WQ0002834_NOV-2019-PC-0546_20190730

July 30, 2019

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

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2019-PC-0546
Permit No. WQ0002834
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 June
25, 2019. 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. An additional information request was submitted
to the Town and received on July 1, 2019. The information requested was received by the Regional Office on July
24, 2019. 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 _________________________________________________________________________________________________________________________________________________________________________
Record Keeping Standard and non-standard parameters (metals and nutrients) were not analyzed in 2018.
Residuals were not sampled and submitted until July 2019. _________________________________________________________________________________________________________________________________________________________________________
Pathogen and Vector Attraction Invalid temperature readings were recorded from a broken temperature probe during the
monitoring period. Unable to assess temperature compliance of all areas of the compost pile. _________________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: F336182A-654D-4502-AD18-8E9201877607

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.
Please carefully review all recommendations noted in the attached inspection report. It is the permittees
responsibility to ensure the residuals are in compliance with all permit conditions before distribution. This includes
documentation and notification of process failures that may affect compliance and verifying all required testing has
been completed within the required monitoring period.
If you should have any questions, please do not hesitate to contact Mikal Willmer 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: WQS-ARO Server
LF
Jadd Brewer

G:\WR\WQ\Yancey\Wastewater\Non-discharge\Town of Burnsville\Inspections\June 26, 2019 CEIARR\20190730_WQ0002834_NOV2019PC0546

DocuSign Envelope ID: F336182A-654D-4502-AD18-8E9201877607
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
Theresa Coletta
Effective:Expiration:Facility:Town of Burnsville DCAR
843 Pine Swamp Rd
Burnsville NC 28714
Title:Phone:[phone]Mayor
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:
On-Site Representative(s):
Related Permits:
NC0020290 Town of Burnsville - Burnsville WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/25/2019 02:00PM 04:30PM
Mikal Willmer 828-296-4686
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 Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: F336182A-654D-4502-AD18-8E9201877607
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
06/25/2019 Annual Report Review
Town of Burnsville
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, began conducting a review of the Town of Burnsville's 2018 Annual
Residual Report on June 25, 2019. This review was conducted to determine whether the facility is operating in compliance
with Permit No. WQ0002834. Due to information missing from the original submittal, an additional information request was
mailed to the Town and emailed to Mr. Brewer on June 27, 2019. Mr. Brewer was additionally notified regarding the add info
after the Town received the hard copy on July 1, 2019. I re-sent the add info request to Mr. Brewer, on July 3, 2019. Mr.
Brewer notified me the metals and nutrients had not been analyzed for the 2018 Annual Report, but had some of the 2018
pile left onsite he could sample. I informed Mr. Brewer to sample to at least show numbers were in compliance with permit
limits. These results were submitted to me on July 24, 2019. After review of the additional information the report is being
completed on July 26, 2019.
The Town distributed 175 dry tons of residuals in 2018. Only one pile is built per year. This pile was assembled in December
of 2017 and monitored into the beginning of 2018.
Non-hazardous Waste Characterization: Completed in August 2017. Will be due again before permit renewal in 2022. In the
future, please verify the correct methodologies are being utilized for ignitibility and corrosivity based on the residuals percent
moisture. An aqueous solid waste has a moisture content of greater than or equal to 20% (Total Solids <81%)
Fecal Coliform Density: Seven samples were collected on the same day in February of 2018. All results were <1000
MPN/gram. Please note, it is recommended to collect these over a two-week period for better representation.
Pathogen & Vector Attraction Reduction: Five of the six probes were operational during the monitoring period. Please note,
even though the NOV response letter, submitted by Ronnie Tipton and received by our office on January 7, 2019, indicates
temperatures were met at all six locations, the temperature sheets do not indicate the probe's pile location on any given
day, only depth. Therefore, we are unable to verify compliance of the entire pile.
Metals and Nutrients Analysis: Sample results received appeared to be in compliance with permit limits; however, these
parameters were not sampled before distribution occurred. Sampling was not completed until 2019 in response to an
additional information request.
SAR & PAN: The permittee should always review and verify laboratory results before submittal. Please verify the correct
SAR and PAN are reported in future annual reports.
Page 2 of 4
DocuSign Envelope ID: F336182A-654D-4502-AD18-8E9201877607
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
06/25/2019 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?
Metals and nutrients analysis were completed, but sampled outside of the reporting year.
Non-hazardous waste characterization was completed in 2017. See summary for details about
appropriate methodolgy based on percent moisture.Primarily used as mulch.
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: F336182A-654D-4502-AD18-8E9201877607
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0002834
06/25/2019 Annual Report Review
Town of Burnsville
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
Time and temperature data for compost was submitted; however, one of the six probes was
broken during this time frame and not immediately replaced. Five of the Six temperature sites
measured met the requirements for Pathogen and Vector Attraction Reduction. The seven fecal
samples were all <1000 MPN/gram. Recommend collecting these over a two week period for a
more representative sample.
Comment:
Page 4 of 4
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217 W. Jones Street
Raleigh, NC 27699
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Mikal Willmer
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Environmental Specialist
North Carolina Department of Environmental Quality
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G. Landon Davidson
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Asheville Regional Office, Regional Supervisor
DEQ, Division of Water Resources, Water Quality
Regional Operatoins
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