WQ0000520_Compliance Evaluation Inspection_20191203

Mitchell, Patrick
From: Mitchell, Patrick
Sent: Tuesday, December 3, 2019 5:08 PM
To: Shane Fletcher
Cc: Brent Collins ([e-mail])
Subject: November 27, 2019 Inspection of AM-116 (WQ0000520)
Attachments: 20191127 Inspect Report.pdf
Shane,
Attached is the report generated from the inspection that I did last week. The inspection reflects compliance with the
permit.
Please let me know if you have any questions.
Thanks,
Patrick
Patrick L. Mitchell, REHS, LSS
Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
�`-^ lothtng Compares
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
1

Compliance Inspection Report
Permit: WQ0000520 Effective: 09/10/18 Expiration: 07/31/22 owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington RLAP
County: Alamance 225 Stone Quarry Rd
Region: Winston-Salem
Burlington NC 272161358
Contact Person: Everett Shane Fletcher Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Everett Shane Fletcher
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0023876 City of Burlington - Southside WWTP
NC0023868 City of Burlington - Eastside WWTP
Inspection Date: 11/27/2019 Entry Time: 10:45AM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Certification: 988745 Phone: [phone]
Exit Time: 12:45PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Land Application Site Pathogen and Vector Attraction Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0000520 Owner - Facility: City of Burlington
Inspection Date: 11/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On November 27, 2019 WSRO staff conducted an unannounced inspection of land application activities. The residuals
source facilities were not reviewed during this inspection. The inspection occurred following Division staff observations of
transport vehicles loading residuals and hauling away from the Eastside WWTP source facility during a forecasted rain
event. Mr. Shane Fletcher with the City of Burlington accompanied staff on the field inspection. The activities and records
reviewed during the inspection reflect compliance with the permit. Below is a summary of notes from the inspection.
❑ Eastside WWTP Residuals analyses suggests that all regulatory limits associated with the land application activities
were met.
- The 1/31/2019 TCLP analysis results were made available for review during the inspection and found to be below regulatory
limits.
- The 10/21/2019 Residuals analysis results were made available for review during the inspection. Metals were found to be
below regulatory limits. Nutrients concentrations were provided and correctly utilized for field loading calculations.
- The most recent Pathogen & Vector Attraction Reduction records for November 2019 were made available for review during
the inspection. Lime stabilization methods were utilized and met for both pathogen reduction and vector attraction reduction.
❑ Land Application Records reviewed during the inspection reflect compliance with the permit.
- Hauling records were reviewed during the inspection. Records provided for review indicate that four 6,500 gal. tankers had
been hauled from the Eastside WWTP to the land app. site AM-116 on 11/27/2019.
- Records indicate that the residuals transport to the land application site started at 7:20 am and land application stopped
at 8:45 am on 11/27/2019.
- Mr. Fletcher indicated that as soon as rainfall began, land application activities were stopped. Reportedly no rainfall
occurred within 24 hours prior to the event.
❑ Observations at the land application site AM-116 also reflect compliance with permit conditions.
- When WSRO staff arrived at the subject site, rain was actively falling, and the field was found to be saturated with
rainwater. The onsite rain gauge had —0.2 inches of rain at the time of arrival.
- No land application activities were observed occurring while staff was onsite. The residuals spreading equipment was found
to be unmanned.
- No residuals or mud was found to be tracked onto the state road at the entrance of the land application site.
- The areas of Field #4 that received land application prior to WSRO staff arriving was reviewed.
• No ponding or runoff was observed in the application area or downslope of the application area (see site photos).
* The application appeared to be evenly spread (see site map sketch for approx. locations spread).
• All observed setbacks were found to be properly buffered. Buffer flags reviewed in the areas that had not been spread yet
were found to meet or exceed required setbacks.
- The field is utilized for row crops. The land application event was occurring prior to establishment of Wheat crops. The
reported loading rate was approx. 1.5 to 2 tankers per acre or —25 to 32 lbs. of PAN per acre. This is below the agronomic
limits for the site and intended crop.
- Field #3 had buffer flags in place, but no land application had occurred to the field.
- The 2019 soil sample results were not available for review. Remind that soil sampling must be competed on or before
12/31 /2019.
While the inspection reflects compliance with the permit, recommend caution is used when planning land application events
on the day of a forecast rain event. Land application prior to rain events can lead to residuals runoff and potentially discharge
to surface waters.
Page 2 of 5

