WQ0000520_Complaint Investigation_20170830

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
S.JAY ZIMMERMAN
Director
Water Resources
Environmental Quality
August 30, 2017
Mr. Shane Fletcher, Residuals Management Coordinator
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Complaint Investigation
City of Burlington, Residuals Land Application Program
Permit No. WQ0000520
Alamance County
Dear Mr. Fletcher:
On August 29, 2017 staff of the North Carolina Division of Water Resources, Winston Salem
Regional Office (DWR) performed a complaint investigation of land application events, occurring
at site NC-CS-36 of the subject permit. This investigation was conducted in response to a complaint
that DWR received from an anonymous source alleging that"over application"was occurring at the
site. This investigation was conducted by DWR staff person Justin Henderson.
The subsequent investigation revealed the following: 1.) Buffer flags were present, and in
compliance with setback requirements for the sections of Fields 11 & 12,that had recently received
bio-solid application. 2.)There was no"ponding" of bio-solids observed in Fields 6, 11, or 12 at the
time of this investigation. 3.) Appropriate signage was present at the entrance to Fields 11 & 12. 4.)
Bio-solid application was not occurring at the time of this investigation. While the above described
observations suggest that land application operations were in compliance with Permit WQ0000520,
the following items of concern are also worth noting:
1.) Bio-Solid residuals had migrated outside of the on-site buffer flags, near the lower end of
Field 12. This migration was likely prompted by a rain event, that occurred the night after
the application event. However,the buffer flags were located beyond the minimum required
setback,thus no setback violations were observed at the time of this application. To prevent
further migration of residuals, and potential setback violations in response to potential
subsequent rain events, stabilization measures may be warranted until proper soil
assimilation can occur.
2.) Appropriate signage per Permit Condition III. (13)was not observed at the entrance to Field
6. As a reminder, you are required to be in full compliance with Condition III. (13) within
180 days from the effective date of the subject permit.
State of North Carolina I Environmental Quality
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone]

As part of this investigation, hauling records, residual analyses, and cumulative pollutant loading
rates for NC-CS-36 Fields 6, 11, &12 were requested. However, as of the date of this
correspondence,the requested information has not been received. Please refer to the enclosed
complaint inspection report for additional observations and comments. If you have any questions
regarding this letter, please contact Justin Henderson or me at(336) 776-9801.
Sincerely,
Sherri V. Knight, P. E.
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: Mr.Brent Collins—EMA Resources, Inc., [e-mail]
Alamance County Environmental Health
DWR WQ Central Office—Permit File WQ0000520

Compliance Inspection Report
Permit: WO0000520 Effective: 08/01/17 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 Certification: 988745 Phone: [phone]
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
NC0023876 City of Burlington-Southside WWfP
NC0023868 City of Burlington-Eastside WWfP
Inspection Date: 08/29/2017 Entry Time: 09:45AM Exit Time: 12:00PM
Primary inspector: Justin L Henderson Phone: [phone]
Secondary inspector(s):
Reason for Inspection: Complaint Inspection Type: Complaint
Permit Inspection Type: Land Application of Residual Solids(503)
Facility Status: II Compliant El Not Compliant
Question Areas:
El Miscellaneous Questions Sampling
(See attachment summary)
Page: 1

perk W00000520 Owner-Facility:City of Burlington
Inspection Date: 08/29/2017 Inspection Type:Complaint Reason for Visit: Complaint •
Inspection Summary:
On August 29,2017 Justin Henderson performed a compliant investigation in reference to permit No.WQ0000520.The
investigation was prompted by a compliant received by WSRO alleging"over application"of bio-solids at a site located near
2820 Milesville Rd. Elon NC. Investigation revealed presence of buffer flags in section of Filed 11 &12.These flags were in
compliance with required setback. No"ponding"was observed in the fields evaluated as part of the investigation. No land
application was occuring during investigation.Appropriate signage located at entrance to Fields 11 &12.
The following concerns were noted:
1.)Appropriate signage was not observed at entrance to Field 6 per permit condition III.(13). Permit grants permittee 180
days from effective date of current permit to be in full compliance with Condition III. (13)
2.) During investigation residuals were observed"out-side"the on-site buffer flags.The buffer flags were located beyond the
minimum setback requirements,thus no violation were incurred at the time of the investigation. However, if residuals are not
stabilized or properly assimilated by the ground prior to subsequent rain events,setback violations may occur.
Page: 2

permit WO0000520 Owner-Facility:City of Burlington
Inspection Date: 08/29/2017 Inspection Type:Complaint Reason for Visit: Complaint
Type Yes No NA NE
Land Application ❑
Distribution and Marketing ❑
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑ ❑
Is sampling representative? 0000
Comment:
Page: 3

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Figure 38 Feet
Site: NC-CS-18 0 160320 640 960 1,280