WQ0001346_Compliance Evaluation Inspection_20180823

NORTH CAROLINA
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MICHAEL S. REGAN
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August 23, 2018
Mr. Russel G. Colbath, P.E. via Email
Director of Water Resources
City of Monroe
P.O. Box 69
Monroe, North Carolina 28111-0069
Subject: Non -Discharge Permit Inspections
City of Monroe WWTP and WTP
WQ0001346 - Land Application of Residuals
WQ0032605 - Bulk Reclaimed Water System
Union County
Dear Mr. Colbath:
Staff of the Mooresville Regional Office (MRO) conducted compliance inspections for the
referenced permits on August 21st, 2018. The inspections included the WWTP residuals
processing, records, storage and land review for the permit renewal with modification; and, the
WWTP bulk reclaimed water system. Both program operations appeared sufficient with
permitting requirements at the time of inspection.
Questions related the WQ0001346 permit renewal may be directed to Troy.Doby(ancdenr.gov.
The MRO would like to thank, Rob Wilcox, L.S.S. (Wilcox and Mabe), Stephen Holden and Kyle
Ketchum, for their time and assistance during the inspections. The attached report should be
self-explanatory; however, you may contact Maria Schutte by phone [phone]) or email
(maria. schutte(@ncdenr.gov) with questions.
Sincerely,
EA
DocuSigned by:
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Andrew A. ner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment(s): Combined WQ0001346 & WQ00326051nspection Report
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

CC: Kyle Ketchum, City of Monroe WWTP Supervisor, LA ORC (email)
Stephen Holden, City of Monroe, LA Coordinator — BU ORC (email)
Rob Wilcox, L.S.S., Wilcox and Mabe (email)
Troy Doby, Central Office Non -Discharge Branch, Raleigh (email)

State of North Carolina Department of Environmental Quality
Division of Water Resources
Roy Cooper, Governor
Michael S. Regan, Secretary
Linda Culpepper, Interim Director
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner: City of Monroe County: Union
Permit No.: WQ0001346 RLAP Issued: 09/30/2013 Expiration: 01/31/2019
Permit No.: W00032605 Reclaimed Bulk Issued: 04/03/2017 Expiration: 04/31/2022
Permittee Contact: Russell Colbath, P.E. (Director) Ph: 704-282-4612 Email: rcolbathgmonroenc.org
LA ORC: Kyle Ketchum LA#13560 Phone: [phone] Email: kketchum(a)monroenc.org
BU ORC: Stephen Holden LA#98766 Phone: [phone] Email: sholdengmonroenc.org
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of Inspection
Collection System Spray Irrigation X Sludge X Other
Inspection Date(s): August 21, 2018
Inspection Summary: (additional comments may be included on attached pages)
This inspection included site visits to the City of Monroe's WWTP and land application field sites. Files are
maintained at the WWTP and appeared to be in good order. The bulk reclaimed distribution system
(WQ0032605) was observed and appeared to be maintained in accordance with permit requirements, and
record keeping discussed, but not requested for review, as the reclaimed system has not been utilized for years
and the MRO has up-to-date reporting records stating no flow.
Please note:
• The WQ001346 permit is currently in the renewal process with Central Office staff in Raleigh.
Questions may be directed to Troy.Doby&ncdenr.gov.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary? yes, X no
Inspector Name/Title: Maria Schutte, Environmental Specialist
Telephone No.: 704-663-1699 Fax No. 704-663-6040
Date of Inspection: 08/21/2018

