WQ0021734_Staff Report_20201229

,s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: [e-mail]
From: Mari a. Schutte&NCDENR. gov
Mooresville Regional Office
Application No.: WQ0021734
Facility name: Charlotte Water - Franklin WTP
County: Mecklenburg
Note: This form has been adapted from the non -discharge facilily staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 12-15-2020.
b. Site visit conducted by: Maria Schulte.
c. Inspection report attached? ❑ Yes or ® No, Will be sent in separate email and available in BIMS.
d. Person contacted: Donna Duckworth (WTP-ORC) via CW staff for biosolids permit inspection scheduled on
same date and their contact information: [phone] or dduckworthkci.charlotte.nc.us.
e. Driving directions: From MRO travel to I-77 S: Exit onto I-85 S: Exit onto Hwy 16Brookshire Blvd W: plant
will be on the right.
2. Discharge Point(s): NA — this is a non-discharg`permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 5

5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
WWTP ORC: SI ORC: Certificate #: This is a Bulk distribution permit for Reclaimed
Water from a Municipal WTP and currently Certified Operators are not required for conjunctive facilities.
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: WTP has a bulk fill / truck loading station in place.
Proposed flow:
Current permitted flow: NA — This is a WTP Reclaimed Bulk Distribution Permit. The current permit does not
state a flow/volume restriction,_ just "use" restrictions and requires tracking of volume distributed.
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.): This permit has not been utilized, but management wants to keep it for emergency drought conditions.
While the purple plumbingis s in place, the system is not operable, as the maintenance staff noted a problem with
the reclaimed water pump (located at the effluent discharge) and removed it w/o concrete plans for replacement.
In addition, the current turbidity meter at the bulk fill station cannot be calibrated w/o flow: and, an in -line,
calibrated flow -meter is needed. The MRO is okay with Charlotte Water keeping this permit, but will request a
permit condition be added requiring the necessarypairs and contact of MRO staff for inspection prior to
distribution.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No NA — This is a WTP bulk distribution of Reclaimed Water Permit,
specific fields and maps are not required.
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ® Yes or ❑ No
If yes, please explain: See IIL2. Infrastructure may affect permit, but field site questions are not applicable.
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain: This facility is covered under the CW residuals permit W00000057.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain: Hydraulic loading will apply to any distribution site, but there are no specified fields
associated with this permit.
FORM: WQROSSR 04-14 Page 2 of 5

7. Is the existing groundwater monitoring program adequate? ❑ Yes ®No ®N/A
If no, explain and recommend any changes to the groundwater monitoring program: See comments under IV.3. to
remove the Attachment B, because it does not apply to this Reclaimed Permit.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
C
C
C
C I II
C I II
C I II
C I II
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ® No
Please summarize any findings resulting from this review: NA — There has been no distribution under this permit
since it was issued, so data is not collected. However, most data would be reflective of and should be coordinated
with current effluent requirements under the NPDES permit as is the case with other Reclaimed water permits.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: Having multiple PPI locations associated with Reclaimed Permits continues to create
unnecessary and unwarranted violations in BIMS. These permits could be simplified with "ONE" PPI Reporting
Form for all flow and data parameters.
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO
been working with the Permittee?
Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ® No ❑ N/A
If no, please explain: Facility will have make repairs and contact MRO staff for a pre -use inspection.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: This is a ND distribution of Reclaimed water, with a 5000 gal discharge
reporting limit. There would be little impact even if there were a release to surface waters, if all treatment is
met. This facility does Chlorinate for disinfection, so there could be a minor concern of adverse impact for
some aquatic organisms.
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: See comments under IIL2. and recommended Permit Condition(s) to address noted in IVA.
below.
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Attachment B
MRO staff is not aware of any Monitoring Wells associated with this permit.
There typically are no groundwater monitoring requirements associated with
Reclaimed Water permits. This appears to be an oversight that needs
correction, unless CO staff has information the MRO does not.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Repairs to system and
measuring equipment; And,
contact MRO for
inspection prior to use.
Missing pump and required measuring devices. See comments under IIL2.
above.
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information (Only, if new waiver is needed.)
® Issue
❑ Deny (Please state reasons: )
FORM: WQROSSR 04-14 Page 4 of 5

6. Signature of report preparer: Maria Schutte — December 22"d. 2020
Signature of regional supervisor:
Date: 12/29/2020
—DocuSigned by:
We'' BX for Andrew Pitner. Asst.
A61696D90CC3437...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Request CO correct/update BIMS information as needed for non-existent monitoring wells that may have been
created when permit was first issued. MRO staff was unable to access BIMS at the time this report was
completed.
FORM: WQROSSR 04-14 Page 5 of 5