WQ0000520_Inspection_20160404

PAT MCCRORY
Governor
DONALD R. VAN DER VAART
Secretary
S. JAY ZIMMERMAN
Water Resources Director
ENVIRONMENTAL QUALITY
April 4, 2016
Mr. Harold T. Owen, City Manger
City of Burlington
P.O. Box 1358
Burlington,NC 27216
SUBJECT: Review of the 2015 Annual Report
City of Burlington, Residuals Land Application Program
Permit No. WQ0000520
Alamance County
Dear Mr. Owen:
The Division of Water Resources Winston-Salem Regional Office (DWR) has completed a
review of the 2015 Annual Report for the subject residuals land application program. Initial
review of the report found it to be incomplete and non-compliant. Additional information was
necessary for determining final compliance with the subject permit. This information was
requested on March 31, 2016, and subsequently received on March 31, 2016. Review of the
additional information reflects compliance with the permit.The incomplete or missing items that
were noted from review of the subject report are listed below.
1. The subject annual report indicated that no land application activities for the Mackintosh
WTP residuals source facility occurred for the year 2015 under the subject permit.
However, DWR conducted a compliance inspection on July 28, 2015 and residuals from
the Mackintosh WTP were actively being land applied to land application site AM-128 at
the time of the inspection. This land application event was taking place under Permit No.
WQ0000520. Therefore these activities along with all other activities of operation under
this permit should have been reported in the 2015 annual report.
Information related to 2015 Mackintosh WTP operations was requested on March 31,
2016, and received on March 31, 2016. This information was also reported in the 2015
annual report for Permit No. WQ0021632. Review of this additional information appears
to be complete and reflects compliance with the permit. Please ensure that all activities
which occur within a calendar year under Permit No.WQ0000520 are included in the
associated annual report for this permit.
2. Residuals pH was not reported on the Annual Residuals Sampling Summary Form for any
of the residuals source facilities in 2015. In the future, please report pH on the Annual
Residuals Sampling Summary Form along with all other required residuals
parameters.
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone] Customer Service 1-877-623-6748
Internet www.ncdenr.gov-www.ncwater.org

3. There were a number of soil analyses results for land application sites included in the
subject report which did not report Exchangeable Sodium Percentage (ESP) as required in
the permit.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.
Your attention and action to the items described above is appreciated. Please be advised that if not
corrected, any reoccurrence of these deficiencies may result in the issuance of a Notice and
potential further enforcement actions by the Division. An announced routine facility compliance
inspection is planned to be scheduled within the next 12 months.
If you have any questions regarding this letter,please contact Patrick Mitchell or me at the
letterhead address or phone number, or by email at [e-mail] or
[e-mail].
Sincerely,
- J -&
Sherri V. Knight, P. E.
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: Mr. Shane Fletcher,Residuals Coordinator—Cityof Burlington, P.O. Box 1358,Burlington,NC 272016
Mr.Brent Collins—EMA Resources, Inc., 755 Yadkinville Rd., Mocksville,NC 27028
Alamance County Environmental Health
DWR WQ Central Office—Permit File WQ0000520
Page 2 of 2

Permit: WQ0000520 Owner-Facility:City of Burlington
Inspection Date: 03/30/2016 Inspection Type:Annual Report Review Reason for Visit: Routine
Inspection Summary:
A review of the 2015 Annual Report for the subject permit has been completed.This inspection did not include site visits to
the residuals generating facility or land application sites. The Annual Report was found to be incomplete and reflects
non-compliance with the permit.Additional information was requested from the Permittee and received on March 31,2016.
This additional information reflects compliance with the permit. Below is a summary of findings.
The following items were found to be missing in the 2015 Annual Report.These were discussed with the Permittee, and
subsequently were received via email on March 31,2016:
-The 2015 Annual Report indicated that no land application of Mackintosh WTP residuals occurred in 2015 under the
subject permit. However,WSRO conducted an inspection on July 28,2015 and residuals from the Mackintosh WTP lagoon
#2 were being land applied onto Site AM-128 under the subject permit.The missing forms and updates were received on
March 31, 2016. Forms indicate that all WTP residuals went to Site AM-128,and reflect compliance with the permit.
-There was no Annual Metals Field Loading Summary Form for AM-18 Field#2 in the report.The form received on March
31,2016 was found to be complete and reflects compliance.
-There was no Annual Land App. Field Summary form in the report for AM-116 Field#1. The form received on March 31,
2016 was found to be complete and reflects compliance.
The following items were discussed, and the Permittee is to take actions to prevent future occurrences:
-Residuals pH was not reported on the Annual Residuals Sampling Summary Form. It was in the lab data from Burlington
Lab and in the pathogen/vector lab results, but not reported on the form as required. Permittee is to be sure that pH along
with all other required parameters are reported on forms in the future.
-The soils analyses completed by the private labs did not report ESP. Permittee is to ensure that ESP is calculated and
reported if the lab doesn't report it on the results sheet. It should be noted that WSRO calculated ESP for several sites, and
they reflect compliance.
Page: 2

