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Home My WebLink AboutWQ0002376_Compliance Evaluation Inspection_20191211ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director NORTH CAROLINA Environmental Quality December 11, 2019 CERTIFIED MAIL # 7013 1710 0002 1922 4044 RETURN RECEIPT REQUESTED Chuck Smith, Public Works Director City of Reidsville 230 West Morehead St. Reidsville, NC 27320 SUBJECT: Notice of Deficiency — (NOD-2019-PC-0253) Compliance Evaluation Inspection Reidsville WWTP Land Application of Residual Solids (503) Permit No. WQ0002376 Rockingham County Dear Mr. Smith: On December 6, 2019 staff from the North Carolina Division of Water Resources (DWR) performed an announced, routine compliance inspection of land application activities conducted under Permit WQ0002376. The inspection was completed by DWR staff person Justin Henderson who was accompanied onsite by EMA Resources staff Boger Hartsell. The inspection reflected non-compliance with Permit No. WQ0002376. The following deficiencies require your attention and action: 1) Failure to request renewal of the permit in accordance with Permit Condition I. (1) which states: No later than six months prior to the expiration of this permit, the Permittee shall request renewal of this permit on official Division forms. 2) Land application site RC0004-01 was visited, to review active application operations being conducted, during this inspection. Runoff of biosolids, from the permitted application area was observed. The runoff was traced to within 5-8 feet of the property boundary. Permit Condition II. (8) requires that a setback of 50 feet from property lines be maintained in accordance with 15A NCAC 02T .1108. Permit Condition III. (9) states: When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind erosion and surface runoff from conveying residuals from the land application sites onto adjacent properties or into surface waters. [G.S. 143-215.1] NORTHCARCL1` D �� DWrb d W Erntronm ,W Qualify North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27103 336.776.9800 3) Failure to ensure the Land -Owner Agreement Attachment (LOAA) between the Permittee and landowners of land application sites were in full force and effect, and failure to request and obtain a permit modification to transfer the application site to new landowners. Application site RC0004-01, per information obtained from the Rockingham County GIS & Register of Deeds website, has apparently changed ownership twice since the LOAA was last updated. Permit Condition III. (16) states: No residuals shall be land applied unless the LOAA is in full force and effect. The LOAA stipulates that the Permittee must request and obtain a permit modification from the Division prior to a transfer of the land application site(s) to a new landowner. 4) Failure to submit payment of the annual fee ($1310) within 30 days after being billed by the Division, in accordance with Permit Condition IV. (8). Payment of the current annual fee is overdue as of December 5, 2019. Along with the above described deficiencies the following items of concern also require your attention: a) There were multiple areas of residual ponding observed within the application area at the time of this inspection. The projected forecast for the day of this event was for rain later the same day and night, and again for the days following. Permit Condition III. (1) requires: The residuals management program shall be properly maintained and operated at all times. The program shall be effectively maintained and operated as a non -discharge system to prevent any contravention of surface water or groundwater standards. Permit Condition III. (11) (d) prohibits land application of bulk residuals if the land is flooded, snow-covered, or is otherwise in a condition such that runoff of residuals would occur. Failure to take weather forecasts into consideration prior to, during, and after planned application events may result in additional violations of runoff and/or discharge to surface waters. b) A water supply well, not shown on the current application site map with appropriate buffer setback, was located at the time of this inspection. Prior to any future application events at application site RC0004-01, a permit modification along with an updated application map that includes this well with appropriate buffers, in accordance with Permit Condition II. (8), shall be requested and obtained from the Division. c) During this inspection, it was noted that not all of the permitted application acreage for site RC0004-01 was planned to receive application of residuals as part of this event. Therefore, to accurately report application rates in accordance with Permit Conditions IV. (7), the total acreage utilized for this event must be determined to allow for accurate reporting of application rates. This office request that you submit a written response to this Notice within 15-days of receipt. This response shall include corrective actions planned to be implemented to address the deficiencies, and items of concern documented herein, as well as how each will be prevented from reoccurring in the future. Your response shall also include a projected schedule of implementation of these proposed corrective actions. Additional inspection observations and comments can be found in the attached inspection report. If you have any questions, please contact Justin Henderson or me at (336) 776-9800. Sincerely, DocuSiiggned by: 1-"49E225C94EA... Lon Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO cc: Brent Collins, EMA Resources — Electronic Copy Laserfiche Files (electronic copies) Compliance Inspection Report Permit: WQ0002376 Effective: 05/15/15 Expiration: 04/30/20 owner: City of Reidsville SOC: Effective: Expiration: Facility: City of Reidsville Residuals Land Application Progral County: Rockingham 230 W Morehead St Region: Winston-Salem Reidsville NC 27320 Contact Person: Steven L Routh Title: Director of Public Works Phone: 336-349-1070 Directions to Facility: System Classifications: LA, Primary ORC: Brent M Collins Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 12/06/2019 Entry Time: 11:30AM Primary Inspector: Justin L Henderson Secondary Inspector(s): Certification: 27651 Phone: 336-751-1441 Exit Time: 01:30PM Phone: 336-776-9701 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment Land Application Site Pathogen and Vector Attraction Transport (See attachment summary) Page 1 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 12/06/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On December 6, 2019 staff from the North Carolina Division of Water Resources (DWR) performed an announced, routine compliance inspection of land application activities conducted under Permit WQ0002376. The inspection was completed by DWR staff person Justin Henderson who was accompanied onsite by EMA Resources staff Boger Hartsell. The inspection reflected non-compliance with Permit No. W00002376. The following deficiencies require your attention and action: 1) Failure to request renewal of the permit in accordance with Permit Condition I. (1) which states: No later than six months prior to the expiration of this permit, the Permittee shall request renewal of this permit on official Division forms. 