Permit: WQ0000520 Owner - Facility: City of Burlington
Inspection Date: 11/27/2019 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Distribution and Marketing
❑
Land Application
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑
❑ ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑ ❑
Are there any GW quality violations?
❑
❑ ❑
Is GW-59A certification form completed for facility?
❑
❑ ❑
Is a copy of current permit on -site?
❑ ❑ ❑
Are current metals and nutrient analysis available?
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
❑ ❑ ❑
a. TCLP analysis?
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ ❑
Are PAN balances being maintained?
❑ ❑ ❑
Are PAN balances within permit limits?
❑ ❑ ❑
Has land application equipment been calibrated?
❑
❑ ❑
Are there pH records for alkaline stabilization?
❑ ❑ ❑
Are there pH records for the land application site?
❑
❑ ❑
Are nutrient/crop removal practices in place?
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
❑ ❑ ❑
Are hauling records available?
❑ ❑ ❑
Are hauling records maintained and up-to-date?
❑ ❑ ❑
# Has permittee been free of public complaints in last 12 months?
❑
❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ ❑
Comment: See summary.
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
❑
❑ ❑
Class A, all test must be <1000 MPN/dry gram
❑
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
Fecal coliform SM 9222 D (Class B only)
❑
❑ ❑
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
❑
b. pH records for alkaline stabilization (Class A)
❑
❑ ❑
c. pH records for alkaline stabilization (Class B)
❑ ❑ ❑
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
❑
❑ ❑
Page 3 of 5

Permit: WQ0000520 Owner - Facility: City of Burlington
Inspection Date: 11/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on: ❑ ❑ 0 ❑
Digester (MCRT) ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ 0 ❑
Comment: See summary.
Treatment
Yes No NA NE
Check all that apply
Aerobic Digestion
❑
Anaerobic Digestion
❑
Alkaline Pasteurization (Class A)
❑
Alkaline Stabilization (Class B)
Compost
❑
Drying Beds
❑
Other
❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑
Is the spill control plan satisfactory? ❑ ❑ ❑
Does transport vehicle appear to be maintained? ❑ ❑ ❑
Comment: Transport had stopped prior to inspection.
Land Application Site
Yes No NA NE
Is a copy of the permit on -site during application events?
❑
❑ ❑
Is the application site in overall good condition?
❑ ❑ ❑
Is the site free of runoff/ponding?
❑ ❑ ❑
If present, is the application equipment in good operating condition?
❑ ❑ ❑
Are buffers being maintained?
❑ ❑ ❑
Are limiting slopes buffered?
10% for surface application
❑ ❑ ❑
18% for subsurface application
❑
❑ ❑
Are there access restrictions and/or signs?
❑ ❑ ❑
Is the application site free of odors or vectors?
❑ ❑ ❑
Have performance requirements for application method been met?
Page 4 of 5

Permit: WQ0000520 Owner - Facility: City of Burlington
Inspection Date: 11/27/2019 Inspection Type : Compliance Evaluation
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment: See summary.
Reason for Visit: Routine
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
❑❑■❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑■❑❑
Page 5 of 5

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS B RESIDUALS LAND APPLICATION
General Information
Facility Name: gWt)l^�i�� �"-r RI P
Permit No.: W00000"
Owner:
Plant ORC Name:
LA ORC / Contract Company: E —t4_1
Other Contact(s):
Facility Location (address, gps or directions):
County: Am,"^
Permit Issuance Date:
Permit Expiration Date:
Telephone No.:
Telephone No.:
Telephone No.:
Reason for Inspection
❑ ROUTINE ❑ FOLLOW- P PERMITTIN Other: �u a
Comments (attach additional pages as necessary) /
7��wyea.. om 0/11 ht , 7� (s � li" t��
�, / s�.��l a 1)
� tl� r�•iG o6�� ��
c��plrr., a.r�ls, �c�- 91viw of at4, dam. � c�,.Ms�pe.
Mud &r brol,ll-'-( a �� �`2 - 7
if na 4,A r�, 411 '-�
j4r4 n.1'j vtc�j lA 0 T " , rS�4' N� r f* V V l K
/ d VAS t r heN(il
Q,'I�Q �, rdr ,
�TG�Q V/Cw'C rj' ��n c � /I�N7rR MP.1L.
Is a follow-up inspection necessary? ❑ Yes ko
Primary Inspector: P. M 1'r ( � Secondary Inspector:
Date of Inspection: 11 f Z% 201 7 Entry Time: 10 ExitTime:

