WQ0005763_NOD-2024-PC-0108_CEIARR 2023_20240618

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED

June 18, 2024

Daniel Manring
Tuckaseigee Water and Sewer Authority
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0108
Permit No. WQ0005763
Tuckaseigee Water and Sewer Authority DCAR
Compliance Inspection Report
Annual Report Review 2023
Jackson County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Tuckaseigee Water and
Sewer Authority DCAR on June 18, 2024. This inspection was conducted to verify that the facility is
operating in compliance with the conditions and limitations specified in Non-discharge Permit No.
WQ0005763. The findings and comments noted during this inspection are provided in the enclosed copy
of the inspection report entitled "Compliance Inspection Report".

The Annual Report Review inspection was conducted by Division of Water Resources staff from the
Asheville Regional Office. The following deficiency was noted during the inspection:
Inspection Area Description of Deficiency __________________________________________________________________________________________________________________________________________________________________ Record Keeping TCLP result for m,p-cresol (756 µg/L) was above the regulatory limit (400 µg/L). __________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286

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, carefully review these deficiencies and
address the causes of non-compliance to prevent the recurrence of similar situations.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Compliance Evaluation Inspection Report

Ec: LF, Joe Ward (ORC)

DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Compliance Inspection Report
Permit:WQ0005763 Effective:08/01/19 Expiration:09/30/24 Owner :Tuckaseigee Water and Sewer Authority
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Jackson
Asheville
Daniel Manring
Effective:Expiration:Facility:Tuckaseigee Water and Sewer Authority DCAR
1871 N River Rd
Sylva NC 28779
Title:Phone:[phone]
Secondary ORC(s):
828-586-9318Phone:[phone]Certification:Joseph William WardPrimary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0063321 Tuckaseigee Water and Sewer Authority - TWSA Plant #3
NC0087602 Tuckaseigee Water and Sewer Authority - Whittier WWTP
NC0020214 Tuckaseigee Water and Sewer Authority - TWSA WWTP#2
NC0039578 Tuckaseigee Water and Sewer Authority - Jackson County WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/18/2024 11:00AM 03:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0005763
06/18/2024 Annual Report Review
Tuckaseigee Water and Sewer Authority
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of TWSA’s 2023 Annual Residuals Report as to
ensure all monitoring and residuals handling are compliant with non-discharge permit WQ0005763.
TWSA is permitted to distribute 659 Dry Tons of Class A residuals annually. Approximately 323 dry tons of residuals were
produced, and 161 dry tons were distributed to the public in 2023. The residuals from TWASA Plants #1, #2, #3, and
Whittier are combined for processing. The total residuals in are calculated by combining press and dryer runs. Total
product out is calculated by estimating truck weights.
Pathogen & Vector Attraction Reduction: All fecal coliform densities reported were below 1,000 MPN/g. Pathogen reduction
was met using PFRP Heat Drying, and vector attraction was met through drying of stabilized residuals (Alternative 7).
The following deficiency was noted:
•The TCLP result for m,p-cresol (756 µg/L) was above the regulatory limit (400 µg/L).
The following issues were noted with the report submittal:
•VAR Alternative 8 was incorrectly checked on PVRF 503, but the ORC confirmed that this was a reporting error, as
alternative 7 is utilized.
•The following values were analyzed for but not included on form RSSF: Aluminum, Calcium, Magnesium, pH, PAN,
Potassium, Sodium, and SAR.
•TCLP reporting limits for 2,4-dinitrotoluene and Hexachlorobenzene were above the regulatory limit.
•Bench sheets for the heat dryer and belt press, as well as lab reports, were not included with the original application but
were emailed upon request after the report was submitted.
Page 2 of 4
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0005763
06/18/2024 Annual Report Review
Tuckaseigee Water and Sewer Authority
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
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?
TCLP reporting limits for 2,4-dinitrotoluene and Hexachlorobenzene were above the regulatory
limit. Additionally, the TCLP result for m,p-cresol (756 µg/L) was above the regulatory limit (400
µg/L). The following values were analyzed but not included in on form RSSF: Aluminum,
Calcium, Magnesium, pH, PAN, Potassium, Sodium, and SAR.
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)
Page 3 of 4
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0005763
06/18/2024 Annual Report Review
Tuckaseigee Water and Sewer Authority
Routine
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
In 2023 quarterly fecal samples (3 per event) were collected, and all were below permit limits.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
VAR Alternative 7 is utilized (Drying of Stabilized Residuals). Form PVRF 503 indicated
Alternative 8, but the ORC clarified that this was a reporting error.
Comment:
Sampling Yes No NA NE
Describe sampling:
Bacteria and %solids/metals/nutrient samples are collected from the silo prior to distribution. Samples are
collected from each dryer run to ensure compliance with VAR alternative 7 and PFRP (heat drying).
Is sampling adequate?
Is sampling representative?
A hot oil dryer dries the solids after being belt pressed. They are then stored in a silo prior to
sampling/distribution.
Comment:
Page 4 of 4
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Annual Report Review Class A Distribution Permit No. WQ00_________

