WQ0000520_NOD-2017-PC-0148_20170417

•
ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
S.JAY ZIMMERMAN
Director
Water Resources
Environmental Quality
Certified Mail#7011 1570 0001 8546 3238
Return Receipt Requested
April 17, 2017
Mr. Harold T. Owen, City Manager
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Notice of Deficiency-NOD-2017-PC-0148
Review of the 2016 Annual Report
City of Burlington, Residuals Land Application Program
Permit No. WQ0000520
Alamance County
Dear Mr. Owen:
The Division of Water Resources (DWR) acknowledges receipt of your 2016 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 the Permit No. WQ0000520. The
following deficiencies require your attention and action:
1. Exchangeable Sodium Percentage (ESP) was not reported as part of the Standard Soil
Fertility Analysis for fields OR-64-1 nor AM-1001-1. This is a repeat deficiency that was
noted on the annual report review letter dated April 4, 2016. Refer to Permit Condition IV.
(5.) to obtain a list of parameters required to be reported on the annual soils analysis.
In the future,please calculate and report the ESP from soil analysis reports if the testing
lab(s) does not provide this value in the results.
Please provide a written explanation to this office, explaining how the above described deficiency
shall be prevented from occurring in the future. Your response should be received within 30 days of
receipt of this Notice.
An announced routine compliance inspection is planned to be scheduled within the next 12
months. If you have any questions regarding this letter,please contact Justin Henderson or me at
[phone].
State of North Carolina I Environmental Quality
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone]

•
Sincerely,
/ 4Y.
Sherri V. Knight, P. E.
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: Mr. Shane Fletcher,Residuals Coordinator—City of [e-mail]
Mr.Brent Collins—EMA Resources, Inc., [e-mail]
Alamance County Environmental Health
DWR WQ Central Office—Permit File WQ0000520

•
Compliance Inspection Report
Permit: WQ0000520 Effective: 08/13/14 Expiration: 07/31/17 Owner: City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington Residuals Land Application Progra
County:Alamance PO Box 1358
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:
NC0083828 City of Burlington-J.D.Mackintosh,Jr.WTP
NC0023876 City of Burlington-Southside WWTP
NC0023868 City of Burlington-Eastside VWVTP
Inspection Date: 04/13/2017 Entry Time: 01:OOPM Exit Time: 04:OOPM
Primary Inspector: Justin L henderson Phone: [phone]
Secondary inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids(503)
Facility Status: ❑ Compliant II Not Compliant
Question Areas:
El Miscellaneous Questions
(See attachment summary)
Page: 1

permit WQ0000520 Owner-Facility:City of Burlington
Inspection Date: 04/13/2017 Inspection Type:Annual Report Review Reason for Visit: Routine
Inspection Summary:
April 17,2017
Mr. Harold T. Owen, City Manager
City of Burlington
P.O. Box 1358
Burlington, NC 27216
SUBJECT: Notice of Deficiency-NOD-2017-PC-
Review of the 2016 Annual Report
City of Burlington, Residuals Land Application Program
Permit No.WQ0000520
Alamance County
Dear Mr. Owen:
The Division of Water Resources(DWR)acknowledges receipt of your 2016 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
the Permit No.WQ0000520. The following deficiencies require your attention and action:
1. Exchangeable Sodium Percentage(ESP)was not reported as part of the Standard Soil Fertility Analysis for fields OR-
64-1 nor AM-1001-1.This is a repeat deficiency that was noted on the annual report review letter dated April 4,2016. Refer
to Permit Condition IV. (5.)to obtain a list of parameters required to be reported on the annual soils analysis.
In the future, please calculate and report the ESP from soil analysis reports if the testing lab(s)does not provide this value
in the results.
Please provide a written explanation to this office,explaining how the above described deficiency shall be prevented from
occurring in the future.Your response should be received within 30 days of receipt of this Notice.
An announced routine compliance inspection is planned to be scheduled within the next 12 months. 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.Shane Fletcher, Residuals Coordinator—City of Burlington-sfletcher©ci.burlington.nc.us
Mr. Brent Collins—EMA Resources, Inc.,[e-mail]
Alamance County Environmental Health
DWR WQ Central Office—Permit File WQ0000520
WSRO Files
Page: 2

