NC0024333_Other Correspondence_20241104

u ° MO"�o CITY OF MONROE
Q ti �� �y�j % P.O.BOX 69 • MONROE.NORTH CAROLINA 28111-0069
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RECEIVED
NOV 0 4 2024
October 31, 2024
NCDEQ/DWR/NPDES
Via e-mail: siving.chen(a,de i.nc.gov
& First Class U.S. Mail
Division of Water Resources
Water Quality Permitting Section—NPDES
ATTN: Siying Chen
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: Lake Lee Package Plant—Cody Downs
Monroe— Union County,NC
Dear Ms. Chen:
Please accept this letter as the City of Monroe's response to a request by the developers of
Cody Downs in Union County to construct a small package wastewater treatment plant that would
discharge into a tributary which drains into Lake Lee, located in the City of Monroe. Lake Lee is
one of three water reservoirs for the City of Monroe.
The City of Monroe vigorously opposes the construction of this plant or any similar plant
which could potentially contaminate the City's drinking water. As you are aware, small
wastewater package plants are constructed,operated and maintained by private developers. These
facilities are notorious for being inadequately managed which generally results in partially treated
effluent being discharged, which effluent finds its way to surface waters. This plant is proposed
to discharge into a tributary which drains in Lake Lee. Partially treated discharge will result in
detrimental water quality and negatively impact the water supply for the City.
These small wastewater treatment plants often lack resiliency and reliability and do not
effectively treat large volumes of inflow and infiltration. Typically,there are no equalization basins
to accommodate wet-weather flow volumes. Further, according to the Environmental Protection
Agency, 60% of recent NPDES significant non-compliance (SNC) violations occur at these
facilities. I have enclosed the March 2022 EPA Compliance Advisory for your review.

Division of Water Resources
Page 2 of 2
October 31, 2024
An additional concern is that these systems often lack financial resources to provide for
preventative maintenance requirements. While local municipalities are often encouraged to
purchase these systems to ensure maintenance,the City has already declined to annex this property
and has no appetite to acquire this facility in the future. As such, the City will not be responsible
for any future operation of this plant should it be constructed.
Finally and most importantly, the City of Monroe lakes are listed as impaired on the
NCDEQ list due to nutrient loading. Given the concerns outlined above,we do not believe a small
wastewater treatment plant will be able to meet and comply with strict water quality limits leading
to further detrimental impact on Lake Lee.
Please feel free to contact me should you have any questions. Thanking you for your
consideration in this matter, I am
Sincerely yours,
.iC
'chard G. Long, Jr.
City Attorney
RGL/adc
Enclosure
cc: Scott Clark
Mark Watson

