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Home My WebLink AboutWQ0000520_2021 Annual Report Review_20220811ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality August 11, 2022 Shane Fletcher, Residuals Management Coordinator City of Burlington P.O. Box 1358 Burlington, NC 27216 SUBJECT: Review of 2021 Residuals Annual Report City of Burlington Residuals Land Application Program Permit No. WQ0000520 Alamance County Dear Mr. Fletcher: Division of Water Resources staff Caitlin Caudle completed a review of the 2021 Residuals Annual Report. This review reflected compliance with the subject permit. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact Caitlin Caudle at the letterhead address or phone number or by email at caitlin.caudle@ncdenr.gov. Sincerely, I DocuSigned by: LLn. l JM.IAhr' 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Alamance County Environmental Health (electronic copy) Laserfiche File WQ0000520 WSRO Electronic Files GDE NORTH C CUNA ' umm mr� eo..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 Compliance Inspection Report Permit: WQ0000520 Effective: 09/10/18 Expiration: 07/31/22 Owner : City of Burlington SOC: Effective: Expiration: Facility: City of Burlington Class B Residuals Program 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: 07/26/2022 Entry Time 08:OOAM Exit Time: 04:30PM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: ▪ Miscellaneous Questions Record Keeping Sampling ▪ Pathogen and Vector Attraction Storage (See attachment summary) Page 1 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 07/26/2022 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: Division of Water Resources staff Caitlin Caudle completed a review of the 2021 Residuals Annual Report. This review reflected compliance with the subject permit. Only residuals from the East WWTP were land applied. A total of 2,057.08 tons were applied on 44 fields. A total of 2,465.15 dry tons of cake residuals from the South WWTP were sent to McGill. Residuals from the East WWTP were sampled monthly. WSRO was notified of all land application activities. Items of concern: • The soil series reported from AM-6-8 and 9 do not match the soil series listed in Attachment B. The Plant Available Nitrogen (PAN) rate reported is appropriate and there is no concern for overapplication. • The property owner for AM-13-2 and 3 do not correspond with the property owner listed in Attachment B. If the property has changed ownership a new Land Owner Agreement is needed. • The PAN reported for AM-14-5 and AM-15-1 and 2 was 122 lbs. The soil series in Attachment B for those fields is not in Alamance County in the NC State Realistic Yield Expectation (RYE) database. Staff opinion is that the closest soil series to this in the RYE would be EnC in Guilford County. This map unit has a PAN rate of 1841bs, or 1381bs with the 25% grazing reduction. If this field is applied on again, please provide a justification for the PAN rate if different than EnC. There was no concern for over application. • The reported PAN rate for AM-14-6 was 2371bs and AM-16-2 was 190lbs for fescue pasture. There does not appear to bE a 25% grazing reduction applied to these fields. The soil series listed in Attachment B for AM-16-2 is not in RYE. If this field is applied on again, please provide justification for the PAN rate is used. There was no concern for over application. • The soil series and PAN rate for AM-35-6 were reported incorrectly. There is no concern for over application. • The soil series was reported incorrectly for AM-116-7 and 8. The PAN rates reported do not match the soil series reported or the soil series in Attachment B. Please provide a justification for the PAN rate used if these fields and this crop are applied on again. • The PAN rate for CH-98-6 was reported incorrectly. There is no concern for over application. • The soil series and PAN rate for CS-18-1 were reported incorrectly. There is no concern for over application. • The soil series and PAN rate were reported incorrectly CS-36-10, 11, and 12. There is no concern for overapplication. • The PAN rates for CS-113-2 and 3 were reported incorrectly. There was no concern for overapplication. Please note that the corresponding map unit to CuB2 (Cullen clay loam, moderately eroded (2-6%)) in Attachment B would be CnB2 in RYE (Cullen clay loam, moderately eroded (2-6%)). Other observations: • AM-16-3 was reported as two fields. The acreage for A and B totaled the amount permitted. • AM-116-7 and 8 were planted in soybeans. Residuals were applied in January, March, and April. The NC Soybean Producers Association states that soybeans are planted starting in March and can be planted as late as July. Nutrients from residuals are slow releasing, but still contain easily available nitrogen that can be leached from the residuals. Please be aware that residuals applied to land without a suitable vegetative cover could result in leaching and runoff of nitrogen and other nutrients. • No residuals were produced in the month of February. • PVRFs were provided for 6x year sampling but PVR was done every month but February in the form of lime stabilization. • Some pH values were less than 6.0 but the residuals applied have a calcium equivalent value above 30%. • Residuals