Non -Discharge Inspections
WQ0001346 and WQ0032605 — City of Monroe
pg. 2
Type of Residual
X Land Application (503 Exempt WTP Alum) X Land Application (Class B WWTP Residuals)
Record Keeping
Y-yes N-no N/A -not applicable N/E-not evaluated
WTP * WWTP
NE Y Copy of current permit available at residual generating site
Y Y Current metals and nutrient analysis (see permit for frequency)
Y Y TCLP analysis, Y SSFA (Standard Soil Fertility Analysis)
Y Y Nutrient and metals loading calculations (to determine most limiting parameter) YTD
Y Y Hauling records (# gal and/or ton hauled during calendar year to date)
Y Y Field loading records, Y Field site maps and information
Y Y Records of lime purchased Lime applications are noted on field sheets in the AR.
NA Y Pathogen & Vector Attraction Reduction
Comments: All residuals records are maintained at the WWTP on computer. Current 2018 analyses appeared
to meet compliance. Data reviewed in the 2017Annual Report (AR) was not requested during this site visit.
* The WTP was not visited during this inspection. The answers above are based on data in the 2017AR.
Ferric Residuals at the WTP are hauled by the city of Monroe staff, either to the WWTP or to a land application
site, and blended with WWTP residuals to ensure land owners are receiving some nutrient rich material.
Proposed WTP upgrades will include on -site de -watering & storage, eliminating additional haulingto the
WWTP_
Pathogen & Vector Attraction Reduction Records
WTP * WTTP
Fecal coliform
NA X SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0* 106 CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0* 106 CFU / dry gram)
Salmonella (Class A, all tests must be < 3MPN / 4 grams dry
Time / Temp records
Digester (MCRT) Compost Class A lime stabilization
NA X Volatile solids calculations
Bench -top aerobic/anaerobic digestion results
pH records for lime stabilization (Class A or B)
SOUR calculations
Comments: * The WTP is a 503 Exempt. Ferric Residuals facility. A typing error noted in the existing Attachment
A is requested to be corrected during this residuals' permit renewal, to adequately state the WTP residuals are
exempt from both fecal and vector attraction reduction analytical requirements. When WTP residuals are hauled
to the WWTP and commingled with the WWTP residuals. thev no longer meet 503 exempt rules and appropriate
analyses are conducted.

Non -Discharge Inspections
WQ0001346 and WQ0032605 — City of Monroe
pg. 3
Treatment * NA to the WTP.
X Aerobic digestion WWTP Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion X Drying beds (may not meet 503's) — used at the WTP.
Alkaline Stabilization Lime X Other -describe WTP - Ferric Residuals
Transport NA — There was no transportation occurring at the time of inspection.
Spill control plan in transport vehicle? NA
Does transport vehicle appear to be maintained? NA
Storage per previous reports
Number of days/weeks/months of storage: >6 months
Describe storage: Both plants have storage for liquid residuals and cake. The WTP still utilizes drying beds.
The WWTP uses the old drying beds as their staging area for the belt filter press and storage of the dewatered
cake, until land applied.
WWTP - Three (3) million -gallon above ground (aerated) storage tank. An earthen berm is located down slope
of the storage tank for containment of material in case of spillage/leakage/tank failure.
WTP also has an above ground storage tank, but unsure of volume.
Odors present N Vectors present N Odors & vectors were not detected in the residuals areas, at
the time of inspection.
Comments: The WTP was not viewed during this inspection. Proposed WTP upgrades will include on -site de -
watering & storage, eliminating additional hauling to the WWTP.
Sampling
Describe Sampling: Sampling is handled in house by Stephen Holden in accordance with permit requirements
and their internal sampling plan. Records are maintained on -site. MRO staff recommended the O&M and
sampling vlans be undated to remove A&L labs. and simply note "Contract Lab " to eliminate need for constant
changes to those documents.
Is sampling adequate? Y Is sampling representative? NE fIf protocol is followed than sampling should be
representative. )
Field Sites (end use for class B biosolids)
Residuals land application and hauling is managed Stephen Holden with the City of Monroe. There was
no active land application at the time of this inspection. Field sites were reviewed for buffers as part of the
permit renewal/modi acation process.
Field identification: There was no active land application at the time of inspection. All sites were reviewed
for buffers.
Permit on site during application
Buffers adequate
Documented exceedances of PAN limits
Signs of runoff / ponding
Spill plan on site
Cover crop specified in permit
Site condition adequate
Rain Gauge on site during application
Are there any limiting slopes on fields?
_10 % for surface application _18% for subsurface application

Non -Discharge Inspections pg. 4
WQ0001346 and WQ0032605 — City of Monroe
Odors/vectors NA — no land application was occurring at the time of inspection.
Describe any nuisance conditions and any corrective actions needed. NA
Odors present NA
Vectors present NA
Monitoring well(s) Y/N: NA - This permit currently does not require groundwater monitoring.
Other noted conditions
There has been no activity under the reclaimed water permit (WO0032605) in recent years. Submitted NDMRs
reflect no flow or no distribution. Permittee and MRO are in continued discussion with Central Office staff to
address appropriate reporting forms. Per Kyle Ketchum, he is to use his existing forms, until CO staf can
address his concerns with the recently updated forms.
Any W00001346 modification or renewal items noted by MRO staff were communicated to Troy Doby (CO
permitting) and will be handled through an additional information request from Mr. Doby.