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HomeMy WebLinkAboutWQ0001800_Non-Discharge Annual Report Review_20210723ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality July 23, 2021 CERTIFIED MAIL 7020 1810 0001 2075 0112 RETURN RECEIPT REQUESTED Mr. Jacob Swaim, Director of Public Works Town of Yadkinville P.O. Box 816 Yadkinville, NC 27055 SUBJECT: Notice of Violation (NOV-2021-PC-0359) Town of Yadkinville, Residuals Land Application Program Permit No. WQ0001800 Yadkin County Dear Mr. Swaim: The Division of Water Resources (DWR) acknowledges receipt of your 2020 Annual Report for the subject permit. A review of this report was conducted by DWR staff person Jim Gonsiewski. The following violations were noted from the review: 1. Attachment A of the permit states that the maximum dry tons to be land applied annually from the Yadkinville WTP is 30 dry tons. A total of 78.73 dry tons from the Yadkinville were distributed in 2020. This is an exceedance of 48.73 dry tons for the year. If you anticipate this condition occurring again, this office recommends that you apply for a permit modification to increase the permit limit. 2. Additionally, two constituents listed in the TCLP analysis for the WWTP were run with detection limits above the regulatory level. Chlordane had a reporting detection limit (RL) of 0.125 mg/L. The regulatory level is 0.03 mg/L. Heptachlor had a RL of 0.0125 mg/L. The regulatory level is 0.008 mg/L. In the future, please ensure that the laboratory analyzes the samples with detection limits at or below the regulatory levels. Please provide a response to this letter within 30 days of receipt by your office indicating the corrective actions taken to address these deficiencies. If these violations occur again, a Notice of Violation/Notice of Intent may be issued. GLEE a9.uUm 1nl EmliumKnlY auam\ North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336,776.9800 If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski at (336) 776-9800 or via email at iim.gonsiewski(a�ncdenr.gov. Sincerely, CDocuSlyned by: 1— T. 3MIcr 145849E225C94EA... Lon T. Snider Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO encl: Compliance Inspection Report cc: Yadkin County Environmental Health (Electronic Copy) Alex Fox— Synagro (Electronic Copy) WSRO Electronic Files Laserfiche Files E Dey.M�MI CI [nwpnmfnUl Oul�� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0001800 Effective: 09/10/20 Expiration: 02/28/22 Owner : Town of Yadkinville SOC: Effective: Expiration: Facility: Town of Yadkinville RLAP County: Yadkin 1620 Fred Hinshaw Rd Region: Winston-Salem Contact Person: Grant Trivette Directions to Facility: Yadkinville NC 27055 Title: Phone: 336-679-2184 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0020338 Town of Yadkinville - Yadkinville VVVVfP Inspection Date: 07/15/2021 Entry Time 01.00PM Exit Time: 05:OOPM Primary Inspector: Jim J Gonsiewski Phone: 336-776-9704 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: ❑ Compliant 1. Not Compliant Question Areas: 1. Miscellaneous Questions Sampling El Pathogen and Vector Attraction (See attachment summary) Page 1 of 3 Permit: WQ0001800 Owner - Facility: Town of Yadkinville Inspection Date: 07/15/2021 Inspection Type :Annual Report Review Reason for Visit: Routine Inspection Summary: The Division of Water Resources (DWR) acknowledges receipt of your 2020 Annual Report for the subject permit. A review of this report was conducted by DWR staff person Jim Gonsiewski. The following violations were noted from the review: 1.Attachment A of the Permit states that the maximum dry tons to be land applied annually from the Yadkinville WTP is 30 dry tons. A total of 78.73 dry tons from the Yadkinville WTP were distributed in 2020. This is an exceedance of 48.73 dry tons for the year. 2.Additionally, two constituents listed in the TCLP analysis for the WWTP were run with detection limits above the regulatory level. Chlordane had a reporting detection limit (RL) of 0.125 mg/I. The regulatory level is 0.03 mg/I. Heptachlor had a RL of 0.0125 mg/I. The regulatory level is 0.008 mg/I. NOV-2021-PC-0359 was issued for the report. Page 2 of 3 Permit: WQ0001800 Owner - Facility: Town of Yadkinville Inspection Date: 07/15/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Type Land Application Distribution and Marketing Pathogen and Vector Attraction a. Fecal coliform SM 9221 E (Class A or B) 