analysis from the 2020 calendar year are included because those residuals were applied in 2021. • The 12/7 SAR was reported incorrectly. The %TS used in the calculation was incorrect. Staff calculated value was 0.92. • TCLP was not included in the ARR. It was requested on 7/28 and provided on 7/28. • Mackintosh WTP Class A material was also applied on AM-6-2, AM-14-5, AM-16 2 and 4, and AM-110-1. • All residuals were applied on fescue hay or pasture, except the two fields mentioned above. • The Alamance County Soil Survey (ACSS) was redone several years ago, resulting in many of the soil map units in the Attachment B not being in the NC State RYE database. The following observations were made regarding the soil map units not available in Alamance County. o CmD is not in the RYE database for any county and was not in the 1956 soil survey for Alamance County. CmB was in RYE for Chatham County. The PAN for fescue hay was 1891bs (141.751bs). If these fields are applied on again, please Page 2 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 07/26/2022 Inspection Type : Annual Report Review Reason for Visit: Routine provide justification for the PAN rates used. o HbB in the ACSS is Helena coarse sandy loam (2-6%). Nash County has a map unit of HeB that is Helena coarse sandy loam (2-6%) with a PAN rate of 1691bs (126.751bs) for fescue hay. Alamance County also has a map unit of HeB with the same PAN. o AbB in the ACSS is Appling coarse sandy loam (2-6%). This map unit is not in AICo in RYE. Catawba County has a map unit of AsB that is Appling sandy loam (2-6%) with a PAN rate of 2371bs (177Ibs) for fescue hay. o DdB2 in the ACSS is Durham sandy loam (2-6%). There is not a similar map unit in RYE. Durham County has a DuB map unit, Durham loamy sand (2-8%). According to the ACSS Appling is a similar soil series. The AsB map unit above can be used. o Tarrus is listed as the soil series in Att. B for AM-13-1,2,3. The FSFs lists TaB2 as the soil series but that is not in RYE. Lee County has a map unit of TaB Tarrus silt loam (2-8%) with a PAN of 184Ibs for fescue hay. If these fields are applied on again, please provide justification for the PAN rates used. o HbC2 in the ACSS is Helena coarse sandy loam, eroded (6-10%). This map unit is not in AICo in RYE. Chatham County has a map unit of HeC Helena sandy loam (6-10%) with a PAN rate of 1581bs (118lbs) for fescue hay. o HbB in the ACSS is Helena coarse sandy loam (2-6%). AICo has a map unit of HeB Helena sandy loam (2-6%) with a PAN of 1691bs (126.751bs) for fescue hay. o EdC2 in the ACSS is Enon fine sandy loam, eroded (6-10%). AICo has a map unit of EnC Enon sandy loam (6-10%) and Guilford County has a map unit of EnC Enon fine sandy loam (2-6%). Both have a PAN of 1841bs (1381bs) for fescue hay. o VbC3 in the ACSS is Vance clay loam, severely eroded (6-10%). There is no Vance clay loam in RYE. AICo has a map unit of VaC Vance sandy loam (6-10%) with a PAN of 1821bs (1381bs) for fescue hay. If these fields are applied on again, please provide justification for the PAN rate used. o EdC in the ALSS is Enon fine sandy loam (6-10%). The same map unit for EdC2 can be used, EnC in Guilford County. o CbB2 in the ACSS is Cecil fine sandy loam, eroded (2-6%). AICo has a map unit of CcB Cecil sandy loam (2-6%) with a PAN rate of 2161bs (162Ibs) for fescue hay. o HdC2 in the ACSS is Herndon silt loam, eroded (6-10%). AICo has a map unit of HnC Herndon silt loam (6-10%) with a PAN rate of 1981bs (148.511bs). o AaB in the ACSS is Alamance silt loam (2-6%). This map unit is not in RYE. The ACSS states that Alamance is similar to Herndon. AICo has a map unit of Herndon silt loam (2-6%) with a PAN rate of 211Ibs (158.251bs) for fescue hay. If these fields are applied on again, please provide justification for the PAN rate used. o GaB2 in the ACSS is Georgeville silt loam, eroded (2-6%). This map unit is not in AICo in RYE. Chatham County has a map unit of GaB Goergeville silt loam (2-6%) with a PAN rate of 2111bs (158.251bs) for fescue hay. o HdB2 in the ACSS is Herndon silt loam, eroded (2-6%). AICo has a map unit of HnB Herndon silt loam (2-6%) with a PAN rate of 2151bs (161.251bs) for fescue hay. o GaB in ACSS is Georgeville silt loam (2-6%). AICo does not have this map unit in RYE. Chatham County has a GaB map unit in RYE with a PAN rate of 2111bs (158.251bs) for fescue hay. o TaB in the ACSS is Tirzah silt loam (2-6%). This map unit is not in RYE. The ACSS states Tirzah is similar to Georgeville. Chatham County has a map unit of GaB Goergeville silt loam (2-6%)with a PAN rate of 2111bs (158.251bs) for fescue hay. If these fields are used again, please provide a justification for the PAN rate used. o Caswell County is not in RYE. EnB can be found in AICo. o Frogsboro is not in RYE. Please provide a justification for the PAN rate used. o CnB2 is Cullen clay loam, moderately eroded (2-6%). CnB2 can be found in AICo. Page 3 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 07/26/2022 Inspection Type : Annual Report Review 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 4 of 5 Permit: WQ0000520 Owner - Facility: City of Burlington Inspection Date: 07/26/2022 Inspection Type : Annual Report Review 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 • ❑ ❑ ❑ • ❑ ❑ ❑ Page 5 of 5