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Home My WebLink AboutWQ0003035_Notice of Deficiency_20230601DocuSign Envelope ID: 6D164011-981C-450D-A6B4-68lE40C104CB ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 2, 2023 Delivered via email to: mward _edennc.us Melinda S. Ward — WWTP Plant Superintendent City of Eden P.O. Box 70 Eden, NC 27829 SUBJECT: Notice of Deficiency (NOD-2023-PC-0139) 2022 Annual Report Review Eden RLAP Permit No. WQ0003035 Rockingham County Dear Ms. Ward: On May 9, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This review reflected noncompliance with the subject permit. The following deficiency was noted: A. Per Permit Condition 111.3 the Permittee shall notify the Winston Salem Regional Office, at least one business day in advance of conducting any land application activity. A review of Division records show that no land application notifications were provided for the 2022 calendar year. Moving forward, please direct all land application notifications to Caitlin Caudle at 336-776-9699 or Caitlin.caudle(a--)ncdenr.gov. If notifications were provided to the Winston Salem Regional Office in the 2022 calendar year, they can be directed to Ms. Caudle. The following items of concern were noted: • Plant available nitrogen (PAN) was reported as 14,996 mg/kg on 1/19/2022 and 12,179 mg/kg on 8/4/2022. Staff calculated PAN as 15,002 mg/kg for 1 /19/2022 and 12,190 mg/kg for 8/4/2022. Please provide an explanation for these reported values to Ms. Caudle. • Quarterly sampling was completed on 10/5/2022. The lab report showed that the samples arrived outside of hold time. Please provide an explanation of why the sample was outside of hold time. 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 NoanicaaouNn oep.m.m or em�nmen� Qualm 336.776.9800 DocuSign Envelope ID: 6D164011-981C-450D-A6B4-681E40C104CB A routine compliance inspection will be scheduled this calendar year. 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 and phone number, or by email at men ny.graznak(o)-deg.nc.gov or Caitlin.caudle(cr-deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F1 B7456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Reports Cc: Ryan Copeland, Synagro (electronic copy) Rockingham County Environmental Health (electronic copy) D North Carolina Department of Environmental Quality I Division of Water Resources ✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly DocuSign Envelope ID: 6D164011-981C-450D-A6B4-681E40C104CB Compliance Inspection Report Permit: WQ0003035 Effective: 04/01/20 Expiration: 08/31/26 Owner: City of Eden SOC: Effective: Expiration: Facility: City of Eden RLAP County: Rockingham 204 Mebane Bridge Rd Region: Winston-Salem Eden NC 27288 Contact Person: Terry Shelton Title: Phone: 336-623-2110 Directions to Facility: To go to the WWTP, from the Eden Town Hall, take Aiken Rd. North --0.75 mi to NC 14 and turn Right. Follow NC-14 South —3.5 miles to the WWTP (on Right). System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0025071 City of Eden - Mebane Bridge WWTP Inspection Date: 05/09/2023 Entry Time 10:OOAM Exit Time: 02:OOPM by: uSigned Primary Inspector: Caitlin Cau e f DocDOC by: Phone: 336-776-9699 Secondary Inspector(s): Tub D SB834968199D49D... 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 Treatment Sampling Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 DocuSign Envelope ID: 6D164011-981C-450D-A6B4-681E40C104CB Permit: WQ0003035 Owner - Facility: City of Eden Inspection Date: 05/09/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On May 9, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This review reflected noncompliance with the subject permit. The following deficiency was noted: A. Per Permit Condition 111.3 the Permittee shall notify the Winston Salem Regional Office, at least one business day in advance of conducting any land application activity. A review of Division records show that no land application notifications were provided for the 2022 calendar year. Moving forward, please direct all land application notifications to Caitlin Caudle at 336-776-9699 or Caitlin.caudle@ncdenr.gov. The following items of concern were noted: Plant available nitrogen (PAN) was reported as 14,996 mg/kg on 1/19/2022 and 12,179 mg/kg on 8/4/2022. Staff calculated PAN as 15,002 mg/kg for 1/19/2022 and 12,190 mg/kg for 8/4/2022. Please provide an explanation for these reported values to Ms. Caudle. Quarterly sampling was completed on 10/5/2022. The lab report showed that the samples arrived outside of hold time. Please provide an explanation of why the sample was outside of hold time. A compliance evaluation inspection will be scheduled this calendar year. Other observations: • Quarterly sampling was completed on 1/19/2022, 4/21/2022, 8/4/2022, and 10/5/2022. pH on 4/21/2022 was 5.5. • TCLP is required once per permit cycle. The current permit is effective from 4/1/2020 to 8/31/2026. TCLP was sampled on 12/20/2020. • Fields RC-05-01 and 02, RC-26-01 B, 04, and 05, RC-27-01 and 02 all had soil pH < 6. No lime was applied in 2022. Only RC-26-05 had an agronomist lime recommendation on the soil reports. All pH values are still within an acceptable range for the crops. • Fecal and SOUR were used for PVR. Page 2 of 4 DocuSign Envelope ID: 6D164011-981C-450D-A6B4-681E40C104CB Permit: WQ0003035 Owner - Facility: City of Eden Inspection Date: 05/09/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Type Yes No NA NE Distribution and Marketing ❑ Land Application Record Keeping Yes No NA NE Is GW monitoring being conducted, if required? ❑ ❑ 0 ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? 0 ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? 0 ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? ❑ ❑ 0 ❑ Are hauling records maintained and up-to-date? ❑ ❑ 0 ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? 0 ❑ ❑ ❑ Comment: Pathogen and Vector Attraction Yes No NA NE a. Fecal coliform SM 9221 E (Class A or B) 0 ❑ ❑ ❑ 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: 6D164011-981C-450D-A6B4-681E40C104CB Permit: WQ0003035 Owner - Facility: City of Eden Inspection Date: 05/09/2023 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: 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: Sampling Yes No NA NE Describe sampling: Is sampling adequate? 0 ❑ ❑ ❑ Is sampling representative? 0 ❑ ❑ ❑ Comment: Page 4 of 4