OFFICE OF ENFORCEMENT
co E PA COMPLIANCE ADVISORY AND COMPLIANCE ASSURANCE
Reducing Significant Non-Compliance with National Pollutant Discharge Elimination System Permits
EPA Document#305F21001 March 2022
Compliance Tips for Small, Mechanical Wastewater
Treatment Plants
Background on this Compliance Advisory
This advisory is directed to owners and operators of small publicly owned ..
wastewater treatment works(POTWs)and small private wastewater
treatment plants, both commonly referred to as wastewater treatment plants
(WWTPs). It is intended to provide small WWTPs with information that will
help them comply with their National Pollutant Discharge Elimination System
(NPDES)permit effluent limits. Smaller WWTPS are a particular focus of an -Now- 't'
EPA National Initiative to reduce significant non-compliance (SNC) because
60%of recent NPDES SNC violations occurred at these facilities. EPA !
reminds WWTP operators of their responsibility to fully comply with their �"`— 'may
NPDES permits, and that compliance assistance is available. As a result of MIIMPt
EPA's focus in this important area, NPDES permittees, regardless of facility •
size or type, will see EPA and states putting increased emphasis on
identifying, addressing and resolving SNC violations using enforcement and
other compliance tools. Note that,while this alert focuses on operational issues, some operators of small mechanical
WWTPs are also failing to submit required discharge monitoring reports (DMRs), or are submitting incomplete or
inaccurate DMRs that can mask serious violations If you are having trouble completing or submitting your DMRs, contact
your permitting authority and request assistance. Increased compliance will improve surface water quality and reduce
potential impacts on drinking water supplies. For more information about EPA's efforts to reduce SNC,
+see: Reducing Significant Non-Compliance with National Pollutant Discharge Elimination System (NPDES)
Permits.
Surface Water Pollution from Small WWTPs
Pollutants commonly discharged by small WWTPs at SNC violation levels include oxygen-demanding substances (e.g.,
biochemical oxygen demand (BOD), chemical oxygen demand (COD)), total suspended solids (TSS), pathogens(i.e.,
fecal coliform/E. coli), nutrients, and total residual chlorine. The tables included below provide information on violation
causes and potential solutions. Table 1 (below)starts by outlining some common issues experienced at WWTPs that can
cause serious permit limit exceedances.
Table 1. WWTP Processes and Common Issues
WWTP Process Common Issues That Can Lead to Noncompliance
Primary Treatment ➢ Bar screen broken111111111111111111.
(solids settling and % Clarifier/sedimentation tanks out of service
sludge removal) D Short circuiting of wastewater flow
Broken/uncalibrated process controls
Inadequate retention time and pH buffering (alkalinity), low food to mass
Secondary ratio, low soluble BOD (low influent loading)
Treatment ➢ Insufficient aeration/dissolved oxygen
➢ Inadequate process control tools and methods
Compliance Advisory Page 1

(conversion of ➢ Clarifiers out of service
pollutants into less r Solids loss from clarifiers
noxious substances)
Tertiary Treatment ➢ Filters (clogged) bound by sludge
(filtration) ➢ Hydrogen sulfide generation in the carbon contactor
➢ No chlorine
Disinfection
✓ No dechlorination
Chlorine ➢ Chlorine contact tank full of biological solids
UV ➢ Poor effluent transmittance
➢ Build-up of scale on bulbs
✓ Electricity is off
Common Underlying Causes of Effluent Violations at Small WWTPs
Small systems often have difficulty keeping trained operators and obtaining adequate funding for operations,
maintenance, and system upgrades needed to achieve and maintain compliance. Table 2 can serve as a critical starting
point for identifying solutions to common causes of effluent violations. (Before making any major process or operation and
maintenance changes, operators are advised to check with their permitting authority.)
Table 2. Effluent Violations at Small WWTPs: Root Causes and Potential Solutions
Topic Common Root Causes Recommended Potential Solutions
r For helpand information on •i
Resource scarcity may ,
involve one or more of the funding sources, such as loans, ,,
following conditions: grants,_accessing State Revolving `6
Funds, bonds, etc., contact your
4 �
➢ Inadequate funding or local Environmental Finance ?
community commitment �a
to make resources Center.
available for infrastructure ➢ Determine if user fees need to be
upgrades and/or increased to cover operation, I
maintenance. maintenance, and replacement
➢ Inadequate funds or costs of treatment equipment.
ability to hire and retain ➢ Use asset management to pursue .
certified operators. and achieve sustainable
P
Resource ➢ Inadequate funds to hire infrastructure. Draft a wastewater
scarcity contract wastewater budget based upon proper operations and maintenance:
engineers to provide Planning for Sustainable Water Infrastructure.
operational oversight. ➢ Encourage best planning and management practices by
➢ Lack of public awareness implementing Capacity, Management, Operation and
of the need to invest in Maintenance (CMOM)programs.
infrastructure upgrades ➢ Explore the Water Finance Clearinghouse.
and/or maintenance.
➢ Operators are not given ➢ Educate municipal leadership.
the resources needed to: ➢ Engage the public by conducting public outreach and
purchase process control education on benefits and true costs of wastewater
testing equipment, collection, transmission, and treatment. Develop an insert
treatment chemicals or for the wastewater billing or post information on the utility's
haul sludge. website.
➢ Operator error is often ➢ Seek training among the many low or no cost online
Operation due to lack of training or sources, such as WaterOperator.org- Process Control
Problems being over-extended. Resources.
➢ Errors may also occur
when written standard
Compliance Advisory Page 2