Reporting Period: ___________

Permit Details:

• Is 503 OR 257
• Maximum Dry Tons Per Year: ________
• Monitoring Frequency for TCLP: ________
• Monitoring Frequency for Residuals Analysis: ________
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: ________

1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? Yes No
• Was distribution conducted during the reported period? Yes No
• How many dry tons were produced and distributed? ________
• Were the distributions with the permitted amount? ________
• Were recipient’s information listed? ________
• Did it indicate compliance? Yes No
• Was form complete? Yes No
• Was it signed by the appropriate people? Yes No

2. Monitoring
• Were the analyses conducted at the required frequency? Yes No
• Was an analyses taken for each source that was distributed? Yes No
• Were the metals analyses reported on the Residual Sampling Summary Form? Yes No
• Were the results reported in mg/kg? Yes No
• Were the pH’s 6.0 or greater for each residual sample? Yes No
• Were the heavy metals within ceiling concentration permit limits? Yes No
o Were the lab analyses attached? Yes No
• Were all the required parameters tested? Yes No
• Was TCLP analysis conducted? Yes No
• Were the TLCP contaminants within regulatory limits? Yes No
• Was a corrosivity, ignitability, and reactivity analysis conducted? Yes No

05763
2023
659
annually
annually
annually
323 produced, 161 distributed
yes
yes
Comments:
-SAR was not calculated and reported-The following TCLP reporting limits were above the regulatory limit: 2,4-dinitrotoluene and Hexachlorobenzene-TCLP result for m,p-cresol (756 µg/L) was above regulatory limit (400 µg/L).-The following values were analyzed for but not included on form RSSF: Aluminum, Calcium, Magnesium, pH, PAN, Potassium, Sodium, and SAR.
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? Yes No
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? Yes No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? Yes No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?Yes No

Class A Pathogen Review

To be Class A, residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 1000 MPN/gram of total solids? Yes No

OR

Salmonella density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 3 MPN/4 grams of total solids? Yes No

To be Class A, residuals shall meet one of the following alternatives:

Alternative 1 – Time/Temperature
· Were the residuals maintained for correct time and temperature? Yes No
· Were logs submitted showing time and temperature? Yes No
· Were temperatures within range for complete time period? Yes No

Alternative 2 – Alkaline Treatment
· Were logs submitted showing time and temperature? Yes No
· Was the pH raised to 12 or greater and maintained for 72 hours or longer? Yes No
· Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
Yes No
· Were logs submitted showing time and pH? Yes No
· Was the temperature corrected to 25°C (77°F)? Yes No

Alternative 5 – Process To Further Reduce Pathogens
PFRP Composting
· Were the within-vessel method or static aerated pile methods used? Yes No
· Was the residuals temperature maintained at 55°C (131°F) or higher for three consecutive days or
longer in the within-vessel method or static aerated pile method? Yes No
OR
· Was the windrow composting method used? Yes No
· Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? Yes No
PFRP Heat Drying
· Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? Yes No
· Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? Yes No

Comment: VAR Alt. 7 should be checked, not Alt. 8. Lab Reports for fecal results were notprovided.
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Vector Attraction Reduction Review

