NC0026441_SOC (Application)_20220914

,6I .G�174
94'�cep®w
Zotun of iter Cite RECEIVED
Town Manager's Office SEP 14 2022
NCDEQIDWRINPDES
September 8, 2022
John Hennessey, Unit Chief
NC DEQ Compliance Unit
512 N Salisbury St.
Raleigh, NC 27604
Application for Special Order by Consent
NPDES Permit No. NC0026441
Town of Siler City 5 Rag co3
Please find enclosed initial application information for a Special Order by Consent and application
fee of$400. The intent of this application is to begin the process to establish a Special Order by Consent
between the Town of Siler City and the North Carolina Division of Environmental Quality. In accordance
with preliminary discussions, we have incorporated information on numerous proposed projects, and
interim action items that are being conducted or plan to be conducted by the Town to address non-
compliance of the Town's permitted facilities. This application is submitted to provide information to
NCDEQ on the Town's efforts however we acknowledge additional information and details will be required
to supplement through the process.
If you have any questions regarding the information contained in this application, please don't
hesitate to contact me or Chris McCorquodale at(919) 742-4731.
Sincerely,
TOWN OF SILER CITY
Hank Raper,Town Manager
Henry E.(Hank)Raper
Town Manager [e-mail]
PO Box 769.311 N Second Avenue Phone:[phone]•Fax:[phone]
Siler City,NC 27344-0769 www.silercity.org
To advance a framework for our success through balanced governance,dynamic partnerships,and an engaged community.

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant(corporation, individual, or other): Town of Siler City
2. Print or Type Owner's or Signing Official's Name and Title: Hank Raper, Town Manager
3. Facility Name(as shown on Permit): Town of Siler Ci WWTP
4. Owner Phone: [phone] (or)
5. Owner Email: [e-mail]
4. Application Date: September 1, 2022
5. NPDES Permit No. (if applicable): NC0026441
6. Name of the specific wastewater treatment facility(if different from 1.3. above):
II. PRE-APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittee: Representative: Hank
Raper, Town Manager and Chris McCorquodale, Public Utilities Director Date: September 1,
2022.
III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non-discharge permit. These circumstances do not include failure to perform proper
maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.
If the requested additional flow is non-domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non-domestic wastewater.

,)
The total domestic additional flow requested: See attached gallons per day.
The total non-domestic additional flow requested: See attached_gallons per day.
The total additional flow (sum of the above): See attached_gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
• The existing treatment process and any process modifications that have been made to
date to ensure optimum performance of existing facilities,
• Collection system rehabilitation work completed or scheduled (including dates),
• Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non-compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements, please attach these agreements,
• Date and outcome of last Industrial Waste Survey,
• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.
2

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction, ending construction, and achieving final compliance at a minimum. In
determining the milestone dates, the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval.
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.) to include a plan of action to minimize
impacts to surface waters.
• Infiltration/Inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if applicable.
• Toxicity Reduction Evaluations (TRE), if necessary.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments,bonds, letters of credit,block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
If funding is not available at the beginning of the SOC process, the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
• If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
3

Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of$400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)
APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, Ia n k £pe , attest this application for a Special Order by
Consent (SOC) has been reviewed by me and is accurate and complete to the best of my
knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement of outstanding violations, may be imposed. {Note: Reference to upfront penalties
in Special Orders by Consent may be found in the North Carolina Administrative Code [T15A
NCAC 2H .1206(c)(3)].}
Date 9/7/ -
Sig ature of Signing O icia
/1k fir
Printed Name of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON-DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1636
4

