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HomeMy WebLinkAboutWQ0028547_NOD-2022-PC-0120_20220811ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Brian Collie, Town Manager Town of Yanceyville P.O Box 727 Yanceyville, NC 27379 NORTH CAROLINA Environmental Quality August 11, 2022 SUBJECT: Notice of Deficiency (NOD-2022-PC-0120) Compliance Evaluation Inspection Town of Yanceyville Residuals Land Application Program Permit No. WQ0028547 Dear Mr. Collie: On August 1, 2022, Division of Water Resources staff Caitlin Caudle conducted a compliance inspection. Brent Collins of EMA Resources was present during the entire inspection. An in - office review of records was completed. An on -site review of storage ponds, transportation vehicles, and application sites was completed. This review reflected non-compliance with the subject permit. The following deficiency was noted: A. Per Permit Condition II.8.a.i there will be a 400ft setback from each habitable residence or place of assembly under separate ownership. There is a house on the corner of Culver Road and Blanch Road that was within 400ft of the residuals application area, approximately 360ft. The house was not buffered on the application map in the Permit. Moving forward, update the application map and apply the appropriate buffers for all future application activities based on current field conditions. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, 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, DocuSigned by: L-on l . <JM,l& F - 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 (electronic copy) Caswell County Environmental Health Department (electronic copy) Laserfiche File WQ0028547 WSRO Electronic Files NORTH caaouvnD_E oep.m.m orEMr nment W.i� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office l 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0028547 Effective: 05/16/19 Expiration: 10/31/24 Owner : Town of Yanceyville SOC: Effective: Expiration: Facility: Town of Yanceyville RLAP County: Caswell 666 Pine Dr Region: Winston-Salem Contact Person: Kamara M Barnett Directions to Facility: Yanceyville NC 27379 Title: Town Manager Phone: 336-694-5431 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0040011 Town of Yanceyville - Yanceyville WWTP Inspection Date: 08/01/2022 Entry Time 10:10AM Exit Time: 11:53AM 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 Land Application Site ▪ Transport (See attachment summary) ▪ Record Keeping ▪ Pathogen and Vector Attraction ▪ Sampling ▪ Storage Page 1 of 5 Permit: WQ0028547 Owner - Facility:Town of Yanceyville Inspection Date: 08/01/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On August 1, 2022, Division of Water Resources staff Caitlin Caudle conducted a compliance inspection. Brent Collins of EMA Resources was present during the entire inspection. An in -office review of records was completed. An on -site review of storage ponds, transportation vehicles, and application sites was completed. This review reflected non-compliance with the subject permit. The following deficiency was noted: A. Per Permit Condition ll.8.a.i there will be a 400ft setback from each habitable residence or place of assembly under separate ownership. There is a house on the corner of Culver Road and Blanch Road that was within 400ft of the residuals application area, approximately 360ft. The house was not buffered on the application map in the Permit. Moving forward, update the application map and apply the appropriate buffers for all future application activities based on current field conditions. Field Observations: • Fields CS-82-2,3, and 4 had been applied on or were being applied on during the inspection. • The well buffered in CS-82-2 is in the pasture close to the tree line. • All application areas were clearly marked. • Residuals were being applied as a liquid using two spreaders. • All fields were fescue hay or pasture. Other observations: • Hauling was taking place from the WTP. • Water is pulled from a small reservoir on Fullers Creek, a WS-III surface water, as part of the Roanoke River Basin. Fuller Creek -> Country Line Creek -> Dan River -> Roanoke River. • Loading was occurring at the top of the hill. A pump and soft hose were being used to transfer liquid residuals to a top loader. • The buffered area in CS-82-4 has never been applied on by EMA. It is currently planted in pine trees and cannot be applied on. • There are two churches on Blanch Rd that are buffered and another house on Powell Road. • There are two concrete lined storage ponds at the WTP. There is approximately 12-18 months of storage. • An alum sludge is produced. • A composite grab sample is collected for all analyses. • CS-82-3 has a ESP of 19.1% based on the soil reports provided in the 2021 annual report. • Fecal samples were collected for the WTP. No vector reduction analysis is required for the WTP. Mr. Collins submitted a request to amend Attachment A to include a footnote from the previous permit This footnote states that no pathogen and vector reduction analysis are needed for WTP residuals. Page 2 of 5 Permit: WQ0028547 Owner - Facility:Town of Yanceyville Inspection Date: 08/01/2022 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 • ❑ ❑ ❑ • • ❑ ❑ ❑ • O 000 O 000 O 000 Page 3 of 5 Permit: WQ0028547 Owner - Facility:Town of Yanceyville Inspection Date: 08/01/2022 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: Is sampling adequate? Is sampling representative? Comment: 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 Yes No NA NE 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? ❑ ❑ • ❑ Page 4 of 5 Permit: WQ0028547 Owner - Facility:Town of Yanceyville Inspection Date: 08/01/2022 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: See comments ❑ ❑ • ❑ ❑ ❑ • ❑ Page 5 of 5