WQ0018688_Compliance Evaluation Inspection_20190530

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Mr. Bill Trudnak, Public Works Director
Town of Dallas
700 E. Ferguson Street
Dallas, North Carolina 28034
Dear Mr. Trudnak:
NORTH CAROLINA
Environmental Quality
May 30, 2019
via F,mail
Subject: Non -Discharge Permit Inspection
Town of Dallas WTP - Permit No.: WQ0018688
Distribution/Land Application of Alum Residuals (503 Exempt)
Gaston County
Staff of the Mooresville Regional Office (MRO) conducted inspections for the referenced residuals permit
and the NPDES (#NC0082694) permit on May 16th, 2019. A separate report was sent for the NPDES
inspection. The MRO would like to thank Zack Foreman for his time during the inspections. The
following issues were also noted in the previous inspection report and should be addressed to
maintain overall compliance:
• Copies of all permit related data and hauling records should be maintained, either electronically
or in paper file, at the WTP for access during inspections. Residuals material was landfilled and
the May 2019 hauling records received after request by email; however, on -site records access will
improve efficiency for both Dallas and MRO staff.
• The residuals storage lagoons (includes the former emergency chemical containment basin, which
was plumbed to the Alum lagoon for overflow) need appropriate water level gauges) for the two
feet of freeboard to be maintained and correctly documented.
This facility received a previous violation for failure to submit the 2017 and 2016 Annual
Reports. The 2018 AR was NOT received, which will be addressed in a separate violation. This
item is noted here as a reminder to submit for 2019, per permit condition IV.7. The form may
be located at: hgps:Hdeq.nc.gov/about/divisions/water-resources/water-resources-
permits/wastewater-branch/non-discharge-permitting-unit/reportin - f�. The Town of Dallas may
request a permit rescission, should it be determined this permit is no longer required.
The attached report is for the residuals inspection only and should be self-explanatory; however, you may
contact Maria Schutte by phone [phone]) or email (maria.schuttekncdenr.gov) with questions.
D Q
� North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
NOAn-icJwauNn i
nwm,em of eem­woviRv 704,663.1699

Sincerely,
Docu Signed by:
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Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0018688 Inspection Report
CC: Zack Foreman, WTP Supervisor, Town of Dallas (email)

State of North Carolina Department of Environmental Quality
Division of Water Resources
Roy Cooper, Governor
Michael S. Regan, Secretary
Linda Culpepper, Director
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
Owner: Town of Dallas County: Gaston
Permit #: W00018688 (Non -Discharge WTP Residuals) Issued: 05/29/2015 Expiration: 07/31/2020
Permittee Contact: Bill Trudnak (Utilities Director) Phone: [phone] Email: btrudnak(a),dallasnc.net
Additional Contact: Zack Foreman (WTP ORC) Phone: [phone] Email: zforeman(a)dallasnc.net
LA ORC: Dennis Key (Southern Soil Builders (SSB)) #15704 Phone: [phone]
BU ORC: Zach Key (y_SSB) LA#23660 Phone: [phone] Email: zachkey(c�southernsoilbuilders.com
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of Inspection
Collection System Spray Irrigation X Sludge Other
Inspection Date(s): May 16, 2019
Inspection Summary: (additional comments may be included on attached pages)
This inspection included a records review and tour of residuals processing and storage at the WTP. On
Tuvia conducted the NPDES permit #NC0082694 inspection and will generate a separate report.
Please note:
• Address issues of concern noted in the cover letter.
• The residuals storage lagoon berm needs maintenance for removal of a large shrub.
• The MRO should be informed of any changes to the contact information noted above by
contacting maria.schutte(aDncdenngov or at 704-663-1699.
Is a follow-up inspection necessary? yes, X no
Inspector Name/Title: Maria Schutte, Environmental Specialist; Ori Tuvia, Environmental En ig neer
Telephone No.: 704-663-1699 Fax No. 704-663-6040
Date of Inspection: 5/16/2019

