WQ0000430_Compliance Evaluation Inspection_20230106

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
January 6, 2023
Mr. Larry Wright, WWTP Superintendent / ORC via Email
Town of Cherryville
116 South Main Street
Cherryville, North Carolina 28021
Subject: Non -Discharge Permit Inspection
Town of Cherryville - Permit No.: WQ0000430
Land Application of Residuals
Gaston County
Dear Mr. Wright:
Staff of the Mooresville Regional Office (MRO) conducted an inspection of the referenced permit on
December 20', 2022. The MRO would like to thank you and Mr. Christopher Heedick for your time with
the facility and records review. The residuals processing, storage and records appeared to meet
program requirements at the time of inspection.
The following items of interest are noted for reference and continued compliance:
• Per the December 21 s1, 2022, email and letter from Central Office (CO) permitting, you currently
cannot land apply under your permit because all associated fields were transferred to Synagro's
Class B permit #WQ0016247. The City of Cherryville WWTP was also added as a source to
permit #WQ0016247, so Synagro may haul your material to the same fields but all reporting will
now be required under their permit.
Based on your discussion during this site inspection, MRO staff was of the impression you
informed your Synagro contact you were not interested in sharing land and wanted to continue
your normal land application activity under your current program (permit #WQ0000430).
It appears there is miscommunication between you, your contractor, and your local landowners,
who signed waiver agreements with Synagro staff for the land transfer between permits. Should
you wish to continue land application under your WQ0000430 permit, you will need to determine
the best course of action to either transfer the fields back with new waiver agreements and / or
acquire new land, both of which will require a permit modification. You may contact MRO staff at
the information below or CO staff, Erickson. Saunders0D_ncdenr.gov for further assistance.
• The recently installed gauge at the residuals, storage lagoon appeared appropriately located as
you discussed. Per our conversation additional markings should be added to meet the required
tenths of a foot or one -inch increments as the current markings are in one -foot increments.
The inspection report should be self-explanatory; however, please contact Maria Schutte by phone (704-
235-2184) or email ( maria.schutte(ab_ncdenr.gov ) with questions.
North Carolina Department of Environmental Quality I Division of Water Resources
e:!r5fD E Q Mooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
NORTH CAROLINA 704.663.1699

Sincerely,
DocuSigned by:
4. w N P:"
F161F969A2D84A3...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0000430 20221nspection Report
CC: Christopher Heedick, Cherryville WWTP BUORC (Email)
Alex Fox, Synagro (Email)
Adam Brigman, Synagro (Email)
Erickson Saunders, CO Non -Discharge Permitting (Email)
North Carolina Department of Environmental Quality I Division of Water Resources
RE;
QMooresville Regional Office 1 601 East Center Avenue, Suite 301 1 Mooresville, NC 28115
NORTHCAaoutia 704.663.1699
n_o .m mn..iitv

