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Home My WebLink AboutWQ0032855_NOV-2023-PC-0131_CEIARR_20230727 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 27, 2023 Doug Barrick Town of Rutherfordton Email: dbarrick@rutherfordton.net SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2023-PC-0131 2022 Annual Report Review Permit No. WQ0032855 Town of Rutherfordton Class B Residuals Program Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Town of Rutherfordton Class B Residuals Program on June 5, 2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0032855. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation was noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Pathogen and Vector Attraction The Town did not demonstrate compliance with the VAR 30-day Bench Scale method before land application. The 30-day method requires a final volatile solids reduction below 15% however, the Town’s reported result is 20.0% after 30 days. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 15 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or melanie.kemp@deq.nc.gov. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report EC: LF, Zach Key (US Biosolids) DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB Compliance Inspection Report Permit:WQ0032855 Effective:05/24/22 Expiration:10/31/28 Owner :Town of Rutherfordton SOC: Contact Person: Region: County: Directions to Facility: Rutherford Asheville Doug Barrick Effective:Expiration:Facility:Town of Rutherfordton Class B Residuals Program 1021 S Main St Rutherfordton NC 28139 Title:Phone:828-287-3520Town Manager From I-40E, take exit 85, stay on Hwy. 221 through the Town of Rutherfordton. Approximately 0.5 mi outside city limits, turn left on gravel road to WWTP (just before intersection of 221&Thunder Rd.) Secondary ORC(s): 336-957-7871Phone:27660Certification:Zach D KeyPrimary ORC: LA,System Classifications: On-Site Representative(s): Related Permits: NC0025909 Town of Rutherfordton - Rutherfordton WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 06/05/2023 12:00PM 03:00PM Melanie Kemp Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Annual Report Review Question Areas: Miscellaneous Questions Record Keeping Treatment Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 06/05/2023 Annual Report Review Town of Rutherfordton Routine Inspection Summary: Melanie Kemp, with the Asheville Regional Office, conducted a review of the Town of Rutherfordton’s 2022 RLAP Annual Report on June 5, 2023. This review was conducted to determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0032855. The Town land applied approximately 19.31 dry tons of Class B residuals to 4 of the 16 permitted fields. Pathogen Reduction (PR) is met through Fecal Coliform Density (Alternative 1). All samples were below limits. Vector Attraction Reduction (VAR): The city meets VAR via the 30-day bench scale test (Option 3). According to the lab results/calculations, the reduction in volatile solids was not met. This option requires volatile solids to be reduced by less than 15%, and solids were reduced by 20%. Pollutants of Concern: The Town’s residuals were all below ceiling concentration for pollutants of concern. Metals & Nutrients: All metals and nutrient parameters for source residuals were analyzed per section IV.3 of the permit. PAN and SAR are reported on the Annual Residual Sampling Summary Form – B and calculation sheets were provided. Soil Fertility Analysis: ESPs were below 15 and lime was applied to fields where the pH was below 6.0 (fields 7 and 8). Please note that the RYE values used for calculating max PAN for fields 10A and 12 do not match current RYE values. Ultimately, PAN application rates were still below limits but should be updated. Please see https://realisticyields.ces.ncsu.edu/ Non-hazardous waste characterization is required annually and was sampled in August 2022. The Town has met the requirements for sampling and all results appear to be within permit limits. The following issues were noted with the report: -On form RSSF, please include an “<” when results are below lab reporting limits. - RYE values used for calculating max PAN for fields 10A and 12 do not match current RYE values. -VAR requirements (Option 3: 30-day bench scale test) were not met. Volatile solids only reduced by 20% (above the required 15% or less). Page 2 of 4 DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 06/05/2023 Annual Report Review Town of Rutherfordton Routine Type Yes No NA NE Distribution and Marketing Land Application Record Keeping Yes No NA NE 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? Fescue allows for year-round application.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 DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0032855 06/05/2023 Annual Report Review Town of Rutherfordton Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results Does not meet requirements of 30-day VAR method - see summary for more details.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: Page 4 of 4 DocuSign Envelope ID: 6CA64D88-8925-47F1-A7C9-DB81E4B204CB