TOWN OF SILER CITY
SOC APPLICATION SUPPORTING INFORMATION
SEPTEMBER 2022
NECESSARY NARRATIVE
• Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
The Town of Siler City anticipates that additional violations will continue to occur at the
WWTP for BOD, Ammonia, toxicity, and monthly average flow until issues Significant
Industrial Users (Mountaire and Siler City Water Treatment Plant), wastewater treatment
deficiencies and infiltration and inflow issues are addressed. Sanitary Sewer overflows
will continue of process water from the WTP. Siler City seeks relief from penalties as
necessary improvements are made to bring these facilities into compliance.
• The existing treatment process and any process modifications that have been made
to date to ensure optimum performance of existing facilities
The existing treatment process includes screening, grit removal, flow equalization,
influent pump station, oxidation ditches, clarifiers, filters, chlorine contact, de-
chlorination and post aeration.
Within the past two years the Town of Siler City has installed two DO sensors in each
oxidation ditch to monitor DO levels, rebuilt blowers, replaced filter media, assessed, and
rebuilt sludge holding aeration system. A significant sewer rehabilitation project was
complete in 2020 in the Lincoln Heights area. Several other minor repairs and
replacements have occurred in the sewer collection system.
• Collection system rehabilitation work completed or scheduled (including dates)
Completed: Lincoln Heights Sewer Rehabilitation Project. Project included the
replacement of 6,951 LF of gravity sewer and was completed July 29, 2020.
Scheduled:
1. Main Interceptor Replacement Project to replace 5,600 LF of the main
interceptor along Loves Creek directly upstream of the WWTP.
Permitted: February 2023
Bid: April 2023
Constructed: April 2024

•
2. Interceptor Replacement and Blood Run Pump Station Relocation. Project has
been selected by FEMA for BRIC funding and includes approximately 835 LF
of 8" gravity sewer, 150 LF of 10" gravity sewer, 3340 LF of 24" gravity
sewer, 5763 LF of 30" gravity sewer and 4064 LF of 36" gravity sewer, 9,950
LF of 18" force main and relocation of the Blood Run pump station out of the
100 year floodplain.
Permitted: TBD
Bid: TBD
Constructed: TBD
3. ARPA Sewer Rehabilitation Project: Project includes the rehabilitation or
replacement of approximately 19,560 LF of 8" Gravity sewer.
Permitted: June 2023
Bid: September 2023
Constructed: December 2024
• Coordination with industrial users regarding their discharges or pretreatment
facilities. Identify any non-compliant significant industrial users and measure(s)
proposed or already taken to bring the pretreatment facilities back into compliance.
If any industrial facilities are currently under consent agreements, please attach
these agreements
Mountaire
Mountaire has been issued violations for exceeding permit limits based on 17
occurrences in 2021 and 22 occurrences in the first 6 months of 2022. It is believed that
these violations have been a contributing factor to violations of the Town of Siler City
WWTP based on excessive loading and chemical feeds that are not consistent with the
facilities Authorization to Construct. A summary of violations is attached to this
narrative.
The Town has regular meetings with Mountaire and held a formal meeting on June 2,
2022 to discuss the ongoing violations. The Town has also increased sampling to daily to
better monitor the levels being sent to the Town's WWTP. Mountaire has indicated a
willingness to work with the Town and is currently consulting with Engineers to develop
a plan for improvements to their facilities. There are no formal consent agreements in
place at this time.
Siler City Water Treatment Plant
Siler City Water Treatment Plant (WTP) has not been permitted as a Significant
Industrial User but is currently in the application process. The WTP has sent high levels
of iron from ferric sludge to the WWTP recently which may be contributing to inhibition
of the WWTP. Since a permit is not in place there have been no violations issued to the

