WQ0016966_NOV-2021-PC-0379 Response_20210811

August 4, 2021
TOWN OF DENTON
nvDepartment iEirl Quality yReceived
North Carolina Department of Environmental Quality
Winston Regional Office
450 W Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
Attn: Patrick Mitchell
Subject: Notice of Violation with 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. Mitchell:
Winston-Salem
Regional Office
The Town of Denton received a Notice of Violation (NOV-2021-PC-0379) dated July 29, 2021. The letter
noted 4 violations that the Town needed to address.
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 or
Permit Conditions IV.2. and 1V.8.
It was my understanding we had been reduced to sampling for TCLP once per permit cycle. I referenced
Compliance Inspection Report dated September 3, 2019 Inspection Summary, 3rd bullet point states
"TCLP was last completed in 2016. *Reminded that the next minimum sample is required within the next
permit cycle (after 2/29/2020)"
We are anticipating land applying within 30 days of the date of this letter. I assure you we will complete
a TCLP sampling to satisfy our permit requirements and the State's rules.
As for the May 2020 NOV, I ask that a copy be forwarded to me as I do not have a copy in my file.
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 to all land application events is a violation of Permit Condition 111.3.
201 W. Salisbury Street
P.O. Box 306
Denton, NC 27239
This institution is an equal opportunity provider and employer
Phone: [phone]
Fax: [phone]

This was an oversight. As this is a relatively new requirement, it was an error on my part. It was not
purposefully omitted. I will ensure this will not happen again.
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 1V.8.
I'm assuming this mistake was made due to submitting an electronic copy instead of submitting hard
copies as we did in the past. The hard copy I have onsite was signed by Permittee, Preparer, and Land
Applier. I am submitting a copy for your files.
4. The Annual Pathogen & Vector Attraction 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.B.
As with the Annual Land Application Certification form, this was an error in switching from sending
multiple paper copies to electronic forms. The form on site was signed by Preparer and Land Applier in
February. I am enclosing a scanned copy for your records.
I sincerely hope that these responses answer any questions and satisfies the States requirements. If you
have further questions or instructions, please contact me at the letterhead address, my email address,
[e-mail] or 336-859-4460.
Troy B. Branch, UMC
Town of Denton
Land Application of Residuals/WWTP ORC

ANNUAL PATHOGEN AND VECTOR ATTRACTION REDUCTION FORM (02T Rules)
Facility Name: Town of Denton
WQ Permit Number: WQ0016966
WWTP Name: Town of Denton WWTP
Monitoring Period: From 1/1/2020
NPDES Number: NC0026689
To 12/31/2020
Pathogen Redaction (15A NCAC 02T .1106) - Please indicate level achieved and alternative performed:
Class A:
Alt. A (timeltemp) 0
Alt B (Alk Treatment) ❑
Alt. C (Prior Testing)❑
AltD (No Prior Test) ❑
Process to Further Reduce Pathogengs In
If applicable to alternative perforated (Class A only) indicate "Process to Further Reduce Pathogens":
Compost 0
Ileat Drying ❑
Beat Treatment 0
Thermophilic ❑
Beta Ray 0
Gamma Ray 0
Pasteurization i3
Class B:
Alt. (1) Fecal Density 0
Alt. (2) Process to Significantly Reduce Pathogens n J
If applicable to alternative performed (Class B only) indicate "Process to Significantly Reduce Pathogens";
Lime Stabilization a
Air Drying 0 I
Composting 0
Aerobic Digestion Q
Anaerobic Digestior. 0
If applicable to alternative performed (Class A or Class B) complete the following monitoring data:
Parameter
Allowable Level
Sludge
Pathogen Density
Number of
E;xcee-
deuces
Frequency
Analysis
of Analysis
Sample
Type
Analytical
Tech -
niche
Minimum
Geo. Mean
Maximum
Units
Fecal Coliform
2x 10 to the
6th power
per gram of'
total solids
MPN
CFI
1000 mpn pe gram
of total solid (dry
weight)
Salmonella bacteria
(in lieu of fecal
coliform)
3 MPN per 4 grams
total solid (dry
weight)
Vector Attraction Reduction (iSA NCAC 02T .1107) - Please indicate alternative performed:
Alt.1 (VS reduction)
❑
Alt. 2 (40-day bench) ❑
Alt. 3 (30-day bench) 0
Alt. 4 (Spec. O, uptake)
li
Alt. 5 (14-Day Aerobic)
❑
Alt. 6 (Alk. Stabilization p
Alt 7 (Drying - Stable) ❑
Alt. 8 (Drying - Unstable)
❑
Alt. 9 (Injection)
0
Alt. 10 (Incorporation) 0
No vector attraction reduction alternatives were performed
0
CERTIFICATION STATEMENT (please check the appropriate statement)
❑ "I certify, under penalty of law, that the pa hogen requirements in 15A NCAC 02T .1106 and the
vector attraction reduction requirement in 15A NCAC 02T .1107 have been met."
❑ "I certify, under penalty of law, that the pathogen requirements in 15A NCAC 02T .1106 and the
vector attraction reduction requirement in 15A NCAC 02T .1107 have not been met." (Please note
if you check this statement attach an explanation wlty you have not met one or both of the
requirements.)
"This determination has been made under my direction and supervision in accordance with the system
designed to ensure that qualified personnel properly gather and evaluate the information used to determine
that the pathogen and vector attraction reduction requirements have been met. 1 am aware that there are
significant penalties for false certification including fine and imprisonment."
fir&vYV\
Prepa/er Name and Title (type`or print)
Dennis Key US Biosolids, Inc.
Land Applier Name and Title (if applicable)(type or print)
;4ij21(• 17'w 1( 9 -(4.1c 1
§i 'of Preparer* Date Signature of Land Applier (if applicable) Date
*Preparcr is defined in 40 CFR Part 503.9(r) and 15A NCAC 2T .1102 (26)
DENR FORM PVRF 02T (12/2006)

