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Home My WebLink AboutWQ0003992_2019 Annual Report NOD_20200505ROY COOPER Governor MICHAEL S. REGAN +�;�°,,• Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality May 5, 2020 Mr. Brantley Price, Town Manager Town of West Jefferson P.O. Box 490 West Jefferson, NC 28694 Subject: Notice of Deficiency (NOD-2020-PC-0214) Review of the 2019 Annual Report Review Town of West Jefferson, Residuals Land Application Program Permit No. WQ0003992 Ashe County Dear Mr. Price, Division of Water Resources (Division) staff person Caitlin Caudle has completed a review of the 2019 Annual Report for the subject permit. The majority of the report reflects compliance with the subject permit. However, the following deficiency was noted during the review which requires your attention and action: 1. Fecal coliform analysis was not conducted in compliance with permit condition IVA, which requires pathogen reduction to be carried out according to 15A NCAC 02T .1106(b). This requirement states that seven fecal coliform samples shall be collected and analyzed. However, only five were reported in the annual report. Please provide, if available, the two additional fecal coliform analysis within 60 days of receipt of this letter. If you are able to provide the two additional fecal coliform analyses, please also provide an updated Pathogen and Vector Reduction Summary Form with a recalculated geometric mean for fecal coliform. Our office appreciates your attention to the above listed item. Please take actions necessary to address the item described above. Failure to properly address items may result in enforcement actions, including issuance of a Notice of Violation. 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.mitchell(u,ncdenr.gov or Ion.snider@ncdenr.gov. Sincerely, EDocuSigned by* Loti T 15m2cr 145B49E2gK94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO cc: Brandon Patrick, ORC — Electronic copy: wmV@townofwj.com Ashe County Environmental Health (Electronic copy) Laserfiche File WQ0003992, WSRO Electronic Files 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 Compliance Inspection Report Permit: WQ0003992 Effective: 04/22/19 Expiration: 07/31/24 Owner : Town of West Jefferson SOC: Effective: Expiration: Facility: Town of West Jefferson RLAP County: Ashe 335 Clearwater Dr Region: Winston-Salem West Jefferson NC 28694 Contact Person: Brantley Price Title: Town Manager Phone: 336-246-3551 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0020451 Town of West Jefferson - West Jefferson WWTP Inspection Date: 05/01/2020 Entry Time 10:OOAM Exit Time: 12:OOPM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Patrick Mitchell 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 Sampling Land Application Site Pathogen and Vector Attraction (See attachment summary) Page 1 of 5 Permit: WQ0003992 Owner - Facility: Town of West Jefferson Inspection Date: 05/01/2020 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: The annaul report was reviewed and found to be non compliant with the subject permit. Adequate pathogen reduction sampling was not represented by the annual report provided. Five fecal coliform samples were reported and the subject permit requires a minimum of seven samples to reflect compliance with pathogen reduction requirements. The two additional fecal coliform samples will be requested, if they were collected, within ten days of teh reciept of the letter. A item of concern is the SAR. It was calculated as 4.9 in the annual report. Page 2 of 5 Permit: WQ0003992 Owner - Facility: Town of West Jefferson 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? ❑ ❑ ❑ Are current metals and nutrient analysis available? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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: 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) ❑ ❑ ❑ Temperature corrected ❑ d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ❑ Page 3 of 5 Permit: WQ0003992 Owner - Facility: Town of West Jefferson 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: 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: Sampling Yes No NA NE Describe sampling: Is sampling adequate? ❑ 0 ❑ ❑ Is sampling representative? ❑ 0 ❑ ❑ Comment: Only five sampling events were reported in the annual report. A minimum of seven is needed. Land Application Site 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? Yes No NA NE ❑❑❑■ ❑❑❑■ ❑❑❑■ ❑❑❑■ ❑❑❑■ ❑❑❑■ Page 4 of 5 Permit: WQ0003992 Owner - Facility: Town of West Jefferson Inspection Date: 05/01/2020 Inspection Type: Annual Report Review Reason for Visit: Routine 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: ❑❑❑■ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑❑■ ❑❑■❑ ■❑❑❑ ■❑❑❑ ❑❑■❑ Page 5 of 5