WQ0010583_NOD-2020-PC-0204 2019 AR Review_20200423

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 23, 2020
Mr. Johnny Lambert, Public Utilities Director
Utilities Director
261 Chaffin Street
Mocksville, NC 27028
SUBJECT: Notice of Deficiency — (NOD-2020-PC-0204)
2019 Annual Report Review
Davie County RLAP
Land Application of Class B Residuals
Permit No. WQ0010583
Davie County
Dear Mr. Lambert:
The Division of Water Resources (DWR) acknowledges receipt of the 2019 Annual Report for
the subject permit. A review of this report was conducted by DWR staff person Justin
Henderson. Review of the subject report reflects non-compliance with Permit No. WQ0010583.
The following deficiencies warrant your attention and action:
1) The total dry tons of residuals reportedly land applied exceeded the Maximum Dry Tons
Per Year limit of 315 dry tons as specified in Attachment A. Either ensure all future
operations are compliant with the limits specified in Attachment A or request permit
modification to increase the maximum dry tons for the applicable source facilities.
2) The reported TCLP results for Lead of 6.85 mg/L constitute an exceedance of the
regulatory level of 5 mg/L. Permit Condition IV. (2) states: Residuals that tests or is
classified as a hazardous or toxic waste under 40 CFR Part 261 shall not be used or
disposed under this permit.
3) Failure to report the above described non -compliant analytical results and operations.
Permit Condition IV. (9) states: The Permittee shall report by telephone to the Winston
Salem Office, telephone number [phone], as soon as possible, of the occurrence
or first knowledge of the occurrence of land application of residuals, abnormal in quantity
or characteristic. Furthermore, compliance was indicated on the Annual Land
Certification Form (ACF) submitted in the subject annual report. Please provide a written
response explaining why the above described non-compliance was not reported via
telephone to the Winston Salem office nor acknowledged on Form ACF, as well as what
corrective actions will be implemented to ensure proper non-compliance notifications are
achieved.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh �HCARO UHA
^^ •^^ma^� u�•i` r 336.776.9800

Along with the above described deficiencies, the following item of concern warrants your
attention:
a) The Pathogen and Vector Attraction Reduction Forms (PVRF), submitted in the subject
report, indicated an annual monitoring period. However, based upon the total amount of
dry tons of residuals that were land applied and per monitoring requirements established
in Attachment A, the PVRF forms should have indicated a quarterly monitoring period.
While analyses conducted to demonstrate pathogen and vector attraction reduction met
the required frequencies, reporting forms should be properly completed to be
representative of the specified monitoring periods in accordance with the monitoring
frequencies established in Attachment A.
b) On Form ACF, submitted in the subject report, you indicated that the facility was not in
operation during the past calendar year. This response conflicts with the included Cover
Letter, and all other Land Application Reporting Forms submitted with the subject annual
report. Please ensure all forms relay consistent and accurate reporting of facility
operations for the specified report period.
Please submit your written response, requested in Item #3 above, within 60-days of receipt of
this Notice. An announced routine compliance inspection is planned to be conducted within the
next 12 months. If you have any questions, please contact Justin Henderson or me at (336) 776-
9800.
Sincerely,
EDocuSigned by:
Loti T 15m2cr
145B49E225C94EA...
Lon Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
encl: Compliance inspection report
cc: Brent Collins, EMA Resources — Electronic Copy
Laserfiche Files — (electronic copy)

Compliance Inspection Report
Permit: WQ0010583 Effective: 12/21/18 Expiration: 04/30/22 Owner: Davie County
SOC: Effective: Expiration: Facility: Davie County RLAP
County: Davie Hwy 801 S
Region: Winston-Salem
Cooleemee NC 27014
Contact Person: James Stockert Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Brent M Collins
Secondary ORC(s):
On -Site Representative(s):
Certification: 27651 Phone: [phone]
Related Permits:
NC0024872 Davie County - Cooleemee WWTP
Inspection Date: 04/23/2020 Entry Time 08:OOAM
Primary Inspector: Justin L Henderson
Secondary Inspector(s):
Exit Time: 11:45PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 04/23/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) acknowledges receipt of the 2019 Annual Report for the subject permit. A review of
this report was conducted by DWR staff person Justin Henderson. Review of the subject report reflects non-compliance with
Permit No. W00010583. The following deficiencies warrant your attention and action:
1) The total dry tons of residuals reportedly land applied exceeded the Maximum Dry Tons Per Year limit of 315 dry tons as
specified in Attachment A. Either ensure all future operations are compliant with the limits specified in Attachment A or
request permit modification to increase the maximum dry tons for the applicable source facilities.
2) The reported TCLP results for Lead of 6.85 mg/L constitute an exceedance of the regulatory level of 5 mg/L. Permit
Condition IV. (2) states: Residuals that tests or is classified as a hazardous or toxic waste under 40 CFR Part 261 shall not
be used or disposed under this permit.
3) Failure to report the above described non -compliant analytical results and operations. Permit Condition IV. (9) states:
The Permittee shall report by telephone to the Winston Salem Office, telephone number [phone], as soon as
possible, of the occurrence or first knowledge of the occurrence of land application of residuals, abnormal in quantity or
characteristic. Furthermore, compliance was indicated on the Annual Land Certification Form (ACF) submitted in the subject
annual report. Please provide a written response explaining why the above described non-compliance was not reported via
telephone to the Winston Salem office nor acknowledged on Form ACF, as well as what corrective actions will be
implemented to ensure proper non-compliance notifications are achieved.
Along with the above described deficiencies, the following item of concern warrants your attention:
a) The Pathogen and Vector Attraction Reduction Forms (PVRF), submitted in the subject report, indicated an annual
monitoring period. However, based upon the total amount of dry tons of residuals that were land applied and per monitoring
requirements established in Attachment A, the PVRF forms should have indicated a quarterly monitoring period. While
analyses conducted to demonstrate pathogen and vector attraction reduction met the required frequencies, reporting forms
should be properly completed to be representative of the specified monitoring periods in accordance with the monitoring
frequencies established in Attachment A.
b) On Form ACF, submitted in the subject report, you indicated that the facility was not in operation during the past
calendar year. This response conflicts with the included Cover Letter, and all other Land Application Reporting Forms
submitted with the subject annual report. Please ensure all forms relay consistent and accurate reporting of facility
operations for the specified report period.
Please submit your written response, requested in Item #3 above, within 60-days of receipt of this Notice. An announced
routine compliance inspection is planned to be conducted within the next 12 months. If you have any questions, please
contact Justin Henderson or me at [phone].
Page 2 of 3

Permit: WQ0010583 Owner - Facility: Davie County
Inspection Date: 04/23/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Page 3 of 3