WQ0011431_Staff Report_20190723

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: (Troy Doby 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: 07/15/2019
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No — available in LaserFiche
c. Person contacted: Paul Land and their contact information: (704) 642 - 2165 ext.
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
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: Sherrill Ray Gambill Certificate #:LA / 985951 Backup ORC: Denise G. Harrison
Certificate #:LA / 987968
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, land app, or landfilling;
see below.
Description of existing facilities:
Proposed flow: N/A
Current permitted flow: This is a Land Application of Residual permit. No flow is associated with this permit.
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.)
FORM: WQROSSR 04-14 Page 1 of 4

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:
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 added influent will be difficult to handle at current capacity. The
addition of digester or storage area for the sludge would be helpful to the facility.
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:
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:
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. However, increased influent could
cause the facility to become out of compliance due to a lack of ability to handle residual sludge.
15. Possible toxic impacts to surface waters: Impacts to surface waters are mitigated through buffers.
16. Pretreatment Program (POTWs only): N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: The facility lacks the capacity to handle elevated influent flow resultingfrom increased
industrial activity.
FORM: WQROSSR 04-14 Page 2 of 4

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
Evaluation of biosolids
capacity
Wastewater flows and biosolids production are sharply higher since late 2018
taxing existing capacity to manage the program. See additional comments on
the next page.
MRO also notes that the Town is inquiring about the purchase of a belt press to
aid with the dewatering of the residual sludge. An option may be to use the
area currently occupied by the drying beds as covered storage for the
dewatered sludge.
3. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition I Reason
1 I Insert the Appendix A table for testing based on sludge application by tonnage.
4. 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: )
5. Signature of report preparer: Edward Watson July 22, 2019
6. Signature of regional supervisor:
Date:
Docu Signed by:
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FORM: WQROSSR 04-14 Page 3 of 4

ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Town of Cleveland's WWTP has been experiencing increased flows largely as a result of additional shifts being
added to the Town's major employer, Daimler Trucks, makers of Freightliners. Their NPDES permit (NC0049867)
has had a number of BOD limit violations in 2019 associated with the increased flows. This has also meant
additional solids production, which is taxing the Town's storage and application capacity.
The dry tonnage produced in 2017 per their annual report was only]]. 4 dry tons of sludge. The dry tonnage of
sludge produced in 2018 was approximately 22.4 dry tons of sludge. The eDMR records indicate beginning in August
of 2018, flow to the WWTP experienced significant increase. In August 2018, approximately 14.5 of dry sludge was
produced at the WWTP.
Based on a calculation of flow for the period of May 2018, through the most recent eDMR report received in May
2019, the total amount of dry tons of sludge produced was slightly over 150 dry tons. The current permit allows for a
total of 82 dry tons of sludge to be applied on the 10 acres of Land Application field in the permit.
The MRO is concerned that with the uptick inflow and biosolids production, Cleveland may not be able to handle the
increased production. MRO is concerned that there isn't sufficient storage capacity or permitted land available for
land application when flows/production is high. Previous permits for this facility have had additional acreage that
would have been able to accommodate at least some of additional sludge tonnage resulting from the increased
influent to the WWTP, but the Town let those drop from the permit.
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 (via belt press, building a storage pad,
another digester and/or other containment/storage structures).
2. Providing additional acreage for land application.
3. Investigate the possibility of hauling septage to another municipality to relieve the pressure being placed on the
WWTP during periods of increased influent.
4. Potentially add the Town as a source to a land applier's permit.
S. Plan for hauling more sludge to the landfill.
Currently, to provide relieffor the over taxed digester, the Town of Cleveland has been utilizing an existing drying bed
and then hauling the dried sludge to the local county landfill for disposal. The hauling records were not reviewed during
the site visit. Therefore, the MRO does not have information regarding the volume of sludge currently being sent to the
landfill. However, the expense of transporting sludge and the tipping fees charged by the landfill may become a financial
burden. This cost can be relieved by permit modification and increased storage capacity at the WWTP.
FORM: WQROSSR 04-14 Page 4 of 4