Non -Discharge Compliance Inspection Report
Residuals Generating Facility
Was the residuals generating facility inspected? ❑ Yes No
Residuals Storage:
Describe storage:
Number of days/weeks/months of storage:
Residuals Sampling: Y N
Is sampling adequate and representative? ❑ ❑
Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP):
Transport Vehicle: y
Is transport occurring at time of inspection? ❑
Are necessary records (i.e. permit & spill plan) present in vehicle? ID ofobsesved vehicle(s): ❑
Record Keeping and Reporting Information: Y
Is current permit and prior annual reports available upon request? [
Has the facility been free of public complaints for the last 12 ths?
-�K'L TCLP analysis conducted and results available? Frequency? 1/yr o El1/permit cycle
-_,Residuals metals and nutrient analysis conducted? Prequenc . JO ee permit for frequency)
futrient and metals loading calculations? (to determine most limiting parameter)
o lab sheets support data reported on Residuals Analysis Summary?
D
Are PAN balance records available and within permit limits?
Are there nutrient (crop) removal practices in place?
Are hauling records available? (gal and/or tons hauled during calendar year to date)
Are field loading records available?
/Are field inspections conducted and are records available?
Are soil sample results available? E
Did soil results call for lime amendment? If so, are there records of application? [
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2, 000)? [
Soil results indicate Na <0.5 meq/100 cm', and Exchangeable Sodium Percentage (ESP) <15%? ❑
Does the permit require groundwater monitoring? ❑
Are groundwater lab results present? E
There are no 21, GW standard violations indicated iu the lab results? F-
■
N
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
Which Alternative was used to demonstrate compliance? Y N NA NE
Alternative 1 Fecal Coliform Density.
Were 7 samples collected and geometric mean <2 million cfu? El El ❑ El Alte alive 2 Process to Significantly Reduce Pathogens ptions)
❑ Alterna ' 3 Use of Equivalent to RSRP (Not com y used - See White House Manual)
If Alternative 2 wa ed, select which Option was rlized and complete the section below.
❑ Option 1 - Aerobic estion Y N NA NE
Are logs present sh 'ng time temperature? ❑ ❑ ❑ ❑
Was the time & temp. be 40 days at 68OF (20°C) and 60 days at 590 F (150C)? ❑ ❑ ❑ ❑
❑ Option 2 - Air Drying
❑ Option 3 - Anaero ' igestion
Are logs esent showing time and temperature. ❑ ❑ ❑ ❑
Was a time & temp. between 15 days at 950 F - 131 35°-55° C) and
days at >680 F (200 C)? ❑ ❑ ❑ ❑
ption 4 - Composting (Not commonly used - See White House Manual)
Option 5 - Lime Stabilization
Are logs present showing time and temperature?
❑ El Was the pH raised to > 12 after two hrs of contact? ❑ ❑ ❑
Was the temperature corrected to 250 C (770 F) (by calculation, NOT auto correct)? ❑ ❑ ❑
Page 2of4