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) e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench -top Aerobic/Anaerobic digestion results Comment: Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • • ❑ ❑ • ❑ 0 ❑ ❑■❑ ❑ ❑•❑ ❑ ❑ • ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ ❑❑■❑ Yes No NA NE • ❑ ❑ ❑ ▪ ❑ ❑ ❑ Page 3 of 3 Annual Report Review SOP Class B Land Application Reporting Period: Permit Details: Is 503? Q • Class A r B? - Maximum Dry Tons Per Year: Q.Q - Number of acres permitted: Ict..1 • Number of fields in permit: J • Counties that land is permitted for GAMY • Monitoring Frequency for TCLP: ivv • Monitoring Frequency for Residuals Analysis: • Monitoring Frequency for Pathogen & Vector Attraction Reduccfion: • Groundwater monitoring:. --� ' `� 1. Annual Land Application Certification Form • Was a certification form submitted?'.Cs • Was land application conducted during the reported year? • How many dry tons and dry tons per acre were applied? • Were the applications within the permitted amount? \les • Verify PAN if more than 10 to s/acre? • Did it indicate compliance? es • Was it signed by the appropriate people? � 2 Monitoring ti 11S (; • Were the analyses conducted at the required frequency? • Was an analyses taken for each source that was land applied? • Were the metals analyses reported on the Residual Sampling Summary Form?)k, • Were the results reported in mg/kg? •,z Were the pH's 6.0 or greater for each residual sample? l • Were the heavy metals within ceiling concentration permit limits?v/ Were the lab analyses attached? \,) • Were all the required parameters to ted. }�y i., _s • Was TCLP analysis conducted? • Were the TLCP contaminants within regulatory limits? \f es • Was a corrosivity, ignitability, and reactivity analysis conducted? )/� 3. Field Summary • Were ail land application events recorded on the FSF and MFLS forms? f,� • How many fields were applied on this year? �----- • Was a Field Summary Form submitted for each field? • Was the Regional Office notified prior to each land a plication event? Via.. • Were all the residuals applied to permitted land? - Were all the residuals applied from permitted sources?\2 • Were the field loading rates for each metal and PAN cal ulated (year to date)? • Were the cumulative pollutant loading rates calculated?.) S S - Were the calculations correct?' • Were the PAN loading rates within permit limits?Y_ - • Were the heavy metal cumulative pollutant loading rates within permit limits?\/' Vie,-�3�5 • Were the residuals applied on a suitable crop? Y•es • Were the applications conducted during the prop's growing season?* • Were the Field Summary Forms complete? y S S • Was lime application on Field Summary Form? !\f c-- /Lm o-vt,o .02ex 3 rep 4. Pathogen and Vector Attraction Reduction • Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? • Did the form(s) indicate the period of coverage, the residual class, and the pathogen reduction alternative and the vector attraction reduction option used? Class B Pathogen Review Alternative 1 — Fecal Coliform Density r Was the sampling conducted t the required frequency?) Were seven samples taken. +r Was the geometric mean calculated and done correctly?-2s • Did the results show compliance (less than either 2,0 0,000 MPN/gram of total solids or 2,000,000 Colony Forming Units/gram of total solids)? Alternative 2 — Use of Process to Significantly Reduce Pathogens (one of five) • Was the sampling conducted at the required frequency? 1. Aerobic Digestion • Was it an aerobic process (Inspection)? • Were logs submitted showing time and temperature? • Were temperatures within range for complete time period? • Was the time and temperature between 40 days at 20°C (68°F) and 60 days at 15°C (59°F)? 2. Air Drying • Were the residuals on sand beds or pave or unpaved basins for three months? • Was the ambient temperature above 0°C (32°F) for two months? • Were the residuals partially digested? • Were residuals exposed to atmosphere during two months above 0°C (not snow covered)? 3. Anaerobic Digestion •Was it an anaerobic process (Inspection)? • Were logs submitted showing time and temperature? • Were temperatures within range for complete time period? •Was the time and temperature between 15 days at 35°C (95°F) to 55°C (131°F) and 60 days at 20°C (68°F)? 4. Composting (usually will be Class A when composting is used) Was it a composting procedure (not natural decay under uncontrolled conditions)? Were logs submitted showing time and temperature? See White House Manual for additional requirements. 