.
Topic Common Root Causes Recommended Potential Solutions
operating procedures ➢ Join listservs and organizations that conduct training such
(SOPs)and documented as U.S. EPA NPDES Training, your state permitting
operational data are not agency, professional associations such as Association of
available or are not Clean Water Administrators (ACWA), Water Environment
implemented. Federation (WEF), National Association of Clean Water
➢ Plant configuration may Agencies (NACWA), American Water Works Association
lack operational flexibility. (AWWA)or your local technical assistance providers like
➢ Operational issues, such
as manifold blower(s) Rural Community Assistance Partnership(RCAP)and the
used to run all air National Rural Water Association (NRWA),
components and cycled ➢ Seek collaboration with neighboring operators with similar
on and off to optimize conditions or process units. Consult with your state or
biological treatment; airlift EPA Region, who can use an ECHO-gov CWA NPDES
return activated sludge National POTW Pairing Dashboard to help put you in
(RAS) pumps are out of touch with operators at similarly sized plants that are
service. successfully meeting their effluent limits.
➢ Operators may need ➢ Develop written SOPs using resources at WEF.orq or EPA
more training on activated Guidance for Preparing SOPs.
sludge process control ➢ Seek training on troubleshooting: Troubleshooting
and troubleshooting, Noncompliance at the Smallest Wastewater Treatment
which is critical to Plants: Part I and Troubleshooting Noncompliance at the
compliance. Smallest Wastewater Treatment Plants: Part II.
➢ Seek lessons learned from other operators of new
➢ Lack of operator training systems.
on its use, failure to follow ➢ Find training on best practices for operating and
best management maintaining treatment systems with new technology.
practices, or lack of ➢ Develop an asset management system that incorporates
Equipment preventative maintenance operation and maintenance plans and tracks equipment
failure planning and/or that may be nearing end of life and will require capital
implementation. investment: Developing an Asset Management Program.
➢ Improper design, ➢ Encourage best planning and management practices by
installation, and/or implementing Capacity, Management, Operation and
construction. Maintenance (CMOM)programs.
For
communities
that have a -
decreased , , Ir
➢ Changes to the influent population: ;-
volume and strength are ➢ Seek :lie
influenced influenced by increased technical
or decreased population,
Significant new or fewer industrial assistance 4
changes in users, or excessive wet or and ., i.
system dry weather. evaluate
influent how
volume or ➢ Widespread current
strength implementation of low- system can be modified to effectively treat the current
flow fixtures can also influent level and strength.
contribute to reduced ➢ Hire an engineer:
influent volume. http://wateroperator.orq/Portals/1/Documents/10112.pdf
➢ Provide education about regionalization: Consolidation of
Water and Wastewater Systems: Options and
Considerations.
Compliance Advisory Page 3

