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Home My WebLink AboutWQ0016966_Annual Report Review - NOV-2020PC0231_20200504DocuSign Envelope ID: 878449A0-06FD-49FD-9DB5-CB3104B7A5DB �+TM i E, e.;m+I ROY COOPER= Governor u f r•� MICHAEL S. REGAN Oft, • Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality May 4, 2020 Mr. Kenneth W. Gamble, Town Manager Town of Denton P.O. Box 306 Denton, NC 27329 Subject: Notice of Violation (NOV-2020-PC-0231) Review of the 2019 Annual Report Town of Denton, Residuals Land Application Program Permit No. WQ0016966 Davidson County Dear Mr. Gamble: Division of Water Resources (Division) staff person Patrick Mitchell has completed a review of the 2019 annual report. Review of the annual report reflects non-compliance with the subject permit. The following violations noted during this review requires your attention and action: 1. Permit Condition II. 6. and II. 7. requires that Class B Residuals shall demonstrate compliance with NCAC 02T .1106 Class B pathogen reduction requirements and NCAC 02T .1107 vector attraction reduction requirements. Permit Condition IV. 8. requires that those results shall be submitted to the Division in annual reports. The Annual Pathogen and Vector Attraction Reduction form (PVRF) included in the 2019 annual report indicated that Alternative No. 2 (Lime Stabilization) was utilized for pathogen reduction and that Option No. 6 (Alkaline Stabilization) was utilized for vector attraction reduction. However, there was no data submitted in the subject annual report to demonstrate compliance with either of these methods for any of the reported land application events that occurred in 2019. This constitutes multiple violations of Permit No. WQ0016966. If present, please submit the data for pathogen and vector attraction reduction for all of 2019. 2. Permit Condition II. 4. requires that only land application site fields as approved in the Permit's Attachment B may be utilized for land application of residuals. The subject permit also requires that residuals field loading data shall be tracked and accurately reported to demonstrate compliance with regulatory limits established in Permit Condition II. 5. (i.e. Cumulative Pollutant Loading Rates for regulated Metals), and Permit Condition II. 10. (Agronomic Loading Limits for Plant Available Nitrogen). The Annual Metals Field Loading Summary forms (MFLS) and Annual Land Application Field Summary forms (FSF) submitted in the 2019 annual report for Land Application Site ID's 02-04 and 02-05 all reported acreages utilized that are greater than those approved in the Permit's Attachment B. Reporting forms indicated 16.6 acres was utilized for Site No. 01 North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 336.776.9800 DocuSign Envelope ID: 878449A0-06FD-49FD-9DB5-CB3104B7A5DB 02-04, and 10.6 acres was utilized for Site No. 02-05. However, Site No. 02-04 is only approved for 11.87 acres and Site 02-05 is only approved for 8.77 acres in the Permit Attachment B. Utilizing more area than what is approved for these two sites in the permit constitutes multiple violations of Permit No. WQ0016966. Inaccurately reporting field loading of Metals and Plant Available Nitrogen by using unapproved increased acreage also constitutes multiple violations of Permit No. WQ0016966. Please provide an explanation for why more area was reported for land application on these sites than the area approved in the Permit Attachment B. Please provide revised MFLS and FSF forms for these two sites using the corrected acreage for each if those acreages reported were not correct. In addition to the violations described above, the item of concern listed below should also be noted from this review. As you are aware, the subject permit was recently renewed. Permit Condition IV. 2. requires that residuals from each source generating facility shall be analyzed to demonstrate they are non -hazardous (TCLP analysis) at the frequency specified in Permit Attachment A. The previous version of this permit dated March 19, 2015, specified a minimum required frequency of once per permit cycle in Permit Attachment A for TCLP analysis of the WWTP and the WTP. Please be aware that the current version of your permit list a minimum required frequency of once per year for TCLP analysis of the WWTP and the WTP. If you desire to reduce the frequency of each residuals source facility to once per permit cycle, please submit a request to the Division asking for reduced TCLP testing frequency. Our office appreciates your prompt attention and action to the above listed violations and item of concern. Please provide the information requested above in items #1 and #2 to me within 60 days following receipt of this letter. If you wish to present additional information related to those items, or if you believe