NC0023884_Correspondence_20231218

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Jim Behmer, Director
Salisbury -Rowan Utilities
1 Water Street
Salisbury, NC 28144
NORTH CAROLINA
Environmental Quality
December 18, 2023
Delivered via email to: [e-mail]
SUBJECT: 24/7 Wastewater Operator Staffing
City of Salisbury WWTP (Town Creek facility)
NPDES Permit #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 NCACO2H.0124 RELIABILITYAII
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), and successfully implementing this over much of 2022 and all of 2023, 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 and this
will continue into 2024 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 I Division of Water Resources
Mooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
HoaraCAaouNa 704.663.1699

3) Certified wastewater operators will remain onsite at the Town Creek WWTP Monday through
Friday from Sam to 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, 2024, 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 704-235-2180 or via
[e-mail].
Sincerely,
DocuSigned by:
F161F969A2D84A3...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Water Quality Regional Operations Section, MRO
Division of Water Resources, DEQ
CC: LaserFiche
Sonja Basinger, Environmental Services Manager, [e-mail]
Jim Amaral, Water Resources Manager, [e-mail]
North Carolina Department of Environmental Quality I Division of Water Resources
D E Q�� Mooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
NORrH CARouNa 704.663.1699