WTP to date. The Town has been working with their sludge hauler to increase frequency
of disposal to keep solids from building up in the lagoon. The lagoon serves as both
storage and treatment for the waste stream from the WTP and the limited volume is not
able to adequately equalize high flows generated by backwashes of multiple filters over a
short period of time. The Town intends to expand the process water handling facilities to
address this issue and incorporate a recycle to reduce the volume of water sent to the
WWTP. A project is currently under construction to install pretreatment units (Actiflo)
and air backwash to the facility. The pretreatment unit will generate a constant process
water flow but will reduce the need for cleaning sedimentation basins and is expected to
increase filter run times. These improvements are expected to improve the consistency of
process water production and reduce overall volume and thereby reduce the potential for
overflow and the amount of ferric sludge sent to the WWTP. This project is expected to
complete construction in May 2023.
• Date and outcome of last Industrial Waste Survey
The most recent industrial waste survey was completed in 2018. The survey found 3
industries that had closed since 2012, 5 industries with only domestic flow, and 5 with
process water that does not come back to the Town of Siler City's sewer. One industry
was determined to send process water to the Town of Siler City. A new IWS will be
required when the new NPDES Permit is issued.
• Whether or not the facility is acting as a regional facility receiving wastewater from
other municipalities having independent pretreatment programs
The Town of Siler City WWTP does not serve as a regional facility.
PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance.
Mountaire Compliance—It is not known at this time if Mountaire can achieve compliance with
the permit limits with the existing facilities or if construction projects may be required. Given
previous compliance history it is anticipated that the facility may be able to be made compliant
with modifications that do not require substantial construction. The schedule for improvements
by Mountaire has not been confirmed and will be added to the application later.
- Develop Plan: TBD
- Construct hmprovements : TBD
- Achieve Compliance TBD
The Town is also taking interim actions to improve compliance until these improvements can be
put into place. These interim improvements include the following:

• Increase penalties to Mountaire due to continued violations.
• Review surcharges for BOD, TSS, Ammonia, and nutrients and update as necessary.
• Review pretreatment permit and revise as necessary to clarify chemical feed
requirements, add limit for chlorine and potential other pollutants of concern.
Water Treatment Plant Compliance: It is expected to achieve consistent full compliance at the
WTP with no further overflows and minimal iron sent to the WWTP a sludge handling project
will need to be completed. The Town plans to utilize ARPA funding for these improvements
which was awarded FY 2022 Budget Bill (S.L. 2022-74) appropriation.
- Submit Permits: April 2023
- Begin Construction: October 2023
- End Construction: October 2024
- Achieve Compliance November 2024
The Town is also taking interim actions to reduce overflows until these improvements can be put
into place. These improvements include the following:
• Issue Pretreatment Permit with compliance schedule
• Increased sludge removal frequency from the sludge lagoon
• Install baffles in the sludge lagoon to reduce short circuiting and washout of solids during
high flow periods.
• Modified sedimentation basin cleaning procedures to drain basin by pumping supernatant
to opposite sedimentation basin to reduce waste flow. Sludge from the bottom of the
basin is then drained to the process water tanks.
• Install sedimentation fence below the pump station to collect solids in the event
overflows do occur.
Wastewater Treatment Plant Compliance: The Town of Siler City is currently developing
plans for expansion of the WWTP from 4 MGD to 6 MGD. The proposed project includes new
screening, grit, influent pump station, new biological treatment process including biological
nutrient removal for TN and TP and a 3'd treatment train, clarifier equipment replacement, new
filters, and UV disinfection. The project will also include a new solids handling facility with
dewatering equipment. The completion of this project will allow the plant to better handle high
influent loading and peak flows from infiltration and inflow.
- Submit Permits October 2022
- Begin Construction June 2023
- End Construction December 2024
- Achieve Compliance January 2025
The Town is also taking interim actions to improve compliance until these improvements can be
put into place. These interim improvements include the following:
• Access sludge accumulation in the oxidation ditches and removal accumulation found.

• Acquire a belt filter press through a rental or purchase agreement to ensure solids can be
adequately removed from the plant and disposed of when land application is not adequate
for sludge production at the plant.
• Install temporary additional aeration/mixing equipment in oxidation ditches to improve
control and levels of dissolved oxygen.
Infiltration and Inflow Reduction
1. Main Interceptor Replacement Project to replace 5,600 LF of the main
interceptor along Loves Creek directly upstream of the WWTP.
Permitted: February 2023
Bid: April 2023
Constructed: April 2024
2. Interceptor Replacement and Blood Run Pump Station Relocation. Project has
been selected by FEMA for BRIC funding and includes approximately 835 LF
of 8" gravity sewer, 150 LF of 10" gravity sewer, 3340 LF of 24" gravity
sewer, 5763 LF of 30" gravity sewer and 4064 LF of 36" gravity sewer, 9,950
LF of 18" force main and relocation of the Blood Run pump station out of the
100 year floodplain.
Permitted: TBD
Bid: TBD
Constructed: TBD
3. ARPA Sewer Rehabilitation Project: Project includes the rehabilitation or
replacement of approximately 19,560 LF of 8" Gravity sewer.
Permitted: June 2023
Bid: September 2023
Constructed: December 2024
The Town is also taking interim actions to improve compliance until these improvements can be
put into place. These interim improvements include the following:
• Conduct additional smoke testing in the system to identify defects that can be rapidly
repaired.
• Review Asset Inventory information to confirm identified defects have been repaired and
repair any items the Town can complete with Town crews.