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 VW TP
Inspection Date: 03/30/2016 Entry Time: 09:45AM Exit Time: 03:30PM
Primary Inspector: Patrick Mitchell 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:
Miscellaneous Questions
(See attachment summary)
Page: 1

i 'y�n — 3 0apr, l�nr//41 L/rlE — 1406QC�S-LC
78
Annual Report Review SOP Class B Land Application 'M '
r.30
Reporting Period: Un�� � �i'�P 5°go
0 , ..if/Iio,
Permit Details:
/Vfls'' ? So" s
• Is 503? �t S, k ,I V
• Class A or B? YKiI iJ
• Maximum Dry Tons Per Year: 791 6
• Number of acres permitted: 4,152. 2.
• Number of fields in permit:2-
• Counties that land is permitted for: AI tA..,a, Ch.g,.,„ (f titl,, .'u,-ig,,Q(4"r}'`r R.-4'1Pk •
• Monitoring Frequency for TCLP: A n Ah,1
• Monitoring Frequency for Residuals Analysis: thoC Aa7>i-ex tl- wT° 6"``/- 1,'
• Monitoring Frequency for Pathogen&Vector Attraction Reduction: '4c. €1,7, , tx ep1--IJT(1,Q;.e .
• Groundwater monitoring:N NA
1.Annual Land Application CertificationForm
• Was a certification form submitted? 0.
• Was land application conducted during the reported year? Y
• How many dry tons and dry tons per acre were applied? 3,r7( `/,9`/ J cis — 2'3 d4-..J1a`r�
2
• Were the applications within the permitted amount? YES.
V.
1_ • Verify PAN if more than 10 tons/acre? NA .
r • Did it indicate compliance? ` 5. / �°'
,,,v� • Was it signed by the appropriate people? `1ES. y�5 40 a nG�`i
1/4`` k e`'`r 2. Monitoring �1.,�" e �at.v'' VIA
..,;� vt p, Vtvt
�`� • Were the analyses conducted at the required frequency? 50"1'� vr` ,� rk� �sf� k�k^°''^
° �� 4<°' ',5 1• Was an analyses taken for each source that was land applied? Ohl,i •- Z '^"'rP (e
e A•ok\ ) • Were the metals analyses reported on t e Residual Sampling Summary Form? `?E3.
N\ �y`'' • Were the results reported in mg/kg? *S, r 1_ Un I hut 441 4,,„-, — s ‘'Cl.
• Were the pH's 6.0 or greater for each residual sample net iepo ,,„, ki ,c.,
RLoY 2 • Were the heavy metals within ceiling concentration permit limits? YES, fF' '* Q n -•-'
`t Were the lab analyses attached? . \\II 7—
�`�d1}j
2 10 • Were all the required parameters tested? YES. k 5a-- C.�IKt -*cL L4 u"P"1`rar<<<!-.
e�k • Was TCLP analysis conducted? ,}s��OL,,,,_q -'Id j
• Were the TLCP contaminants within regulatory limits? ki/c5. ki,
• Was a corrosivity, ignitability, and reactivity analysis conducted? YE5. 6.A`1 p\.1,
3. Field Summary 511
iV 4
^,^ • Were the land application events recorded on the Field Summary Fo • .. yyyW-K�_18 ,1�2
FCe , How many fields were applied on this year? 9 > `�^ m,� Af �G Pea 4, s` y;
Was a Field Summary Form submitted for each fie d? YES,h,, '1s$ N° 1
( ( I
� �� b' - Were all the residuals applied to permitted land? �� � �' � ^°� 7�,err d-.
6"4
�`\'� • ct�• Were all the residuals applied from permitted sources? tfES AM-7 3 3
Were the field loading rates for each metal and PAN calculated(year to date)? `/65. ., /t}F;8 )is 9 �1�
1�3"'l• Were the cumulative pollutant loading rates calculated? ''F Far., rcpa.4t1 A.2- ac iE
6vr! Sil(^TM 7 • Were the calculations correct? `( , a`k /kM- Ipe V.-1oA,, ?'�',k4ok2• Were the PAN loading rates within permit limits? �( I . M16 1,,1- 3D.o
`�'IA\' "o' ' • Were the heavy metal cumulative pollutant loading rates wi in permit limits? �{u f -�,, n k1 21.0 p 44
• Were the residuals applied on a suitable crop? ‘1),65 u 't-p►`i Qc..."•• AM -10oi F-1
5; OR-o7 F 2— rr4kA - tt 1;11- 1v.2'U+'
V 8 Am �rC� t- ` ` 1/, sGc/VJ U1�1rua,�,,I I _,rnn,, (trill 11.9acru?
hM 111, F-1 +J PP' J �..r 1 fepc r a��, J 6��,��K� }? z f°"
(1t`Le'J,4,4 ft' „tit ;5 A 3 list 19 G�krr Rrti-�64• " ,104.
CL L ,s iai..? S�4Re� (w.J's1

