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Home My WebLink AboutWQ0037135_NOV-2021-PC-0291 & 2020 Annual Report Review_20210518DocuSign Envelope ID: 1993A821-3CD2-423B-914A-022145E5093F ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality May 18, 2021 CERTIFIED MAIL 7018 1130 0000 1612 5358 RETURN RECEIPT REQUESTED Mr. Zach Key, President US Biosolids, Inc. 958 Hoots Road Roaring River, NC 28669-9148 Subject: Notice of Violation (NOV-2021-PC-0291) Review of the 2020 Annual Report US Biosolids, Residuals Land Application Program Permit No. WQ0037135 Wilkes County Dear Mr. Key: Staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (Division) has completed a review of the 2020 Annual Report for the subject facility. This review was completed by DWR staff person Patrick Mitchell. Review of the subject report reflects noncompliance with Permit No. WQ0037135. The violations listed below warrant your attention and action. 1. The 2020 annual report did not include the required Annual Pathogen & Vector Attraction Reduction forms (PVRF) for three of the residuals source facilities (i.e., Yadkin Valley Sewer Authority WWTP, Town of North Wilkesboro WWTP, and the City of Belmont WWTP). As a result, the following required information was also not provided for these source facilities: • Monitoring period(s) of coverage, • Class B pathogen alternative utilized, • Fecal Coliform sampling info, if applicable (minimum, maximum, geometric mean, etc.), • Class B vector attraction reduction option utilized, • Annual certification and signatures. This represents violations of Permit Conditions IV.4. and IV.8. As a result, the Division was unable to determine compliance with Permit Conditions 11.6. and 11.7. Please provide properly completed PVRF forms for Yadkin Valley Sewer Authority WWTP, the Town of North Wilkesboro WWTP, and the City of Belmont WWTP to this office within 10 days of receipt of this Notice. 2. It appears that vector attraction reduction "Option 3", the 30-Day Bench Scale Test, was utilized to meet vector attraction reduction requirements for the three source facilities _1121,..„E\93 North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 336.776.9800 DocuSign Envelope ID: 1993A821-3CD2-423B-914A-022145E5093F described above, which were missing the PVRF forms. However, the information provided in the 2020 annual report was not sufficient for determining compliance with this vector attraction reduction method. Documentation of the 30-day test period (e.g., daily/weekly logs with required measurements), and the calculation method utilized along with calculations need to be provided for all three of these source facilities. It should be noted that this is a repeat item that was also included in a NOD issued following review of the 2019 annual report. Please provide this office the additional information required for determining compliance with 30-day bench scale tests for Yadkin Valley Sewer Authority WWTP, the Town of North Wilkesboro WWTP, and the City of Belmont WWTP within 10 days of receipt of this Notice. In addition to the violations described above, the following item of concern was also noted during review: • The Annual Land Application Field Summary forms (FSF) included in the annual report failed to indicate if Fescue crops were utilized for hay harvest or if it was utilized as grazed pasture. As a reminder, grazed pasture fields must take a 25% reduction in the Plant Available Nitrogen (PAN) loading limit. Please ensure that all future annual reports indicated if Fescue crops are hay or pasture and report the associated PAN limit on the FSF reporting forms. Failure to use the appropriate PAN limits could result in exceeding agronomic loading for fields. A routine compliance inspection is planned to be scheduled within this inspection year. As a reminder, Permit Condition III.3. requires that the regional office shall be notified prior to land application events. The Division request that you please notify the appropriate regional office in which land application events will be occurring prior to these events. The Division appreciates your attention to the above -mentioned violations and item of concern. Please be aware that failure to properly address these items may result in further enforcement actions. Please refer to the enclosed compliance inspection report form for additional observations and comments. If you have any questions regarding this Notice, please contact Patrick Mitchell or me at the letterhead phone number or address, or by email at patrick.mitchell@ncdenr.gov or lon.snider@ncdenr.gov. Sincerely, DocuSigned by: `OD C 3F96 456... Lon '1R.3S maer, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO enc: Compliance Inspection Report cc: Wilkes County Environmental Health (Electronic Copy) ARO (Electronic Copy) MRO (Electronic Copy) Laserfiche File WQ0037135 WSRO Electronic Files Page 2 of 2 Compliance Inspection Report Permit: WQ0037135 Effective: 07/23/20 SOC: Effective: County: Wilkes Region: Winston-Salem Contact Person: Zachery Key Directions to Facility: System Classifications: LA, Primary ORC: Zach D Key Secondary ORC(s): On -Site Representative(s): Related Permits: NC0006564 NC0025909 NC0020761 NC0025984 N C0021181 NC0020567 NC0020664 Expiration: 09/30/24 Expiration: Owner : U S Biosolids Inc Facility: U.S. Biosolids RLAP 397 Riverside Dr Forest City NC 28043 Title: President Phone: 336-957-7871 Certification: 27660 Phone: 336-957-7871 Baxter Healthcare Corporation - Baxter Healthcare