WQ0022155_ARR NOV2020PC0251_20200521

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ROY COOPER
Governor
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MICHAEL S. REGAN
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Secretary
S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
May 21, 2020
CERTIFIED MAIL 70181130 0000 1612 7383
RETURN RECEIPT REQUESTED
Ms. Cathy Howell, Town Manager
Town of Jefferson
P.O. Box 67
Jefferson, NC 28640
Subject: Notice of Violation (NOV-2020-PC-0251)
Review of the 2019 Annual Report
Town of Jefferson, Distribution of Class A Residuals Program
Permit No. WQ0022155
Ashe County
Dear Ms. Howell,
Division of Water Resources (Division) staff person Patrick Mitchell has completed a review of
the 2019 Annual Report for the subject permit. The report was found to be incomplete and
therefore noncompliant with the subject permit. The following violations require your attention
and action:
1. The Annual Distribution & Marketing Certification form included in the 2019 report did
not list the recipients information required in Part B of the form. This is a violation of
Permit Condition IV. 7. which requires annual reporting of required records (form Parts
A, B and C must be completed). Please submit an amended Annual Distribution &
Marketing Certification form that contains all the required information and ensure
that complete forms are included in future annual reports.
2. There was no Residual Sampling Summary form (RSSF) included in the 2019 report for
the subject Class A permit. There was a statement included in the subject Class A report
(i.e. Additional laboratory information for Metals, Nutrients, SAR calculations ... is
included in the Class B report) that refers to the 2019 Annual Report for your Class B
Residuals Land Application Program under Permit No. WQ0004166 for sampling results.
The RSSF included for the Class B program only included results for samples of the liquid
Class B residuals from the digester and no results for the Class A solids residuals produced
from the dryer. Failure to sample the Class A dryer residuals and report the results on form
RSSF as required are violations of Permit Conditions IV. 3., IV. 5., and IV. 7. Please
submit a properly completed RSSF form and provide the required 2019 sample
results for the Class A residuals solids from the dryer if they are present. Please
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336.776.9800

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ensure that separate sampling and reporting of the Class A residuals solids from the
dryer is conducted moving forward. Class A residuals solids produced from the dryer
(i.e. >90% solids content) for Permit No. WQ0022155 should be sampled and reported
independently from the Class B liquid residuals collected from the digester (i.e. approx.
2% solids content) for Permit No. WQ0004166. Parameter concentrations and sample
results likely will differ in the Class A residuals solids when compared to the Class B
liquid residuals. Therefore, separate sampling and reporting is required to meet
requirements for each individual permit.
3. By failing to collect samples and report results of the Class A residuals produced from the
dryer as described above in item #2, the residuals that were distributed during 2019 failed
to demonstrate compliance with regulated pollutant limits contained in Permit No.
WQ0022155. This is a violation of Permit Condition II. 4. (Heavy Metals) and II. 10.
(Sodium Adsorption Ratio). Please ensure that Class A residuals solids are sampled
and reported as required in the future.
4. The Annual Pathogen and Vector Attraction Reduction (PVRF) form included in the 2019
report indicated that Alternative 5 - Heat Drying was utilized as the process to reduce
pathogens and Option 7 - Drying of Stabilized Sludge was utilized as the process for
vector attraction reduction. However, there was no data provided in the 2019 Class A
report to demonstrate compliance with PVRF requirements (e.g. temperature
measurement logs and percent solids results) beyond a single Fecal Coliform result.
Failure to submit the data necessary to demonstrate compliance with PVRF requirements
is a violation of Permit Conditions II. 5., II. 6., IV. 4., and IV. 7. Please submit all
required 2019 data necessary to demonstrate compliance with the indicated Class A
pathogen and vector attraction reduction methods.
It should be noted that if the sample results reported for the Class B residuals were to be
utilized for Class A pathogen and vector attraction reduction, those results do not meet the
regulatory limits (e.g. residuals sample results reported solids contents of 1.8% and 1.5%;
while the 503 Class A dryer method requires >90% solids content with residuals exiting
the dryer having a temperature of 80' C (176' F) or higher for pathogen reduction, and
>75% solids for vector attraction reduction).
In addition to the violations described above, the following item of concern also warrants your
attention and action:
A. There were no residuals analyses results for non -hazardous determination (i.e. TCLP,
corrosivity, ignitability and reactivity test results) included in the 2019 report for the
subject Class A permit. Again, the statement included in the report described above in
violation item #2 (i.e. Additional laboratory information for... TCLP is included in the
Class B report) refers to the 2019 Annual Report for your Class B Residuals Land
Application Program under Permit No. WQ0004166 for sampling results.
The TCLP test results for non -hazardous determination included for the Class B program
only included results for samples of the liquid Class B residuals from the digester, and no
results for the Class A residuals solids produced from the Dryer.
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As a reminder, The Attachment A of Permit No. WQ0022155 requires testing for non-
hazardous determination at a minimum frequency of once per permit cycle (i.e. due before
June 30, 2021). If an independent sampling event of the Class A residuals for TCLP
has not been completed yet, please ensure that this is completed prior to the end of
the current permit cycle.
The Division requests that you submit a written response which includes the above requested
information within thirty (30) days following receipt of this Notice. Please be advised that
further enforcement actions including issuance of civil penalties may be taken if the requested
information is not submitted within the time provided, and/or should these violations persist.
Our office appreciates your attention to the above described violations and item of concern. If you
have any questions regarding this Notice, please contact Patrick Mitchell or me at the letterhead
address or phone number, or by email at patrick.mitchellkncdenr.gov or Ion. sniderkncdenr. gov.
Sincerely,
IL
DocuSignedby:
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14 49 25C EA
Lon . m er.,.Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Tim Church, Water Resources Director (Electronic copy: jeffwnsncentMlink.net)
Ashe County Environmental Health (Electronic)
DWR Laserfiche File WQ0022155
WSRO Electronic Files
Page 3 of 3