• Were the applications conducted during the crop's`/ growing season? Ira o�kJ a� s '' - f1P „
• Were the Field Summary Forms complete? 1/5. `P
• Was lime application on Field Summary Form? �. No f' =%i! ,-,
4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? VC-5.
• Did the form indicate the period of coverage,the residual class,and the pathogen reduction
alternative and the vector attraction reduction option used? YES,
• Was the approp iate documentation to show pathogen and vector attraction reduction included
in the report? �5,
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? `ref
w
Class B Pathogen Review
A rnative 1 —Fecal Coliform nsity
• Was sampling cond ed at the required frequency?
• Were seve taken?
• Was the ge • mean calculated and done correctly?
• Did t esults show c liance(less than either 2,000,000 MPN/gram of total solids or
2, ,000 Colony Forming • /gram of total solids)?
Alternative 2—Use of Process to Significantly Reduce Pathogens(one of five)
• Was the sampling conducted at the required frequency?
. Aerobic Digestion
• as it an aerobic process(Inspecti. )?
• ere logs submitted showing ti and temperature?
• -re temperatures within rang- 'or complete time period?
• W. the time and temperature .etween 40 days at 20°C (68°F)and 60 days at 15°C
(59°F 9
2. Air D•t ing
• Were th- residuals on s., d beds or pave or unpaved basins for three months?
• Was the • bient temp rature above 0°C (32°F)for two months?
• Were the esiduals p•4 ially digested?
• Were resi. als exposed to atmosphere during two months above 0°C(not snow
covered)?
3. Anaerobic D.•estion
•Was it an an. r.bic process(Inspection)?
•Were logs s,bmi ed showing time and temperature?
•Were tem.-rature within range for complete time period?
•Was the • me and to uperature between 15 days at 35°C (95°F)to 55°C (131°F)and 60
days at • 1°C(68°F)?
4. C. posting(usually • 1 be Class A when composting is used)
W.. it a composting proce• re(not natural decay under uncontrolled conditions)?
ere logs submitted showin_ time and temperature?
0 as the temperature raised to -0
5. Lime Stabilization

13rt4-cr f-- 1
6 . Caere, E-i( F 3,F-10
tiubl, 3 �'`� F �
6 g, Wog f`L F"31E
I, D. S;Mroont F-1r F-8 F-9
o, sr °"f F Z 1�"3 F l,F i 1
1--'0, 1-11/f-i z,
E.K,M,rc) F �A F i r3 f
1Tt Obis.n F 3, F-1 F 7if_ip1 12_

ss
B t 645B so SO ��f8 `fir~
641 krfe, T-l F2,F 3�F'4 f/ F-5,F.-C.,
`7 13kA44,1 z
/J e41 F-z fr
M TL,e l F 2
1-1-cAtty F-I 1-3
(Zr,"-el F-2_, F-7,111 ES
C, 6Jy4 1 l f-2, F- F-1/-
A , M:its F-z
ice F-c
/ewi' F-1/ F-3
Md'Aer
L.1.t1saA F ►,F-2—
`JL-n/ I,%, F-i, f-a-
D. R;dl;n F-1/f-3 F-4-1 F-7,r-g;F-13
ae S.kp ..,s i 'F ZiF 3 f-fi r 9
7. 8rcwU' F-I,F-11F-3,F-'f

