HomeMy WebLinkAboutWQ0004609_Review of 2020 Annual Report_20210610DocuSign Envelope ID: 65812C6C-380B-4D99-B64F-6AC41A03F939
ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
S. DANIEL SMITH
Director
Mr. Cory Early, Plant Superintendent
Wayne Farms, LLC
P.O. Box 383
Dobson, NC 27017
NORTH CAROLINA
Environmental Quality
June 11, 2021
Subject: Review of the 2020 Annual Report
Wayne Farms, LLC — Residuals Land Application Program
Permit No. WQ0004609
Surry County
Dear Mr. Early:
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 Division staff person Patrick Mitchell. Review of the subject report reflects
compliance with the Permit No. WQ0004609. However, please note the following items:
• As a reminder, Permit No. WQ0004609 requires that a TCLP test shall be conducted at
minimum once per permit cycle. The current permit cycle runs from November 25, 2019
until December 31, 2025. The TCLP test results provided in the 2020 Annual Report
were from a sample collected in July 2019, before the current permit cycle. Please ensure
that that at least one TCLP test is performed on residuals by December 31, 2025.
• Permit No. WQ0004609 requires that annual soils analyses shall be conducted each
calendar year for land application fields receiving land application in that year. One of
the required parameters is soil pH. This is required for maintaining appropriate soil pH
in fields to ensure the soils capability to assimilate constituents found in residuals (i.e.,
pH of 6.0) and to maximize crop health for uptake.
The annual soil sampling results for land application site SU-23 Field 1 indicated a soil
pH of 5.6 with an Agronomist recommendation for lime amendment to the field.
However, the 2020 Annual Report indicated no lime was applied to this field. It should
be noted that the Calcium Carbonate Equivalent (CCE) for the lime stabilized residuals
that were land applied to the subject field would have provided lime amendment to the
field as required. Please ensure that lime amendment values or CCE loading values
are reported in future Annual Reports for all fields with a reported soil pH which
includes an Agronomist recommendation for lime amendment.
_11A.,E\T
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: 65812C6C-380B-4D99-B64F-6AC41A03F939
A routine compliance inspection is planned to be scheduled within this inspection year. If you
have any questions regarding this letter, 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,
EDocuSigned by:
.-0A, 'f . Smiler
145B49E225c94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Mr. Jeremey Bowlin — Wayne Farms (Electronic Copy)
Mr. Alex Fox — Synagro (Electronic Copy)
Surry County Environmental Health (Electronic Copy)
Laserfiche File WQ0004609
WSRO Electronic Files
Page 2 of 2
Compliance Inspection Report
Permit: WQ0004609 Effective: 11/25/19 Expiration: 12/31/25 Owner : Wayne Farms LLC
SOC: Effective: Expiration: Facility: Wayne Farms RLAP
County: Surry 802 E Atkins St
Region: Winston-Salem
Contact Person: Guy Hinton
Directions to Facility:
System Classifications: LA,
Primary ORC: Jeremy Elden Bowlin
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Dobson NC 27017
Title: Phone: 770-297-3437
NC0006548 Wayne Farms LLC - Dobson Plant
Certification: 990264 Phone: 336-386-5867
Inspection Date: 06/10/2021 Entry Time 09:OOAM Exit Time: 11:30AM
Primary Inspector: Patrick Mitchell Phone: 336-776-9698
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
II Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Permit: WQ0004609 Owner - Facility: Wayne Farms LLC
Inspection Date: 06/10/2021
Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
On June 10, 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 report reflects compliance with the subject permit. However, the items listed below should
be noted.
1 The subject permit requires a minimum of one TCLP test be conducted on residuals per permit cycle. The TCLP test
results provided in the 2020 annual report were for a sample obtained in July 2019. This is prior to the current permit cycle
beginning (November 25, 2019 through December 31, 2025). Remind Permittee that at least one TCLP test needs to be
conducted by end of this permit cycle (December 31, 2025).
1 The subject permit requires that annual soil sampling be conducted on all land application fields utilized within a given
calendar year. Land application site SU-23 Field 1 was reported with land application. The soil sampling results for this field
indicated a soil pH of 5.6 with an Agronomist recommendation for lime amendment. However, the lime amendment log
provided in the report indicated that no lime amendment (or CCE) was applied to this field.
It should be noted; using an assumed CCE value for the lime stabilized residuals and using the reported dry tons/acre
application rate of the residuals results in an estimated CCE loading near the Agronomist recommendation for lime. Remind
Permittee for future reporting to provide the CCE or lime amendments for all fields utilized with a soil pH less than 6.0 which
have an Agronomist recommendation for lime amendment.
