WQ0001863_Compliance Evaluation Inspection_20211210

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Mr. David E. Johnson, P.E., Utilities Director
City of Mount Holly
P.O. Box 406
Mount Holly, North Carolina 28120
Dear Mr. Johnson:
NORTH CAROLINA
Environmental Quality
December 10, 2021
via Email
Subject: Non -Discharge Permit Inspection
City of Mount Holly - Permit # WQ0001863
Land Application of Residuals
Gaston County
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection and viewed an active
land application event on December 1st, 2021. The MRO would like to thank Doug Shoudt (Mt. Holly
WWTP and LA ORC) and Mike Cox (Synagro) for their time during the inspection.
Residuals processing, storage, and application appeared to meet program requirements at the time of
inspection. Records were well organized. January data for vector attraction reduction was not present at
the facility at the time of inspection and will be reviewed in the annual report; however, the item is noted as
a reminder for both permittee and contractor that a copy of all records (5 years) need to be maintained at
the WWTP.
Field conditions noted at time of inspection: Field ID # NC-LT-46-02
Y-yes N-no NE -not evaluated NA -not applicable
Y Permit on site during application Y Spill plan on site
Y Buffers adequate Y Cover crop specified in permit
Y Site condition adequate N Documented exceedances of PAN limits
N Signs of runoff / ponding Y Rain gauge on site during application
Y Signage posted Y Current Residuals Analyses (PVAR, Metals, etc.)
Y Vehicles (Spreader and Transportation) appeared sufficiently maintained at the time of inspection.
Are there any limiting slopes on fields?
Y 10 % for surface application NA 18% for subsurface application
Odors present: Odors were NOT detected.
Vectors present: Vectors were NOT detected.
Additional comments: Application was to continue to NC-LT-46-04. Field buffers were partially flagged.
The farmer was working on -site and disrupted some flags which were to be replaced and confirmed by Mr.
Shoudt as part of Mt. Holly's internal inspections.
NCD_E
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North Carolina Department of Environmental Quality j Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

One transportation vehicle (recently brought in from SC) only had a copy of the first page of the spill plan.
Another transportation vehicle examined, had a complete copy. The third transportation vehicle operating
that day was not examined.
The inspection report is attached, should you have any questions please contact Maria Schutte by phone at
[phone] or email at [e-mail].
Sincerely,
DocuSigned by:
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Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0001863 Inspection Report.
CC: Douglas Shoudt, Mt. Holly (Email)
Alex Fox, Synagro (Email)

Compliance Inspection Report
Permit: WO0001863 Effective: 12/01/19 Expiration: 05/31/25 Owner : City of Mount Holly
SOC: Effective: Expiration: Facility: City of Mount Holly RLAP
County: Gaston 201 Broome St
Region: Mooresville
Mount Holly NC 28120
Contact Person: Miles Braswell Title: City Manager Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Douglas Eugene Shoutd Certification: 1000246 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0021156 City of Mount Holly - Mount Holly WWTP
Inspection Date: 12/01/2021
Entry Time 09:30AM Exit Time: 01:OOPM
Primary Inspector: Maria Schutte Phone: [phone]
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
▪ Sampling
▪ Storage
(See attachment summary)
▪ Record Keeping
▪ Land Application Site
▪ Transport
▪ Treatment
▪ Pathogen and Vector Attraction
Page 1 of 5

Permit: WQ0001863 Owner - Facility: City of Mount Holly
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection and viewed an active land application
event on December 1st, 2021. The MRO would like to thank Doug Shoudt (Mt. Holly WWTP and LA ORC) and Mike Cox
(Synagro) for their time during the inspection.
Residuals processing, storage, and application appeared to meet program requirements at the time of inspection. Records
were well organized. January data for vector attraction reduction was not present at the facility at the time of inspection and
will be reviewed in the annual report; however, the item is noted as a reminder for both permittee and contractor that a copy
of all records (5 years) need to be maintained at the WWTP.
Field conditions noted at time of inspection: Field ID # NC-LT-46-02
Y-yes N-no NE -not evaluated NA -not applicable
Y Permit on site during application Y Spill plan on site
Y Buffers adequate
Y Site condition adequate
N Signs of runoff / ponding
Y Signage posted
Y Cover crop specified in permit
N Documented exceedances of PAN limits
Y Rain gauge on site during application
Y Current Residuals Analyses (PVAR, Metals, etc.)
Y Vehicles (Spreader and Transportation) appeared sufficiently maintained at the time of inspection.
Are there any limiting slopes on fields?
Y 10% for surface application NA 18% for subsurface application
Odors present: Odors were NOT detected.
Vectors present: Vectors were NOT detected.
Additional comments: Application was to continue to NC-LT-46-04. Field buffers were partially flagged. The farmer was
working on -site and disrupted some flags which were to be replaced and confirmed by Mr. Shoudt as part of Mt. Holly's
internal inspections.
One transportation vehicle (recently brought in from SC) only had a copy of the first page of the spill plan. Another
transportation vehicle examined, had a complete copy. The third transportation vehicle operating that day was not
examined.
Page 2 of 5

Permit: WQ0001863 Owner - Facility: City of Mount Holly
Inspection Date: 12/01/2021 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?
Yes No NA NE
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Yes No NA NE
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Comment: Residual Analysis Summary and Soils analyses (ph included) are reviewed each year w/ the
Annual Report and were last viewed in 2020. Any concerns are noted with that inspection.
MRO staff received communication last year from SynagrotNate Roth) that vehicle
maintenance and calibration data is available at their office.
Pathogen and Vector Attraction Yes No NA NE
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) ❑ ❑ • ❑
Page 3 of 5

Permit: WQ0001863 Owner - Facility: City of Mount Holly
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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
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Comment: The WWTP uses 30-day bench to prove VAR requirements are met. The Jan. VAR data was
not available on -site. The contractor attempted to email a copy, but a simple PDF was not
sent. This information will be reviewed in 2021 Annual Report. See comments in the cover
letter and summary, as a reminder that data needs to be available at the WWTP. This facility
does a great job w/ records maintenance; this was a minor oversight.
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: Mt. Holly WWTP is a liquid biosolids application.
Sampling
Describe sampling:
Sampling was discussed, but not viewed.
Is sampling adequate?
Is sampling representative?
Yes No NA NE
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Yes No NA NE
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Comment: The residuals storage tanks are mixed after final decanting and prior to land application,
sampled as best as possible from the catwalk. Since, this is the only means of sampling, it
appears to be as adequate and representative as possible.
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?
Yes No NA NE
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Comment: Some vehicles have complete permit copies; however, current permits only require a spill
control plan be present. See comments in the cover letter and summary section, specific to the
recent land application event.
Page 4 of 5

Permit: WQ0001863 Owner - Facility: City of Mount Holly
Inspection Date: 12/01/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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?
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 1'/3' bls.
Is application occurring at the time of the inspection?
Yes No NA NE
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Comment: This permit currently does not require groundwater monitoring. These field sites are large
enough and slope in a manner that are unlikely to impact off -site wells. Soils are assessed with
new fields only. Existing setbacks were maintained and appeared adequate at the time of
inspection. Given recent drought conditions across the state, distance to water table concerns
are unlikely.
Page 5 of 5