NC0023884_confirmation of 24/7 operations requirement_20220411

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAR { INA
Environmental Quality
11 April 2022
Mr. Jim Behmer, Director
Salisbury -Rowan Utilities
1 Water Street
Salisbury, NC 28144
SUBJECT: 24/7 Wastewater Operator Staffing
City of Salisbury WWTP (Town Creek facility)
NPDES Permit No. NC0023884
Rowan County
Dear Mr. Behmer,
The City of Salisbury (City) operates two (2) wastewater treatment facilities covered by a single
NPDES Permit (NC0023884). The smaller of these two facilities, with a design capacity of 5.0 MGD,
is the Town Creek wastewater treatment facility. Based on the design capacity of 5.0 MGD,
continuous operation, 24 hours per day, seven days per week staffing with each shift staffed by
at least one certified wastewater operator is required by 15A NCAC 02H .0124(4) which states,
"15A NCAC 02H .0124 RELIABILITY All facilities shall provide adequate reliability measures to
ensure continued treatment and disinfection where the interruption of such treatment would
result in a discharge of insufficient quality to protect the best intended uses of the affected surface
waters. The reliability measures shall include the following: (4) For mechanical facilities with a
design capacity equal to or greater than 5.0 MGD and continuous operation, 24 hours per day,
seven days per week staffing with each shift staffed by at least one certified wastewater operator
unless the applicant can demonstrate that this requirement is not necessary to ensure reliability
of its facility."
Pursuant to a request from Salisbury -Rowan Utilities staff regarding interpretation of 15A NCAC
02H .0124(4), the Division hereby confirms that the City has demonstrated that the 24/7 certified
wastewater operator staffing requirement is not necessary to ensure reliability of its Town Creek
wastewater treatment facility based on the following:
1) Both wastewater treatment facilities owned and operated by the City (Town Creek WWTP
and Grants Creek WWTP) are located within approximately 2 miles of one another with a
travel time of approximately 5 minutes;
2) The SCADA system utilized by the City provides sufficient control of wastewater
operations at both wastewater treatment facilities;
North Carolina Department of Environmental Quality 1 D`n,stun of Water Resources
Mooresville Reglanat Office 1 b10 fast Center Avenue, Suite 301 1 Mooresville. North Carotina
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3) Certified wastewater operators will remain onsite at the Town Creek WWTP Monday
through Friday until 5pm each day;
4) Certified wastewater operators will remain on staff 24/7 at the Grants Creek WWTP;
5) Routine visits by certified wastewater operators will occur at the Town Creek WWTP after
5pm weekdays, and on weekends and holidays.
In order to continue this approval beyond December 31, 2022, the Division will schedule a meeting
with Salisbury -Rowan Utilities staff to discuss whether or not this approval has been successful
and what, if any, additional requirements may be necessary to continue to demonstrate that the
24/7 certified wastewater operator staffing requirement is not necessary to ensure reliability of
its Town Creek wastewater treatment facility.
Should you have any questions or concerns, please do not hesitate to contact me at 704-235-2168
or via email at [e-mail].
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: LaserFiche
Sonja Basinger, Environmental Services Manager (via email)
Jason Wilson, SRU Asst. Director (via email)