A routine compliance inspection is planned for this inspection year.
hAqikir FARMS1ZOF
QooaY6o9
Annual Report Review SOP Class B Land Application
Reporting Period: 2D20
Permit Details:
• Is 503? t10
• Class A or B? 13
• Maximum Dry Tons Per Year: 60O
Number of acres permitted: tf o. /
• Number of fields in permit: Z(n
• Counties that land is permitted for: `�f xi"
• Monitoring Frequency for TCLP: I/Ie /M ; '1"
• Monitoring Frequency for Residuals Analysis ` t/ 1
• Monitoring Frequency for Pathogen & Vector Attraction Reduction:3
• Groundwater monitoring: NA.
1. Annual Land Application Certificationyorm
• Was a certification form submitted?
• Was land application conducted during the reported year? 1
• How many dry tons and dry tons per acre were applied? ) $V. 89
• Were the applications within the permitted amount? -IEf,
• Verify PAN if more than 10 to/acre? (OA
• Did it indicate compliance? `•—f
• Was it signed by the appropriate people? yEf,
2. Monitoring `�
• Were the analyses conducted at the required frequency? 7 E '
• Was an analyses taken for each source that was land applied? kiES l /
• Were the metals analyses reported on the Residual Sampling Summary Form? '1
• Were the results reported in mg/kg? 1't y,1_
• Were the pH's 6.0 or greater for each residual sample? '1 CS.
• Were the heavy metals within ceiling concentration permit limits?
Were the lab analyses attached? LES, Z1�I
• Were all the required parameters tecon sted? '-1'L �q f %�j ZS
Was• TCLPanalysisducted E--5 b ��' sq
e
Was a corrosivity, ignitability, and reactivity analysis condu
cted? '
Were the TLCP contaminants within regulatory limits? ' '
CGS
CA1(13%.,AP
Te- LP .7:5 014E 8�
I211I/2-oZ5,-
3. Field Summary y�f
• Were all land application events recorded on the FSF and MFLS forms.
• How many fields were applied on this year? �o
• Was a Field Summary Form submitted for each field?
• Was the Regional Office notified prior to each land application event?
• Were all the residuals applied to permitted land? L-(0.
• Were all the residuals applied from permitted sources? yrS. YEA
Were the field loading rates for each metal and PAN calculated (year to date)? l
• Were the cumulative pollutant loading rates calculated? fef,
Were the calculations correct? YES:
Were the PAN loading rates within permit limits? I �s
• Were the heavy metal cumulative pollutant loading rates within permit limits? 7
�E�
al 4rci
L�Meff /6)
g AIJon ell \I
1 V4bv�,1-1''lc?
• Were the residuals applied on a suitable crop? "1 CS `7,�E_ S•
4u,
: fir /� J .✓ t/ �/
• Were the applications conducted during the crop's growing season? •
• Were the Field Summary Forms complete? -h 2.
• Was lime application on Field Summary Form? Ni ai ova a hme, ROP%•�^am'
4. Pathogen and Vector Attraction Reduction 11
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
Class B Pathogen Review
lternative 1 — Fecal Coliform Density
as the sampling conducted at the required frequency?
• W - e seven samples taken?
• Was e geometric mean calculated and done correctly?
• Did th- esults show compliance (less than either 2,000,000 PN/gram of total solids or
2,000,000 olony Forming Units/gram of total solids)?
Alternative 2 Use of Process to Significantly Reduce ' . thogens (one of five)
• Was the sample , g conducted at the required freque y?
1. Aerobic Digestio
• Was it an aerobic process (Inspection)?
• Were logs submitted sowing time and to .erature?
Were temperatures with range for com ' ete time period?
• Was the time and tempera re betwee 40 days at 20°C (68°F) and 60 days at 15°C
(59°F)?
2. Air Drying
- Were the residuals on sand be s or save or unpaved basins for three months?
• Was the ambient temperatu above I °C (32°F) for two months?
Were the residuals partial digested?
- Were residuals exposed o atmosphere du ng two months above 0°C (not snow
covered)?
3. Anaerobic Dige
• Was it an anaer
• Were logs su
• Were tempe
•Was the t
days at 2
on
is process (Inspection)?
fitted showing time and temperature.
atures within range for complete time pen
e and temperature between 15 days at 35°C
°C (68°F)?
9
°F) to 55°C (131°F) and 60
4. C. posting (usually will be Class A when composting is used
W. it a composting procedure (not natural decay under uncontrolleconditions)?
ere logs submitted showing time and temperature?
ee White House Manual for additional requirements.
r 1
fri
5. Lime Stabilization
' Was alkaline material added to residuals a form of lime (hydrated lime, quicklime, lime
containing kiln dust or fly ash)? J' 5. _
• Were logs submitted showing time and temperature? 1 6-S
• Was the pH raised to I d1 after 'er of contact? `{ Ef
• Were logs submitted showing time and pH? `t 61, r,
Was temperature corrected to 25°C (77°F) (by calculation, NOT auto correct)? `�
(Not use. See White ouse Manua pag 1 1 and 11-2.)