• Was the sampling conducted at the required frequency? Yes No

Option 1 – 38% Volatile Solids Reduction
· Was there 38% reduction? Yes No
· Were lab sheets/calculations in report? Yes No
· Was the reduction on volatile solids (not total solids)? Yes No
· Were the samples taken at beginning of digestion process and before application (Inspection)?
Yes No
· Were calculations correct? Yes No

Option 2 – 40-Day Bench Scale Test
· Were residuals from anaerobically digested treatment (Inspection)? Yes No
· Were residuals anaerobically digested in lab? Yes No
· Was the test run for 40 days? Yes No
· Was the test done between 30°C (86°F) and 37°C (99°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 17%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 3 – 30-Day Bench Scale Test
· Were residuals from aerobically digested treatment (Inspection)? Yes No
· Were residuals aerobically digested in lab? Yes No
· Were residuals 2% or less total solids? Yes No
· If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
Yes No
· Was the test run for 30 days? Yes No
· Was the test done at 20°C (68°F)? Yes No
· Was the reduction of on volatile solids (not total solids)? Yes No
· Was the reduction less than 15%? Yes No
· Were lab sheets/calculations in report? Yes No
· Were calculations correct? Yes No

Option 4 – Specific Oxygen Uptake Rate (SOUR)
· Were residuals form aerobically digested treatment (Inspection)? Yes No
· Were residuals 2% or less total solids (dry weight basis) (not diluted)? Yes No
· Was the test done between 10°C (50°F) and 30°C (86°F)? Yes No
· Was the temperature corrected to 20°C (68°F)? Yes No
· Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry
weight basis)? Yes No
· Was the sampling holding time two hours? Yes No
· Was the test started within 15 minutes of sampling or aeration maintained? Yes No

Option 5 – 14-Day Aerobic Process
· Were the residuals from aerobically digested treatment (Inspection)? Yes No
· Were the residuals treated for 14 days? Yes No
· Was the residuals temperature higher than 40°C (104°F) for a 14-day period? Yes No
· Was the average residuals temperature higher than 45°C (113°F)? Yes No

DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Option 6 – Alkaline Stabilization
· Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes No
· Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
Yes No
· Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? Yes No
· Was the pH corrected to 25°C (77°F)? Yes No

Option 7 – Drying of Stabilized Residuals
· Does the residuals contain any unstabilized residuals? Yes No
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried up to 75% total solids? Yes No

Option 8 – Drying of Unstabilized Residuals
· Were the residuals mixed with any other materials? Yes No
· Were the residuals dried to 90% total solids? Yes No

Option 9/10 – Injection/Incorporation
· Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
Yes No
· Was injection done on pasture or hay field? Yes No
· Was injection done at time that crop was growing? Yes No
· If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? Yes No
· Was incorporation done six hours after application (Inspection)? Yes No

4. General
• Was the report in the proper format? Yes No
• Was the annual report complete? Yes No
• Was the report submitted on time? Yes No
Comment: Bench sheets and lab reports were not provided with original application but were sent upon request and reviewed after the report was submitted.
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286
Pollutant Limits
Pollutant Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic 75 41
Cadmium 85 39
Copper 4300 1500
Lead 840 300
Mercury 57 17
Molybdenum 75 N/A
Nickel 420 420
Selenium 100 100
Zinc 7500 2800

TCLP
Parameter Below
Limit
Parameter Below
Limit
Parameter Below
Limit
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (0.7) Pyridine (5.0)
Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (5.0)
Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0)
Chlorodane (0.03) Hepatachlor (and its
epoxide) (0.008)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0) Hexachlorobenzene (0.13) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)

m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)

Residuals Analysis
Parameter Analyzed For Parameter Analyzed For Parameter Analyzed For
Aluminum Mercury Potassium
Ammonia-
Nitrogen
Molybdenum Selenium
Arsenic Nickel Sodium
Cadmium Nitrate-
Nitrite
Nitrogen
SAR
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN

y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
n
y
n
y
RL issue
RL issue
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
DocuSign Envelope ID: 435B8EC0-A4A4-4812-BEBE-A88B3846D286