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HomeMy WebLinkAboutWQ0018007_BIMS Report_20240305Compliance Inspection Report Permit:WQ0018007 Effective:08/01/19 Expiration:12/31/24 Owner :Town of Broadway SOC: Contact Person: Region: County: Directions to Facility: Lee Raleigh John M Godfrey Effective:Expiration:Facility:Town of Broadway RLAP 6614 Bradley Rd Broadway NC 27505 Title:Phone:919-258-9922Town Manager Secondary ORC(s): Phone:Certification:Primary ORC: LA,System Classifications: On-Site Representative(s): Related Permits: NC0059242 Town of Broadway - Broadway WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 03/01/2024 09:35AM 10:45AM Chris Smith 919-791-4200 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Land Application Site Pathogen and Vector Attraction Storage (See attachment summary) Page 1 of 6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0018007 03/01/2024 Compliance Evaluation Town of Broadway Routine Inspection Summary: 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. Note: Dustin Kornegay is listed as Town Manager in DWR records. Please contact DWR Central Office to update this information. 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: 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. 6.The 2023 Residuals Annual Report was received on time per permit requirement. The report was not available for review Page 2 of 6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0018007 03/01/2024 Compliance Evaluation Town of Broadway Routine 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. Page 3 of 6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0018007 03/01/2024 Compliance Evaluation Town of Broadway 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? 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 4 of 6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0018007 03/01/2024 Compliance Evaluation Town of Broadway Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results 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? Is sampling representative? 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? 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? Page 5 of 6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0018007 03/01/2024 Compliance Evaluation Town of Broadway Routine 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 1'/3' bls. Is application occurring at the time of the inspection? .Comment: Page 6 of 6