.o
Class B Vector Attraction Reduction Review
if-ref#11;)--f-P4.62-
• Was the sampling conducted at the required frequency? C
/
tion 1 — 38% Volatile Solids Reduction
as there 38% reduction?
• W : e lab sheets/calculations in report?
• W • the reduction on volatile solids (not total •lids)?
• Were e samples taken at beginning of dige ion process and before application
(Inspect) 3 n)?
• Were ca ulations correct?
Option 2 — 4 1 Day Bench Scale Test
• Were residua from anaerobically di - sted treatment (Inspection)?
• Was average to .erature of the P digester between 30°C (86°F) — 40°C (104°F)?
• Were residuals an: erobically dige ed in lab?
Was the test run fo - 0 days?
- Was the lab bench-sce test do • e between 30°C (86°F) and 37°C (99°F)?
Was the reduction of o volat' e solids (not total solids)?
• Was the reduction less th: %?
Were lab sheets/calculatio .. in report?
• Were calculations correct
Option 3 — 30-Day BencScale T. t
• Were residuals from . robicaIly did -sted treatment (Inspection)?
• Were residuals aero • cally digested lab?
• Were residuals 2% .r less total solids?
If not 2% total so ds, was the test ran on
effluent?
- Was the test ru for 30 days?
- Was the test .. ne at 20°C (68°F)?
- Was the red ction of on volatile solids (not total s. ids)?
• Was the re uction less than 15%?
• Were lab heets/calculations in report?
• Were c. culations correct?
ample diluted to 2% with unchlorinated
Optio 4 — Specific Oxygen Uptake Rate(SOUR)
• W re residuals form aerobically digested treatment (Inspection
ere residuals 2% or less total solids (dry weight basis) (not dilu
Was the test done between 10°C (50°F) and 30°C (86°F)?
Was the temperature corrected to 20°C (68°F)?
54 -2 3, F-)
L,Me teraW
,,t� 6.General , ,I ,
�, 0 -F/i+� Was the report in the proper format?, 'T4 e/e1
+ no GCE-14 He • Was the annual report complete? 7 111 } 1� rrt
Option 9 — Injectio
• Was there any gnificant amount of residu
(Inspection)?
• Was inj - ion done on pasture or hay field?
- Was jection done at time that crop was growing?
• I lass A with respect to pathogen, were residuals injected with ei
ischarge from pathogen treatment?
on land surface one hour after injection
hours after
• Was the appro�pf iate documentation to show pathogen and vector attraction reduction included
in the report? 7 P i Cf,n44.‘.
• Was pathogen and vector attraction reduction demonstrated according
5. Soil Tests 1 ,
- Was a Standard Soil Fertility Analysis condu ed for each application field? `7 d
- Were all the required parameters reported? 'Ff. oy? y y i� •
• Were the soil pH's 6.0 or greater for each application field? jJ 0 L u �"edA
°`
the SOUR equal to or Tess than 1.5 mg of oxygen per hour per gram of total
residua . s lids (dry weight basis)?
• Was the s • : ' : holding time two hours?
• Was the test starte• ' hin 15 minutes of sampl'• _ .r aeration maintained?
Option 5 — 14-Day Aerobic Proc Were the residuals from a- . ,wally di_ - •d treatment (Inspection)?
Were the residual . ted for 14 days?
• Was the rye als temperature higher than 40°C (10
• Was-ttfe average residuals temperature higher than 45°C (
* Option 6 — Alkaline Stabilization
• Was the pH of the residuals raised to 1. or higher by the addition of alkali?
• Did the pH ofresiduals remain at 119or higher for without the addition of
more alkali? ' •3 MM
• Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? `71E5„
tion 7 — Drying of Stabilized Residuals
• Do; the residuals contain any unstabilized
• Were residuals mixed with any other
• Were the r 'duals dried up to 75% to
Option 8 — Drying o
Were the residuals mixe
Were the residuals drie
stabiliz
• .•IP
duals?
terials?
solids?
' esiduals
any other materials?
total solids?
•
to 67
- If no, was lime applied to those fields if recommended by the Agronomist? `1 - c-c • ��
- Were the copper and zinc indexes in the soil less than 2000 for each application field? 'rr s
dium less than 0.5 and exchan
•
fora 14-day period?
?
• Was so meq,
- Was the report submitted on time? Y�5,
geable sodium percentage (ESP) less than 15%? Lj