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Selegt which Option was used to demonstrate compliance and complete answer associated questions
❑ O lion 1 - 38%Volatile Solids Reduction
Y
N
NA
NE
Are lab results and calculations present?
❑
❑
❑
❑
Was the reduction on volatile solids (not total solids)?
❑
❑
❑
❑
ere samples collected at correct locations?
❑
❑
❑
(b inning of digestion process & before land application)
Wa there a >38% reduction?
❑
❑
❑
❑
❑ Option 2 - -Day Bench Scale Test
N
NA
NE
Were r iduals from an anaerobic digester with average temp. 30°C — 40°C?
❑
❑
❑
Are lab r ults and calculations present?
El
El
El
El
Was the to anaerobically digested to lab; and test run for 40 days?
El
El
El
ElWas
the lab ench-scale test done between 30°C (86°F) and 37°C (990F)?
❑
❑
❑
❑
Was the reduc 'on of on volatile solids (not total solids)?
❑
❑
❑
❑
Was the reducti n less than 17%?
❑
❑
❑
❑
❑ Option 3 - 30-Day Benc Scale Test
Y
N
NA
NE
Were residuals from erobic digestion?
❑
❑
❑
❑
Are lab results and cal lations present?
❑
❑
❑
❑
Were residuals 2% or le total solids?
❑
❑
❑
❑
If not 2% total solids, was he test ran on a sample dilute o 2%
with unchlorinated effluent.
❑
❑
❑
❑
Was the test run for 30 days?
❑
❑
❑
❑
Was the test done at 20°C (68°
❑
❑
❑
❑
Was the reduction of on volatile so 'ds (not at solids)?
❑
❑
❑.
❑
Was the reduction less than 15%?
❑
❑
❑
❑
❑ Option 4 - Specific Oxygen Uptake Rate ( R Test)
Y
N
NA
NE
Were residuals from aerobic diges ' n?
❑
❑
❑
❑
Were residuals <2% total solids weight asis) (not diluted)?
❑
❑
❑
❑
Was the test done between I O (50°F) and 3 °C (86°F)?
❑
❑
❑
❑
Was the temperature corre ed to 20°C (68°F)?
❑
❑
❑
❑
Was the sampling holdi time <2 hours?
❑
❑
❑
❑
Was the test started ' hin 15 minutes of sampling aeration maintained?
❑
❑
❑
❑
Was the SOUR a at to or less than 1.5 mg of oxyge per hour per gram of
total residual s ids (dry weight basis)?
❑
❑
❑
❑
❑ Option 5 - 14- y Aerobic Process
Y
N
NA
NE
Were a residuals from aerobic digestion?
❑
❑
❑
❑
W the average residuals temperature higher than 45°C (113 ?
❑
❑
❑
❑
ere the residuals treated for 14 days and temperature maintain igher
than 40°C (104°F) for the 14-day period?
❑
❑
❑
❑
[Option 6 - Alkaline Stabilization
Y
N
NA
NE
/1 Was the pH of the residuals raised to >_12 and maintained for two hours
without addition of more alkali?
❑
❑
❑
f1+J t' Did the pH of residuals remain at>11.5 an additional twenty-two hours
rjr fl (i.e. 24 hours total) without the addition of more alkali?
P`�
❑
❑
El
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)?
❑
❑
❑
❑ Opt 7 - Drying of Stabilized Residuals
Y
N
NA
NE
Th siduals do not contain unstabilized resid Is>'
❑
❑
❑
❑
Were siduals mixed with any of erials?
❑
❑
❑
❑
Were the rest tied >750 a solids?
❑
❑
❑
❑
❑ Option 8 - Drying of Uns i Residuals
Y
N
NA
NE
Were the resi s mixed wit ther materials?
❑
❑
❑
❑
Were th siduals dried >90%total so
❑
❑
❑
❑
❑ Optio 0 — Injection/ Incorporation of Residuals (Not my used - See White House Manual)

