WQ0022155_WQ0022155 Response to 2019 ARR NOV_20200708

Town of Jefferson Wat"e rr 2e40U rCe4-
1233 Highway 16 South P.O. Box 67 Jefferson, NC 28640 336.246.2165
"Prate, wuWthe,New9iverBasiW
Cathy KoweU, Town Manager Tim Church, Director
July 2, 2020
NC Dept. of Environmental Quality
Division of Water Resources N C Department of
450 West Hanes Mill Road, Suite 300 Environmental Quality
Winston-Salem, NC 27105 Received
ATTN: Mr. Lon T. Snider, Regional Supervisor
JUL 0 8 2020
Subject: Notice of Violation (NOV-2020-PC-0251 Winston-Salem
Town of Jefferson Class A Residuals Annual Report, 2019 Regional Office
Permit No. WQ0022155
Dear Mr. Snider:
Please find included herein the Town of Jefferson's response to incomplete items found by Mr. Patrick
Mitchell in the 2019 Class A Residuals Annual Report.
1. The Annual Distribution & Marketing Certification form has been revised to include recipient's
information in Part B of the form.
2. The Residual Sampling Summary Form (RSSF) includes the results for % Total Solids
demonstrating compliance with Vector Attraction Reduction requirements.
3. A narrative has been included to confirm that in the future the Town will be sampling Class A dry
residuals and Class B liquid residuals separately for reporting purposes. The Class A and Class B
residuals have been sampled separately in 2020 as per the requirements of the individual
permits. The sample reports for Class B have been received and we are awaiting the results for
the Class A residual samples.
4. The Annual Pathogen and Vector Attraction Reduction (PVRF) form has been revised to
demonstrate compliance with pathogen and vector attraction reduction requirements. The
temperature and drying time log for the sludge dryer has also been included along with the
manufacturers' bulletin, Class A Compliance Under the 503 Rules.
A. The TCLP sampling for Class A Residuals has been completed in 2020.
If you have questions or require additional information regarding this matter please call me at (336)
246-2165 or contact me by email at [e-mail]. Thank you for your assistance with the
Town of Jefferson WWTP Residuals programs.
Respectfully,
-'
Ttnv UAJ-
Tim Church, Water Resources Director
Town of Jefferson
[e-mail]

ANNUAL LAND APPLICATION CERTIFICATION FORM C&S / t
WQ Permit#: W00022155 County:
Facility Name (as shown on permit):
Land Application Operator:
Ashe Year:
Town of Jefferson
Tim Church
Phone:
Land application of residuals as allowed by the permit occurred during the past calendar year?
d Yes Ll No - If No, skip Part A, and Part B and proceed to Part C. Also, If residuals were
generated but not land applied, please attach an explanation on how the residuals were handled.
Part A - Residuals Application Summary:
2019
Received
;L U 8 2G20
Winston-Salem
Total number of application fields in the eermit.1 rpglonal Office
Total number of fields utilized for land application during the year_ na
Total amount of dry tons applied during the year for all application sites: 9.2
Total number of acres utilizes for land application during the year na
Part B - Annual Comniance Statement:
Facility was compliant during calendar year 2019 with all conditions of the land application permit
(including bill not limited to items 1-13 below) issued by the Division of Water Resources. Z Yes J No
If no please, provide a written description why the facility was not compliant, the dates, and explain corrective action
taken.
1) Only residuals approved for this permit were applied to the permitted sites.
2) Soil pH was adjusted as specified in the permit and lime was applied (if needed) to achieve a soil pH of at least 6.0 or the
limit specified in the permit.
3) Annual soils analysis were performed on each site receiving residuals during the past calendar year and three (3) copies of
laboratory results are attached.
4) Annual TCLP analysis (if required) was performed and three (3) copies of certified laboratory results are attached.
5) All other monitoring was performed in accordance with the permit and reported during the year as required and three (3)
copies of certified laboratory results are attached.
6) The facility did not exceed any of the Pollutant Concentration Limits in 15A NCAC 02T .I 105(a) or the Pollutant Loading
Rates in 15A NCAC 02T .I 105(b) (applicable to 40 CFR Part 503 regulated facilities).
7) All general requirements in as specified in the Land Application Permit were complied with (applicable to 40 CFR Part 503
regulated facilities).
8) All monitoring and reporting requirements in 15A NCAC 02T .I 11 1 were complied with (applicable to 40 CFR Part 503
regulated facilities).
9) All operations and maintenance requirements in the permit were complied with or, in the case of a deviation, prior
authorization was received from the Division of Water Resources,
10) No contravention of Ground Water Quality Standards occurred at a monitoring well or explanations of violations are
attached to include appropriate actions and remediations.
I I ) Vegetative cover was maintained and proper crop management was performed on each site receing residuals, as specified in
the permit.
12) No runoff of residuals from the application sites onto adjacent property or nearby surface waters has occurred.
13) All buffer requirements as specified on the permit were maintained during each application of residuals,
Part C - Certification:
"1 certify, under penalty of law, that the above information is, to the best of my knowledge and belief, true, accurate, and
complete. 1 ant aware that there are significant penalties for submitting false information, including the possibility of
roes and imprisonment for knowing violations."
Tim Church, Water Resources Director
Pennittee Name and Title (type or print)
'L P�WJ� Z115126'?L
Signature of Permittee Date
Signature of Preparer*
Date Signature of Land Applier
Date
(if different from Pennittee) (if different from Permittee and Preparer)
* Preparer is defined in 40 CFR Part 503.9 (r) and 15A NCAC 02T .1 102 (26) ncnio cnotA A rr 14nlnnn�'

