WQ0003035_Notice of Violation_20231207

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
December 7, 2023
CERTIFIED MAIL No. 7019 1120 0001 5505 1374
RETURN RECEIPT REQUESTED
Melinda S. Ward — WWTP Superintendent
City of Eden
P.O. Box 70
Eden, NC 27289
SUBJECT: Notice of Violation (NOV-2023-PC-0599)
Compliance Evaluation Inspection
Eden Residual Land Application Program
Permit No. WQ0003035
Rockingham County
Dear Ms. Ward:
On November 30, 2023, Division of Water Resources staff Caitlin Caudle conducted a routine
compliance inspection of the Eden Residuals Land Application Program. Ryan Copeland,
Synagro, was present during the entire inspection. A review of storage facilities, loading
equipment, transport and application equipment, and application fields was completed. An in -
office review of residual analysis was completed. This review reflected non-compliance with
the subject permit. The following violation was noted:
1. A review of available records shows that notification was not provided for the
commencement of land application activities at fields RC-5 and RC-28 on November
16, 2023. This same deficiency was noted in correspondence dated June 2, 2023. Per
Permit Condition 111.3, the Winston Salem Regional Office shall be notified of all land
application activities at least one business day in advance of conducting any land
application. Moving forward, direct all land application notifications to Caitlin
Caudle at 336-776-9699 or Caitlin.caudle(cD_deg.nc.gov.
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 and phone
number, or the above email address.
Sincerely,
Docu Signed by:
OMMCF3F1 B7456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enc: Inspection Report 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 Winston-Salem, North Carolina 27105
Moan caaouNn 336.776.9800
oep.m.m or em�nmen� Qualm

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: [phone]
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: 11/30/2023 Entry Time 09:OOAM
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Exit Time: 10:50AM
Phone: [phone]
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 Sampling
Land Application Site Pathogen and Vector Attraction Storage
Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0003035 Owner - Facility: City of Eden
Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On November 30, 2023, Division of Water Resources staff Caitlin Caudle conducted a routine compliance inspection of the
Eden Residuals Land Application Program. Ryan Copeland, Synagro, was present during the entire inspection. A review of
storage facilities, loading equipment, transport and application equipment, and application fields was completed. An in -office
review of residual analysis was completed. This review reflected non-compliance with the subject permit. The following
violation was noted:
A. A review of available records shows that notification was not provided for the commencement of land application activities
at fields RC-5 and RC-28 on November 16, 2023. This same deficiency was noted in correspondence dated June 2, 2023.
Per Permit Condition 111.3, the Winston Salem Regional Office shall be notified of all land application activities at least one
business day in advance of conducting any land application. Moving forward, direct all land application notifications to
Caitlin Caudle at 336-776-9699 or [e-mail].
Field RC-28
• An on -site house has been built with a water supply well. A buffer was marked for the water supply well, reducing the
application area.
• The application area was clearly marked.
• Residuals application was even with no signs of ponding or runoff.
• Due to a natural gas pipeline crossing the field, tankers were being offloaded in an adjacent field that is also permitted.
Field RC-5
• The application area was clearly marked.
• Residuals application was even with no signs of ponding or runoff.
• The offloading area was in the application area.
Other observations:
• Cake residuals are produced and stored on a covered concrete pad, with approximately six months of storage.
• Residuals applied during this inspection were liquid residuals from an aeration basin cleanout. The clean out is about
two thirds done with approximately 1 MG left before solids are removed.
• Spreaders are calibrated once a year.
• Most fields in the permit are hay or pasture, with a few row crop fields that are primarily land applied in the spring.
• Pre -application calculations include a PAN reduction for residual PAN from previous applications. PAN is calculated as
Ibs/6,200 gallons.
• According to operators, the allowable number of 6,200 gallon tankers per field is calculated, and that number of tankers
per field is not exceeded. If a field is covered before the allowable number of tankers is reached, additional applications are
not made.
• Permitted flow is 13.5MG, average flows are 4MG.
• Nutrient and metal, and TCLP samples are collected from stored biosolids. PVR samples are collected from the
headworks of the belt press.
• Field RC-26-5 had a lime recommendation based on the soil reports, but no lime application was reported in 2022.
Page 2 of 5

Permit: WQ0003035 Owner - Facility: City of Eden
Inspection Date: 11/30/2023 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?
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?
❑
❑ ❑
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: WQ0003035 Owner - Facility: City of Eden
Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation 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 0 ❑ ❑ ❑
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
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?
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?
❑
❑ ❑
Page 4 of 5

Permit: WQ0003035 Owner - Facility: City of Eden
Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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:
Page 5 of 5