WQ0002834_NOV-2018-PC-0483_20181220

North Carolina Department of Environmental Quality | Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

Certified Mail # 7017 2620 0000 9759 1758
Return Receipt Requested

December 20, 2018

Theresa Coletta, Mayor
Town of Burnsville
PO Box 97
Burnsville, NC 28714

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2018-PC-0483
Permit No. WQ0002834
Annual Report (2017) Review
Town of Burnsville DCAR
Yancey County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Town of Burnsville DCAR on
November 28, 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. WQ0002834. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.

The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________
Pathogen and Vector Attraction Pathogen reduction requirements for compost: Temperature must be maintained at 55
deg C (131 deg F) or higher for three consecutive days. The temperature was not met
for three consecutive days for 1 of the 6 monitoring points. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D

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):

1. The Water Quality Lab & Operations data sheets show a sample analysis date of December 21, 2016 for
Sludge Fecal; the sample location shows Burnsville #2. The compost pile temperature data sheets show
Town of Burnsville Pile #1, 2017. Please clarify if fecal coliform analyses were conducted for the compost
generated from the Town of Burnsville for compost pile #1, 2017.

2. Corrosivity pH (See permit condition IV.2.) was analyzed out of hold time. The residuals pH (See permit
condition IV. 3.) was analyzed out of hold time. The analyses were performed by Environmental Testing
Solutions, Inc. You may be able to perform the above referenced pH analyses at your facility in order to meet
the hold time. Please contact Jason Smith with the NC Laboratory Certification Section @ 828.296.4679 or
[e-mail] to determine if you can add the required pH certifications for biosolids to your
laboratory certification.
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, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.
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

Ec: Jason Smith
Ronnie Tipton
WQS ARO Server
LF

G:\WR\WQ\Yancey\Wastewater\Non-discharge\Town of Burnsville\Inspections\November 28, 2018 CEIARR (2017)\20181220_WQ0002834_NOV2018PC0483
DocuSign Envelope ID: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D
Compliance Inspection Report
Permit:WQ0002834 Effective:12/01/17 Expiration:11/30/22 Owner :Town of Burnsville
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Yancey
Asheville
Ronnie Leonard Tipton
Effective:Expiration:Facility:Town of Burnsville DCAR
843 Pine Swamp Rd
Burnsville NC 28714
Title:Phone:[phone]Public Works Director
Go north on Hwy. 19-23 from Asheville. Take the Burnsville exit. Go east on Hwy 19E past Mountain Heritage HS to Westside Dr.
(SR 1196) and turn right. Turn left on Pine Swamp Rd. (SR 1138). WWTP is located on the right approximately 1/2 mile.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Ronnie Leonard Tipton 828-682-2420
On-Site Representative(s):
Related Permits:
NC0020290 Town of Burnsville - Burnsville WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/28/2018 09:30AM 10:30AM
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: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
11/28/2018 Annual Report Review
Town of Burnsville
Routine
Inspection Summary:
The 2017 Annual Report Review was conducted by Beverly Price of the Asheville Regional Office.
65.14 dry tons of residuals were distributed in 2017. The Class A Distribution and Marketing Certification & Summary Form
did not show the correct volumes for “Amendment/Bulking Agents” and “Residuals In”. The volumes should indicate the
volume of dry tons and residuals used for building each individual compost pile.
Residuals analysis (nutrients/metals) was conducted as required by the permit and was based on the volume distributed.
Metals results appeared to be compliant with the ceiling concentration and monthly average concentration limits. A TCLP
analysis was conducted and results indicate compliance with regulatory limits. Ignitability, Corrosivity, Reactivity analyses
were conducted as required.
The pH analyses were run out of hold time.
Pathogen and Vector Attraction Reduction (VAR):
Pathogen Reduction Verification – permittee uses a “Process to Further Reduce Pathogens” (PFRP) – Compost, and
Pathogen Density using Fecal Coliform monitoring.
VAR – permittee uses Option 5 – 14 Day Aerobic Process.
The Water Quality Lab & Operations data sheets show a sample analysis date of December 21, 2016 for Sludge Fecal; the
sample location shows Burnsville #2. The compost pile temperature data sheets show Town of Burnsville Pile #1, 2017.
Please clarify if fecal coliform analyses were conducted for the compost generated from the Town of Burnsville compost
temperature data sheets labeled Pile #1, 2017.
Fecal coliform monitoring data that was submitted shows regulatory limits were met. All samples were collected on the
same day. The EPA guidance document Environmental Regulations and Technology, Control of Pathogens and Vector
Attraction in Sewage Sludge (the White House Manual [WHM]) recommends collecting samples over a two-week period.
The time and temperature requirements for Option 5, 14-day aerobic process were met based on data sheets labeled Pile
#1, 2017.
PFRP Compost requirements: Residuals temperature is maintained at 55 deg C (131 deg F) or higher for three consecutive
days. Temperatures were monitored at 6 different points and three different depths. Although temperatures were met at five
of the points, the sixth temperature point never reached the required temperature of 131 deg F
Page:2
DocuSign Envelope ID: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
11/28/2018 Annual Report Review
Town of Burnsville
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?
Nutrient/metals analyses are for 2017.
Corrosivity (pH) analyzed out of hold time.
Residuals pH analyzed out of hold time.
Residuals Sampling Summary Form: aluminum & sodium were analyzed but not listed on the
Form. Arsenic & Mercury were reported incorrectly (transposition errors) on the Form.
Residuals recipient information (name, volume received, intended use) was provided.
There were no seasonal restriction windows.
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)
Page:3
DocuSign Envelope ID: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
11/28/2018 Annual Report Review
Town of Burnsville
Routine
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)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Pathogen reduction requirements for compost: Temperature must be maintained at 55 deg C
(131 deg F) or higher for three consecutive days. The temperature was not met for all 6
monitoring points for three consecutive days.
Fecal coliform laboratory sheets for analysis show December 2016.
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:
Page:4
DocuSign Envelope ID: 2465BE8A-A98D-41D6-B3A5-056A93B07F0D
Certificate Of Completion
Envelope Id: 2465BE8AA98D41D6B3A5056A93B07F0D Status: Completed
Subject: Please DocuSign: 20181220_WQ0002834_NOV2018PC0483.docx, 20181220_WQ0002834_CEIARR draft.pdf
Source Envelope:
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Certificate Pages: 2 Initials: 1 Beverly Price
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217 W. Jones Street
Raleigh, NC 27699
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IP Address: 149.168.204.10
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12/20/2018 8:17:01 AM
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Beverly Price
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North Carolina Department of Environmental Quality
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G. Landon Davidson
[e-mail]
Asheville Regional Office, Regional Supervisor
DEQ, Division of Water Resources, Water Quality
Regional Operatoins
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