Corporation Town of Rutherfordton - Rutherfordton WWTP Town of North Wilkesboro - Thurman Street WWTP Town of Forest City - Forest City WWTP City of Belmont - Belmont WWTP Yadkin Valley Sewer Authority - Yadkin Valley Sewer Authority WWTP Town of Spindale - Spindale WWTP Inspection Date: 05/18/2021 Primary Inspector: Patrick Mitchell Secondary Inspector(s): Entry Time 08:OOAM Exit Time: 11:OOAM Phone: 336-776-9698 Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: E Compliant Not Compliant Question Areas: Miscellaneous Questions (See attachment summary) Record Keeping Pathogen and Vector Attraction Page 1 of 4 Permit: WQ0037135 Owner - Facility: U S Biosolids Inc Inspection Date: 05/18/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: On May 18, 2021, WSRO staff conducted a review of the subject facility's 2020 Annual Report. No site visit was made as part of this inspection event. The annual report was found to be noncompliant with Permit No. WQ0037135. The violations listed below were noted during review. 1. Annual Pathogen & Vector Attraction Reduction forms (PVRF) were not submitted for three of the residuals source facilities that reported land application in 2020. Yadkin Valley Sewer Authority WWTP, Town of North Wilkesboro WWTP, and the City of Belmont WWTP were all missing PVRF forms. As a result, the following required information was not provided for these source facilities: • Monitoring period(s) of coverage, • Class B pathogen alternative utilized, • Fecal Coliform sampling info, if applicable (minimum, maximum, geometric mean, etc.) • Class B vector attraction reduction option utilized, • Annual certification and signatures. Request the missing PVRF forms with required information be provided to the Division. 2. Option 3 (30-Day Bench Scale Test) was utilized for three of the source facilities with PVRF forms provided. It appears that the 30-day bench scale test was also utilized for the three source facilities that did not provide PVRF forms. However, the information provided from the testing lab for these three facilities as related to the 30-day bench scale test results was insufficient to determine compliance with this 503 vector attraction reduction option. This is a repeat item that was also noted in an NOD issued following review of the 2019 annual report. Request additional information for 30-day bench scale test (30-day logs with measurements, calculation method, etc.) for Yadkin Valley Sewer Authority WWTP, Town of North Wilkesboro WWTP, and the City of Belmont WWTP be provided to the Division. In addition to the violations described above, the following item of concern was also noted during review: • The Annual Land Application Field Summary forms (FSF) which indicated Fescue as the crop did not provide if the crop was utilized for hay harvest or if it was utilized for a grazed pasture. Grazed pasture fields must take a 25% reduction in the PAN loading limit. Request that all future annual reports provide hay or pasture for Fescue crops with the associated PAN limit on reporting form FSF. Failure to use the appropriate PAN limits could result in exceeding agronomic loading for fields. OTHER NOTES: - Remind Permittee of regional office notifications prior to land application events requirement Request Permittee notify the regional office in which the planned activities for a given event are to occur. - There was a total of 32 soil sample results provided in the annual report for permitted fields. While there was only 22 fields reported as receiving land application during 2020. Requested an explanation via email to ensure no additional fields were utilized for land application without reporting. Response indicated sampling was conducted just in case fields would be utilized and as a service to the landowners in the program. A routine onsite compliance inspection is planned for this year. Page 2 of 4 Permit: WQ0037135 Owner - Facility: U S Biosolids Inc Inspection Date: 05/18/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Type Distribution and Marketing Land Application Record Keeping Is GW monitoring being conducted, if required? Are GW samples from all MWs sampled for all required parameters? Are there any GW quality violations? Is GW-59A certification form completed for facility? Is a copy of current permit on -site? Are current metals and nutrient analysis available? Are nutrient and metal loading calculating most limiting parameters? a. TCLP analysis? b. SSFA (Standard Soil Fertility Analysis)? Are PAN balances being maintained? Are PAN balances within permit limits? Has land application equipment been calibrated? Are there pH records for alkaline stabilization? Are there pH records for the land application site? Are nutrient/crop removal practices in place? Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? Are hauling records maintained and up-to-date? # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? Comment: See summary. Pathogen and Vector Attraction 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) Yes No NA NE El • Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ▪ ❑ ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ • ❑ Page 3 of 4 Permit: WQ0037135 Owner - Facility: U S Biosolids Inc Inspection Date: 05/18/2021 Inspection Type : Annual Report Review Reason for Visit: Routine e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench -top Aerobic/Anaerobic digestion results Comment: No PVRF forms for 3 sources and missing info on 30-Day test results. Page 4 of 4