Danieley Brown, P.E.
Chief Executive Officer
Enclosures
Cc: Gene St. Clair, Chairman
Mack Wiggins
Gregg Camp
File
a\31181-raMl J81-0091®8lnowada&f0ltrdw Page:
6/6

Attachment F

Mercury Minimization Plan
NPDES Permit Renewal Summary Report
The Roanoke Rapids Sanitary District (District) Wastewater Treatment Plant (WWTP) current
NPDES Permit (permit), issued in 2018 contains a requirement for the development of a Mercury.
Minimization Plan (MMP). The MMP's purpose is to help reduce amounts of mercury received
by the WWTP and receiving stream, Roanoke River. The MMP focuses on best management
practices (BMP's) to accomplish mercury reduction. The WWTP does not have a mercury limit
nor a monitoring_ requirement in its current permit. Mercury. testing has been necessitated by
current permit due to the Priority Pollutant Analysis (PPA) Scan and due to the Long Term
Monitoring. Plan (LTMP)_ requirement of the Industrial Pretreatment Program. As a result of a
detectable level of mercury in the WWTP effluent and flows exceeding two million gallons a day
(MGD), a MMP is required. The MMP contains needfulness mercury testing_ as well. The permit
required the development of a MMP within 180 days of the 2012 permit issuance and subsequent
implementation within two years. These requirements were met. In addition, a requirement of
the MMP is a summary report describing activities during the current permit period for submittal
with the next NPDES permit renewal application.
Other than permit renewal summary report requirement the MMP addresses four basic areas:
evaluation of non-domestic sources, control measures, tracking and monitoring, and
implementation of control measures.
Evaluation of non-domestic users
In order for WWTP personnel to establish and evaluate the potential sources contributing
mercury to the treatment system, information gathering was conducted. This was accomplished
primarily through conference and workshop attendance and extensive website research.
A target list of non-domestic users was developed. The list focused chiefly on significant and non-
significant industrial users, medical and dental facilities. Industrial users' permit required
mercury monitoring data was reviewed. This information was correlated with influent and
effluent data at the WWTP. Additionally, industrial users were instructed to do an internal review
of chemicals used in their process and evaluate for mercury presence. If amounts were

discovered above industrial level averages, alternative use chemicals were requested. Another
means of industrial user over sight is through the pretreatment program annual facility
inspection. Inspections offer opportunity to discuss mercury issues such as chemical usage and
proper disposal. Further, industry slug -spill plans required by the pretreatment program control
the accidental release of mercury to the POTW.
As well as industrial users, medical and dental facilities were surveyed. Contact lists were in part
established through the use of the telephone directory yellow pages. Surveys were both written
form and telephone. The surveys served several purposes: one) awareness of the problems with
mercury introduction into the WWTP; two) education on identifying mercury on location and;
three) best management practices for use and disposal.
The District continuously evaluates potential non-domestic sources of mercury contribution to
the WWTP. When an existing_ facility makes a customer service request, office staff notify the
WWTP if there may be a need to investigate potential contaminants. Also, the District is a
member of the City of Roanoke Rapids' Development Review Committee and reviews a new
facility's construction building plans as a condition of being issued a City building permit. This
review provides a means to examine potential contaminants.
Control Measures
Pollution Prevention: An internal review of chemicals and equipment that may contain mercury_
is ongoing at the WWTP. Alternate chemicals and equipment containing lesser or no amount of
mercury are evaluated for use. This internal review has been successful in accomplishing,
mercury reduction throughout the plant site.
Housekeeping Spill Control and Collection and Education: Employees at the WWTP have been
informed of the MMP. Awareness has been raised on the importance of mercury control
procedures to minimize the possibility of any spill or release. In addition, identification of
possible mercury containing items has been recognized. Employees are informed on the use of
labels, Safety Data Sheets (SDS), suppliers, manufacturers and website for information on
mercury presence. The WWTP has a stormwater permit. This permit requires the development
of a stormwater pollution prevention plan (5131313). The goal of the SPPP is to prevent the
accidental release of contaminants from leaving the plant site. Mercury is one of the
contaminants which must be controlled. Annual training includes spill containment, clean up
and proper disposal.
The WWTP has hundreds of compact florescent lamps (CFCs), florescent tube lamps, and metal
halide lamps. The first two are inside bulb use with the latter being mainly outside use.
Recyclingof these mercury containing lamps has been occurring since the early 2000's. When
low level mercury containing lamps became available they were installed as the regular lamps
burned out. Again the low level lamps were recycled as well. With light -emitting diode (LED)

