WQ0018007_Compliance Evaluation Inspection_20240305

North Carolina Department of Environmental Quality | Division of Water Resources | Raleigh Regional Office
3800 Barrett Drive | 1628 Mail Service Center | Raleigh, North Carolina 27699-1628
919.791.4200

March 5, 2024

John Godfrey – Town Manager
Town of Broadway
P. O. Box 130
Broadway, NC 27505

Subject: Compliance Evaluation Inspection
Town of Broadway – RLAP
Permit Number: WQ0018007
Lee County

John Godfrey,
On March 1, 2024 Staff of the NC Division of Water Quality (DWQ), Water Quality Regional
Operations Section (WQROS), Raleigh Regional Office (RRO) conducted a compliance
evaluation inspection of the wastewater treatment residuals Class B land application program
(permit no. WQ0018007) for the Town of Broadway. The purpose of this inspection was to
ensure compliance with the subject permit. During the inspection, the cooperation and assistance
of W. Craig Buchanan and Jacob Melvin was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit
• Review of the owner/facility information
• Review of ORC logbooks
• On-site inspection of treatment components and application fields
The current permit was issued effective August 1, 2019 and expires on December 31, 2024.
The Town of Broadway Wastewater Treatment Plant (WWTP) is permitted for the operation of a
residuals management program consisting of the land application of a maximum of 40 dry tons
of Class B residuals generated by the approved facilities listed in Attachment A of the permit
(Broadway WWTP) to the approved fields listed in Attachment B of the permit with no
discharge of wastes to surface waters. The inspection of the WWTP included the drying beds and
residuals storage area.

The following conditions were noted during the inspection:
DocuSign Envelope ID: DE12EA7E-32B7-48DB-9308-1F8486A236CF
WQ0018007
Lee
March 5, 2024
Page 2 of 3

North Carolina Department of Environmental Quality | Division of Water Resources | Raleigh Regional Office
3800 Barrett Drive | 1628 Mail Service Center | Raleigh, North Carolina 27699-1628
919.791.4200

1. According to the 2022 Residuals Annual Report, the total amount of residuals applied
to the permitted fields during 2022 was equal to approximately 5.36 dry tons. This
was applied to approximately 4.2 acres, resulting in approximately 1.3 dry tons per
acre. The annual report includes the Standard Soil Fertility Analysis for the field
where residuals were applied in 2022. The current permit includes 5 fields available
for application listed in Attachment B. The Town of Broadway hauls and applies all
the WWTP residuals generated under this permit.

2. The 2022 annual report submitted by Branch Residuals & Soils, LLC on behalf of the
Town of Broadway indicates annual sampling and analysis for metals and nutrients
with results reported in mg/kg as required. The non-hazardous determination,
including TCLP analysis, is required once during the permit cycle.

• Permit condition IV. 2. states “Residuals shall be analyzed to demonstrate
they are non-hazardous under the Resource Conservation and Recovery
Act (RCRA). Residuals that tests or is classified as a hazardous or toxic
waste under 40 CFR Part 261 shall not be land applied. The analyses [i.e.,
corrosivity, ignitability, reactivity, and toxicity characteristic leaching
procedure (TCLP)] shall be performed at the frequency specified in
Attachment A.”

3. The annual report submitted by Branch Residuals & Soils, LLC on behalf of the
Town of Broadway indicates the Class B pathogen reduction method used was air
drying and was conducted as required by the permit. Incorporation was used for
vector attraction reduction and was conducted as required by the permit. The review
of the analytical data and report indicated compliance with all permit limits.

• Permit condition IV. 4. states “Residuals shall be monitored for
compliance with pathogen and vector attraction reduction requirements
at the frequency specified in Attachment A.”

4. The drying beds and storage area appeared to be well maintained.

5. No land application activities were occurring during the inspection. Application fields
where residuals were applied during the previous year were visited. All the fields had
good vegetative cover.

DocuSign Envelope ID: DE12EA7E-32B7-48DB-9308-1F8486A236CF
WQ0018007
Lee
March 5, 2024
Page 3 of 3

North Carolina Department of Environmental Quality | Division of Water Resources | Raleigh Regional Office
3800 Barrett Drive | 1628 Mail Service Center | Raleigh, North Carolina 27699-1628
919.791.4200

6. The 2023 Residuals Annual Report was received on time per permit requirement. The
report was not available for review at the writing of this letter.

At the time of this inspection the Town of Broadway Class B residuals land application program
appeared to be in compliance with all permit requirements.
If you have any questions about this inspection or this letter, please contact Chris Smith at
[e-mail] or 919-791-4200.
Sincerely,

Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

Attachments: Compliance Inspection Report
cc: Laserfiche

DocuSign Envelope ID: DE12EA7E-32B7-48DB-9308-1F8486A236CF