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Home My WebLink AboutWQ0023178_Compliance Evaluation Inspection_20190927ROY COOPER Governor MICHAEL S, REGAN secretary LINDA CULPEPPER Director Mr. Steve Biggs — Town Manager Town of Clayton PO Box 879 Clayton, North Carolina 27528 Dear Mr. Biggs, NORTH CAROLINA Environmental Quality September 27, 2019 Subject: Compliance Inspection Permit No. WQ0023178 Town of Clayton Residuals Land Application Program Johnston County Staff of NC Division of Water Resources (DWR), Water Quality Regional Operations Section (WQROS), Raleigh Regional Office (RRO) observed delivery and application of wastewater residuals from the Town of Clayton WQ0023178 Residuals Land Application Permit on September 25, 2019. James Warren, ORC, Johnnie Smith and Jonathan Smith assisted with the inspection. Jonathan was operating the transfer pump and land application tractor and equipment for Triple S Farms which is contracted to do the hauling and land application under permit WQ030998. The application fields are owned by Triple S farms and are located outside of Beaulaville. The facility uses a drum thickener to generate about 360 to 400,000 gallons of 2.5 to 3% residuals per month. These residuals can be land applied or they can be turned to cake with a rented belt press. Cake can be land applied, or send to the Johnston County landfill or sent to McGilI for their composting process. Liquid can also be brought to the landfill, but it is expensive. The residuals were lime stabilized in the digester tank at the Clayton Wastewater Recovery Facility. pH was maintained above 12 for at least two hours and remained above 10.5 until transported for application. Vector attraction reduction is accomplished by incorporating the residuals. A copy of the permit which was issued May 19, 2015 and expires September 30, 2020 was maintained on -site in the cab of the tractor application equipment. O&M procedure and Spill Plan was available in both transport trucks and on -site. Proper signs were posted at the access road to the fields. _ m North Carolina Departent of nt Environmeal quality ; Division of Water Resources D� E Q� RalcigltReglanal Officv 1 3800 Barrel Drive i Raleigh. North Carolina 27609 IAtTIIMll �f inWtllM.wMMt�iM\ 41111 '1111 1'II\I\ The transfer into on -site tanker pulled by tractor with balloon tires indicated minimal dripping during tranfer operations. The field was properly flagged. The residuals analyses appeared compliant with permit requirements. Nutrient loadings were monitored and records maintained. There was no odor noted at the held. The fields were sufficiently dry to prevent excess compaction by application equipment. The residuals were adequately dispersed so as to prevent ponding or runoff. The fields were covered with healthy grass crop which has been properly maintained. This residuals application event appeared to be fully compliant with permit requirements and personnel were aware of processes to be performed to assure compliance. Please refer to the attached inspection report. If you have any questions or would like technical assistance, please contact me via email at ray.milosh@ncdenr.gov or at (919) 791-4240. Sincerely, Ray Milosh Environmental Specialist ray.milosh@ncdenr.gov Attachment: Inspection Report cc: RRO-WQROS Files Water Quality Section Central Files Compliance Inspection Report Permit: WQ0023178 Effective: 10/01/15 Expiration, 09r30120 owner. Town of Clayton SOC: Effective: Expiration_ Facility: Town of Clayton Residuals Land Application Progran County: Johnston Region: Raleigh Contact Person: G. F. Baker Title: Phone: 336-288-7169 Directions to Facility: System Classifications: LA Primary ORC: James O Warren Certification: 17618 Phone: 919-553-1536 Secondary ORC(s): On -Site Representative(s): Related Permits - Inspection Date: 09/25/2019 Entry Time: 08 30AM Exit Time: 12 30PM Primary Inspector: Raymond M Mdosh Phone: 919-791-4200 Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Pathogen and Vector Attracticr. Transport (See attachment summary) Inspection Type: Compliance Evaluation Land Application Site Page 1 of 5 Permit- W00023178 Owner - Facility: Town or Clayton Inspection Date,• 09/2512019 Inspection Type : Compliance Evaluation reason for Visit: Routine Inspection Summary: Staff of NC Division of Water Resources (DWR), Water Quality Regional Operations Section (WOROS), Raleigh Regional Office (RRO) observed delivery and application of wastewater residuals from the Town of Clayton WQ0023178 Residuals Land Application Permit on September 25. 