WQ0001346_Staff Report_20230919

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑NPDES Unit®Non-Discharge Unit Application No.: WQ0001346
Attn: Leah.Parentegncdenr.gov Facility name: City of Monroe WWTP
County: Union
From: [e-mail]
Mooresville Regional Office
Note: This form has been adapted from the non-discharge fg acili , staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are pplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or❑No
a. Date of site visit: 8-24-2023.
b. Site visit conducted by: Maria Schutte.
c. Inspection report attached? ❑ Yes or®No, BIMS to be updated.
d. Person contacted: Kyle Ketchum(ORC)byphone: [phone] or kketchunikinonroenc.org.
e. Driving directions: From MRO travel to 1-77 S, Exit onto I-485 E;to 74 E into Monroe;turn Left onto Walk-
up Ave.; Left onto Treeway lane. WWTP is on the left.
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 Source facility is not new. Some LA fields are new.
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? ❑ Yes or❑No
If no, explain:
3. Are site conditions(soils, depth to water table, etc.)consistent with the submitted reports? ® Yes ❑No ❑N/A
If no,please explain: New field sites for this land application permit were reviewed for existing setbacks. MRO
staff reviewed sites with Ken Morris, City of Monroe's LA coordinator. When a field is split between two soil
classifications per soils maps (LA acreage only not that lost to buffers),MRO suggests going with the more
restrictive soil,as typically there is only one soil boing conducted regardless of acreage. This item is noted below
in Section IV. Seasonal high-water table in low lying areas or near water buffers should always be reassessed by
the land applier at the time of application.
FORM:WQROSSR 04-14 Pagel of 5

4. Do the plans and site map represent the actual site(property lines,wells, etc.)? ® Yes ®No ❑N/A
If no,please explain: Only new fields were reviewed. Observations apply to the time of the site visit only. There
is always a potential that buffers will change with new construction.
Map of site NC-UN-35 shows a well near the home on field 3 but does not show a well near the home on field 2
(we did not access the property and view behind the home). Monroe staff did not know if the area was served by
public water and if the well at field 3 might be for irrigation. The home setback at field 2 is likely sufficient to
meet a well setback also; however,MRO staff recommended Mr. Morris(Monroe)verify when he flags for LA.
In addition,the acreage SW of the pond on field 3 will not be used, as both MRO and Monroe staff agreed it was
not easily accessible with LA equipment.
NOTE: MRO staff also requested the City of Monroe NOT cross the stream between these fields for access unless
the owner wishes to provide a proper crossing to protect the stream. Mr. Morris stated he would access field 3
using the Hwy 74 entrance.
These items are also noted below in Section IV.
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? ® Yes ❑No ❑N/A
If no,please explain: Since PAN rates are based on soils and crop. The proposed rates will change if the farmer
changes crops.
Their Soil Scientist(Rob Willcox)is requesting age in the PAN Calc. The 0.40 mineralization rate has been
used for WTP alum residuals as it is MRO Staff understanding the WTP residuals were viewed as raw wastewater
process(limited treatment). The request is to change to a 0.20 mineralization rate, as Mr. Willcox states that is
the industry standard for WTP residuals. The MRO is okay with CO decision on this topic, as a change here
should be reflected for all permits when land applying WTP residuals.
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or®No
If yes, attach a map showing conflict areas.
8. 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:
9. 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: WWTP and WTP both dewater and store cake residuals
on-site. Unfortunately,they do not have any covered storage. Currently covered storage is proposed at the
WWTP,but project completion is uncertain.
10. Possible toxic impacts to surface waters: High solids,BOD and Nutrients. If the program is managed properly,
there should be no impact to surface waters; however,there is always a potential of a spill during transit or mishap
at a field site.
11. 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
WWTP ORC: Kyle Ketchum SI ORC: Certificate#: LA-15703
BU-ORC: Kenneth Morris SI ORC: Certificate#: LA-1007897
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: WWTP and WTP both dewater and store cake residuals on-site. Unfortunately,
they do not have any covered storage. Currently covered storage is proposed at the WWTP,but project
completion is uncertain.
FORM:WQROSSR 04-14 Page 2 of 5