Residuals Inspection
WQ0018688 Town of Dallas WTP— Gaston County
Type of Residual
X Land Application (Alum Residuals) X Distribution and Marketing (Alum Residuals)
Record Keeping
Y-yes N-no N/A -not applicable N/E-not evaluated
Y Copy of current permit available at residual generating site
NA Current metals and nutrient analysis (see permit for frequency)
* N TCLP analysis, NA SSFA (Standard Soil Fertility Analysis)
Y Nutrient and metals loading calculations (to determine most limiting parameter) YTD
** N Hauling records (# gal and/or ton hauled during calendar year to date)
NA Field loading records, NA Field site maps and information (Reviewed at LA field site)
NA Records of lime purchased
NA Pathogen & Vector Attraction Reduction
pg. 2
Comments: * Above answers are based on historical data reviews. The WTP has not distributed or land
applied under this permit for many years. The 2018 AR was not received, which may result in a
separate violation. This item is noted here as a reminder to submit for 2019.
** Hauling records were NOT available for review on -site, but were received by email on May 22,2019.
As noted in the previous inspection report, the permittee is reminded to maintain copies of hauling
records for on -site review, whether electronic or paper.
Pathogen & Vector Attraction Reduction (PVAR) records 503 Exempt for VAR
Fecal coliform
X SM 9221 E (Class A or B)
(Class A, all test must be <1000 MPN / dry gram)
(Class B, Geometric mean of 7 samples/monitoring period - <2.0* 106 CFU / dry gram)
SM 9222 D (Class B only)
(Geometric mean of 7 samples/monitoring period for Class B <2.0* 106 CFU / dry gram)
Salmonella (Class A, all tests must be < 3MPN / 4 grams dry
Time / Temp records
Digester (MCRT) Compost Class A lime stabilization
Volatile solids calculations
Bench -top aerobic/anaerobic digestion results
pH records for lime stabilization ( Class A or B )
SOUR calculations
Treatment
Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
Alkaline Stabilization Lime X Other -describe WTP - Alum Residuals
Transport NA -There was no loading or transportation of residuals occurring at the time of inspection.

Residuals Inspection pg. 3
WQ0018688 Town of Dallas WTP— Gaston County
Spill control plan in transport vehicle? NA
Does transport vehicle appear to be maintained? NA
Storage per previous reports
Number of days/weeks/months of storage: Days ofstorage is unknown (no documented calculation
however. east annual reports indicate that solids are typically removed from the plant once every couple
of years.
Describe storage: The water treatment plant has 2 earthen lagoons for alum sludge storage. And 2 drying
beds° or processing.
Comments: The residuals storage lagoons (includes the former emergencv chemical containment basin
which was plumbed to the Alum lagoons or overflow) appeared adequately maintained, at the time of
inspection. Residuals have been hauled to a lands for disposal. However, water level gauge(s) have NOT
been installed at either bond and there is one large plant growing in the residuals lagoon berm which should
he removed
(Please note, should any chemicals be released to this basin, both it and the Alum storage basin would
need to be analyzed and disposed in an appropriate landfill. Distribution or land application would not
be an option.) The previous items were noted in the last inspection report and are also noted in the
cover -letter.
Odors present N Vectors present N
Sampling
Describe Sampling: Per previous inspection reports, residuals sampling is handled by Southern Soil
Builders in accordance with permit requirements.
Is sampling adequate? NE Is sampling representative? NE Lf protocol is followed than sampling
should be representative.)
Field Sites (end use for class B biosolids) No land application was taking place during this inspection.
Residuals land application has historically been managed by Southern Soil Builders.
Field identification: NA — no land application at the time of inspection.
Permit on site during application _ Spill plan on site
Buffers adequate _ Cover crop specified in permit
Documented exceedances of PAN limits _ Site condition adequate
Signs of runoff / ponding
Rain Gauge on site during application
Are there any limiting slopes on fields?
10 % for surface application _ 18% for subsurface application
Odors/vectors
NA — no land application at the time of inspection.
Monitoring well(s) Y/N: N This permit does not require groundwater monitoring_
If yes, location of well(s):