2) Land application site RC0004-01 was visited, to review active application operations being conducted, during this inspection. Runoff of biosolids, from the permitted application area was observed. The runoff was traced to within 5-8 feet of the property boundary. Permit Condition II. (8) requires that a setback of 50 feet from property lines be maintained in accordance with 15A NCAC 02T .1108. Permit Condition III. (9) states: When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind erosion and surface runoff from conveying residuals from the land application sites onto adjacent properties or into surface waters. [G.S. 143-215.11 3) Failure to ensure the Land -Owner Agreement Attachment (LOAA) between the Permittee and landowners of land application sites were in full force and effect, and failure to request and obtain a permit modification to transfer the application site to new landowners. Application site RC0004-01, per information obtained from the Rockingham County GIS & Register of Deeds website, has apparently changed ownership twice since the LOAA was last updated. Permit Condition III. (16) states: No residuals shall be land applied unless the LOAA is in full force and effect. The LOAA stipulates that the Permittee must request and obtain a permit modification from the Division prior to a transfer of the land application site(s) to a new landowner. 4) Failure to submit payment of the annual fee ($1310) within 30 days after being billed by the Division, in accordance with Permit Condition IV. (8). Payment of the current annual fee is overdue as of December 5, 2019. Along with the above described deficiencies the following items of concern also require your attention: a) There were multiple areas of residual ponding observed within the application area at the time of this inspection. The projected forecast for the day of this event was for rain later the same day and night, and again for the days following. Permit Condition III. (1) requires: The residuals management program shall be properly maintained and operated at all times. The program shall be effectively maintained and operated as a non -discharge system to prevent any contravention of surface water or groundwater standards. Permit Condition III. (11) (d) prohibits land application of bulk residuals if the land is flooded, snow-covered, or is otherwise in a condition such that runoff of residuals would occur. Failure to take weather forecasts into consideration prior to, during, and after planned application events may result in additional violations of runoff and/or discharge to surface waters. b) A water supply well, not shown on the current application site map with appropriate buffer setback, was located at the time of this inspection. Prior to any future application events at application site RC0004-01, a permit modification along with an updated application map that includes this well with appropriate buffers, in accordance with Permit Condition II. (8), shall be requested and obtained from the Division. c) During this inspection, it was noted that not all of the permitted application acreage for site RC0004-01 was planned to receive application of residuals as part of this event. Therefore, to accurately report application rates in accordance with Permit Conditions IV. (7), the total acreage utilized for this event must be determined to allow for accurate reporting of application rates. This office request that you submit a written response to this Notice within 15-days of receipt. This response shall include corrective actions planned to be implemented to address the deficiencies, and items of concern documented herein, as well as how each will be prevented from reoccurring in the future. Your response shall also include a projected schedule of implementation of these proposed corrective actions. Page 2 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 12/06/2019 Inspection Type : Compliance Evaluation 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ Comment: Pathogen and Vector Attraction Yes No NA NE a. Fecal coliform SM 9221 E (Class A or B) ❑ ❑ 0 ❑ 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 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 12/06/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine e. Time/Temp on: ❑ ❑ 0 ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations 0 ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ❑ ❑ 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 Transport Yes No NA NE Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑ Is a copy of the spill control plan in the vehicle? 0 ❑ ❑ ❑ Is the spill control plan satisfactory? 0 ❑ ❑ ❑ 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? ❑ ❑ ❑ Is the application site in overall good condition? ❑ ❑ ❑ Is the site free of runoff/ponding? ❑ ❑ ❑ If present, is the application equipment in good operating condition? ❑ ❑ ❑ Are buffers being maintained? ❑ 0 ❑ ❑ Are limiting slopes buffered? 10% for surface application ❑ ❑ ❑ 18% for subsurface application ❑ ❑ ❑ Are there access restrictions and/or signs? ❑ ❑ ❑ Is the application site free of odors or vectors? ❑ ❑ ❑ Have performance requirements for application method been met? Page 4 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 12/06/2019 Inspection Type : Compliance Evaluation For injection? For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 173' bls. Reason for Visit: Routine ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑❑■ ❑❑❑■ Is application occurring at the time of the inspection? M ❑ ❑ ❑ Comment: Runoff was observed occuring during inspection. Runoff resulted in encroahment on required setback to property boundary. A few steeper slopes should be evaulated to ensure they are < 10%. Page 5 of 5