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HomeMy WebLinkAboutWQ0004825_Notice of Deficiency_20230612ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 12, 2023 Delivered via email to: michaelglass816(a_gmail.com Michael Glass, Wastewater Director City of Randleman 204 S Main Street Randleman, NC 27137 SUBJECT: Notice of Deficiency (NOD-2023-PC-0169) City of Randleman Residuals Land Application Program Permit No. WQ0004825 Randolph County Dear Mr. Glass: On June 7, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This review reflected non-compliance with the subject permit. The following deficiency was noted: A. The Winston Salem Regional Office was not notified of the March and April land application activities. 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 activities. Moving forward, all land application notifications can be directed to Caitlin Caudle at Caitlin.caudle(a)deg.nc.gov or 336-776-9699. The following items of concern were noted: • The Annual Land Application Field Summary Form reported the maximum Plant Available Nitrogen (PAN) for RC-18-03 as 220 Ibs/ac. The Realistic Yield Expectation database lists PAN for the permitted soil series as 209 Ibs/ac. There is no concern for overapplication. Moving forward, please ensure the most recent PAN rates are being reported. • The Annual Land Application Certification Form lists 18 fields in the permit. On January 19, 2023, an updated Attachment B was issued after the transfer of several fields to a different land application permit. Moving forward, please ensure that the most recent permit, Attachment A, and Attachment B are being used. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 NoanicaaouNn oep.m.m or em�nmen� Qualm 336.776.9800 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 lon.snider(a--)deg.nc.gov or Caitlin.caudle(a-_)deg.nc.gov. Sincerely, DocuSiTgned by: %A. l . 5,,. Gr 145B49E225CMEA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Ryan Copeland, Synagro (electronic copy) Randolph 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 Compliance Inspection Report Permit: WQ0004825 Effective: 01/19/23 Expiration: 05/31/26 Owner: City of Randleman SOC: Effective: Expiration: Facility: City of Randleman Class B Residuals Program County: Randolph 3475 Applewood Rd Region: Winston-Salem Randleman NC 27317 Contact Person: Scott Douglas Berg Title: Phone: 336-998-7150 Ext.13 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0025445 City of Randleman - Randleman WWTP Inspection Date: 06/07/2023 Entry Time 11:OOAM Primary Inspector: Caitlin L(?M±v, aL4igned by: Secondary Inspector(s):(""""J& 968199D49D_ Exit Time: 12:30PM Phone: 336-776-9699 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 (See attachment summary) Page 1 of 4 Permit: WQ0004825 Owner - Facility: City of Randleman Inspection Date: 06/07/2023 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On June 7, 2023, Division of Water Resources staff Caitlin Caudle completed a review of the 2022 Annual Report. This reviev reflected non-compliance with the subject permit. The following deficiency was noted: A. The Winston Salem Regional Office was not notified of the March and April land application activities. 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 activities. Moving forward, all land application notifications can be directed to Caitlin Caudle at Caitlin.caudle@deq.nc.gov or 336-776-9699. The following items of concern were noted: • The Annual Land Application Field Summary Form reported the maximum Plant Available Nitrogen (PAN) for RC-18-03 as 220 Ibs/ac. The Realistic Yield Expectation database lists PAN for the permitted soil series as 209 Ibs/ac. There is no concern for overapplication. Moving forward, please ensure the most recent PAN rates are being reported. • The Annual Land Application Certification Form lists 18 fields in the permit. On January 19, 2023, an updated Attachment B was issued after the transfer of several fields to a different land application permit Moving forward, please ensure that the most recent permit, Attachment A, and Attachment B are being used. Other observations: • TCLP was completed 3/25/21 for this permit cycle. • Only one field was applied on in 2022 during March, April, and July. A compliance evaluation inspection was completed during the July activities. • Lime stabilization was completed on 3/24/2022 and 7/1/2022. Page 2 of 4 Permit: WQ0004825 Owner - Facility: City of Randleman Inspection Date: 06/07/2023 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? ❑ ❑ 0 ❑ 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? 0 ❑ ❑ ❑ 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) ❑ ❑ ❑ ❑ 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 Permit: WQ0004825 Owner - Facility: City of Randleman Inspection Date: 06/07/2023 Inspection Type: Annual Report Review 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: Reason for Visit: Routine ❑ ❑ ❑ ❑ El ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Page 4 of 4