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Home My WebLink AboutWQ0032855_CEIARR_NOD2022PC0076_20220519 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED May 19, 2022 Doug Barrick Email: dbarrick@rutherfordton.net Town of Rutherfordton SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2022-PC-0076 Annual Report Review 2021 Permit No. WQ0032855 Town of Rutherfordton Class B Residuals Program Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Town of Rutherfordton Class B Residuals Program 2021 Annual Report on May 18, 2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0032855. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Pathogen and Vector Attraction Facility did not demonstrate compliance with Vector Attraction Reduction Method 30 -day Bench Scale Test as required under Section IV.4 of the permit. _________________________________________________________________________________________________________________________________________________________________________ In addition, the issues below must also be addressed: Compliance Issues: ESP: The ESP does not appear to be reported on the soils report as required by Section IV.5 of the permit. Soil pH: Fields 6, 8, 10 and 11 had reported pHs below 6.0; however, the field summary forms do not indicate lime was applied per Section III.11.h of the permit. DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. It is recommended the permittee request Waypoint Analytical use the NCDAS Tabular Soils Format when reporting results to better demonstrate compliance with NC requirements. If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at Mikal.willmer@ncdenr.gov. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Zach Key- US Biosolids DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE Compliance Inspection Report Permit:WQ0032855 Effective:01/01/17 Expiration:12/31/21 Owner :Town of Rutherfordton SOC: Contact Person: Region: County: Directions to Facility: Rutherford Asheville Doug Barrick Effective:Expiration:Facility:Town of Rutherfordton Class B Residuals Program 1021 S Main St Rutherfordton NC 28139 Title:Phone:828-287-3520Town Manager From I-40E, take exit 85, stay on Hwy. 221 through the Town of Rutherfordton. Approximately 0.5 mi outside city limits, turn left on gravel road to WWTP (just before intersection of 221&Thunder Rd.) Secondary ORC(s): 336-957-7871Phone:27660Certification:Zach D KeyPrimary ORC: LA,System Classifications: On-Site Representative(s): Related Permits: NC0025909 Town of Rutherfordton - Rutherfordton WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 05/18/2022 07:00AM 09:30AM Mikal Willmer 828-296-4686 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Annual Report Review Question Areas: Miscellaneous Questions Record Keeping Treatment Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 05/18/2022 Annual Report Review Town of Rutherfordton Routine Inspection Summary: Mikal Willmer, with the Asheville Regional Office, completed the review of the Town of Rutherfordton’s 2021 RLAP Annual Report on May 18, 2022. This review was conducted to determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0032855. The Town land applied approximately 45 dry tons of Class B residuals to six of sixteen permitted fields. Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 2,000,000 MPN/g. The geometric mean for 2021 was below 2,000,000 MPN/g. Vector Attraction Reduction (VAR): The Town did not demonstrate compliance with the VAR 30-day Bench Scale method before land application. The 30-day method requires a final volatile solids reduction below 15%; however, the Town’s reported result is 16.4% after 30 days. Metals, Nutrients & Pollutants of Concern: Values were below the ceiling and cumulative pollutant loading rates for Class B residuals. All metals and nutrient parameters were analyzed per section IV.3 of the permit. PAN & SAR balances are being calculated and maintained. Soil Fertility Analysis: Fields 6, 8, 10 and 11 had reported pH’s below 6.0; however, the field summary forms do not indicate lime was applied. Per section III.11.h of the permit, the residuals shall not be applied to land with a pH below 6 unless sufficient lime is applied. Additionally, it does not appear the ESP was reported on the soil fertility analysis. Recommend permittee request waypoint use the NCDAS Tabular Soils Format when reporting results to better demonstrate compliance with NC requirements. Non-Hazardous Waste Characterization: TCLP, corrosivity, reactivity and ignitibility are required annually and appear to be in compliance with regulatory requirements. Page 2 of 4 DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 05/18/2022 Annual Report Review Town of Rutherfordton Routine Type Yes No NA NE Distribution and Marketing Land Application Record Keeping Yes No NA NE 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? Fescue is listed as primary crop. See summary for details regarding soil fertility analysis.Comment: 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) Temperature corrected d. Salmonella (Class A, all test must be < 3MPN/4 gram day) Page 3 of 4 DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 05/18/2022 Annual Report Review Town of Rutherfordton Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results Results provided, but do not meet requirements of 30-day VAR method. See summary for details. Comment: Treatment Yes No NA NE Check all that apply Aerobic Digestion Anaerobic Digestion Alkaline Pasteurization (Class A) Alkaline Stabilization (Class B) Compost Drying Beds Other Comment: Page 4 of 4 DocuSign Envelope ID: 64E4FA07-977D-4CA1-B860-8F0851236AAE