WQ0001346_Staff Report_20180823

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: [e-mail] Facility name: City of Monroe RLAP
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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 8-21-2018
b. Site visit conducted by: Maria Schutte
c. Inspection report attached? ❑ Yes or ® No To be entered in BIMS, emailed, and via Laser ache, but
there are no issues. The only comment(s) will be related to the modifications addressed in this staff report.
d. Person contacted: Stephen Holden and their contact information: [phone] ext.
Driving directions: From MRO take Evergreen St to Carpenter and turn Rt.; Right onto Hwy 3; Right onto
Odell School Road; Access I-85 South via Poplar Tent Road (No left turns at this intersection, so you have to
turn Rt onto Poplar Tent and get in left lane to make the U-turn back, then continue straight thru light and turn
Right onto I-85S); Take exit 48 & keep left to follow fork to Inner 1-485 (toward Matthews); take exit 49 for
Idlewild Rd & turn Left; Cont. straight onto Secrest Shortcut Rd; Turn left onto Roosevelt Blvd (Hwy 74E)
then left onto Walk -Up Ave; Left onto Treeway Lane, ends at WWTP.
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
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:
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:
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:
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:
10. Possible toxic impacts to surface waters:
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
ORC: Kyle Ketchum Certificate #: LA#13560 Backup ORC: Stephen Holden Certificate #: LA#98766
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: This is a residuals land application permit for the City of Monroe and includes
their WWTP and WTP facilities. Residuals at the WWTP are belt -pressed and the cake stored until land applied.
Residuals at the WTP are either placed on drying beds at the WTP or hauled to the WWTP, belt pressed and the
cake stored until land applied.
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.) Planned WTP upgrades will include dewatering and storage of residuals on -site, eliminating the
additional hauling step to the WWTP.
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: This is a land application permit utilizing non -dedicated fields. Site conditions require
permittee (and contractor) assessment at the time of application.
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: This is a residuals land application permit with modification for new land. Acreage will
change, maps will be updated & the attachment B changed accordingly.
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: This is a land application permit utilizing non -dedicated fields. Site conditions require
permittee (and contractor) assessment at the time of application (includes changing crops/application rates),
FORM: WQROSSR 04-14 Page 2 of 5

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. This is a land application permit utilizing non -dedicated fields.
Site conditions require permittee (and contractor) assessment at the time of 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 l lI
O I II
O l lI
O I II
O l lI
O I II
O / //
O / //
O / //
O / //
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:
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? 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:
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 corrections
See additional comments for details. The list is short for two reasons: Rob
Wilcox did a very good job in assessing stream vs. drainage ditches, so there
FORM: WQROSSR 04-14 Page 3 of 5

were no buffer corrections for these items. And, most items (signature related
issues) were alreadv noted by Trov Dobv. (Thank vou. Trov!)
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Correct Attachment A
Correct the footnote language to state that WTP residuals are exempt for both
Pathogen and Vector Attraction Reduction requirements. The language in this
permit is slightly different than other RLAP permits with a WTP source.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
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
❑ Issue
DocuSigned by:
❑ Deny (Please state reasons: ) r-
6. Signature of report preparer:
Signature of regional supervisor:
Date: 8/23/18
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
1.) NC-UN-26-06 needs correction for removal of a small pond and buffer at the Southern field boundary.
Steve Holden questioned this location last year during application. Per the MRO staff comments from that
field inspection,
("A portion of this field at the south tree line, on ilv buffered for a pond, is now planted as part of the field.
By MRO review ofsatellite photo timeline, it appears the pond has naturally dried or been.filled in overtime;
however, per conversation with Mr. Holden this area will be assessed for seasonal high water as part of the next
permit renewal application due July 31, 2018. ")
the area was assessed by Rob Wilcox, L.S.S. during this renewal review. A soil auger was driven to 24" to
confirm adequate separation distance to SHWT.
2.) The approved 2C rule allowance for property line setback waivers will likely alter additional sites going forward,
but these potential changes should not delay this renewal. This item is noted here for CO information, as Mr.
Holden inquired how to best handle these between permit renewals and email submissions/requests for minor
modifications were discussed.
FORM: WQROSSR 04-14 Page 5 of 5