Topic Common Root Causes Recommended Potential Solutions
➢ For communities that have increased population:
➢ Seek education on financing for expansion and new
technology: contact your local Environmental Finance
Center.
If the plant design includes flexibility, there are operation
techniques that can expand capacity to treat high strength flow
and wet weather flow such as step feeding for high strength
waste streams and contact stabilization for wet weather flows.
For systems that have new or increased flow from industrial
users:
➢ Establish a pretreatment program and revise the sewer
use ordinance.
➢ Reduce influent strength by implementing septic hauling
for a portion of the wastewater.
➢ In municipalities without a pretreatment program, consider
establishing a program pretreatment program.
➢ Revise and enforce the sewer use ordinance.
➢ Seek training for states
➢ Pass-through and and municipalities on
interference from pretreatment program
industrial users and implementation,
institutions (high strength including handling of i , f
I or non-compatible
Pass-through p slug loads. r,
and influent)can cause or ➢ Conduct outreach on
contribute to effluent
interference effective municipal
violations. level Enforcement aM -_-
➢ Small plants that accept
septage may experience Response Plans
resultant effluent (escalation of enforcement response against non-
violations. complying Industrial Users).
➢ Conduct an inventory of WWTPs and industrial users to
target likely impacts.
➢ Implement best practices for sampling and treating
septage: Septaqe Management.
Plants may have design issues:
➢ With parallel treatment
trains,the flow splitting may ➢ Promote the use of operations manuals rather than
be poor. engineering manuals (eg Design Standards: Wastewater
➢ Plant was designed using a Treatment Plants and Collection Systems <100,000 qdp.
textbook number for raw ➢ Adjust valves to improve splitting.
Design flaws sewage composition,which ➢ Explore operational changes to limit the effects of the
may lead to unnecessarily design flaws.
high capacity. ➢ Take treatment units out of service during periods of low
➢ Lack of operational flexibility loading.
such as airlift pumps that
cannot be turned down;
insufficiently sized sludge
holding tanks.
Compliance Advisory Page 4

•
Compliance and Financing Assistance Resources
In addition to the resources listed in Table 2,the following resources can help you correct violations and achieve
compliance.
Compliance Assistance Resources
Reducing Significant Non-Compliance (SNC)with NPDES Permits -Resources for NPDES Permittees and
Other Organizations (https://www.epa.gov/enforcement/national-compliance-initiative-reducing-significant-non-
compliance-snc-npdes-permits)
• EPA Small and Rural Wastewater Systems Website and Tools (https://www.epa.gov/small-and-rural-wastewater-
systems/tools-training-and-technical-assistance-small-and-rural)
• WaterOperator.org is a free training resource portal for operators of small • —- -
systems
•
• Rural Community Assistance Partnership Website
(https://www.rcap.orq/) ` ;
• National Rural Water Association (nrwa.org)
• EPA National Pollutant Discharge Elimination System Website
(https://www.epa.gov/npdes/national-pretreatment-program-events-training-and-publications)
• Activated Sludge Process Control and Troubleshooting Chart Methodology
(https://epa.ohio.gov/Portals/29/documents/CAU/Activated%20Sludge%20Process%20Control%20and%20Troublesh
ootinq%20Manual.pdf)
• NetDMR Support Portal https://usepa.servicenowservices.com/oeca_icis
Potential Funding and Financing Sources
Funding Sources for Small and Rural Wastewater Systems (https://www.epa.gov/small-and-rural-wastewater-
systems/fu nd i ng-sources-smal l-and-ru ral-wastewater-systems)
EPA Water Infrastructure and Resiliency Finance Center(https://www.epa.gov/waterfinancecenter/efcn)
• Clean Water State Revolving Funds (www.epa.gov/cwsrf)
General References
U.S. EPA, 1998, How Wastewater Treatment Works... The Basics (EPA/833/F-98/002). Office of Water, Washington,
D.C. (https://www3.epa.gov/npdes/pubs/bastre.pdf)
• U.S. EPA, 2004, Primer for Municipal Wastewater Treatment Systems (EPA/832/R-048/001). Office of Water,
Washington, D.C. (https://www3.epa.gov/npdes/pubs/primer.pdf)
Disclaimer
This Compliance Advisory addresses select provisions of EPA regulatory requirements using plain language. Nothing
in this Compliance Advisory is meant to replace or revise any NPDES permit, any EPA regulatory provision, or any
other part of the Code of Federal Regulations, the Federal Register, or the Clean Water Act. EPA recommends that
operators consult with their permitting agency prior to making major changes to their systems.
Pa e5
Compliance Advisory 9