lamps; which contain no mercury, now on the market, the WWTP has begun to replace all
mercury containing lamps with LED lamps. To date, 5% of CFL's and florescent lamp tubes
remain to be changed out. The metal halide lamps have begun to be replaced as well with
approximately 35% of these type lamps remain.
As equipment is upgraded or added, mercury free devices and accessories are sought. One
example would be mercury -containing level indicating or actuating float switches. Many tanks,
pumps, and mixers use these switches. As these fail or are upgraded, they are being replaced
with mercury -free level indicating or actuating devices. As existing switches are removed, they
will be sent to a recycler. New equipment added to plant processes are required to be
controlled with mercury free devices.
Laboratory Practices: The WWTP laboratory has thoroughly reviewed chemicals and equipment
for mercury presence. Two tests being performed incorporated the use of mercury. Ammonia
Nitrogen is permit required and Chemical Oxygen Demand (COD) is for process control. The
permit required test required a dry chemical in its procedure which contained mercury. To
eliminate mercury, an alternative Selective Electrode Method test procedure is now performed.
The process control test required the use of a vial that has a liquid in it which contained
mercury. The lab switched to a vial that has no mercury for process control testing. However,
mercury containing vials are still used annually for blind studies to maintain certification and
quarterly as quality assurance/control. A recycling kit was obtained from the supplier for these
- used vials. When the kit reaches capacity it is recycled. Mercury containing thermometers
used throughout the lab and various locations around the plant site have been replaced with
alcohol filled thermometers. Because of the small amount of mercury used in the lab a spill
recovery/cleanup kit is reserved.
Public Outreach: The District has been active in making available educational information
regarding issues with mercury. The system annual performance report describes and addresses
the goals and requirements of the MMP. The annual consumer confidence report; a synopsis of
the system annual performance report posted on the District's website, includes an attached
MMP and the Mercury Minimization Plan Implementation (MMPI), document. This document is
a brief overview of the MMP. It discusses problems with mercury in the environment, the MMP
goals, identification of sources of mercury, proper disposal, and web links where additional
information can be obtained. The District released a public service announcement (PSA) to the
local newspaper and radio station. It touched on the problems with mercury in the environment
and its impact on the WWTP. Further, the PSA announced that the District would be holding a
mercury collection day. In addition, a three and one half by eight -foot -long. banner announcing,
the collection day was posted at the collection site located by a busy thoroughfare. The event
was also discussed at the monthly public board meeting., The collection day was set for a
Saturday, June 18, 2016. Phone calls were made to medical and dental facilities during the prior
week to be sure they were aware of the collection day. it was decided to collect mercury or any
device containing. mercury. The collection day was a success with 73 mercury containing items

