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Home My WebLink AboutWQ0007349_202005 ARR 2019_20200506ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S. REGAN Secretary LINDA CULPEPPER Director May 6, 2020 Ms. Nicole Johnston, Executive Director Yadkin Valley Sewer Authority P.O. Box 828 Elkin, NC 28621 Subject: Review of the 2019 Annual Report Yadkin Valley Sewer Authority, Residuals Land Application Program Permit No. WQ0007349 Surry County Dear Ms. Johnston: Division of Water Resources (Division) staff person Caitlin Caudle has completed a review of the 2019 annual report. Review of the annual report reflects compliance with Permit No. WQ0007349. However, the following items of concern were noted which require your attention: • Permit Condition II.10 requires that Plant Available Nitrogen (PAN) shall not be applied in exceedance of agronomic rates. The PAN limits provided on the Land Application Field Summary Form (FSF) are higher than the PAN rates calculated by North Carolina State University's Realistic Yield Expectations for the listed soil type. Please ensure that the correct PAN limit is listed for soil types on FSF forms in future annual reports. This may prevent overapplication of PAN due to incorrect limits. • The newly issued subject permit requires that TCLP analysis be preformed annually. Incomplete TCLP analysis was provided with this annual report. As a reminder, please provide annual TCLP analysis in future annual reports, or request permit modification to reduce the frequency of TCLP analysis. Also, please ensure that complete TCLP results are provided moving forward. • A 30-Day Bench Scale Test was utilized to demonstrate compliance with Vector Attraction Reduction requirements. While the test results reflect compliance, the required full test results were not provided in the report Please include the full lab report data from the 30-day test lab results in future annual reports. • The soil test results provided in the annual report included an Agronomist recommendation for lime amendment to land application fields. Lime was reported as being applied to these fields. However, four of these fields received insufficient lime application rates when compared to the Agronomist's recommended application rate. Permit Condition IV.5. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 336-776-9800 requires that an annual soil test shall be completed for each application field and soil pH is one of the required parameters. Soil pH at land application fields must be maintained at 6.0 unless the Agronomist recommends different based on the specific crops and site. Please apply lime at the rates specified by the Agronomist to all land application fields in the future. Please be aware that failure to properly address items of concern may result in future non- compliance. If you have any questions regarding this letter, please contact Patrick Mitchell or me at the letterhead address or phone number, or by email at patrick.mitchelIgncdenr.gov or Ion. snider&ncdenr. gov. Sincerely, Docu Signed bby: 145B4g "2 C 4EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO cc: Mr. Dennis Key, ORC — Southern Soil Builders (Electronic copy: dkeyksouthernsoilbuilders.com) Mr. Hal Transou, ORC — (Electronic copy) Surry County Environmental Health (Electronic copy) Laserfiche File WQ0007349, WSRO Electronic Files Page 2 of 2 Compliance Inspection Report Permit: WQ0007349 Effective: 06/13/19 Expiration: 02/28/25 Owner: Yadkin Valley Sewer Authority SOC: Effective: Expiration: Facility: Yadkin Valley Sewer Authority RLAP County: Surry 211 Marion Rd Region: Winston-Salem Elkin NC 28621 Contact Person: Zach D Key Title: Phone: 336-957-7871 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0020567 Yadkin Valley Sewer Authority - Yadkin Valley Sewer Authority WWTP Inspection Date: 05/05/2020 Entry Time 03:OOPM Exit Time: 05:OOPM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Patrick Mitchell Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Land Application Site Pathogen and Vector Attraction (See attachment summary) Page 1 of 5 Permit: WQ0007349 Owner -Facility: Yadkin Valley Sewer Authority Inspection Date: 05/05/2020 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On 05/05/2020 a review of the annual report was completed. The annual report reflects compliance with the subject permit. A site visit was not included in this inspection. Several items of concern were noted. 1. The PAN rates listed on the land application summary forms do not match PAN rates provided by NC State's RYE. The PAN rates provided on the land application form are higher than RYE rates. 2. Lime was applied to each field, but the fields did not recieve the agronomist recommended lime rates. 3. The 2019 subject permit requires TCLP analysis to be reported annually. This was updated from the previous subject permit, which only required TCLP analysis to be reported once per permit cycle. Partial TCLP analysis was provided in this annual report. 4. 30 day bench scale test is designated as the vector attraction reduction analysis by the Pathogen and Vector Attraction Reduction form. Lab results were provided that noted volatile solids were reduced 2%. Lab analysis was not provided in this annual report to verify the test was carried out correctly. Page 2 of 5 Permit: WQ0007349 Owner -Facility: Yadkin Valley Sewer Authority Inspection Date: 05/05/2020 Inspection Type: Annual Report Review 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? ❑ ❑ 0 ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? 0 ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? 0 ❑ ❑ ❑ Are hauling records maintained and up-to-date? 0 ❑ ❑ ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑ 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: WQ0007349 Owner -Facility: Yadkin Valley Sewer Authority Inspection Date: 05/05/2020 Inspection Type: Annual Report Review 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 0 ❑ ❑ ❑ 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: Sampling Yes No NA NE Describe sampling: Is sampling adequate? ❑ ❑ ❑ Is sampling representative? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ Page 4 of 5 Permit: WQ0007349 Owner -Facility: Yadkin Valley Sewer Authority Inspection Date: 05/05/2020 Inspection Type: Annual Report Review Reason for Visit: Routine 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? Comment: ❑❑❑■ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑❑■ ❑❑■❑ ■❑❑❑ ■❑❑❑ ❑❑❑■ Page 5 of 5