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Home My WebLink AboutWQ0005763_NOD-2018-PC-0315_20181108 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 November 8, 2018 Dan Harbaugh Tuckaseigee Water & Sewer Authority 1246 W Main St Sylva, NC 28779 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2018-PC-0315 Annual Report (2017) Review Permit No. WQ0005763 Jackson County WWTP Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted a review of the 2017 Annual Report for the Tuckaseigee Water and Sewer Authority’s Distribution of Class A Residuals on October 31, 2018. 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. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. Please review the Inspection Summary Page 2 for detailed information regarding sampling guidance. The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Pathogen and Vector Attraction Residuals Temperature: Sewage sludge is dried by direct or indirect contact with hot gases to reduce the moisture content of the sewage sludge to 10 percent or lower. Either the temperature of the sewage sludge particles exceeds 80 degrees Celsius or the wet bulb temperature of the gas in contact with the sewage sludge as the sewage sludge leaves the dryer exceeds 80 degrees Celsius. The Discharge Product temperature recorded on the Dyer Operations Daily Record log showed that the required temperature was met less than 1/2 of the time. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 In addition, the issues below must also be addressed: Compliance Issue(s): Division approved reporting Forms should be used for the Annual Report. The 02T Land Application Forms and instructions are found here. https://deq.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/non-discharge-per mitting-unit/reporting-forms 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. If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Stan Bryson WQS ARO Server LF G:\WR\WQ\Jackson\Wastewater\Non-discharge\Tuckaseigee Water & Sewer Authority\Inspections\October 31, 2018 CEIARR\20181108_WQ0005763_NOD2018PC0315.rtf DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A Compliance Inspection Report Permit:WQ0005763 Effective:09/11/14 Expiration:07/31/19 Owner :Tuckaseigee Water & Sewer Authority SOC: Contact Person: Region: County: Directions to Facility: Jackson Asheville Dan Harbaugh Effective:Expiration:Facility:Jackson County WWTP 1871 N River Rd Sylva NC 28779 Title:Phone:828-586-5189 Ext.203Executive Director Hwy 40 W to Hwy. 74 W to Dillsboro. Hwy. 23 South to River Road. Facility is located at 1871 N River Rd Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: 24 hour contact name Stan D Bryson 919-346-8443 On-Site Representative(s): Related Permits: NC0063321 Tuckaseigee Water & Sewer Authority - TWSA Plant #3 NC0087602 Tuckaseigee Water & Sewer Authority - Whittier WWTP NC0020214 Tuckaseigee Water & Sewer Authority - TWSA WWTP#2 NC0039578 Tuckaseigee Water & Sewer Authority - Jackson County WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 10/31/2018 09:00AM 11:30AM Beverly Price 828-296-4500 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 Pathogen and Vector Attraction (See attachment summary) Page:1 DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 10/31/2018 Annual Report Review Tuckaseigee Water & Sewer Authority Routine Inspection Summary: The inspection consisted of a review of the 2017 Annual Report. The review was conducted by Beverly Price of the Asheville Regional Office. 294 dry tons of residuals were distributed in 2017. Based on the volume distributed in 2017, 1/year monitoring was required for metals, nutrients and pathogen & vector attraction reduction (VAR). Residuals were monitored for metals/nutrients/TCLP/Ignitability/Corrosivity/Reactivity - Analytical results appeared to be compliant with permit conditions. TCLP monitoring is required annually. Pathogen Reduction is verified using Fecal Coliform Density: requirements were met. Five compliance (collected from the silo) samples were collected; one sample was run out of hold time. Pathogen Reduction is verified using Alternative #5 Process to Futher Reduce Pathogens - PFRP Heat Drying – Requirements: Moisture Content: 10% or lower when residuals are dried by indirect or direct contact with hot gases. Temperature Requirement: 80 degrees C (176 degrees F) for residuals or the wet bulb temperature of the gas in contact with the residuals as the residuals leave the dryer: Residuals met the requirement for percent (10%) moisture reduction. The documented dryer temperatures for residuals leaving the dryer were met less than 1/2 of the dryer runs. Vector Attraction Reduction is verified using Option 8 - Drying of Unstabilized Residuals - Requirements: Solids content is 90% or greater. Division approved Forms should be used for reporting. Annual Pathogen and Vector Attraction Reduction Form: Do not calculate or report the Geometric Mean for fecal coliform analyses. The Geometric Mean is used to determine compliance for fecal coliform bacteria analyses for Class B residuals. Class A residuals require all samples to be <1000 MPN/gram of total solids. Do not report process control results on this Form. Please include the Analytical Method on this Form. Sampling Guidance for Pathogen/Vector Attraction Reduction: The EPA Environmental Regulations and Technology, Control of Pathogens and Vector Attraction in Sewage Sludge guidance document (also known as the White House Manual (WHM))does not specify the number of samples that must be analyzed for compliance with Class A microbiological parameters, however, it strongly recommends multiple samples per sampling event. The number of samples taken must be sufficient to adequately represent biosolids quality. Please review the WHM Chapter 4 - Class A Pathogen Requirements, Section 4.3. Monitoing of Fecal Coliform to Detect Growth of Bacterial Pathogens; Chapter 7 - Processes to Futher Reduce Pathogens, Sections 7.1 Introduction, 7.3 Heat Drying; Chapter 9 - Sampling Procedures and Analytical Methods, Section 9.5 Sampling Frequency and Number of Samples Collected, Section 9.8 Sampling Dry Sewage Sludges; Chapter 10 - Meeting the Quantitative Requirements of the Regulation, Section 10.1 Introduction, Section 10.3 Schedule and Duration of Monitoring Event, Section 10.7 Regulatory Objectives and Number of Samples that Should be Tested. For process control samples used for Percent Solids: If samples are re-set, the results of the two samples should be averaged. For Sodium Adsorption Ratio (SAR) calculations: sodium, calcium and magnesium should be converted from mg/kg to mg/l in order to determine milli equivalents. Page:2 DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 10/31/2018 Annual Report Review Tuckaseigee Water & 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? Arsenic sample reported 8/1/18 was 1.0 mg/l. The laboratory report showed 1.4 mg/l.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:3 DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 10/31/2018 Annual Report Review Tuckaseigee Water & Sewer Authority Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results Residuals Temperature: Sewage sludge is dried by direct or indirect contact with hot gases to reduce the moisture content of the sewage sludge to 10 percent or lower. Either the temperature of the sewage sludge particles exceeds 80 degrees Celsius or the wet bulb temperature of the gas in contact with the sewage sludge as the sewage sludge leaves the dryer exceeds 80 degrees Celsius. The Discharge Product temperature recorded on the Dyer Operations Daily Record log showed that the required temperature was met less than 1/2 of the time. 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 DryerComment: Page:4 DocuSign Envelope ID: 672639A5-090B-4631-AD11-58CA54FD214A