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HomeMy WebLinkAboutWQ0001684_NOD-2023-PC-0189_20230621ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 21, 2023 Delivered electronically via email to: mwiseman6a�ci.asheboro.nc.us Michael Wiseman — WWTP Manager City of Asheboro P.O. Box 1106 Asheboro, NC 27204 SUBJECT: Notice of Deficiency (NOD-2023-PC-0189) Compliance Evaluation Inspection Asheboro Residuals Land Application Program Permit No. WQ0001684 Randolph County Dear Mr. Wiseman: On June 14, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection. David Ackley, EMA Resources, was present during the entire inspection. A review of records, storage structures, transport vehicles, application equipment, and application fields was completed. This review reflected non-compliance with the subject permit. The following deficiencies were noted: A. Per Permit Condition 11.10 land application areas shall be clearly marked and Permit Condition 11.8.a.iii property lines shall have a 50 ft setback and 11.8.a.vii ditches shall have a 25 ft setback. Field RD-42-2 had all buffers clearly marked, but the setback from the northern property line was less than 50ft. Ms. Caudle recommended that Mr. Ackley move the buffer flags to 50ft from the property line where residuals had not already been applied. Moving forward, please ensure that all buffers listed in Permit Condition 111.8 are followed. B. The approved land application areas are shown in the field maps included in the Attachment B of the subject permit. Biosolids were noted within the buffered areas of the field. Based on field observations, it is likely that the spread pattern from the side spreader exceeded the application area and the biosolids were not intentionally applied in the buffers. Ms. Caudle recommended that application practices be altered to ensure that biosolids are not applied in the buffers of a field for the remained of this application event. Moving forward, please ensure that no residuals are applied in buffers. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm 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 deg.nc.gov or Caitlin.caudle(c).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 Report Cc: Brent Collins, EMA Resources (electronic copy) David Ackley, EMA Resources (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: WQ0001684 Effective: 09/14/22 Expiration: 09/30/25 Owner: City of Asheboro SOC: Effective: Expiration: Facility: City of Asheboro Class B Residuals Program County: Randolph 1032 Bonkemeyer Dr Region: Winston-Salem Asheboro NC 27203 Contact Person: John N Ogburn Title: City Manager Phone: 336-626-1213 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0026123 City of Asheboro - Asheboro WWTP Inspection Date: 06/14/2023 Entry Time 09:OOAM Primary Inspector: Caitlin Ca dlffeDDocusi9nedd by: Secondary Inspec(s): t -rub' -- tor8B834968199D49D_ Exit Time: 11:20AM Phone: 336-776-9699 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 Record Keeping Treatment Sampling Land Application Site Pathogen and Vector Attraction Storage Transport (See attachment summary) Page 1 of 5 Permit: WQ0001684 Owner - Facility: City of Asheboro Inspection Date: 06/14/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On June 14, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection. David Ackley, EMA Resources, was present during the entire inspection. A review of records, storage structures, transport vehicles, application equipment, and application fields was completed. This review reflected non-compliance with the subject permit. The following deficiencies were noted: A. Per Permit Condition 11.10 land application areas shall be clearly marked and Permit Condition 11.8.a.iii property lines shall have a 50 ft setback and 11.8.a.vii ditches shall have a 25 ft setback. Field RD-42-2 had all buffers clearly marked, but the setback from the northern property line was less than 50ft. Ms. Caudle recommended that Mr. Ackley move the buffer flags to 50ft from the property line where residuals had not already been applied. Moving forward, please ensure that all buffers listed in Permit Condition 111.8 are followed. B. The approved land application areas are shown in the field maps included in the Attachment B of the subject permit Biosolids were noted within the buffered areas of the field. Based on field observations, it is likely that the spread pattern from the side spreader exceeded the application area and the biosolids were not intentionally applied in the buffers Ms. Caudle recommended that application practices be altered to ensure that biosolids are not applied in the buffers of a field for the remained of this application event. Moving forward, please ensure that no residuals are applied in buffers. Field 42-2 • A side spreader was being used. • Application was even. • The staging area was within the application area. • Minimal tracking was noted in the road. • A ditch was present in the northeastern corner of the field that is not marked on the application map, but the flagged buffers maintained >25ft from the ditch. RD-42-1 • Application was already completed for this field at the time of inspection. • Application appeared even. • Flags were not present, but the biosolids application pattern showed that the appropriate buffers were maintained. Other observations: • Fields are not limed unless requested by the landowner. • The storage facilities were in good condition. An open atmosphere concrete pad with walls was used to store residuals as well. • TCLP was completed on 1/4/2023 and 2nd quarter sampling was completed on 4/5/2023. • Mike Wiseman, Permittee, provided the fecal and 40-day bench scale test on 6/19/2023. • The WWTP was last inspected on 1/27/2022. Page 2 of 5 Permit: WQ0001684 Owner - Facility: City of Asheboro Inspection Date: 06/14/2023 Inspection Type: Compliance Evaluation 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? ❑ ❑ ❑ 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 5 Permit: WQ0001684 Owner - Facility: City of Asheboro Inspection Date: 06/14/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine e. Time/Temp on: ❑ ❑ ❑ ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations 0 ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results N ❑ ❑ ❑ 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: 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? 0 ❑ ❑ ❑ 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? Page 4 of 5 Permit: WQ0001684 Owner - Facility: City of Asheboro Inspection Date: 06/14/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine 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? 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 summary. Page 5 of 5