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 NA—review of new field sites for LA.
If no,please explain:
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 NA—review of new field sites for LA.
If yes,please explain:
5. Is the residuals management plan adequate? ® Yes or❑No
If no,please explain:
6. Are the existing application rates(e.g.,hydraulic,nutrient) still acceptable? ® Yes or❑No
If no,please explain: Will need to change if crops change.
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. But buffers mange with new construction, etc. and need to
be assessed at the time of land application.
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 / // O I If
O / 1/ O I If
O / // O / //
O / // O / If
O / // O / If
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: Review is by Annual Report—the 2022 report was
received at the time of this site visit and only—partially reviewed. The most recent 2023 lab data was reviewed at
the time of inspection and appeared adequate.
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:
14. Check all that apply:
®No compliance issues ❑ 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?
FORM: WQROSSR 04-14 Page 3 of 5

Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑No ❑N/A
If no,please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No ❑N/A
If yes,please explain:
16. Possible toxic impacts to surface waters: Only if there is a spill,then solids and nutrients could be an impact.
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
Map of site NC-UN-35 shows a well near the home on field 3 but does not
show a well near the home on field 2 (we did not access the property and view
behind the home). Monroe staff did not know if the area was served by public
water and if the well at field 3 might be for irrigation. The home setback at
field 2 is likely sufficient to meet the well setback also;however,MRO staff
recommended Mr. Morris(Monroe)verify when he flags for LA. In addition,
the acreage SW of the pond on field 3 will not be used,as both MRO and
Corrections to field maps Monroe staff agreed it was not easily accessible with LA equipment. These
and/or acreage as items are also noted above in II.4. NOTE: MRO staff also requested the City of
discussed with City of Monroe NOT cross the stream between these fields for access unless the owner
Monroe, LA coordinator wishes to provide a proper crossing to protect the stream. Mr. Morris stated he
while on-site. would access field 3 using the Hwy 74 entrance.
Because there is only one soil boing conducted(the rules minimum)regardless
of field acreage,when a field is split between two soil classifications per soils
maps(LA acreage only-not that lost to buffers),MRO suggests going with the
more restrictive soil if applicable. This item is also noted in 11.3. MRO staff
opinion is based on soils maps provided in the permit modification.No
additional soil borings were conducted during the site visit.
Diagram is on Pg#142 in the LaserFiche document. While the diagram is
Clarify if there is a more informative, it does not show the more recent upgrades for the WTP centrifuge,
recent WTP diagram. residuals processing. MRO staff requests this item not hold up the renewal
process and is okay with it being noted as a requested update for the O&M plan.
Adjustments to The modification deletes sites 25, 26,27 and 33; adds site 35 and adds or
Attachments modifies the following fields:NC-UN-18-08,NC-UN-31-05 and 07.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
FORM: WQROSSR 04-14 Page 4 of 5

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
Reminder to update Spill Unsure if this item warrants a PC,but their spill plan(LasherFiche pg#29) uses
Plans etc. older DENR language and should be changed to DEQ.
5. Recommendation: ❑ Hold,pending receipt and review of additional information by regional office
❑ Hold,pending review of draft permit by regional office
® Issue upon receipt of needed additional information (As needed for item IV.2.)
❑ Issue
❑ Deny(Please state reasons: )
6. Signature of report preparer: Maria Schutte—September 19',2023
DocuSigned by:
Signature of regional supervisor:
9/19/2023 c1
Date' F161FB69A2D84A3..
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Their Soil Scientist(Rob Willcox)is requesting a change in the PAN Calc. The 0.40 mineralization rate has been used for
WTP alum residuals as it is MRO Staff understanding the WTP residuals were viewed as raw wastewater process(limited
treatment). The request is to change to a 0.20 mineralization rate, as Mr. Willcox states that is the industry standard for
WTP residuals. The MRO is okay with CO decision on this topic,as a change here should be reflected for all permits
when land applying WTP residuals. Also noted in 11.6.
FORM: WQROSSR 04-14 Page 5 of 5