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The %Total Solids analysis on this RSSF was performed on the Class A dry residuals. However,
as has been previously discussed, sampling has been typically performed on the Class B liquid
residuals and those results also applied to the Class A dry residuals since both residuals are
generated from the same source. Therefore the remainder of the results appearing on the
RSSF are from the liquid residuals.
It is now understood that separate sampling will be required on both the Class A and Class B
products. To that end, samples of the Class A dry residuals have been collected in 2020 and
sent to the laboratory to be analyzed for each of the parameters required under the Class A
permit, including TCLP. Sample results for the Class B residuals for 2020 have been completed
and received by the town. D /

ANNUAL PATHOGEN AND VECTOR ATTRACTION REDUCTION FORM (503 Rules)
Facility Name: Town of Jefferson WWTP
WWTPName: Jefferson WWTP
WQ Permit Number: W00022155
NPDES Number: NCO021709
Monitoring Period: From 1/1/2019 To 12/31/2019
Pathogen Reduction (40 CFR 503.32) - Please indicate level achieved and alternative performed:
Class A:
Alternative 1 ❑
Alternative 2 ❑
Alternative 3 ❑
............... .. .
Alternative 4 ❑
Alternative 5 Rl
Alternative 6 ❑
If applicable to alternative performed (Class A only) indicate "Process to Further Reduce Pathogens":
Compost ❑
Heat Drying ❑
Heat Treatment ❑
Therniophilic ❑
Beta Ray ❑
Ganrrna Ray ❑
Pasteurization ❑
Class B:
Alternative 1 ❑
Alternative 2 ❑
If applicable to alternative performed ((:lass B only) indicate "Process to Significantly Reduce Pathogens":
Lime Stabilization ❑
Air Drying❑
Composting ❑
jAcrobic Digestion ❑
Anaerobic Digestion ❑
...............
If applicable to alternative performed (Class A or Class B) complete the following
monitoring data:
Parameter
Allowable Level
inSludge
Pathogen Density
NUmber or
Excee-
Frequency
of Analysis
Sample
Type
na ytica
Tech-
nioue
Minimu
Geo.MeanMaximu
Units
Fecal Coliform
2 x 10 to the
6[h power
per gram of
total solids
MPN
19
19
19
mpn
0
1
Grab
M-9222L
CFU
1000 mpn per gram
of total solid (dry
weight)
Salmonella bacteria
(in lieu of fecal
coliform)
3 MPN per 4 grams
total solid (dry
weight)
Vector Attraction Reduction (40 CFR 503.33) - Please indicate option performed:
AR.1 (VS reduction) ❑
Alt. 2 (40-day bench) ❑
alr. 3 (30-day bench) ❑
lAlt. 4 (Spec. Or uptake) ❑
Alt. 5 (14-Day Aerobic) ❑ jAlt.
6 (Alk. Stabilization ❑
Alt 7 (Drying - Stable) Rl
lAlt. 8 (Drying - Unstable) ❑
Alt. 9 (Injection) ❑
lAlt. 10 (Incorporation) ❑
INo vector attraction reduction alternatives were performed ❑
CERTIFICATION STATEMENT (please check the appropriate statement)
❑ "I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector
attraction reduction requirement in 40 CFR 503.33 have been met."
❑ "I certify, under penalty of law, that the pathogen requirements in 40 CFR 503.32 and the vector
attraction reduction requirement in 40 CFR 503.33 have not been met." (Please note if you check
this statement attach an explanation why you have not met one or both of the requirements.)
"This determination has been made under my direction and supervision in accordance with the system
designed to ensure that qualified personnel properly gather and evaluate the information used to determine
that the pathogen and vector attraction reduction requirements have been met. I am aware that there are
significant penalties for false certification including tine and imprisonment."
Tim Church , Dlrecr
Preparer Name and Title (type or print)
Signature of Preparer* Date
Applier Name and Title (if applicable)(type or print)
Signature of Land Applier (if applicable)
*Preparer is defined in 40 CFR Par 503.9(r) and 15A NCAC 2T .1102 (26)
Date
DENR FORM PVRF 503 (12/2006)