Compliance Inspection Report
Permit: WQ0000430 Effective: 07/02/20 Expiration: 08/31/26 Owner: City of Cherryville
SOC: Effective: Expiration: Facility: City of Cherryville RLAP
County: Gaston 736 Tot Dellinger Rd
Region: Mooresville
Cherryville NC 28021
Contact Person: Ben Blackburn Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0044440 City of Cherryville - Cherryville WWTP
Inspection Date: 12/20/2022 Entry Time 10:02AM
Primary Inspector: Maria Schutte
Secondary Inspector(s):
Exit Time: 11:13AM
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 Treatment
Sampling Land Application Site Pathogen and Vector Attraction
Storage Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0000430 Owner - Facility: City of Cherryville
Inspection Date: 12/20/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted an inspection of the referenced permit on December 20th, 2022.
The MRO would like to thank you and Mr. Christopher Heedick for your time with the facility and records review. The
residuals processing, storage and records appeared to meet program requirements at the time of inspection.
The following items of interest are noted for reference and continued compliance:
• Per the December 21 st, 2022, email and letter from Central Office permitting, you currently cannot land apply under your
permit because all associated fields were transferred to Synagro's Class B permit #W00016247. The City of Cherryville
WWTP was also added as a source to permit #WQ0016247, so Synagro may haul your material to the same fields, but all
reporting will now be required under their permit.
Based on your discussion during this site inspection, MRO staff was of the impression you informed your Synagro contact
you were not interested in sharing land and wanted to continue your normal land application activity under your current
program (permit #W00000430).
It appears there is miscommunication between you, your contractor, and your local landowners, who signed waiver
agreements with Synagro staff for the land transfer between permits. Should you wish to continue land application under
your WQ0000430 permit, you will need to determine the best course of action to either transfer the fields back with new
waiver agreements and / or acquire new land, both of which will require a permit modification. You may contact MRO staff at
the information below or CO staff, [e-mail] for further assistance.
• The recently installed gauge at the residuals, storage lagoon appeared appropriately located as you discussed. Per our
conversation additional markings should be added to meet the required tenths of a foot or one -inch increments as the current
markings are in one -foot increments.
The inspection report should be self-explanatory; however, please contact Maria Schutte by phone [phone]) or email
([e-mail]) with questions.
Page 2 of 5

Permit: WQ0000430 Owner - Facility: City of Cherryville
Inspection Date: 12/20/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Yes No NA NE
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?
❑
❑ ❑
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?
❑
❑ 0 ❑
Comment: This was an inspection of the WWTP Residuals processing,
storage and records only. MRO
staff attempted to coordinate the facility visit with their land application
event. Per Mr. Wright,
samples were collected in Oct. for planned LA in last quarter,
but Synagro never land applied
and were talking early next year.
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)
❑
❑ ❑
Page 3 of 5

Permit: WQ0000430 Owner - Facility: City of Cherryville
Inspection Date: 12/20/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Temperature corrected ❑
d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ 0 ❑
e. Time/Temp on: ❑ ❑ 0 ❑
Digester (MCRT) ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results 0 ❑ ❑ ❑
Comment: Answers are based on results from the 2021 Annual Report - the most recent data onsite. Per
Mr. Wright, they were billed for sampling results collected by Synagro in October 2022, but a
LA event was never conducted and he did not receive a copy of the results. Their 2022
Annual Report will show no land application was conducted that year. MRO staff advised
resampling would be necessary for land application in Jan. 2023, or later and recommended
discussion with their contractor over the expressed concern for lab expenses incurred in 2022,
and not utilized.
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: Oxidation ditch. Liquid residuals application.
Sampling Yes No NA NE
Describe sampling:
Sample collection at the lagoon was discussed. Mr. Wright was uncertain how Synagro ensures a
well -mixed representative sample around the lagoon storage.
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? ❑ ❑ 0 ❑
Comment: Sampling should be adequate and represent if Cherryville and Synagro Sampling plan protocol
is followed. MRO staff will request to be notified of the sampling event for observation, but
recommends Cherryville plant staff routinely observe their contractor sampling events.
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? ❑ ❑ ❑
Page 4 of 5

Permit: WQ0000430 Owner - Facility: City of Cherryville
Inspection Date: 12/20/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: There was no transportation or land application activity conducted at the time of this
inspection.
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?
❑
❑ ❑
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: There was no transportation or land application activity conducted at the time of this
inspection. Odors and vectors were not detected at the residuals storage lagoon during this
site visit. A new gauge with one -foot increments was installed for lagoon free -board
measurements and discussed to add inch or tenth of inch increments to meet requirements -
See the Summary Section and Cover Letter, also highlighted are comments / concerns related
to recent land transfer that leaves this permit currently with no acreage for land application. It
appears there is miscommunication between City of Cherryville staff, Synagro staff and local
land -owners that has adversely impacted Cherryville staff's ability to manage and operate their
permit as they have historically.
Page 5 of 5