Compliance Inspection Report
Permit: WQ0022155 Effective: 07/28/16 Expiration: 06/30/21 Owner: Town of Jefferson
SOC: Effective: Expiration: Facility: Jefferson WWTP
County: Ashe 1233 NC Hwy 16 S
Region: Winston-Salem
Jefferson NC 28640
Contact Person: Cathy Howell Title: Town Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0021709 Town of Jefferson - Jefferson WWTP
Inspection Date: 05/15/2020 Entry Time 08:30AM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Exit Time: 10:30AM
Phone: [phone]
Inspection Type: Annual Report Review
Miscellaneous Questions Record Keeping
Sampling Pathogen and Vector Attraction
(See attachment summary)
Treatment
Page 1 of 4

Permit: WQ0022155 Owner - Facility: Town of Jefferson
Inspection Date: 05/15/2020 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
A review of the 2019 Annual Report for the subject permit has been completed. No site visit was conducted. The report was
found to be incomplete and noncompliant with the subject permit. The following violations were noted during the review:
1. The Annual Distribution & Marketing Certification form included in the 2019 report did not list the recipients information
required in Part B of the form. Requested an amended form with missing info added.
2. There was no Residual Sampling Summary form included in the 2019 report for the subject Class A permit. There was a
statement included that 'Additional laboratory information for Metals, Nutrients, SAR calculations ... is included in the Class
B report'. However, the form included for the Class B program only included results for samples of the liquid Class B
residuals from the digester and no results for the Class A solids residuals produced from the dryer. Requested a completed
form along with sample results if they exist. Also reminded Permittee that separate sampling and reporting is required to
meet requirements for each individual permit.
3. By failing to collect samples of the Class A residuals produced from the dryer and report the results as described above in
item #2, the residuals that were distributed during 2019 failed to demonstrate compliance with regulated pollutant limits.
4. There was no data provided in the 2019 Class A report to demonstrate compliance with the pathogen reduction method
nor the vector attraction reduction method selected on the PVRF form (temperature measurement logs and percent solids
results) beyond a single Fecal Coliform result. Requested a completed form and the missing data for 2019.
It should be noted that if the sample results reported for the Class B residuals were to be utilized for Class A pathogen and
vector attraction reduction, those results do not meet the regulatory limits (e.g. residuals sample results reported solids
contents of 1.8% and 1.5%; while the 503 Class A dryer method requires >90% solids content with residuals exiting the
dryer having a temperature of 80' C (176' F) or higher for pathogen reduction, and >75% solids for vector attraction
reduction).
In addition to the violations described above, the following item of concern was also noted:
There was no TCLP results included in the 2019 report for the Class A residuals. Again, the statement included in the report
described above in violation item #2 (i.e. Additional laboratory information for ... TCLP is included in the Class B report) refers
to the 2019 Annual Report for Class B Permit No. WQ0004166 for sampling results. The TCLP test results included for the
Class B program only included results for samples of the liquid Class B residuals from the digester, and no results for the
Class A residuals solids produced from the Dryer. Reminded Permittee that TCLP is required once per permit cycle and if
not completed yet, it must be done before June 30, 2021.
* An onsite follow-up inspection needs to be conducted to review 2020 records for compliance. Technical assistance has
been offered to assist the Permittee with questions related to annual reporting requirements.
Page 2 of 4

Permit: WQ0022155 Owner - Facility: Town of Jefferson
Inspection Date: 05/15/2020 Inspection Type: Annual Report Review
Reason for Visit: Routine
Type
Yes No NA NE
Land Application
❑
Distribution and Marketing
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?
❑
❑ 0 ❑
Are current metals and nutrient analysis available?
❑
0 ❑ ❑
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?
❑
❑ 0 ❑
Are there pH records for alkaline stabilization?
❑
❑ 0 ❑
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: See summa
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 4

Permit: WQ0022155 Owner - Facility: Town of Jefferson
Inspection Date: 05/15/2020 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 ❑ ❑ M ❑
Comment: See summary.
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: See summa
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? ❑ ❑ ❑
Comment:
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