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Home My WebLink AboutWQ0003226_CEI & NOV-2020-PC-0211_20200422ROY COOPER MICHAEL S. REGAN t.�. �'" r S. DANIEI SNUTH �xrrc:.x NOPTiO CAP0 INA Fn rironmrnlal 4u atiry Certified Mail # 7017 0190 0000 9562 6537 Return Receipt Reguested April 22, 2020 Roy Lynch, Manager Town Town of Siler City PO Box 769 Siler City, NC 27344 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2020-PC-0211 Permit No. WQ0003226 Town of Siler City RLAP Chatham County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Town of Siler City RLAP on April 21, 2020. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non -discharge Permit No. WQ0003226. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Annual Report Review inspection was conducted by Division of Water Resources staff from the Raleigh Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Sampling Condition IV.3 requires analysis be conducted on residuals from each source generating facility at the frequency specified in Attachment A. During 2019, there were only three samples of residuals from the WWTP when there were required to be four samples based on dry tons applied. This was noted in the land application certification form submitted in the 2019 annual report. There were no sampling results submitted from the WTP residuals as required in Attachment A. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. An explanation of non-compliance was submitted with the annual report stating that the fourth quarter sample for the WWTP was lost in shipment. Additionally, there was no annual sample submitted for the WTP residual. To prevent further action, please respond in writing to this office within 60 days upon your receipt of this Notice of Violation documenting that the fourth quarter sample was shipped but lost in shipment. Explain why the WTP residual was not sampled or if it was performed but not submitted then please submit those results. If you should have any questions, please do not hesitate to contact Gary Kreiser with the Water Quality Regional Operations Section in the Raleigh Regional Office at 919-791-4200. Sincerely, Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: WQS Raleigh Regional Office - Enforcement File NON -DISCHARGE Compliance/Enforcement Unit - Enforcement File Permit: WO0003226 SOC: County: Chatham Region: Raleigh Contact Person: Roy Lynch Compliance Inspection Rel2ort Effective: 02/15/17 Expiration: 01/31/22 Owner: Town of Siler City Effective: Expiration: Facility: Town of Siler City RLAP 370 Waste Treatment Plant Rd Title: Town Manager Siler City NC 27344 Phone: 919-742-4581 Directions to Facility: Highway 64 west towards Siler City. Left on Wastewater Treatment Plant Rd, just before intersection with Highway 421 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NCO026441 Town of Siler City - Siler City WWTP Inspection Date: 04/21/2020 Entry Time 01 OOPM Exit Time: 02 4C-PM Primary Inspector: Gary S Kreiser Phone: 919.791-4200 Secondary Inspectorls): Reason for Inspection: Routine Inspection Type: Annua Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 permit: WQ0003226 Owner - Facility: Town of Siler City Inspection Date: 04/2112020 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: Inspection Summary: A review of the 2019 residuals annual report was conducted by the DEQ Raleigh Regional Office. The certification form was was complete and indicated non compliance due to not sampling quarterly for the WWTP residuals The Permittee land applied 447.33 dry tons on 95.4 acres 340.73 DT of WWTP residuals were applied and 106.6 DT of WTP residuals were applied. The WWTP residuals monitoring was suppose to be conducted quarterly. However, the fourth quarter sampling was not completed According to Synagro the sample was lost in the mail and by the time it was detected in was already 2020. There was no WTP analysis submitted and it is unknown if any sampling was performed for2019 as required in the permit. The field summary forms were provided and indicated acceptable loadings. The PAN loadings for all fields were below the permitted limits. The quarterly analysis of WWTP residuals for Pathogens used the Fecal Density Method, while Specific Oxygen Uptake Rate (SOUR) was used for the analysis of Vector Attraction Reduction (The WTP residuals do not require this analysis). The appropriate soil tests were performed on the farms that were utilized in 201 B. The annual report was correctly formatted, submitted on a timely basis, however the sampling frequency (WWTP) and no WTP sampling makes the report noncompliant. Page 2 of 4 Permit: W00003226 Owner - Facility: Town of Siler City Inspection Date: 04e21+2020 Inspection Type : Annual Report Review Reason for Visit: Roul++e TVpE 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? ❑ ❑ ❑ E Is GW 59A certification form completed for facility? ❑ ❑ ❑ E Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? ❑ ❑ ❑ E Are nutrient and metal loading calculating most limiting parameters ❑ ❑ ❑ a TCLP analysis? ❑ ❑ ❑ b SSFA (Standard Soil Fertility Analysis)? ❑ ❑ ❑ Are PAN balances being maintained? ❑ ❑ ❑ E Are PAN balances within permit limits? ❑ ❑ ❑ 0 Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ ❑ ❑ Are there pH records for the Jand application site? ❑ ❑ ❑ ❑ Are nutrient/crop removar practices in p ace? ❑ ❑ ❑ ❑ 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? ❑ ❑ ❑ ❑ • i�T t 1"ITMIN 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 MPNIdry gram ❑ Geometric mean of 7 samples per monitoring period for class B<2 0' 1 OE5 CFU?dry gram ❑ Fecal coliform SM 9222 D (Class B only) 0 ❑ ❑ ❑ Geometric mean of 7 samples per monitoring period for class 13<2 0'10E6 CFU?dry gram ❑ b, pH records for alkaline stabilization (Class A) ❑ ❑ ❑ ❑ c. pH records for alkaline stabilization (Class B) ❑ ❑ 1111 Temperature corrected ❑ d. Salmonella (Class A, all test must be < 3MPN14 gram day) ❑ ❑ ❑ ❑ Page 3 of 4 permit: W00003226 Owner - Facility: Town of Siler City Inspection Date: 04121/2020 Inspection Type: Annual Report Review Reason for Visit: Routine e Timeffemp on ❑ ❑ ❑ ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations 00011 g Bench -top AerobiclAnaerobic digestion results ❑ ❑ ❑ ❑ Comment: Treatment Yes No NA NE Check all that apply Aerobic Digestion ❑ Anaerobic Digestion ❑ Alkaline Pasteunzation (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost ❑ Drying Beds ❑ Other ❑ Comment: Sampling Yes No NA NE Describe sampling Permit conditions require sampling quarterly sampling for nutf�ents and metals for MMfrP residuals according to attachment A. Annual sampling for nutrients and metals is requ..red for WTP residuals according to attachment A Is sampling adequate? ❑ 0 ❑ ❑ Is sampling representative? M ❑ ❑ ❑ Comment: Only sampled three times in 2019 for metals and nutrients for the WWTP residuals. No metal or nutrient samples were submitted for the WTP residuals. Page 4 of 4