there are other factors which should be considered, please include such information in writing within sixty (60) days following receipt of this letter. Please be advised that enforcement actions may be taken should these violations persist. If you have any questions regarding this Notice, please contact Patrick Mitchell or me at the letterhead address or phone number, or by email at patrick.mitchellkncdenr.gov or Ion. snidergncdenr. gov. Sincerely, Docu&gned by tP 9 Mjtjd t, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO cc: Mr. Troy Branch, ORC — Town of Denton (Electronic copy: tbranch(c-triad.rr.com) Mr. Zach Key, ORC — Southern Soil Builders (Electronic copy: zkey(a-southernsoilbuilders.com) Davidson County Environmental Health (Electronic copy) Laserfiche File WQ0016966, WSRO Electronic Files Page 2 of 2 Compliance Inspection Report Permit: WQ0016966 Effective: 04/14/20 Expiration: 09/30/26 Owner : Town of Denton SOC: Effective: Expiration: Facility: Town of Denton RLAP County: Davidson 300 Council Access Rd Region: Winston-Salem Denton NC 27239 Contact Person: Zach D Key Title: Phone: 336-957-7871 Directions to Facility: System Classifications: LA, Primary ORC: Troy B Branch Secondary ORC(s): On -Site Representative(s): Related Permits: NC0026689 Town of Denton - Denton WWTP NC0082949 Town of Denton - Denton WTP Inspection Date: 05/01/2020 Entry Time 08:OOAM Primary Inspector: Patrick Mitchell Secondary Inspector(s): Certification: 22733 Phone: 336-859-4460 Exit Time: 10:30AM Phone: 336-776-9698 Caitlin Caudle 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 Record Keeping Treatment Land Application Site Pathogen and Vector Attraction (See attachment summary) Page 1 of 5 Permit: WQ0016966 Owner - Facility: Town of Denton Inspection Date: 05/01/2020 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On May 1, 2020, WSRO staff conducted a review of the 2019 annual report. No site visit was made during this review. The subject annual report was found to be non -compliant with Permit No. WQ0016966. The violations listed below were noted during this review. 1. There were no pathogen or vector attraction reduction records provided in the 2019 annual report. The annual pathogen & vector certification form included in the subject report indicated that lime stabilization was used for all land application events in 2019. However, no pH, time, and temperature logs were provided for these events to demonstrate compliance. Requested that these missing records be submitted if present. 2. Incorrect acreages, greater than those permitted, were reported on the MFLS and FSF forms submitted in the 2019 annual report. The forms indicated that 02-04 utilized 16.6 acres and 002-05 utilized 10.6 acres. However, 02-04 and 02-05 are only permitted for 11.87 acres and 8.77 acres, respectively. Requested an explanation for why these increased acreages were reported for land application and that revised forms be submitted if applicable. In addition to the two violations listed above, the following concern was provided: • The permit was recently renewed in April 2020. The new frequency for TCLP is once per year. Previously the frequency was once per permit cycle. Reminded Permittee of the new frequency and informed them that if they want this to return to once per permit cycle to please submit a written request for this reduction. Page 2 of 5 Permit: WQ0016966 Owner - Facility: Town of Denton Inspection Date: 05/01/2020 Inspection Type: Annual Report Review 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? ❑ 0 ❑ ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ 0 ❑ Are current metals and nutrient analysis available? 0 ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? ❑ 0 ❑ ❑ a. TCLP analysis? ❑ 0 ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? 0 ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ 0 ❑ ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? 0 ❑ ❑ ❑ Are hauling records maintained and up-to-date? 0 ❑ ❑ ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑ Comment: See summa Pathogen and Vector Attraction Yes No NA NE a. Fecal coliform SM 9221 E (Class A or B) ❑ ❑ 0 ❑ 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) ❑ 0 ❑ ❑ Temperature corrected ❑ d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ❑ Page 3 of 5 Permit: WQ0016966 Owner - Facility: Town of Denton Inspection Date: 05/01/2020 Inspection Type: Annual Report Review 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: 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? For injection? ❑ ❑ ❑ For incorporation? ❑ ❑ 0 ❑ 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? ❑ ❑ ❑ Page 4 of 5 Permit: WQ0016966 Owner - Facility: Town of Denton Inspection Date: 05/01/2020 Inspection Type: Annual Report Review 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