Town of Siler City Pretreatment Program Enforcement
Mountaire Farms Significant Industrial User
January 2021-June 2022 Violation Summary
Date Date of Limit Reported Penalty
Issued Violation Parameter Value Value 'Type of Violation Assessed
3/1/2021 BOD 540 Exceeded Daily Max
3/4/2021 BOD 540 543 Exceeded Daily Max
5/6/2021 BOD 540 662 Exceeded Daily Max $300
6/16/2021 BOD 540 695 Exceeded Daily Max $550
7/8/2021 BOD 540 745 Exceeded Daily Max
NH3 50 75.6 Exceeded Daily Max
7/30/2021 NH3 50 94.6 Exceeded Daily Max
7/31/2021 NH3 50 95 Exceeded Daily Max $10,550
8/1/2021 NH3 50 111 Exceeded Daily Max
8/5/2021 NH3 50 62 Exceeded Daily Max
BOD 540 680 Exceeded Daily Max
8/6/2021 NH3 50 56.8 Exceeded Daily Max
8/7/2021 NH3 50 75.8 Exceeded Daily Max
8/8/2021 NH3 50 95.3 Exceeded Daily Max
8/9/2021 NH3 50 64 Exceeded Daily Max
8/15/2021 NH3 50 54.1 Exceeded Daily Max $12,100.00
12/1/2021 BOD 540 589 Exceeded Daily Max $800
2/3/2022 1/6/2022 BOD 540 599 Exceeded daily max $800
Ammonia 40 47.5 Exceeded monthly max
3/9/2022 2/9/2022 Peroxide
3/9/2022 2/10/2022 BOD 540 607 Exceeded daily max $1,215
TP 7.2 9.3 Exceeded daily max $800
4/19/2022 3/15/2022 TP 7.2 8.3 Exceeded daily max $1,550
6/23/2022 5/17/2022 TP 7.2 7.7 Exceeded daily max
5/16/2022 BOD 540 638 Exceeded daily max
5/18/2022 BOD 540 574 Exceeded daily max
5/19/2022 BOD 540 557 Exceeded daily max
5/23/2022 BOD 540 617 Exceeded daily max
5/26/2022 BOD 540 1002 Exceeded daily max
5/27/2022 BOD 540 575 Exceeded daily max
5/31/2022 BOD 450 568.8 Exceeded monthly max $1,550
7/29/2022 6/2/2022 BOD 540 680 Exceeded daily max
6/3/2022 BOD 540 621 Exceeded daily max
6/6/2022 BOD 540 582 Exceeded daily max
6/13/2022 BOD 540 548 Exceeded daily max
6/16/2022 BOD 540 575 Exceeded daily max
6/17/2022 BOD 540 599 Exceeded daily max
6/20/2022 BOD 540 553 Exceeded daily max
6/27/2022 BOD 540 630 Exceeded daily max
6/30/2022 BOD 450 523 Exceeded monthly max $24,550

REQUESTED ADDITIONAL FLOW DURING SPECIAL ORDER BY CONSENT.
The Town of Siler City would like to request additional flow allocation during the period
of the SOC for several projects. We understand the circumstances required and that a
complete analysis will be required to confirm the additional flow will not adversely
impact the wastewater collection or treatment facilities or surface waters. All flows are
based on NCAC 02T regulations or specific request from user.
Project Hibernian (CAM Site) 290,000 gpd
Cambridge Southeast 25 units with 3 bedrooms= 9,000 gpd
Community Baptist 400 Seat Church = 2,000 gpd
Harold Andrews Road 214 units with 3 bedrooms = 77,000 gpd