ANNUAL LAND APPLICATION CERTIFICATION FORM
WQ Permit/4: WQ0016966 County:
Davidson
Year: 2020
Facility Name (as shown on permit):
Land Application Operator:
Town of Denton
U.S. Biosolids, Inc. Phone: [phone]
Land application of residuals as allowed by the permit occurred during the past calendar year?
0 Yes 0 No - If No, skip Part A, and Part B and proceed to Part C. Also, If residuals were
generated but not land applied, please attach an explanation on how the residuals were handled.
Part A - Residuals Application Summary:
Total number of application fields in the permit:I
15
Total number of fields utilized for land application during the year:l
4
Total amount of dry tons applied during the year for all application sites:I
43.7
Total number of acres utilizes for land application during the year:
28.63
Part B - Annual Compiance Statement:
Facility was compliant during calendar year 2020 with all conditions of the land application permit
(including but not limited to items 1-13 below) issued by the Division of Water Resources. &I Yes 0 No
If no please, provide a written description why the facility was not compliant, the dates, and explain corrective action
taken.
1) Only residuals approved for this permit were applied to the permitted sites.
2) Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at least 6.0 or
the limit specified in the permit.
3) Annual soils analysis were performed on each site receiving residuals during the past calendar year and three (3) copies
of laboratory results are attached.
4) Annual TCLP analysis (if required) was performed and three (3) copies of certified laboratory results are attached.
5) All other monitoring was performed in accordance with the permit and reported during the year as required and three
(3) copies of certified laboratory results are attached.
6) The facility did not exceed any of the Pollutant Concentration Limits in 15A NCAC 02T .1 105(a) or the Pollutant
Loading Rates in I5A NCAC 02T .1 I05(b) (applicable to 40 CFR Part 503 regulated facilities).
7) All general requirements in as specified in the Land Application Permit were complied with (applicable to 40 CFR Part
503 regulated facilities).
8) All monitoring and reporting requirements in 15A NCAC 02T .11 1 1 were complied with (applicable to 40 CFR Part
503 regulated facilities).
9) All operations and maintenance requirements in the permit were complied with or, in the case ofa deviation, prior
authorization was received from the Division of Water Resources.
10) No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of violations are
attached to include appropriate actions and rentediations.
I I) Vegetative cover was maintained and proper crop management was performed on each site receing residuals, as
specified in the permit.
12) No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
13) All buffer requirements as specified on the permit were maintained during each application of residuals.
Part C - Certification:
"I certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate,
and complete. 1 am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
Permittee Name and Title (type or ' t) Signature of Permittee
Osmi t pure �7�D77ate d (pp
naiure—f Preparer" Date Signature of Land ppher
Date
2-M.atYYl
Date
(if different from Permittee) (if different from Permittee and Preparer)
* Preparer is defined in 40 CPR Part 503.9 (r) and I5A NCAC 02T .1102 (26) DENR FORM ACF (12(2006)

Mitchell, Patrick
From: Mitchell, Patrick
Sent: Wednesday, August 11, 2021 9:37 AM
To: Troy Branch
Cc: Zachery Key; Snider, Lon; Graznak, Jenny
Subject: Response to NOV-NOI, Town of Denton 2020 Annual Report (WQ0016966)
Attachments: 20200504 NOV for 2019 ARR WQ0016966.docx.pdf
Troy, Signed forms received 8/09/2021
Thank you for the quick response on the NOV-NOI. I have reviewed the response but I am not sure if my supervisors
have reviewed it yet.
. sinReel innuaI pathogc") Q. for certification form that you indicated will be sent. Once we have received the
signcd forms and I receive my supervisors recommendations, I will let you know if any further actions will be taken.
As requested, I have attached the May 4, 2020 NOV that was issued last year following review of the 2019 Annual
Report. I double checked in the file and the letter was emailed to you as an attachment at the following email addresses:
[e-mail] and [e-mail] on May 5, 2020. On the same day you replied via email
providing the missing 2019 pathogen & vector attraction records requested in the NOV.
Please note that your permit was renewed April 14, 2020, with the required TCLP testing frequency being once per year.
The inspection report that you referenced (dated September 3, 2019) was generated based on the previous permit
conditions which required a TCLP frequency of once per permit cycle. We reminded you of this change in permit
required testing frequency in the first bullet point of the NOV letter dated May 4, 2020. We also informed you that you
have the option to request a reduction in testing frequency. However, no request for reduction in testing frequency has
been received to date.
You still have the option to request a minor modification to the permit with a reduction in TCLP testing frequency. If you
desire to make this request please send a written request to Nathaniel Thornburg in our central office permitting group
at [e-mail].
Please let me know if you have questions or would like to discuss any of these items further.
Patrick L. Mitchell, REHS, LSS
Environmental Program Consultant — Soil Scientist
Water Quality Regional Operations Section
Division of Water Resources
NC Department of Environmental Quality
Phone: [phone]
Mobile: [phone]
Fax: [phone]
Winston-Salem Regional Office
450 W. Hanes Mill Road, Suite 300
Winston-Salem, NC 27105
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