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Home My WebLink AboutWQ0022155_CEI_20210322ROY COOPER Governor DIONNE DELLI-CATTI Secretary S. DANIEL SMITH Director Ms. Cathy Howell, Town Manager Town of Jefferson P.O. Box 67 Jefferson, North Carolina 28640 NORTH CAROLINA Environanentaf Quality March 22, 2021 SUBJECT: Compliance Evaluation Inspection Town of Jefferson, Distribution of Class A Residuals Programs Permit No. WQ0022155 Ashe County Dear Ms. Howell: On March 11, 2021 Division of Water Resources staff person Caitlin Caudle completed a scheduled compliance and permitting inspection. The facility was found to be compliant with the subject permit. Please review the enclosed inspection report for additional comments. If you or your staff have any questions regarding this letter, please contact Caitlin Caudle or me at the letterhead address or phone number, or by email at caitlin.caudle(a)ncdenr.gov or Ion.snider(a-)ncdern.gov. Sincerely, DocuSigned by: OD2D3CE3F187456... for Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO enc: Inspection Report cc: Tim Church, Water Resources Director (leffwns6a�centurylink. net) Ashe County Environmental Health (tonya.hartsog6a�apphealth.com, and rew.blethen a( apphealth.com) Laserfiche Files WSRO Electronic Files D E Q North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CARoiiNA Oepeftead of FiMrmon "Quay 336.776.9800 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: Tim Church Title: Water Resources Director Phone: 336-246-2165 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: 03/11/2021 Entry Time 09:OOAM Primary Inspector: Caitlin Caudle Secondary Inspector(s): Exit Time: 10:15AM Phone: 336-776-9699 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Sampling Land Application Site Storage (See attachment summary) Treatment Pathogen and Vector Attraction Page 1 of 5 Permit: WQ0022155 Owner - Facility: Town of Jefferson Inspection Date: 03/11/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On March 11, 2021 DWR staff person Caitlin Caudle completed a scheduled compliance inspection and permitting site visit Mr. Tim Church of the Town of Jefferson was present during the entire inspection. The facility was compliant with the subject permit. At this time all Class A material is being applied to the Bower Walters site, which was removed from the Class B permit during the last renewal. Ms. Caudle asked that a field summary form be kept for this location to ensure there is no over -application of PAN. In 2020 4.5 dry tons of Class A material were distributed to Fred Walters. There is no concern for overapplication. Mr. Walters has been the only recipient of residuals since the last inspection in 2019. Mr. Walters does not have an inspection log before applying to the Bower site, but Mr. Church states that Mr. Walters does inspect the location before applying. An inspection log was not available containing facility inspections, maintenance, and repairs. Mr. Church stated the Class A facility requires little maintenance and a standard start up procedure is used, as well as a standard troubleshooting procedure. Ms. Caudle recommended that multiple fecal samples be collected to better represent Class A material produced throughout the year. Samples are collected from the spreader truck as Class A material is loaded. The Class A and Class B permit are still being sampled separately. Currently an ice spreader truck is being borrowed from the Town's maintenance department to spread the Class A material. Mr. Church stated that the spreader is cleaned before and after use. The manufacturer provided a narrative for the dehydrator that stated it satisfies Alternative 1. Phoenix #EC3315 polymer is added to the sludge to dewater the sludge before drying. Part of the Bower site was reviewed during this visit. The last application was March 5, 2021. The Class A material was not visible, but the site was in good condition. Mr. Church stated that the operation and maintenance plan, spill plan, and residuals management plan were still up to date. The permit description is still up to date. A single line will be used on the "Tracking Record" form for each individual batch. Page 2 of 5 Permit: WQ0022155 Owner - Facility: Town of Jefferson Inspection Date: 03/11/2021 Inspection Type: Compliance Evaluation 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: 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: WQ0022155 Owner - Facility: Town of Jefferson Inspection Date: 03/11/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine e. Time/Temp on: 0 ❑ ❑ ❑ Digester (MCRT) Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations ❑ ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ❑ ❑ 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: residuals are heated and dried Sampling Yes No NA NE Describe sampling: Samples are collected at the end of the process when Class A material enters the spreader truck Is sampling adequate? 0 ❑ ❑ ❑ Is sampling representative? ❑ 0 ❑ ❑ Comment: At this time only one fecal sample is being collected. Ms. Caudle recommended collecting more samples throughout the year to accurately represent all material applied. Land Application Site Yes No NA NE Is a copy of the permit on -site during application events? 0 ❑ ❑ ❑ 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? Page 4 of 5 Permit: WQ0022155 Owner - Facility: Town of Jefferson Inspection Date: 03/11/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine For injection? ❑ ❑ 0 ❑ For incorporation? ❑ ❑ 0 ❑ Does permit require monitoring wells? ❑ 0 ❑ ❑ Have required MWs been installed? ❑ ❑ 0 ❑ Are MWs properly located w/ respect to RB and CB? ❑ ❑ 0 ❑ Are MWs properly constructed (including screened interval)? ❑ ❑ 0 ❑ Is the surrounding area served by public water? ❑ ❑ 0 ❑ If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ 0 ❑ Are soil types consistent w/ Soil Scientist report/evaluation? 0 ❑ ❑ ❑ Is the water table greater than 173' bls. 0 ❑ ❑ ❑ Is application occurring at the time of the inspection? ❑ 0 ❑ ❑ Comment: The facility is currently borrowing a truck with a salt spreader from the maintenance department to apply Class A material. Page 5 of 5