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HomeMy WebLinkAboutWQ0016247_Report of Non Discharge RLAP Inspection_20211209ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality December 9, 2021 Mr. Jamie Whitten Suez 2625 Neudorf Road Clemmons, North Carolina 27012 Subject: Compliance Evaluation Inspection Town of Mayodan, Residuals Land Application Program Permit No. WQ0016247 Rockingham County Dear Mr. Whitten: On November 16, 2021 staff of the North Carolina Division of Water Resources Winston- Salem Regional Office (DWR) performed an announced routine compliance inspection of the Town of Mayodan's residuals land application program. This inspection was conducted by DWR staff member Jim Gonsiewski. Mr. Ryan Copeland of Synagro was present during this inspection. The inspection reflects compliance with the permit. Please refer to the enclosed inspection report for additional observations and comments. If you have any questions regarding this letter, please contact Jim Gonsiewski or me at (336) 776-9800. Sincerely, SI n.d by: tbou �L o 1 . SM2CP Lont.Snider- Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO enc.: Compliance Inspection Report cc: Nadine Blackwell — Suez (Electronic Copy) Ryan Copeland - Synagro (Electronic Copy) Rockingham County Environmental Health (Electronic Copy) WSRO Electronic Files Laserfiche Files Deouiaeni �Fm%t�e�vnartW OWrtry North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336,776.9800 1: r, z _ zrist LI • 1 7-• r /..'fthP r" _440•!-'• :! ! iffr7: . . e : 1 Ey I r: z-zisz _1 : l'1 — Z: ?.z4Tiair /-)`_ -;" — - - • • — •‘-'' 1 1 I_ 1711—L — -1 — ' • •-• r 'r _ z. 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I• I I Z,V: ' 1,11 J, 1 : 1 41 ,7z _1 I TI : 9 Compliance Inspection Report Permit: WQ0016247 Effective: 11/05/21 Expiration: 10/31/22 Owner : Synagro Central LLC SOC: Effective: Expiration: Facility: Synagro Western Piedmont Class B Residuals County: Alexander 284 Boger Rd Region: Mooresville Mocksville NC 27028 Contact Person: Alex Fox Directions to Facility: System Classifications: LA, Primary ORC: Robert Nathaniel Roth Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Phone: 336-703-8681 Certification: 1001672 Phone: 336-403-4324 NC0020591 City of Statesville - Third Creek VW TP NC0043532 Stanly County - West Stanly WWTP NC0031836 City of Statesville - Fourth Creek WWTP NC0088722 Lincoln County - Killian Creek WWTP NC0021873 Town of Mayodan - Mayodan WWTP NC0021890 Town of Granite Falls - Granite Falls WWTP NC0021636 Harnett County - North Harnett Regional WWTP NC0021369 Town of Columbus - Columbus VVWTP NC0026441 Town of Siler City - Siler City VVWTP NC0021628 Town of Norwood - Norwood VVWTP Inspection Date: 11/16/2021 Entry Time 10:50AM Exit Time: 12:20PM Primary Inspector: Jim J Gonsiewski Phone: 336-776-9704 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: ▪ Miscellaneous Questions Record Keeping Sampling • Land Application Site 1. Transport (See attachment summary) Page 1 of 4 Permit: WQ0016247 Owner - Facility:Synagro Central LLC Inspection Date: 11/16/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On November 16, 2021 staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR) performed an announced routine compliance inspection of the Town of Mayodan's residuals land application program This inspection was conducted by DWR staff member Jim Gonsiewski. Mr. Ryan Copeland of Synagro was present during this inspection. Loading operations at the Town of Mayodan WWTP and field application of residuals were observed. The inspection reflects compliance with the permit. Page 2 of 4 Permit: WQ0016247 Owner - Facility: Synagro Central LLC Inspection Date: 11/16/2021 Inspection Type :Compliance Evaluation Reason for Visit: Routine Type Land Application Distribution and Marketing 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: Yes No NA NE Yes No NA NE ❑ ❑•❑ O 01110 ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 111000 • ❑ ❑ ❑ ❑ ❑ ❑• ■ ❑❑❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ O 0011 • ❑ ❑ ❑ ❑ ❑ ❑• ■ ❑❑❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ ■ ❑❑❑ Sampling Yes No NA NE Describe sampling: TCLP, metals, nutrients. Is sampling adequate? • ❑ ❑ ❑ Is sampling representative? • ❑ ❑ ❑ 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? MOOD Page 3 of 4 Permit: WQ0016247 Owner - Facility: Synagro Central LLC Inspection Date: 11/16/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Does transport vehicle appear to be maintained? Comment: Land Application Site 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 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? Comment: No monitoring wells are required. • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ ▪ ❑ ❑ ❑ ■ ❑❑❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ ❑ ❑•❑ ❑ ❑ U ❑ ■ ❑❑❑ ❑ ❑■❑ ❑ ❑ U ❑ ❑ ❑ • ❑ ❑ ❑■❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑• ❑ ❑ ❑• ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 4 North Carolina Department of Environmental Qual ity Division of Water Resources Water Quality Section NON -DISCHARGE COMPLIANCE INSPECTION REPORT CLASS B RESIDUALS LAND APPLICATION General Information Facility Name: Town of Mayodan VWVTP County: Rockingham Permit No.: WQ00 16247 Permit Issuance Date: 3/3/20 Owner: Town of Mayodan Permit Expiration Date: 8/31/26 Plant ORC Name: Jamie Whitten Telephone No.: 336-427-5733 LA ORC / Contract Company: Nate Roth, Synagro Telephone No.: 336-403-4324 Other ContaCt(S): Ryan Copeland, Synagro Telephone No.: 336-607- 4494 Facility Location (address, gps or directions): 293 Cardwell Road, Mayodan Reason for Inspection ® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other: Comments (attach additional pages as necessary) Arrived at Mayodan WWTP at 10:50AM. Ryan Copeland with Synagro was at the facility. Discussed operations at the WWTP. Two 6,200 gallon tankers were transporting residuals to the application field. There was one 5,000 gallon spreader truck at the application field. Truck loading was good with no spillage noted at the VVWTP or the exit from the facility. Left WWTP at 11:15 AM for the application field (RC-49-1). Arrived at 11:35 AM. Inpected the field. The terrain was relatively flat with slopes ranging from 3% to 6%. The solids content of the residuals was 2.35%. The field was properly flagged. No runoff or ponding of residuals from spreading was observed. One tanker truck was applying residuals. The O&M plan and the permit were present. The plan was adequate. All trucks had O&M plans and maps. The residual spreading was good. No additional runoff or ponding was observed. Buffers were properly maintained. Left application field at 12:20 PM. Is a follow-up inspection necessary? ❑ Yes 71 No Primary Inspector: Jim Gonsiewski Date of Inspection: 11/16/21 Secondary Inspector: Entry Time: 10:50 AM Exit Time. 12:20 PM Non -Discharge Compliance Inspection Report Residuals Generating Facility Was the residuals generating facility inspected? Residuals Storage: Describe storage: Digester #1 - 400,000 gallons Yes ❑ No Number of days/weeks/months of storage: 6-0 months Residuals Sampling: Is sampling adequate and representative for each sample type? Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP): Pathogens, Nutrients/Metals, TCLP Y N NA NE V DOD Transport Vehicle: Y N NA Is transport occurring at time of inspection? ❑ ❑ Are necessary records (spill plan) present in vehicle? ID of observed vehicle(s): 52 021p, 52 0231, 52 0226 ® ❑ ❑ Record Keeping and Reporting Information: Y N NA Is current permit and prior annual reports available upon request? ▪ ❑ ❑ Has the facility been free of public complaints for the last 12 months? DO TCLP analysis conducted and results available? Frequency? ❑ 1/yr or ® 1/permit cycle ODD Residuals metals