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HomeMy WebLinkAboutWQ0003351_Compliance Evaluation Inspection_20220420ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Kenneth Gamble, Town Manager Town of Mocksville 171 North Clements Street Mocksville, NC 27028 NORTH CAROLINA Environmental Quality April 20, 2022 SUBJECT: Compliance Evaluation Inspection Town of Mocksville Residuals Land Application Program Permit No. WQ0003351 Davie County Dear Mr. Gamble: On April 14, 2022, Division of Water Resources staff Caitlin Caudle completed a routine compliance inspection. Brent Collins and Roy Whitaker of EMA Resources, Inc. were present during the entire inspection. Mr. Collins accompanied Ms. Caudle to review additional application fields for permitting purposes. This review reflected compliance with the subject permit. The following item of concern was noted: A. Per Permit Condition V.2 "prior to each bulk residuals land application event, the Permittee or his designee shall inspect the residuals storage, transport, and application facilities to identify malfunctions, facility deterioration and operator errors ... The permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken...." Mr. Collins stated that a record of field inspections is not available, but all fields are inspected and flagged prior to application activities. Moving forward, please keep a log of all field inspections prior to the commencement of land application activities. GDE NORTH CAROLINA ' omm mr� ep..of 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 Please refer to the enclosed inspection report for additional comments and observations. If you have any questions regarding this letter please contact me or Caitlin Caudle at the letterhead address or phone number, or by email at lon.snider@ncdenr.gov or caitlin.caudle@ncdenr.gov. Sincerely, ig DocuSigned by:by� %A. l . c%n.aGr "- 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Brent Collins, EMA Resources, Inc. (electronic copy) Davie County Environmental Health (electronic copy) Laserfiche File WQ0003351 WSRO Electronic Files D_E NORTH CAROLINA gaparMeM of Environment,/quay North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0003351 Effective: 01/08/21 Expiration: 12/31/22 Owner : Town of Mocksville SOC: Effective: Expiration: Facility: Town of Mocksville RLAP County: Davie 171 Clement St Region: Winston-Salem Contact Person: Brent M Collins Directions to Facility: Mocksville NC 27028 Title: Phone: 336-751-1441 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0021491 Town of Mocksville - Dutchman Creek WWTP Inspection Date: 04/14/2022 Entry Time 10:OOAM Exit Time: 12:45PM 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 II Sampling ▪ Storage (See attachment summary) ▪ Record Keeping ▪ Land Application Site ▪ Transport ▪ Treatment ▪ Pathogen and Vector Attraction Page 1 of 5 Permit: WQ0003351 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On April 14, 2022, Division of Water Resources staff Caitlin Caudle completed a routine compliance inspection. Brent Collins and Roy Whitaker of EMA Resources, Inc. were present during the entire inspection. Mr. Collins accompanied Ms. Caudle to review additional application fields for permitting purposes. This review reflected compliance with the subject permit. The following item of concern was noted: A. Per Permit Condition V.2 "prior to each bulk residuals land application event, the Permittee or his designee shall inspect the residuals storage, transport, and application facilities to identify malfunctions, facility deterioration and operator errors ... The permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken...." Mr. Collins stated that a record of field inspections is not available, but all fields are inspected and flagged prior to application activities. Moving forward, please keep a log of all field inspections prior to the commencement of land application activities. DV-08-01 Field Observations: • Additional sources have not been applied to DV-08-01 this year. • Field conditions were acceptable for land application. • All buffers were flagged. • Surface application is used. • Fescue pasture was the intended crop. • Public access signs were posted at the fence line next to the cul-de-sac on Bunker Way and at the gate that immediately accesses the field on South Benson Lane. • The application area was being accessed by a gate on Walt Wilson Road approximately 0.3 miles from the application areas and the other posted signs. Other observations: • Two storage structures are present that serve as storge and treatment. A 176,000 gallon and a 253,700 gallon digestor store residuals, with approximately 90 days of storage. Aeration is present in both digestors. No other storage is present. • A sludge thickening process was implemented with the plant expansion, but it has not been utilized yet due to issues with water pressure. The process is introducing polymers to the wasted sludge, running the sludge through a rotary screen, and wasting the thickened sludge into the digestors. The current sludge thickening process is manually decanting wastewater from settling sludge. • Mr. Collins stated that application equipment is calibrated when initially purchased and after maintenance activities. • Mr. Whitaker stated that the WWTP has an application event every 3-4 months with approximately 50 dry tons per event. Samples are collected from the digestor that is being emptied. • Mr. Collins stated that they do not reach 250 dry tons per year and that amount was permitted to have a buffer. • Pumper truck 606 was being used. This truck has a 4,500 gallon capacity. Hauling records, current permit, and O&M plan were in the truck. The rain gauge was also on the pumper truck, which is kept at the WWTP over night during application events. • Fecal coliform density and 30 day bench test were used for the most recent application event to ensure compliance with Pathogen and Vector Reduction requirements. • According to the 2021 Annual Report no lime amendments were recommended for the application fields. Page 2 of 5 Permit: WQ0003351 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 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: A complaint was investigated in February 2022. 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 • ❑ ❑ ❑ • • ❑ ❑ ❑ • O 000 O 000 O 000 Page 3 of 5 Permit: WQ0003351 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 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: Treatment Check all that apply Aerobic Digestion Anaerobic Digestion Alkaline Pasteurization (Class A) Alkaline Stabilization (Class B) Compost Drying Beds Other Comment: Sampling Describe sampling: Is sampling adequate? Is sampling representative? Comment: Yes No NA NE • Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Transport Yes No NA NE 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 5 Permit: WQ0003351 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine 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 173' bls. Is application occurring at the time of the inspection? Comment: • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 5 of 5