- > 5, L;h.e 5-4-o I lmibn
• Was alkaline material added to residuals a form of lime (hydrated lime,quicklime, lime
containing kiln dust or fly ash)? 65
41\i`6c0ib • Were logs submitted showing time and temperature? Or
,,ID 1M� • Was the pH raised to 12 after two hours of con act? YES.
'" f ,p7 : Were logs submitted showing time and pH? 'ES
.of . it S,�,W �polk AWas temperature corrected to 25°C (77°F ? YE5,
for SUii+^ N11. I ��aI�1I"` v Alternativ o esses Equivalent to RSRP
• 1 J'w. �� (Not coin use. See Manual page 100-103,tables 11-1 and 11-2.)
0- Vector Attraction Reduction Review
kf_A Ij{' i,tx . 4J • Was the sampling conducted at the required frequency? 'E5
,+ 40- 6 .tion 1 -38%Volatile Solids Reduction
• •_'.• - A • ' as there 38%reduction?
• 'ere lab sheets/calculations in reps ?
` _V. ,kt 1 I�� • :s the reduction on volatile soli. (not total solids)?
\P 01tl !O • W, e the samples taken at begin ng of digestion process and before application
„ 2 (Insp-ction)?
• Wei-, calculations correct?
V\-\A-1141°P'"
,, Option ` -40-Day Bench Scal, Test
P'_ i r �� • Were r:siduals from anaerob cally digested treatment(Inspection)?
A. LN • Were re iduals anaerobical, digested in lab?
\\q i\\1 • Was the -st run for 40 da s?
• A� • Was the t, t done betwe- 30°C (86°F)and 37°C (99°F)?
Z�0g� �' • Was the re a uction of on olatile solids(not total solids)?
I.� I4(7/I • Was the red ction less han 17%?
Gs_
I�it,1,S • Were lab she-ts/calcu ations in report?
(.1-1' 11 • Were calculat ens c.. ect?
.MM (, 9I11'IIS Option 3 -30-Da 'ench Scale Test
l�Were residuals fr. aerobically digested treatment(Inspection)?
'Z<�ffM'
-P M-- 12o I 123 9108 1 • Were residuals . -r.bically digested in lab?
2� • Were residuals % • less total solids?
�a 12 174 • If not 2%tota solids, as the test ran on a sample diluted to 2%with unchlorinated
M i g 11011 f effluent?
• 1Z3/ 12�/ Apo $IZ�)K• Was the• Was the test done at 20°C 68°F)?
64 1 2-`1 J I{ • Was the r•duction of on vo :tile solids(not total solids)?
0 • Was the eduction less than 1 %?
p • Were 1. . sheets/calculations in eport?
LLA -3 '1'9I0‹ • Were 'alculations correct?
pm- 12t II
�M. 16 Iq I S, I$ K No►COptio 4-Specific Oxygen Uptake .te(SOUR)
• W- e residuals form aerobically dige- ed treatment(Inspection)?
o R -71 ! - 3 6 • W-re residuals 2%or less total solids o ry weight basis)(not diluted)?
C�, • as the test done between 10°C (50°F) . d 30°C (86°F)?
_ 1( 51\21 I • as the temperature corrected to 20°C (6:°F)?
- A�
SIII iI' • Was the SOUR equal to or less than 1.5 m: of oxygen per hour per gram of total
M,31`� 4 ( sidual solids(dry weight basis)? / �r a/L
1 t1 d �n
InA- I3�'7 V2.V".- _ AM z,g, IoR,II8i127 zfig/ir ea
v G utMe/ of le tiren
,Gn �L'/I' or ,t no•!+r '
n �.
- kM - �s', I Cif- 2s1, - et-PA- 1I8, I Ii liog/Is ((id,� - .•• f�.I r` �"►P
JFM - 3 i/zo/1s' / nb•T` fr reitocd . &NJ.

the sampling holding time two ho .
• Was test started within 15 min s of sampling or aeration maintained?
Option 5 — 14-Da erob• rocess
• Were the residuals erobically digested treatment(Inspection)?
• Were the resi s treated o days?
• Was the iduals temperature highe n 40°C (104°F) for a 14-day period?
W e average residuals,temperature highe 45°C(113°F)?
.-- Option 6—Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? kiie
Did the pH of residuals remain at 12 or higher for two hours without the addition of
more alkali? YCf-
• Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
without the addition of more alkali?
• Was the pH corrected to 25°C (77°F)? ` E:5,
•.tion 7—Drying of Stabilized Residu.
• D.-s the residuals contain any uns . .ilized residuals?
• We the residuals mixed with . • other materials?
• Were •e residuals dried up t• 5%total solids?
Option 8— ing of Uns . •ilized Residuals
• Were the resi. . .1s mi.'-d with any other materials?
• Were the residua • ied to 90%total solids?
Option 9—Inje ' on
• Was there a, significant . • ount of residuals on land surface one hour after injection
(Inspectio .
• Was i ,-ction done on pasture o 4 ay field?
• Was • jection done at time that crop as growing?
• If r lass A with respect to pathogen,we - residuals injected with eight hours after
d• charge from pathogen treatment?
5. Soil Tests A
• Was a Standard Soil Fertility Analysis conducted for each application field? AP( )
• Were the soil pH's 6.0 or greater for each application field? tJ 0,
• If no,was lime applied to those fields? YES,
Were the copper and zinc indexes in the soil less than 2000 for each application field? T€S
• Was sodium less than 0.5 meq/100 cm^3? YES,
• Was the exchangeable sodium percentage(ESP) less than 15%? �cs re -
6.General fit (�.► rP�kl� d11 .0 ��"
• Was the report in the proper format? OK• Fl�• Mar - C��cKle - n
• Was the annual report complete? d f ham, Lb 0., i�
• Was the report submitted on time?