Non -Discharge Compliance Inspection Report
Land Application Site(s)
Were application site(s) inspected? Ifso, please list Site ID(s) below. Yes ❑ No
Application Site ID(s): M ` I ��' %IJlet t r
Is application occurring at the time of inspection? ❑ Yes M No If no, note the date of the last event:
Was the Division notified of the application event(s)? I IyYes ❑ No
Weather Conditions:
❑ Sunny ❑ Partly Cloudy ,%%Cloudy ❑ Overcast ❑ Stormy
❑ Windy ind ireeti;onn: , 6reeze 6j>,�Calm
KNo Precipit ion J Drizzle ❑ Rain ❑ Cloudburst (If applicable, precipitation measurement
Is there a rain gauge onsite? Yes ❑ No
p f
Weather Notes (i.e. Significant Changes, Forecasts,. etc): L) aL4, lgln
Temp. (° F): ❑ <32 ❑ 32 — 40 K40 — 60 ❑ 60 — 80 ❑ >80
Permit and Spill Plan onsite during application? ❑ Yes ❑ No�
of
Application Site-FieldID(s): "k* I IG Inh%A - ': "
Intended Crop: Wk^4- PAN/Requirement: Ibs/ac
Application Rate (gallons/acre): 16 / �%nker ^zit s .W-
NutrientContent: lb(fvW 4smo1 ^ 2rki/aUc-
t� r�
Application occurring
yattttime of visit: El Yes y� No
Application Method: I�j Surface ElIncorp/Inje\ction
Incorporation/Injec[io!\ uring visit: ❑ Yes ❑ Noy�,,N/A
0Ve ❑ etative Buffer description: None Grass,*Crop ,WShrub
ree El
/�
Cake
Application Site -Field
Intended Crop:_
Application Rate
Nutrient Content:
PAN Requirement: Ibs/ac
Application occurring at time of visit: ❑ Yes ❑ No
Application Method: ❑ Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ❑ N/A
Vegetative Buffer description: ❑None ❑Grass ❑Crop ❑ Shrub
❑Tree ❑ Other
Current Fie Conditions: // a / Iq I Current Field Conditions: —
❑ Bare Stubble ❑ Planted `:*o 1 04 ❑ Pasture ❑ Bare ❑ Stubble Planted (croo) ❑ Pasture
Soil Condition: L�
Dry ❑ Moist [yf Wet ❑ Saturated
Soil Condition:
El Dry [I moist El wet El Saturated
Not -Frozen [-Ir st Frozen ❑ Snow -Covered
,Slope:
❑tuot-Frozen ❑Frost ❑Frozen ❑ Snow -Covered
❑ 0-3% ❑ 3-6% A16-10% ❑ 10-18% ❑ >18%
Slope: ❑ 0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: ❑ None dd ❑ Moderate ❑ Strong
Odor: ❑ None ❑ Mild ❑ Moderate ❑ Strong
Vectors: 'None Few El Many El Excessive
Vectors: El None El Few ❑ Many [I Excessive
/
Application Details:
N
NA
NE
Application Details: -
Y
N
NA
NE
Application areas clearly marked?
❑
❑
❑
Application areas clearly marked?
❑
❑
❑
❑
Application within authorized area?
❑
❑
❑
Application within authorized area?
❑
❑
❑
❑
Application method appropriate?
❑
❑
❑
Application method appropriate?
❑
❑
❑
❑
Application is even (no pending)?
❑
❑
❑
Application is even (no pending)?
❑
❑
❑
❑
Sufficient setbacks from wells/residences?
❑
❑
❑
Sufficient setbacks from wells/residences?
❑
❑
❑
❑
Sufficient setbacks from surface waters?
❑
❑
❑
Sufficient setbacks from surface waters?
❑
❑
❑
❑
Slopes>10% avoided (Surface App.)?
❑
❑
Slopes>10% avoided (Surface App.)?
❑
❑
❑
❑
Slopes >18%avoided (Inwrp/Inject)?
❑ ❑
❑
Slopes>18% avoided (Incorp/Inject) ?
❑
❑
❑
❑
Incorp./Injection within time -frame?
❑ ❑
❑
Incorp./Injection within time -frame?
❑
❑
❑
❑
Biosolids visible on surface?
g ❑
❑
❑
Biosolids visible on surface?
❑
❑
❑
❑
Site Restrictions
Y N
NA
NE
Site Restrictions
Y
N
NA
NE
Public access is restricted / Signage present?
❑
❑
❑
Public access is restricted / Signage present?
❑
❑
❑
❑
Grazingsestdctions are met?
❑
;9(
❑
Grazing restrictions are met?
❑
❑
❑
❑
Transfer of biosolids is in permitted area?
❑
❑
❑
Transfer of biosolids is in permitted area?
❑
❑
❑
❑
No evidence of shallow GW?
❑
❑
❑
No evidence of shallow G W?
❑
❑
❑
❑
Sufficient timing for harvest restrictions?
❑
❑
❑
Sufficient timing for harvest restrictions?
❑
❑
❑
❑
Off Site Transport
Y N
NA
NE
Off Site Transport
Y
N
NA
NE
Tracking is prevented?
❑
❑
❑
Tracking is prevented?
❑
❑
❑
❑
Biosolids run-off is prevented?
❑
❑
❑
Biosolids run-off is prevented?
❑
❑
❑
❑
Windblown biosolids prevented?
❑
❑
❑
Windblown biosolids prevented?
❑
❑
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Vegetative buffers exist?
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Vegetative buffers exist?
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