WQ0016966_NOV-2021-PC-0379 _Annual Report Review_20210729

DocuSign Envelope ID: 26AD7AAE-E8CA-4E1 E-8D61-EA9658131 C11
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 29, 2021
CERTIFIED MAIL 7018 1130 0000 1612 5273
RETURN RECEIPT REQUESTED
Mr. Kenneth W. Gamble, Town Manager
Town of Denton
P.O. Box 306
Denton, NC 27329
Subject: Notice of Violation and Intent to Enforce (NOV-2021-PC-0379)
Review of the 2020 Annual Report
Town of Denton, Residuals Land Application Program
Permit No. WQ0016966
Davidson County
Dear Mr. Gamble:
North Carolina Division of Water Resources (Division) staff has completed a review of the 2020
annual report for the subject facility. Review of the annual report reflects non-compliance with the
subject permit. The following violations noted during this review requires your attention and
action:
1. The 2020 Annual Report did not include toxicity characteristic leaching procedure (TCLP)
results for year 2020. Failure to conduct TCLP analysis at the minimum frequency required
in your permits Attachment A and/or failure to submit results in the annual reporting is a
violation of Permit Conditions IV.2. and IV.8. Please submit the missing 2020 TCLP
analysis results to this office within ten (10) days of receipt of this Notice.
In the NOV dated May 4, 2020, issued following review of the previous year's annual report,
you were reminded that the current version of your permit list a minimum required frequency
of once per year for TCLP analysis of the WWTP and the WTP. Again, if you desire to
reduce the TCLP testing frequency of each residuals source facility to once per permit
cycle, please submit a request to the Division requesting reduced TCLP testing
frequency to once per permit cycle.
2. The 2020 Annual Report indicated that three land application events occurred in year 2020
(i.e., events in March, July and November). However, prior to event notification to the
Division was only made for the March 2020 land application event. Failure to notify the
Winston-Salem Regional Office prior to all land application events is a violation of Permit
Condition III.3. Please ensure that the regional office is notified in compliance with
permit conditions prior to all future land application events.
_11A.,E\T
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

DocuSign Envelope ID: 26AD7AAE-E8CA-4E1 E-8D61-EA9658131 C11
3. The Annual Land Application Certification form was not signed by the Permittee as required.
Failure to sign the annual certification form is a violation of Permit Condition IV.8. Please
submit a revised annual certification form that has been properly signed within ten (10)
days of receipt of this Notice.
4. The Annual Pathogen & Vector Attraction Reduction form was not signed by the Residuals
Preparer. If the person or entity that prepares the residuals to meet pathogen and vector
requirements is different from the land applier, that person or entity must sign the form. It
should be noted that prior forms submitted to the Division included signature from Town
personnel preparing residuals at the WWTP. Failure to sign the form is a violation of Permit
Condition IV.8. Please provide a written explanation if the person or entity that
prepares residuals has changed or submit a properly signed form, as applicable.
The Division requests that you submit a written response within ten (10) days following receipt
of this Notice. This response should provide items requested above. If you wish to present an
explanation for the violations cited, or if you believe there are other factors which should be
considered, please send such information to me in writing with this response.
The Division is considering the pursuit of punitive sanctions for these violations. Pursuant to
G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may
be assessed against any person who violates or fails to act in accordance with the terms, conditions,
or requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional
information regarding the noted violations, please include this in the written response. A review of
this information will be conducted, and you will then be notified of any civil penalties that may be
assessed regarding the subject violations. If no response is received in this Office within the 10-day
period, a civil penalty assessment may be prepared.
Your immediate attention is greatly appreciated. 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
[e-mail] or [e-mail].
Sincerely,
/—DocuSigned by:
L.oti T. Smote-
'-145 9E 5Q9 EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Mr. Troy Branch, ORC — Town of Denton (Electronic copy)
Mr. Zach Key, ORC — US Biosolids (Electronic copy)
Davidson County Environmental Health (Electronic copy)
Laserfiche File WQ0016966,
WSRO Electronic Files
Page 2 of 2

Compliance Inspection Report
Permit: WQ0016966 Effective: 04/14/20 Expiration: 09/30/26 Owner : Town of Denton
SOC: Effective: Expiration: Facility: Town of Denton RLAP
County: Davidson 300 Council Access Rd
Region: Winston-Salem
Contact Person: Zach D Key
Directions to Facility:
System Classifications: LA,
Primary ORC: Troy B Branch
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0026689
NC0082949
Denton NC 27239
Title: Phone: [phone]
Town of Denton - Denton WWTP
Town of Denton - Denton WTP
Inspection Date: 07/29/2021 Entry Time 07:OOAM
Certification: 22733 Phone: [phone]
Exit Time: 09:OOAM
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 Not Compliant
Question Areas:
▪ Miscellaneous Questions Record Keeping Treatment
▪ Land Application Site Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 07/29/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
On July 29, 2021, WSRO staff conducted a review of the subject facility's 2020 Annual Report. No site visit was made as
part of this inspection event. The report was found to be noncompliant with the subject permit. Below is a summary of
violations.
1. The Annual Land Application Certification form was not signed by the Permittee as required.
2. The Annual Report did not include a complete TCLP analysis are required. Permittee was reminded following review of the
2019 report that TCLP is required once per year and if reduction in frequency is desired to request minor modification of the
permit.
3. The Regional Office was not notified prior to the July and November 2020 land application events as required.
4. The Annual Pathogen & Vector Attraction Reduction form was not signed by the Residuals Preparer as required. Required
information related to Pathogen & Vector requirements was missing in the 2019 report.
Request missing information be submitted to WSRO.
Page 2 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 07/29/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment: See Summary.
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)
Yes No NA NE
El
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Yes No NA NE
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Yes No NA NE
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Page 3 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 07/29/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment: See Summary.
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: See Summary.
Yes No NA NE
•
Land Application Site Yes No NA NE
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? ❑ ❑ • ❑
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? ❑ ❑ • ❑
Page 4 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 07/29/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
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: See Summary.
❑ ❑ • ❑
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