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Home My WebLink AboutWQ0000520_Compliance Inspection_20220330ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality March 30, 2022 Mr. Shane Fletcher, Residuals Management Coordinator City of Burlington PO Box 1358 Burlington, NC SUBJECT: Compliance Evaluation Inspection City of Burlington, Residuals Land Application Program Permit No. WQ0000520 Alamance County Dear Mr. Fletcher: On March 7, 2022, Division of Water Resources staff person Caitlin Caudle conducted a scheduled compliance inspection and a permitting visit. You were present during the entire inspection. A review of records, application activities, and application fields was completed. The East WWTP and South WWTP were not inspected. This review reflected compliance with the subject permit. Please review the enclosed inspection report for additional comments and observations. If you have any questions regarding this letter, please contact Caitlin Caudle or me at the letterhead address or phone number, or by email at caitlin.caudle@ncdenr.gov or lon.snider@ncdenr.gov. Sincerely, DocuSigned by: LL-0, l . c%njGf 145B49E225C94EA... Lon Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Nate Roth, Synagro (electronic copy) Alamance County Environmental Health (electronic copy) Laserfiche File WQ0000520 WSRO Electronic File GDE NORTH C CUNA ' D. mmmr� .ore.nt o�.i North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0000520 Effective: 09/10/18 Expiration: 07/31/22 Owner : City of Burlington SOC: Effective: Expiration: Facility: City of Burlington RLAP County: Alamance 225 Stone Quarry Rd Region: Winston-Salem Contact Person: Everett Shane Fletcher Directions to Facility: Burlington NC 272161358 Title: Phone: 336-570-6138 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0023876 City of Burlington - Southside WWTP NC0023868 City of Burlington - Eastside WWTP Inspection Date: 03/08/2022 Entry Time 09:20AM Exit Time: 03:15PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: ▪ Miscellaneous Questions Record Keeping Sampling ▪ Land Application Site Pathogen and Vector Attraction Transport (See attachment summary) Page 1 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 03/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On March 7, 2022, Division of Water Resources staff person Caitlin Caudle conducted a scheduled compliance inspection and a permitting visit. Shane Fletcher, Residuals Management Coordinator, was present during the entire inspection. A review of records, application activities, and application fields was completed. The East WWTP was not inspected. This review reflected compliance with the subject permit. All residuals produced at the South WWTP go through the belt press and are hauled to McGill for composting. The South WWTP has 2.356 MG of storage in digestors and a covered building for the storage of cake, approximately 95 days. Residuals are land applied from the East WWTP. The East WWTP has 1.138 MG of storage in digestors, approximately 2 months. Residuals are produced in batches that are stored in individual digestors and applied by Synagro. Lime stabilization is used for both pathogen and vector requirements. Mr. Fletcher stated that there will be no changes in this process for the foreseeable future. Metals and nutrient samples are collected at the beginning of each month, and the results are used for the following month. Composite samples are collected from the storage digestors after lime treatment. TCLP is analyzed once a year. Metals and nutrient calculations are completed by Synagro before application activities commence for an individual batch of residuals. Synagro also calculates PAN and hydraulic loading for each individual field. Application rates are calculated to not exceed RYE for each field. Application activities were completed on AM-116-11 in January and February. Application activities had moved to AM-002-02 at the time of inspection. Barney James, Project Manager, and Ryan Copeland, Project Technical Specialist, were on site at the time of application. Synagro is using a single tractor and tanker to apply residuals to a field and two to three tanker trucks to transport residuals to the application field. The tractor tanker has a 6,000 gallon capacity. The tractor and the truck inspected both had and Operations and Maintenance Plan, Spill Plan, and a copy of the most recent permit and Attachment B. Field Observations: AM-002-02 through -05 • Approximately 1/10th of an inch of rain fell the previous night but the field was dry enough to spread on. • Application was even with no ponding visible. • No limiting slopes were present in the field. • A good stand of fescue hay was present. • No odor or vectors were present. • Application was in the authorized area and the field buffers were appropriate. Additional buffers were added to areas that were unsuitable for application based on current site conditions. • Public access restrictions were posted. • Rain was forecasted for the following day. Based on a review of local weather data, less than a half an inch of rain fell. AM-116-11 • The application area was even with no visible ponding or runoff. • The staging area did have some ponding present from loading of the tractor tanker. • Seasonal rills and ditches were buffered. Permitting observations can be reviewed in the staff report. Page 2 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 03/08/2022 Inspection Type : Compliance Evaluation 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: 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 • Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE ❑ ❑ • ❑ • Page 3 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 03/08/2022 Inspection Type : Compliance Evaluation 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: Sampling Describe sampling: See summary. Is sampling adequate? Is sampling representative? Comment: Transport Is a copy of the permit in the transport vehicle? Is a copy of the spill control plan in the vehicle? Is the spill control plan satisfactory? Does transport vehicle appear to be maintained? Comment: Land Application Site 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page 4 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 03/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? 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: ❑ ❑ • ❑ ❑ ❑ • ❑ Page 5 of 5