5. Lime Stabilization • Was alkaline material added to residuals a form of lime (hydrated lime, quicklime, lime containing kiln dust or fly ash)? • Were logs submitted showing time and temperature? • Was the pH raised to 12 after two hours of contact? • Were logs submitted showing time and pH? • Was temperature corrected to 25°C (77°F) (by calculation, NOT auto correct)? Alternative 3 — Use of Processes Equivalent to RSRP (Not commonly use. See White House Manual page 100-103, tables 11-1 and 11-2.) Class B Vector Attraction Reduction Review - Was the sampling conducted at the required frequency? Option 1 — 38% Volatile Sold Reduction Was there 38% reduction?' Were lab sheets/calculations in report? - Was the reduction on volatile solids (no total solids)? - Were the s ies taken at beginning of digestion proc ss an before application (Inspection)? • Were calculations correct? /12",.. Option 2 — 40-Day Bench Scale Test • Were residuals from anaerobically digested treatment (Inspection)? - Was average temperature of the WWTP digester between 30°C (86°F) — 40°C (104°F)? • Were residuals anaerobically digested in lab? • Was the test run for 40 days? • Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? • Was the reduction of on volatile solids (not total solids)? • Was the reduction less than 17%? • Were lab sheets/calculations in report? • Were calculations correct? Option 3 — 30-Day Bench Scale Test • Were residuals from aerobically digested treatment (Inspection)? • Were residuals aerobically digested in lab? • Were residuals 2% or less total solids? • If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent? Was the test run for 30 days? • Was the test done at 20°C (68°F)? • Was the reduction of on volatile solids (not total solids)? • Was the reduction less than 15%? Were lab sheets/calculations in report? Were calculations correct? Option 4 — Specific Oxygen Uptake Rate(SOUR) • Were residuals form aerobically digested treatment (Inspection)? • Were residuals 2% or less total solids (dry weight basis) (not diluted)? • Was the test done between 10°C (50°F) and 30°C (86°F)? Was the temperature corrected to 20°C (68°F)? • Was the SOUR equal to or Iess than 1.5 mg of oxygen per hour per gram of total residual solids (dry weight basis)? • Was the sampling holding time two hours? - • Was the test started within 15 minutes of sampling or aeration maintained? Option 5 - 14-Day Aerobic Process • Were the residuals from aerobically digested treatment (Inspection)? • Were the residuals treated for 14 days? • Was the residuals temperature higher than 40°C (104°F) for a 14-day period? • Was the average residuals temperature higher 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? • Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali? • Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours (i.e. 24 hours total) without the addition of more alkali? • Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? Option 7 - Drying of Stabilized Residuals • Does the residuals contain any unstabilized residuals? Were the residuals mixed with any other materials? • Were the residuals dried up to 75% total solids? Option 8 - Drying of Unstabilized Residuals • Were the residuals mixed with any other materials? - Were the residuals dried to 90% total solids? Option 9 - Injection • Was there any significant amount of residuals on land surface one hour after injection (Inspection)? • Was injection done on pasture or hay field? • Was injection done at time that crop was growing? • If Class A with respect to pathogen, were residuals injected with eight hours after discharge from pathogen treatment? • Was the appropriate documentation to show pathogen and vector attraction reduction included in the report? • Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? 5. Soil Tests • Was a Standard Soil Fertility Analysis condu ted for each application field? • Were all the required parameters reported? 1.es • Were the soil pH's 6.0 or greater for each application field? ti f • If no, was lime applied to those fields if recommended by the Agronomist? )e` • Were the copper and zinc indexes in the soil less than 2000 for each applica ion fi ? • Was sodium less than 0.5 meq, and exchangeable sodium percentage (ESP) less than 1 6.General • Was the report in the proper forma?\le • Was the annual report complete?'25 • Was the report submitted on time? +�f