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Home My WebLink AboutWQ0016247_CEI_20210712 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 12, 2021 Alex Fox Email: afox@synagro.com Synagro Central LLC SUBJECT: Compliance Inspection Report Synagro Western Piedmont RLAP Non-discharge Permit No. WQ0016247 Alexander County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Synagro Western Piedmont RLAP on 6/23/2021. This field inspection was conducted to verify that the land application activities for the residual source facility Columbus WWTP (NC0021369) were compliant with the conditions and limitations specified in Non-discharge Permit No. WQ0016247. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact me at 828-296-4686 or via email at mikal.willmer@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Compliance Inspection Report Permit:WQ0016247 Effective:06/01/21 Expiration:10/31/22 Owner :Synagro Central LLC SOC: Contact Person: Region: County: Directions to Facility: Alexander Mooresville Alex Fox Effective:Expiration:Facility:Synagro Western Piedmont RLAP 284 Boger Rd Mocksville NC 27028 Title:Phone:336-703-8681 Secondary ORC(s): Phone:Certification:Primary ORC: LA,System Classifications: On-Site Representative(s): Related Permits: NC0020591 City of Statesville - Third Creek WWTP NC0043532 Stanly County - West Stanly WWTP NC0031836 City of Statesville - Fourth Creek WWTP NC0088722 Lincoln County - Killian Creek WWTP NC0021890 Town of Granite Falls - Granite Falls WWTP NC0021369 Town of Columbus - Columbus WWTP NC0021628 Town of Norwood - Norwood WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 06/23/2021 10:20AM 12:30PM Mikal Willmer 828-296-4686 Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Land Application of Residual Solids (503) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Land Application Site Pathogen and Vector Attraction Transport (See attachment summary) Page 1 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0016247 06/23/2021 Compliance Evaluation Synagro Central LLC Routine Inspection Summary: Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Synagro's land application activities for the Residual Source Facility, Columbus WWTP (NC0021369). This inspection was conducted to determine whether land application activities are being operated and maintained in compliance with RLAP Permit No. WQ0016247. Alex Fox (Synagro) and Chris Cochran (Town of Columbus) were present at the time of the inspection. The rain gauge was documented on site and the area received less than 0.1” in the preceding 24 hours. There did not appear to be any ponding or pooling of applied residuals on the permitted application site (NC-PO-07-2). Buffers appeared to be adequately flagged and signs were posted upon entry to the field. Mr. Fox reported there were no known changes to the surrounding property (new wells, homes etc.). Synagro’s pre-operating checklist was complete and indicated no additional nitrogen sources were applied to the field. Maintenance logs are retained in the vehicles. TCLP, non-hazardous waste characterization, nutrient, metals and Pathogen and Vector Attraction results were reviewed after the inspection. The residuals appeared to be within regulatory limits for the non-hazardous waste characterization. Columbus utilizes process to significantly reduce pathogens (PSRP) lime stabilization and vector attraction reduction is met using alkaline stabilization. Calcium hydroxide records maintained by the Residuals Source Facility were reviewed and complete. Columbus WWTP- A mobile loading station was utilized to load residuals from the digester to the hauling trucks. Three trucks were used on the day of the inspection. No issues or spills noted near the loading area. The WWTP ORC was onsite and manually operated the pump between loads. At the time of my site visit, the ORC had recorded approximately 14 truckloads and an estimated 24 truckloads were scheduled to be applied to field NC-PO-07-2. Page 2 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0016247 06/23/2021 Compliance Evaluation Synagro Central LLC Routine Type Yes No NA NE Distribution and Marketing Land Application Record Keeping Yes No NA NE 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? Field NC-PO-07-2 was being applied to at the time of the inspection. Synagro was awaiting final soil fertility analysis results at the time of the inspection. Calcium hydroxide records were reviewed. See summary for details. Comment: Pathogen and Vector Attraction Yes No NA NE 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) Page 3 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0016247 06/23/2021 Compliance Evaluation Synagro Central LLC Routine Temperature corrected d. Salmonella (Class A, all test must be < 3MPN/4 gram day) e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench-top Aerobic/Anaerobic digestion results Columbus utilizes the process to significantly reduce pathogens (PSRP) Lime stabilization and Vector attraction reduction is met through alkaline stabilization. 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: Transport Yes No NA NE Is a copy of the permit in the transport vehicle? Is a copy of the spill control plan in the vehicle? Is the spill control plan satisfactory? Does transport vehicle appear to be maintained? Mr. Fox indicated the O&M and Spill Control plans are provided digitally and updated copies were supplied with the most recent modification. Hard copies are retained in vehicles. Comment: Land Application Site Yes No NA NE Is a copy of the permit on-site during application events? 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 Page 4 of 5 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0016247 06/23/2021 Compliance Evaluation Synagro Central LLC Routine Are there access restrictions and/or signs? Is the application site free of odors or vectors? Have performance requirements for application method been met? For injection? For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 1'/3' bls. Is application occurring at the time of the inspection? Both the spreader and three hauling trucks onsite on June 23 appeared to be well-maintained. Mr. Fox indicated the spreader is calibrated annually. See summary for details. Comment: Page 5 of 5 Certificate Of Completion Envelope Id: 9357D67BAFA5493797476BAA4E077C03 Status: Completed Subject: Please DocuSign: WQ0016247_CEI_20210712.ltr.docx, WQ0016247_CEI_20210712.pdf Source Envelope: Document Pages: 6 Signatures: 1 Envelope Originator: Certificate Pages: 1 Initials: 1 Mikal Willmer AutoNav: Disabled EnvelopeId Stamping: Disabled Time Zone: (UTC-05:00) Eastern Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Mikal.willmer@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original Jul 12, 2021 | 09:40 Holder: Mikal Willmer Mikal.willmer@ncdenr.gov Location: DocuSign Security Appliance Status: Connected Pool: StateLocal Storage Appliance Status: Connected Pool: North Carolina Department of Environmental Quality Location: DocuSign Signer Events Signature Timestamp Mikal Willmer Mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: Jul 12, 2021 | 09:42 Viewed: Jul 12, 2021 | 09:42 Signed: Jul 12, 2021 | 09:42 Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Witness Events Signature Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted Jul 12, 2021 | 09:42 Certified Delivered Security Checked Jul 12, 2021 | 09:42 Signing Complete Security Checked Jul 12, 2021 | 09:42 Completed Security Checked Jul 12, 2021 | 09:42 Payment Events Status Timestamps