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Home My WebLink AboutWQ0016247_NOD-2019-PC-0198_20190910Roy COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality September 10, 2019 Mr. Nate Roth, Technical Services Manager via Email Synagro Central, LLC 284 Boger Road Mocksville, NC 27028 Subject: Notice of Deficiency NOD-2019-PC-0198 Non -Discharge Permit Inspection Synagro Western Regional — Permit No.: WQ0016247 Land Application of Residuals for the Norwood WWTP source facility Stanly County Dear Mr. Roth: Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on August 22nd 2019. Synagro is the permittee and Norwood WWTP the source. Inspection included active application at field NC-ST-04-02 and the facility storage/loading areas. MRO staff would like to thank Mike Boone for his time during the field inspection. There were a couple issues noted to return to overall compliance: Ensure all hauling and application vehicles have a complete copy of the permit with spill and operations and maintenance plans. A subcontracted hauler did not have all required paperwork. MRO staff located a single page copy of the spill plan in one of the drivers' clip boards. A complete permit with maps, O&M & Spill plans were on -site in the spreader vehicle; And, another was viewed on -site at the Norwood Plant. • Spill plan was deficient for contact information. Synagro spill plans typically include specific titles and phone #'s for spill reporting; however, the version of the spill plan on -site in all copies MRO staff viewed was missing this information. These items were also discussed with Adam Brigman, at a scheduled site visit the following day, since the spill plan needs correction for additional permits Synagro is involved with as permittee or contractor. MRO staff recommends at least one 24hr contact # for a Synagro Position Title and one for the Permittee if different. Also, verify all phone #'s for state reporting are current. NORTH CAROHNA � D E 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 o.namremor �w.c�giuuei� /`� 704.663.1699 Y-yes N-no NE -not evaluated NA -not applicable Y Permit on site during application Y Spill plan on site (inadequate as noted above) Y Buffers adequate Y Cover crop specified in permit Y Site condition adequate N Documented exceedances of PAN limits N Signs of runoff / ponding *NE Rain gauge on site during application Y Signage posted Y Current Analytical data for PVAR, Metals, TCLP *MRO staff was informed the rain gauge was located near the owners' home, but exact location was unknown by site personnel. Per follow-up conversation with Mr. Brigman, the rain gauge is located at the owners' maintenance shop. Are there any limiting slopes on fields? NA 10 % for surface application NA 18% for subsurface application Odors present: No odors were detected. Vectors present: No vectors were detected. Flying insects present appeared unrelated to the residuals activity. Field site NC-ST-04-02 was viewed for active application. Only a portion of the field was to be land applied, as the remaining facility residuals volume was insufficient coverage for the whole field. Flagging was placed for sufficient guidance on the field portion applied only. The equipment appeared well maintained and distributed liquid application evenly with no signs of drift, odors or vectors at the time of inspection. This inspection does NOT cover additional facilities or sources included in this regional permit. It is requested an updated spill plan be submitted within 30 days to the Mooresville Regional Office, by email to: maria.schutte(a-_)ncdenr.gov. Please contact Maria Schutte, by email or phone (704-235-2184) with questions. Sincerely, Docu Signed by: p 41tw H pzut4 F161FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment: WWQ0016247 BIMS Data Base Inspection Report CC: Adam Brigman, SYNAGRO Charlotte Office (email) David Ezzell, Stanly County Environmental Health Supervisor (email) Compliance Inspection Report Permit: WQ0016247 SOC: County: Alexander Region: Mooresville Contact Person: Alex Fox Directions to Facility: System Classifications: LA, Primary ORC: Secondary ORC(s): On -Site Representative(s): Effective: 05/16/19 Expiration: 10/31/22 owner: Synagro Central LLC Effective: Expiration: Facility: Synagro Western Piedmont RLAP 284 Boger Rd Mocksville NC 27028 Title: Phone: 336-703-8681 Certification: Phone: Related Permits: NC0020591 City of Statesville - Third Creek WWTP NC0043532 Stanly County - West Stanly WWTP NC0031836 City of Statesville - Fourth Creek WWTP NC0021890 Town of Granite Falls - Granite Falls WWTP NC0021369 Town of Columbus - Columbus WWTP NC0021628 Town of Norwood - Norwood WWTP Inspection Date: 08/22/2019 Entry Time: 01:20PM Primary Inspector: Maria Schutte 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 Treatment Pathogen and Vector Attraction Storage (See attachment summary) Exit Time: 03:OOPM Phone: 704-663-1699 Inspection Type: Compliance Evaluation Land Application Site Transport Page 1 of 4 Permit: WQ0016247 Owner - Facility: Synagro