WQ0013252_Staff Report_20220118

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: Maria. Schutte(a,NCDENR.gov
Mooresville Regional Office
Application No.: WQ0013252
Facility name: Mallard Creek WRF
County: Mecklenburg
Note: This form has been adapted from the non -discharge facility 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: 01-14-2022.
b. Site visit conducted by: Maria Schutte.
c. Inspection report attached? ❑ Yes or ® No, BIMS to be completed.
d. Person contacted: Mr. Shannon Sypolt (Water Quality Program Administrator) and their contact information:
[phone] or [e-mail].
e. Driving directions: From MRO travel to NC-3 S; Left onto Odell School Rd; At Poplar Tent Road follow signs
to access I-85S; Take Right exit to I-485 toward Matthews; Take exit 32 to US-29 N at end of ramp turn left
onto Hwy 29 N; The facility entrance will be on the right.
2. Discharge Point(s): NA — this is a non -discharge 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 NA — Renewal
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? n Yes or n No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes n No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? n 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? n Yes n No n N/A
If no, please explain: Are there any setback conflicts for proposed treatment, storage and disposal sites?
❑ Yes or❑No
If yes, attach a map showing conflict areas.
7. 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:
8. 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:
9. Possible toxic impacts to surface waters:
10. 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 This is a
reclaimed water system permit, which currently does not require designated operators (SI); Henry Eudy (704-547-
0680 Plant; or 980-214-5977 cell) is the ORC for the WWT Facility — NPDES Permit NC0030210.
WWTP ORC:
BU-ORC:
SI ORC:
Certificate #:
Certificate #:
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: Plant has the option to divert some effluent discharge to the Reclaimed Water
System for offsite irrigation at the Mecklenburg County owned Traditions Golf Course and the Mallard Creek
Community Park.
Proposed flow:
Current permitted flow:
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.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain: Based on historical inspection(s). It has been several years since the reclaimed system was
utilized. Charlotte Water has an agreement to notf MRO staff for attendance at their reclaimed use training
prior to restart of the distribution system. This meeting allows MRO staff the opportunity to meet end -users and
schedule field visits.
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:
5. Is the residuals management plan adequate? ® Yes or n No
If no, please explain: The reclaimed permit does not generate additional residuals beyond the NPDES permit.
This plant is a source under Charlotte Waters' RLAP permit WQ0000057. Charlotte Water also has a residuals
permit in SC.
FORM: WQROSSR 04-14 Page 2 of 5

6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain: NA — There are no established limits for end use. The irrigation sites are controlled by the
end user(s) with the intention of conserving potable water by utilizing reclaimed water to maintain field
vegetation. The only limit is to NOT create ponding or run-off issues.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
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
O ,
,/
0 ,
II
O ,
,/
0 ,
II
O ,
,/
0 ,
If
O ,
„
0 ,
If
O ,
„
0 ,
ft
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:
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: Unwarranted violations continue to be generated by BIMS for this and other MRO
assigned WWI permits, that are only required to report an estimated monthly flow; or, infrequently irrigate. It
appears some non -violations are related to how IPU enters the information ("no flow" vs "no data" checked
box) and in other cases may be related to "calculation" limitations/interpretations by the BIMS system (monthly
total w/o daily entries). Michele Scott (IPU) has addressed some of the "no flow" concerns per past email
communication; however, the MRO is open to suggestions, if CO staff has ideas on how to correct for these
ongoing (likely system and statewide) issues.
14. Check all that apply:
® No compliance issues n 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 n No n N/A
If no, please explain: MRO has not requested a separate O&M plan for this permit because the existing site
plan(s) under the NPDESpermit would be sufficient; however, CW took the initiative and had their contractor
(Hazen & Sawyer) create an O&M plan specific to this Reclaimed Water permit. MRO staff requested an
electronic copy be emailed. CO will either be copied on their email or the item will be fwd. by MRO staff.'
It is unclear how the Charlotte Water O&M (including spill plan) would apply to irrigation equipment and
field sites, because the end -users have responsibility for irrigation. — This item is noted in Section IV.2.
FORM: WQROSSR 04-14 Page 3 of 5

15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes ®NonN/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
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
Closer view — Site Map of
Mallard Creek Community
Park distribution system
Not included as described in the cover letter.
What are proposed
timelines to add UNCC?
CO issued a permit (WQ0042478) to UNCC in 2021 as an end user of
reclaimed water from Mallard Creek. It's not clear when UNCC will actually
be added as an end user and connected to this system (or if this question should
be asked under this permit or UNCC's or both).
MRO requests clarification
from CO.
Since the end users have responsibility for irrigation, it is unclear how the
Charlotte Water O&M (including spill plan) would apply to irrigation
equipment and field sites. — This item is noted in Section 1II.14.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
n Issue
n Deny (Please state reasons: )
FORM: WQROSSR 04-14
Page 4 of 5

6. Signature of report preparer: Maria Schutte — January 181h, 2022
Signature of regional supervisor: DocuSigned by:
Date: 1.18.22 r�.cw fl P ue4
F161 FB69A2D84A3...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS No additional items.
FORM: WQROSSR 04-14 Page 5 of 5