2019_ James Warren, ORC, Johnnie Smith and Jonathan Smith assisted with the inspection. Jonathan was operating the transfer pump and land application tractor and equipment for Triple S Farms which is contracted to do the hauling and land application under permit WQ030998. The application fields are owned by Triple S farms and are located outside of Beaulaville. The facility uses a drum thickener to generate about 360 to 400,000 gallons of 2.5 to 3% residuals per month. These residuals can be land applied or they can be turned to cake with a rented belt press. Cake can be land applied, or send to the Johnston County landfill or sent to McGill for their composting process. Liquid can also be brought to the landfill, but it is expensive. The residuals were lime stabilized in the digester tank at the Clayton Wastewater Recovery Facility. pH was maintained above 12 for at least two hours and remained above 10.5 until transported for application. Vector attraction reduction is accomplished by incorporating the residuals. A copy of the permit which was sssued May 19. 2015 and expires September 30, 2020 was maintained on -site in the cab of the tractor application equipment. O&M procedure and Spill Plan was available in both transport trucks and on -site. Proper signs were posted at the access road to the fields. The transfer into on -site tanker pulled by tractor with balloon tires indicated minimal dripping during tranfer operations. The field was properly flagged_ The residuals analyses appeared compliant with permit requirements. Nutrient loadings were monitored and records maintained_ There was no odor noted at the field. The fields were sufficiently dry to prevent excess compaction by application equipment. The residuals were adequately dispersed so as to prevent ponding or runoff. The fields were covered with healthy grass crop which has been properly maintained. This residuals application event appeared to be fully compliant with permit requirements and personnel were aware of processes to be performed to assure compliance. Page 2 of 5 Permit W00023176 Owner - Facility: Town of Claytin Inspection Date: 09/2512019 Inspection type : Ccmp:lance EvalLation Reason for Visit: Routine Type Yes No NA NE Distribution and Marketing Land Application ■ 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? ■ri Is GW-59A certification form completed for facility? ■ Is a copy of current permit on -site? ■ 0 1:1 El Are current metals and nutrient analysis available? . Are nutrient and metal loading calculating most limiting parameters? N El El El 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? ❑ 1:1 El Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? ■ Are hauling records maintained and up-to-date? El El 1:1 # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? ❑ ❑ 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 <i 000 MPNIdry gram Geometric mean of 7 samples per monitoring period for class B<2.0'10E6 CFUIdry gram IJ Fecal coliform SM 9222 D (Class B only) . El Geometric mean of 7 samples per monitoring period for class B<2.0`1 DE6 CFU/dry gram 0 b. pH records for alkaline stabilization (Class A) c. pH records for alkaline stabilization (Class B) 0❑ ❑ Temperature corrected d. Salmonella (Class A, all test must be < 3MPN/4 gram day) .rl Page 3 of 5 permit: VV00023178 owner - Facility: Town of Clayton inspection pate: 0912512019 Inspection Type :Compliance Evaluation Reason for Visit: Routine e Timerremp on: ❑ ❑ E ❑ Digester (MCRT) ❑ Compost ❑ Class A time stabilization ❑ f. Volatile Solids Calculations ❑ ❑ 0 ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ M ❑ Comment: Transport Yes No NA HE Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑ Is a copy of the spill control plan in the vehicle? E ❑ ❑ ❑ Is the spill control plan satisfactory? M ❑ 1111 Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑ Comment: Land Application -Site Yes No NA NE Is a copy of the permit on -site during application events? 0 ❑ ❑ ❑ Is the application site in overall good condition? M ❑ ❑ ❑ Is the site free of runoff/pond.ng? M ❑ ❑ ❑ If present is the application equipment in good operating condition? M ❑ ❑ ❑ Are buffers being maintained? M ❑ ❑ ❑ Are limiting slopes buffered? 1 a% for surface application 0 ❑ 1311 18% for subsurface application M ❑ ❑ ❑ Are there access restrictions and/or signs? M, ❑ ❑ ❑ Is the application site free of odors or vectors? ❑ ❑ ❑ Have performance requirements for application method been met? For injection? ❑ ❑ ❑ For incorporation? E ❑ ❑ ❑ Does permit require monitoring welts? ❑ ❑ M ❑ Have required MWs been installed? ❑ ❑ 0 ❑ Are MWs properly located wt respect to RB and CB? ❑ ❑ M ❑ Are MWs properly constructed (including screened interval)? ❑ ❑ M ❑ Is the surrounding area served by public water? ❑ ❑ 0 ❑ If Annual Report indicates overapplication of PAN are wells nearby that may be impacted? ❑ ❑ M ❑ Are soil types consistent wt Soli Scientist report/evaluation? ❑ ❑ ❑ Is the water table greater than 173' his ❑ ❑ ❑ M Is application occurring at the time of the inspection? M ❑ ❑ ❑ Page 4 of 5