WQ0011431_Staff Report_52020101

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.: WQ0011431
Attn: Erik Saunders, Water Quality Permitting Section — Non -Discharge Branch
Facility name: Town of Cleveland RLAP
From: Edward Watson, Hydrogeologist
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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 10/15/2024
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No
c. Person contacted: Rob Wilcox, LSS and his contact information: (336) 339 - 9128 ext.
e. Driving directions:
2. Discharge Point(s): N/A This is a RLAP permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Rob Wilcox, Certificate #:LA / 13285 Backup ORC: Martin Mabe, Certificate #: LA / 22753
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: In general, yes, but higher flows will require additional storage, or land application; see
below.
Description of existing facilities: The facility is a package plant for the Town of Cleveland. The flow is 50%
domestic and 50% industrial during plant operations. A total of 82.0 DT/Yr. of residuals is the current solids
production. Flows tend to rise and fall with production activity at Cleveland's Daimler Freightliner facility. The
permittee is adding 19.8 acres of field for RLAP purposes.
Current permitted flow: 82 DT/Y
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.) The permit will have a new ORC and backup ORC. They are listed above.
FORM: WQROSSR 04-14 Pagel of 3

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:
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: NC-RA-02-01 for 5.2 acres and NC-RA-02-02 for 14.6 acres. New land be added to the
permit.
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain: The facility is experiencing a significant increase in influent flow to the WWTP due to
added discharge from local businesses. The corresponding increase in residuals will be better accommodated
with the additional fields to land apply to. There should no longer be a need to send residual sludge to a landfill
for disposal.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program: Monitor wells are not
required for this permit.
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. 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: DMRs have shown BOD limit violations since early
2019 when flows to the plant increased; no ND -related violations have been documented.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: Please add site 2, fields 1 & 2.
13. 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? 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:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain: The facility is currently in compliance with the permit. The addition of the 19.8 acres, will
assist the permittee with residual management.
15. Possible toxic impacts to surface waters: Impacts to surface waters are mitigated through this ND permit. There
shouldn't be toxic impacts to surface waters from this activity.
16. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 3

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. 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
® Issue
❑ Deny (Please state reasons: )
3. Signature of report preparer: Edward Watson October 15, 2024
6. Signature of regional supervisor:
Date: 10/15/2024
Docu Signed by:
F161 FB69A2D84A3...
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
MRO is concerned that there is not sufficient residuals storage capacity at the WWTP.
The MRO sees several options to help address this issue, but we should ask the Town to provide their evaluation of
the situation and plans to address it:
1. Accommodate the storage of additional sludge expected to be produced with the addition of another digester to
accommodate the influent flow to the POTW. The digester could be installed at the location of the drying beds.
2. With the additional fields being added to receive residual material, more frequent LA events can occur, reducing
the need for additional storage.
FORM: WQROSSR 04-14 Page 3 of 3