SLAS2711_INSP_20160316

FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

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UNIT TYPE:
Lined
MSWLF LCID YW Transfer Compost SLAS X COUNTY: Currituck
Closed
MSWLF HHW White
goods Incin T&P FIRM PERMIT NO.: SLAS-27-11
CDLF Tire T&P /
Collection Tire
Monofill Industrial
Landfill DEMO SDTF FILE TYPE: COMPLIANCE

Date of Site Inspection: 03/16/16 Date of Last Inspection: 01/15/16

FACILITY NAME AND ADDRESS:
Paul Hoffman
Hoffman Septic Tank Pumping
110 Enterprise Dr.
Elizabeth City, NC 27909-7863
GPS COORDINATES: N: 36.37103 E: -75.99829
FACILITY CONTACT INFORMATION:
Name: Paul Hoffman
Address: Same as above
Telephone: [phone]
Email address: [e-mail]

PARTICIPANTS: Chester Cobb

STATUS OF PERMIT: Active EXPIRES: 6/28/15

PURPOSE OF SITE VISIT: Re-permit

STATUS OF PAST NOTED VIOLATIONS:
No violations noted on previous inspection conducted on 01/15/16.

OBSERVED VIOLATIONS:
1) Upon review of the septage land application records, it was noted that there were application events where the
recorded pH was not at least 12. See table in the Comment Section for the application events that had a recorded
pH less than 12. The failure to not raise the pH of septage to 12 prior to application is a violation of Rules
.0838(c)(1), (2), and (3). Rule .0838(c) states “Septage treatment standards:
(1) Domestic septage shall be treated in accordance with the requirements in 40 CFR Part 503 Subpart D
(including Appendix A and B) except that 503.33(b)(11) is not incorporated;
(2) Grease septage, treated grease septage, commercial or industrial treatment plant septage, and
commercial/industrial septage shall be treated in accordance with 40 CFR 257.3-6 or treated by an
equivalent or more stringent process in 40 CFR 503 Subpart D;
(3) Grease septage, or any part of grease septage, mixed with domestic septage shall be treated as grease
septage…”

If the future, you need to make sure that the pH of septage is 12 prior to land application.
FACILITY COMPLIANCE INSPECTION REPORT
Division of Waste Management
Solid Waste Section

Page 2 of 2

The item(s) listed above were observed by Section staff and require action on behalf of the facility in order to come into or maintain compliance
with the Statutes, Rules, and/or other regulatory requirements applicable to this facility. Be advised that pursuant to N.C.G.S. 130A-22, an
administrative penalty of up to $15,000 per day may be assessed for each violation of the Solid Waste Laws, Regulations, Conditions of a Permit,
or Order under Article 9 of Chapter 130A of the N.C. General Statutes. Further, the facility and/or all responsible parties may also be subject to
enforcement actions including penalties, injunction from operation of a solid waste management facility or a solid waste collection service and
any such further relief as may be necessary to achieve compliance with the North Carolina Solid Waste Management Act and Rules.

AREAS OF CONCERN AND COMMENTS:

1) The recorded application events from the submitted records were the pH of septage was less than 12 are in the table
below.

Date
Discharged
Time
Discharged Septage Grease Field A pH
03-02-11 13:05 3000 500 3500 7
09-30-11 10:00 3000 500 3500 11.5
02-21-12 12:05 3000 500 3500 11?
06-04-12 9:00 3000 500 3500 11.5
05-01-13 16:00 3000 3000 11.5
08-05-13 15:45 2000 1500 3500 11.5
04-17-14 16:20 2000 2000 11.5
08-07-14 14:20 3500 3500 11.5

Rule .0838(c) references the Code of Federal Regulations 40 CFR Part 503 and Part 257 which cover the treatment
of septage prior to land application. 40 CFR Part 503.33(b)(12) states “The pH of domestic septage shall be raised to
12 or higher by alkali addition and, without the addition of more alkali, shall remain at 12 or higher for 30 minutes.”
40 CFR Part 257.3-6(b)(2) states “Septic tank pumping that are applied to the land surface or incorporated into the
soil are treated by a Process to Significantly Reduce Pathogens (as listed in Appendix II, Section A) prior to
application or incorporation…” In Appendix II Section A.5, Lime stabilization, it states “Sufficient lime is added to
the sewage sludge to raise the pH of the sewage sludge to 12 after two hours of contact.”

2) I talked to Paul about the pH readings. He said that the 7 came from an inspection conducted by myself and Joe
Gallo. There was an inspection conducted on 03/02/11 by myself and Joe Gallo but there was no mention of pH
being checked in the inspection report. For the other readings, Paul said that he was told at a training class that it
was ok if the pH was around 11.5 (eleven and one half) to 12.

3) Regulations clearly state that the pH of septage shall be at 12 prior to application. In the future, you need to
make sure that you follow the regulations accordingly.

Please contact me if you have any questions or concerns regarding this inspection report.

____________________________ Phone: [phone] .
Chester R. Cobb, Soil Scientist
Division of Waste Management, NCDEQ
Regional Representative

Sent on: 3/28/16 Email Hand delivery X US Mail Certified No. [ _]