and nutrient analysis conducted? Frequency? (See permit for frequency) ® ❑ ❑ Nutrient and metals loading calculations? (to determine most limiting parameter) ❑ ❑ ❑ Do lab sheets support data reported on Residuals Analysis Summary? ODD Are PAN balance records available and within permit limits? ® ❑ ❑ Are there nutrient (crop) removal practices in place? ® ❑ ❑ Are hauling records available? (gal and/or tons hauled during calendar year to date) ® ❑ ❑ Are field loading records available? ® ❑ ❑ Are field inspections conducted and are records available? ® ❑ ❑ Are soil sample results available? ❑ ® ❑ Did soil results call for lime amendment? If so, are there records of application? ODD Soil results indicate that Cu & Zn indices are <3,000 (ideally <2,000)? ❑ ❑ ❑ Soil results indicate Na <0.5 meq/100 cm3, and Exchangeable Sodium Percentage (ESP) <15%? ❑ ❑ ❑ Does the permit require groundwater monitoring? ❑ Are groundwater lab results present? D ❑ I(] There are no 2L GW standard violations indicated in the lab results? ❑ ❑ Pathogen and Vector Attraction Reduction Records Pathogen Reduction: Which Alternative was used to demonstrate compliance? ® Alternative 1 Fecal Coliform Density. Were 7 samples collected and geometric mean <2 million mpn/cfu? ❑ Alternative 2 Process to Significantly Reduce Pathogens (5 options) ❑ Alternative 3 Use of Equivalent to RSRP (Not commonly used - See White House Manual) If Alternative 2 was used, select which Option was utilized and complete the section below. ❑ Option 1 - Aerobic Digestion Are logs present showing time and temperature? Was the time & temp. between 40 days at 68°F (20°C) and 60 days at 59° F (15°C)? ❑ Option 2 - Air Drying ❑ Option 3 - Anaerobic Digestion Are logs present showing time and temperature? Was the time & temp. between 15 days at 95° F — 131° F (35°-55° C) and 60 days at >68° F (20° C)? ❑ Option 4 — Composting (Not commonly used - See White House Manual) ❑ Option 5 - Lime Stabilization Are logs present showing time and temperature? Was the pH raised to > 12 after two hrs of contact? Was the temperature corrected to 25° C (77° F) (by calculation, NOT auto correct)? Page 2 of 4 ❑ ®a®❑❑❑❑❑❑®®❑❑❑❑4 ❑❑4 Y N NA NE Y N NA NE DODO ❑ ❑ DODO DODD O LIO ❑ Non -Discharge Compliance Inspection Report Vector Attraction Reduction: Select which Option was used to demonstrate compliance and complete answer associated questions. ❑ Option 1 - 38% Volatile Solids Reduction Y N NA NE Are lab results and calculations present? DODO Was the reduction on volatile solids (not total solids)? ❑ ❑ ❑ ❑ Were samples collected at correct locations? ❑ ❑ ❑ ❑ (beginning of digestion process & before land application) Was there a >38% reduction? ❑ DOO ['Option 2 - 40-Day Bench Scale Test Y N NA NE Were residuals from an anaerobic digester with average temp. 30°C — 40°C? ❑ ❑ ❑ ❑ Are lab results and calculations present? ❑ ODD Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ ❑ ❑ Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? ❑ ❑ ❑ ❑ Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑ Was the reduction less than 17%? ❑ ❑ ❑ ❑ ❑ Option 3 - 30-Day Bench Scale Test Y N NA NE Were residuals from aerobic digestion? ❑ ❑ ❑ ❑ Are lab results and calculations present? ❑ ❑ ❑ ❑ Were residuals 2% or less total solids? ❑ ❑ ❑ ❑ If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent? ❑ ❑ ❑ ❑ Was the test run for 30 days? ❑ DOO Was the test done at 20°C (68°F)? ❑ ❑ ❑ ❑ Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑ Was the reduction less than 15%? ❑ ❑ ❑ ❑ ® Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE Were residuals from aerobic digestion? lZi ❑ ❑ ❑ Were residuals <2% total solids (dry weight basis) (not diluted)? ® ❑ ❑ ❑ Was the test done between 10°C (50°F) and 30°C (86°F)? ® ❑ ❑ ❑ Was the temperature corrected to 20°C (68°F)? ❑ ❑ ❑ ❑ Was the sampling holding time <2 hours? V ❑ ❑ ❑ Was the test started within 15 minutes of sampling or aeration maintained? EDED Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids (dry weight basis)? 