Class A Dry Biosolids Production Record
Pathogen Reduction Alternative I
DATE
"Thermal Fluid
Temperature F
Discharge
Temperature F
Drying Timc, hrs.
(includes fill time)
N of batches
made today
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Fenton Environmental Technologies, Inc.
RK Series Municipal Biosolids Dehydrator,
1(800)777-1371
Class A Compliance Under the 503 Rules
The SludgeMASTER RK series automatic batch style biosolids dehydrator is uniquely suited to
insure compliance with the 40 CFR 503 regulations pertaining to achieving Class "A" biosolids.
The RK dehydration chamber is loaded automatically with a predetermined amount of dewatered
biosolids which starts the batch cycle.
The total sludge load is subjected to a minimum temperature of 212 degrees F for a minimum of
two and one-half hours which exceeds the time and temperature requirements of the 503
regulations pertaining to pa how rreedu ion, This compliancb is shown as follows using Regime
A under Alternative I which requires that solids be heated at 50 degrees C or higher for 20
minutes or longer.
Time (in days) = 131,700,000
10^ 0.14 (temperature) Qr, for the RK dehydrator at 212 degrees F (=100 C)
Time= 131.700.000 gr Time= 131,700.000 gr Time = less than 1.3/10^6 day.
10^ 0.14(100) 101\14
The time required in the RK for pathogen reduction would be less than 1 minute. Therefore, the
minimum time requirement of 20 minutes specified in the 503 Rules must be followed. Following
the 20-minute requirement, the RK dehydrator exceeds the time requirement by about 700%.
Total cycle time is determined by achieving the desired sludge dryness. We normally recommend a
minimum of 90 % dry solids for a finished product to qualify under 503.33 "Option-8" regarding
-k vector attraction reduction. (Fully digested sludges need be dried to 75%- 503.33 "Option r.)
The SludgeMASTER RK patented process automatically adjusts the time and temperature regime
for the varying incoming wet sludge solids content. This feature is very important since dewatering
operations will vary from time to time in solids consistency yet we must maintain consistent Class
A biosolids at all times. Convelrsely, automatic flow through systems cannot adjust to varying
conditions without disrupting their normal operation and compromising the finished Product
Class "A" parameters.
Please refer to 40 CFR 503.32 Pathogens - (a) (3) (i) (9) for pathogen reduction requirements and
to 40 CFR 503.33 (b) (7) and (8) for vector attraction reduction requirements.
Fenton Environmental Technologies, Inc. guarantees Class A compliance on a continued basis
with each SludgeMASTER RK Dehydration System
In choosing Class A biosolids thermal dehydration utilizing Sludge"TER RK technology, your
utility will be assured of an environmentally correct sludge; handling solution for many years in the
future.