(excluding fluorescent light tubes) removed from the environment. A regional recycling facility
was contracted for disposal of the collected mercury. The collection committee met soon
afterwards to go over the day's proceedings and discuss lessons learned for improved future
mercury collection days. It was also decided to keep a collection container on hand and receive
mercury at any time.
The WWTP conducts tours of the facility throughout the year. These tours provide an excellent
opportunity to educate the general public. Mercury awareness is a part of this education
opportunity. In addition, District personnel have on occasion had opportunity to speak at various
functions and locations. This provides opportunity for educating about mercury issues.
The summary of the MMP for permit renewal can also be posted on the District's website as
further rrreans to keep the public informed of the efforts being made to control mercury issues.
Tracking and Monitoring
In order to assess the implementation of control measures the WWTP will make evaluations of
several areas. Continue to review water customers and new construction projects. Survey
annually a minimum of ten percent. (10%) of non-domestic users. This will include industrial,
medical and dental facilities, and any other potential source identified as a mercury contributor
to the WWTP. The surveys will be conducted primarily through a written questionnaire and serve
as an awareness reminder. To encourage participation, self-addressed postage paid return
envelopes are provided. (Nearly 75% of the recent written questionnaires were responded to.)
Secondly, phone questionnaires will be conducted. This will target the non-responsive written
questionnaires that will be sent out. The pretreatment program will continue to be an integral
part of the MMP. The annual industry pretreatment inspection will be a valuable tool for
discussing mercury issues and as a reminder to be vigilant about assessing bulk use chemicals.
Influent and effluent mercury is•monitored quarterly as a requirement of the pretreatment
program LTMP. One year before the next headworks analysis (HWA) is due the testing frequency
increases too monthly. The testing requirement calls for standard method level testing (method
245). This method can detect to as low as 200 parts per trillion. All Influent results are less than
this level. To have a better understanding of the actual amount of mercury present ,low level
testing (method 1631) has been done. This method can detect down to 1 part per trillion.
Effluent monitoring is done as a requirement of the annual PPA Scan. Testing for this
requirement calls for method 1631. In addition, the WWTP has been active in looking for side
streams into the plant such as septic tank haulers and porta john wastes; which have been tested;
leachate from the county solid waste transfer station has been monitored; and residuals from
the water treatment plant process discharged to the WWTP have been analyzed. Additionally,
water treatment test records for mercury levels in finished drinking water have been reviewed.

The WWTP produces a solids by-product or biosolids. Biosolids are land applied to various land
parcels in the area. In order to monitor and control the various constituents, including mercury;
land applied testing of the biosolids is conducted regularly.
A filing system has been developed for tracking and monitoring. The laboratory and
administration have worked closely together as a means of check and balance. A schedule will
be developed which will incorporate the requirements of the permit, LTMP, PPA, and the MMP
to consolidate and coordinate mercury monitoring and tracking.
Implementation of Control Measures
Employee training will continue in an effort to identify internal mercury and mercury containing
devices and its proper disposal. This applies to the WWTP lab, programs, and plant operations.
The pretreatment program will be instrumental in working with industries through the permitting
process and annual inspections. Industries are required to give previous notice of any significant
process or chemical change. This allows time to evaluate affects to the WWTP before change is
initiated. The pretreatment program will continue annual surveys as a means to identify mercury
sources and promote awareness. The lab will continue to identify, evaluate and monitor side
streams in an effort to maintain oversight of mercury introduction into the WWTP. The lab data
collected from non-domestic users will continue to be evaluated for its effect on WWTP influent,
effluent and biosolids mercury concentration.
Public awareness and education continues to be 'a large part of the MMP and its application
towards mercury reduction. Avenues used include annual performance reports, consumer
confidence reports, website postings, public service announcements with newspaper and radio,
bill inserts, plant tours, and public forums.
The District's sewer use ordinance (SUO), a general ordinance which limits or prohibits the
introduction of substances into the WWTP system, protects the WWTP, its employees, public
health and the environment. Mercury is limited by the SUO.

Water Resources
ENVIRONMENTAL QUALITY
PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretmp
S. JAY ZIMMERMAN
Director
September 28, 2016
Mr. Dan Brown, PE, CEO
Roanoke Rapids Sanitary District
Po Box 308
1000 Jackson Street
Roanoke Rapids, NC 27870
Subject: Permit Renewal
Application No. NCO024201
Roanoke Rapids Sanitary District
Halifax County
Dear Mr. Brown:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on September 23, 2016. The primary reviewer for this renewal
application is Teresa Rodriguez.
The primary reviewer will review your application, and she will contact you if additional
information is required to complete your permit renewal. Per G.S. 150B-3 your current permit
does not expire until permit decision on the application is made. Continuation of the current permit
is contingent on timely and sufficient application for renewal of the current permit.
Please respond in a timely manner to requests for additional information necessary to
complete the permit application. If you have any additional questions concerning renewal of the
subject permit, please contact Teresa Rodriguez at 919-807-6387 or [e-mail].
cc: Central Files
NPDES
Raleigh Regional Office
Sincerely,
?Am !%4*%d
Wren Thedford
Wastewater Branch
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-807-6300