Annual Report Review SOP Class B Land Application
Reporting Period: Z.G t L
Permit Details:
• Is 503? qe ` i 6QG
� c.•,:,_�
• ClassAorB? 'U , ?- -1-ko v7rh HI
• Maximum Dry Tons Per Year:
• Number of acres permitted: 3, ,50. 2
• Number of fields in permit: 10 y
• Counties that land is permitted for: A•le-^-F^« C *'4> 1 vi 7 cr.(L., 0 rQ , eana„,ljL
• Monitoring Frequency for TCLP: Ni%(\vc ,•" Se'J �L
• Monitoring Frequency for Residuals Analysis: '/`o Do-`f C sE CQucAr 1-tJ W T?)
• Monitoring Frequency for Pathogen&Vector Attraction Reduction: a v-� � +v P
• Groundwater monitoring:N/A: `1LG .9 Etek Ste" ) 'r e^`ro ea
1.Annual Land Application Certification Form
• Was a certification form submitted? k'2`,
• Was land application conducted during the reported year? Ye.--5 ,S11S/C(c_
• How many dry tons and dry tons per acre were applied? 3,6 t/q�761 PT
�K
• Were the applications within the permitted amount? y'e5
• Verify PAN if more than 10 tons/acre? A)
• Did it indicate compliance? 'e5
• Was it signed by the appropriate people? )" 9
2. Monitoring k� `1e5ea
q C!? S�
rA
• Were the analyses conducted at the required frequency? r� L5
• Was an analyses taken for each source that was land applied? 1'65
• Were the metals analyses reported on the Residual Sampling Summary Form? .0_5
• Were the results reported in mg/kg? M e 5
• Were the pH's 6.0 or greater for each residual sample? 4es
• Were the heavy metals within ceiling concentration permit limits? Yes
Were the lab analyses attached? `{Q 5
• Were all the required parameters tested? yc,5
• Was TCLP analysis conducted? 't e 5 Fv r 69.9A- dt SOJ V--
• Were the TLCP contaminants within regulatory limits? 6 a ';t5 ' ''
• Was a corrosivity, ignitability, and reactivity analysis conducted? yes
3. Field Summary
• Were the land application events recorded on the Field Summary Forms? %( s
• How many fields were applied on this year? 460
683• Was a Field Summary Form submitted for each field? '1
'tot' • Were all the residuals applied to permitted land?
• Were all the residuals applied from pe tted sources? %?e
• Were the field loading rates for each metal and PAN calculated(year to date)? 2S
• Were the cumulative pollutant loading rates calculated? L✓
• Were the calculations correct? ye,b
• Were the PAN loading rates within permit limits? ti%y e5
• Were the heavy metal cumulative pollutant loading rates within permit limits? (
• Were the residuals applied on a suitable crop? \,j

\,
V
• Were the applications conducted during the crop's growing season? V
• Were the Field Summary Forms complete? ye E
• Was lime application on Field Summary Form?No lime applied.
4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Re uction Form sub,fitted? '�CS
• Did the form indicate the pefj�iod of coveraethe residual ass,and the pathogen reduction �es
t alternative and the vector attraction reduction option used?
• Was the appropriate documentation to show pathogen and vector attraction reduction included
in the report? ',,QS
— • Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? ?P S
Class B Pathogen Review
Alternative 1 —Fec Coliform De ity
• Was the sampling co ucte the required frequency?
• Were seven samples
• Was the geometric lculated and done correctly?
• Did the results sh compli e(less than either 2,000,000 MPN/gram of total solids or
2,000,000 Colo Forming Units am of total solids)?
Alternative 2—Use of Process to Significantly Reduce Pathogens(one of five)
• Was the sampling conducted at the required frequency? e,5
1.Aerobic Digestion
• . it an aerobic process(Inspection)?
• W_e logs submitted showing time and tempera' re?
• Wer- emperatures within range for complete •me period?
• Was th• time and temperature between 40 • . s at 20°C(68°F)and 60 days at 15°C
(59°F)?
2.Air Drying
• Were the resid on sand beds or •ave or unpaved basins for three months?
• Was the ambient to • •erature ab• e 0°C(32°F)for two months?
• Were the residuals p. .lly di:-sted?
• Were residuals exposed t• osphere during two months above 0°C(not snow
covered)?
3.Anaerobic Digestio
•Was it an anaerobi •rocess(Inspec •,n)?
•Were logs subm••ed showing time and -mperature?
•Were tempera Nres within range for comp • e time period?
•Was the ti - and temperature between 15 da s at 35°C(95°F)to 55°C(131°F)and 60
days at 20° (68°F)?
4. Co posting(usually will be Class A when compos g is used)
W• it a composting procedure(not natural decay under • controlled conditions)?
Were logs submitted showing time and temperature?Was the temperature raised to 40
5. Lime Stabilization