Central LLC Inspection Date: 08/22/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on August 22nd, 2019. Synagro is the permittee and Norwood WWTP the source. Inspection included active application at field NC-ST-04-02 and the facility storage/loading areas. MRO staff would like to thank Mike Boone for his time during the field inspection. There were a couple issues noted to return to overall compliance: • Ensure all hauling and application vehicles have a complete copy of the permit with spill and operations and maintenance plans. A subcontracted hauler did not have all required paperwork. MRO staff located a single page copy of the spill plan in one of the drivers' clip boards. A complete permit with maps, O&M & Spill plans were on -site in the spreader vehicle; And, another was viewed on -site at the Norwood Plant. • Spill plan was deficient for contact information. Synagro spill plans typically include specific titles and phone #'s for spill reporting; however, the version of the spill plan on -site in all copies MRO staff viewed was missing this information. These items were also discussed with Adam Brigman, at a scheduled site visit the following day, since the spill plan needs correction for additional permits Synagro is involved with as permittee or contractor. MRO staff recommends at least one 24hr contact # for a Synagro Position Title and one for the Permittee if different. Also, verify all phone #'s for state reporting are current. Y-yes N-no NE -not evaluated NA -not applicable Y Permit on site during application Y Spill plan on site (inadequate as noted above) Y Buffers adequate Y Cover crop specified in permit Y Site condition adequate N Documented exceedances of PAN limits N Signs of runoff / ponding ' NE Rain gauge on site during application Y Signage posted Y Current Analytical data for PVAR, Metals, TCLP *MRO staff was informed the rain gauge was located near the owners' home, but exact location was unknown by site personnel. Per follow-up conversation with Mr. Brigman, the rain gauge is located at the owners' maintenance shop. Are there any limiting slopes on fields? NA 10 % for surface application NA 18% for subsurface application Odors present: No odors were detected. Vectors present: No vectors were detected. Flying insects present appeared unrelated to the residuals activity. Field site NC-ST-04-02 was viewed for active application. Only a portion of the field was to be land applied, as the remaining facility residuals volume was insufficient coverage for the whole field. Flagging was placed for sufficient guidance on the field portion applied only. The equipment appeared well maintained and distributed liquid application evenly with no signs of drift, odors or vectors at the time of inspection. This inspection does NOT cover additional facilities or sources included in this regional permit. It is requested an updated spill plan be submitted within 30 days to the Mooresville Regional Office, by email to: maria.schutte@ncdenr.gov. Please contact Maria Schutte, by email or phone (704-235-2184) with questions. Page 2 of 4 Permit: WQ0016247 Owner - Facility: Synagro Central LLC Inspection Date: 08/22/2019 Inspection Type : Compliance Evaluation Type Distribution and Marketing Land Application Reason for Visit: Routine Yes No NA NE 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) ❑ ❑ ❑ 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 0 ❑ ❑ ❑ Comment: PVAR and additional analytical data were reviewed when this source was added to the permit last year. MRO and CO staff agreed additional analyses were not necessary as long as no new material was added and the application event occurred this year. This was permitted as a one time aDrAcation event for the Norwood WWTP laaoon clean -out. Treatment Check all that apply Yes No NA NE Aerobic Digestion Anaerobic Digestion ❑ Alkaline Pasteurization (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost ❑ Drying Beds ❑ Other ❑ Comment: Lagoon (actually a plant digester) utilized for long-term storage, until repaired and placed back in service. Transport Yes No NA NE Page 3 of 4 Permit: WQ0016247 Owner - Facility: Synagro Central LLC Inspection Date: 08/22/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Is a copy of the permit in the transport vehicle? ❑ ❑ ❑ Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑ Is the spill control plan satisfactory? ❑ ❑ ❑ Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑ Comment: Spill plan is the subject of this Notice of Deficiency, for missing Permittee/Contractor emergency contact information. 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? ❑ ❑ ❑ 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? 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. ❑ ❑ ❑ Is application occurring at the time of the inspection? 0 ❑ ❑ ❑ Comment: Soils are only reviewed when new land is added to the program. MRO staff reminds all contractors and permittees to assess Seasonal High Water Table, as local wet weather conditions dictate. and adiust buffers accordinalv. Page 4 of 4