Was alkaline material added to residuals a form of lime(hydrated lime,quicklime, lime
containing kiln dust or fly ash)? 7'e
• Were logs submitted showing time and temperature? q es
• Was the pH raised to 12 after two hours of contact? ye
• Were logs submitted showing time and pH? Kt
• Was temperature corrected to 25°C(77°F)? e5
Alternative 3 —Use of P ,c= ses Equivalent to RSRP
(Not commonly use. See •1'"ite House Manual page 100-103,tables 11-1 and 11-2.)
Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency? Y G S
Option 1 —38%Volatile Solids Reduction
• Was ere 38%reduction?
• Were lb sheets/calculations in report?
• Was the reduction on volatile solids(not total solids)?
• Were the .amples taken at beginning of digestion process and be'ore application
(Inspection)'
• Were calcul. ions correct?
Option 2—40-Da Bench Scale Test
• Were residuals fr• anaerobically digested treatment( spection)?
• Were residuals ana, obically digested in lab?
• Was the test run for 1 days?
• Was the test done be -en 30°C(86°F)and 37°C '9°F)?
• Was the reduction of on olatile solids(not tota solids)?
• Was the reduction less th.h• 17%?
• Were lab sheets/calculation in report?
• Were calculations correct?
Option 3 —30-Day Bench Scale ;st
• Were residuals from aerobically d sted treatment(Inspection)?
• Were residuals aerobically digest-• ' lab?
• Were residuals 2%or less total •lids'
• If not 2%total solids, was the -st ran . a sample diluted to 2%with unchlorinated
effluent?
• Was the test run for 30 da ?
• Was the test done at 20°' (68°F)?
• Was the reduction of o volatile solids(not t.,tal solids)?
• Was the reduction le than 15%?
• Were lab sheets/ca ulations in report?
• Were calculation correct?
Option 4—Spe• fic Oxygen Uptake Rate(SOUR)
• Were resid - s form aerobically digested treatment spection)?
• Were resi• als 2%or less total solids(dry weight bas )(not diluted)?
• Was the -st done between 10°C(50°F)and 30°C(86° )?
• Was t • temperature corrected to 20°C(68°F)?
• Was . e SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total
resid al solids(dry weight basis)?

• Was the sampling h lding time two hours?
• Was the test started w in 15 minutes of piing or aeration maintained?
Option 5 — 14-Day Aerobic cess
• Were the residuals from aerob ly digested treatment(Inspection)?
• Were the residuals treated f 14 s?
• Was the residuals tempe re highe an 40°C(104°F)for a 14-day period?
• Was the average resid als temperature ' er than 45°C(113°F)?
Option 6—Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? `(e---,
• Did the pH of residuals remain at 12 or higher for two hours without the addition of
more alkali? y e-5
• Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
without the addition of more alkali? ‘(e—S
• Was the pH corrected to 25°C (77°F)? `(e-----
Option 7—Drying •f Stabilized Residuals
• Does the residuals •ntain any unstabilized resi• als?
of • Were the residuals mi -d with any other mat= ials?
• �5 • Were the residuals dried . ► to 75%total s• ids?
(\' Option 8—Drying of Unstabili.-d Res'•uals
M • Were the residuals mixed with . •ther materials?
vo • Were the residuals dried to 90% o solids?
kOption 9—Injection
_A tv • Was there any signific. •amount of residu. on land surface one hour after injectionif (Inspection)?
\ • Was injection done .n pasture or hay field?
• Was injection do • at time that crop was growing?
• If Class A with espect to pathogen,were.residuals in ted with eight hours after
N., v v' P P g J
N � discharge from •athogen treatment?
ao N n
N f 5. Soil Tests ceg,w,gL -
!..
�a • Was a Standard Soil Fertility Analysis conducted for each application field? V C 5 ' `, 907• c„.11 t•f_A.
fV
i • Were the soil pH's 6.0 or greater for each application field? t`-' o
• If no,was lime applied to those fields?
• Were the copper and zinc indexes in the soil less than 2000 for each application field? �e..3
• Was sodium less than 0.5 meq/100 cm^3? `k25
• Was the exchangeable sodium percentage(ESP) less than 15%? eS
6.General
• Was the report in the proper format? �P9� Cam-d N ok r - of 4- .{�lcl ,�+ r . cc"
• Was the annual report complete? 0 �`T; T`ow;, ,0t % ` G . 7
ati
• Was the report submitted on time? i c5
ATA , bai — I

permit WC0000520 Owner-Facility:City of Burlington
Inspection Date: 04/13/2017 Inspection Type:Annual Report Review Reason for Visit: Routine
Tyne Yes No NA NE
Distribution and Marketing ❑
Land Application III
Page: 3