0 ❑ ❑ ❑ ❑ Option 5 - 14-Day Aerobic Process Y N NA NE Were the residuals from aerobic digestion? ❑ ❑ ❑ ❑ Was the average residuals temperature higher than 45°C (113°F)? ❑ ❑ ❑ ❑ Were the residuals treated for 14 days and temperature maintained higher than 40°C (104°F) for the 14-day period? ❑ ❑ ❑ ❑ ❑ Option 6 - Alkaline Stabilization Y N NA NE Was the pH of the residuals raised to >12 and maintained for two hours without addition of more alkali? ❑ ❑ ❑ ❑ Did the pH of residuals remain at >11.5 an additional twenty-two hours (i.e. 24 hours total) without the addition of more alkali? ❑ ❑ ❑ ❑ Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DODD ❑ Option 7 - Drying of Stabilized Residuals Y N NA NE The residuals do not contain unstabilized residuals? ❑ ❑ ❑ ❑ Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑ Were the residuals dried >75% total solids? DODO ❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑ Were the residuals dried >90% total solids? DODO ❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual) Page 3 of 4 Non -Discharge Compliance Inspection Report Land Application Site(s) Were application site(s) inspected? If so, please list Site ID(s) below. ® Yes ❑ No Application Site ID(s): NC-RC-49-1 Is application occurring at the time of inspection? ® Yes ❑ No If no, note the date of the last event: Was the Division notified of the application event(s)? ® Yes ❑ No Weather Conditions: ® Sunny ❑ Partly Cloudy ❑ Cloudy ❑ Overcast ❑ Stormy 0 Windy (wind direction: ) ❑ Breeze ® Calm ® No Precipitation ❑ Drizzle ❑ Rain ❑ Cloudburst (If applicable, precipitation measurement: Is there a rain gauge onsite? ® Yes 0 No ) Weather Notes (i.e. Significant Changes, Forecasts, etc): Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60 0 60 — 80 ❑ >80 Permit and Spill Plan onsite during application? ® Yes 0 No Application Observations: [Type of application: 0 Liquid ® Cake 0 Other Application Site —Field ID(s): NC-RC-49-1 Intended Crop: Fescue, pasture PAN Requirement: 156 lbs/ac Application Rate (tons or gallons/acre): 12,000 gallons/acre Nutrient Content: 18 Ibs PAN/6200 gallons % of total field area utilized or anticipated for this event? 100 Application occurring at time of visit: ® Yes ❑ No Application Method: ® Surface 0 Incorp/Injection Incorporation/Injection during visit: ❑ Yes ❑ No ® N/A Vegetative Buffer description: ❑None ®Grass 0Crop 0 Shrub ®Tree ❑ Other Current Field Conditions: ❑ Bare 0 Stubble ❑ Planted (crop) Soil Condition: 0 Dry 0 Moist 0 Wet ❑ Saturated ❑ Not -Frozen 0 Frost 0 Frozen 0 Snow -Covered Slope: ❑ 0-3% ® 3-6% 0 6-10% 0 10-18% ❑ >18% Odor: ® None ❑ Mild 0 Moderate ❑ Strong Vectors: ® None 0 Few 0 Many 0 Excessive Application Details: Application areas clearly marked? Application within authorized area? Application method appropriate? Application is even (no ponding)? Sufficient setbacks from wells/residences? Sufficient setbacks from surface waters? Slopes>I0% avoided (Surface App.) ? Slopes >18% avoided (Incorp/Inject) ? Incorp./Injection within time -frame? Biosolids visible on surface? Site Restrictions Public access is restricted / Signage present? Grazing restrictions are met? Transfer of biosolids is in permitted area? No evidence of shallow GW? Sufficient timing for harvest restrictions? Off Site Transport Tracking is prevented? Biosolids run-off is prevented? Windblown biosolids prevented? Vegetative buffers exist? ® Pasture l N NA NE O ❑ ❑ ❑ O 000 ❑❑❑ is❑❑❑ §000 ❑ ❑ D O 000000 ❑ ❑Gan O 000 Y N NA NE MODE VI ✓ ODO ❑❑❑ • On ❑ Y N NA NE V ❑ D ❑ Wood Application Site —Field ID(s): Intended Crop: PAN Requirement: lbs/ac Application Rate (tons or gallons/acre): Nutrient Content: % of total field area utilized or anticipated for this event? Application occurring at time of visit: ❑ Yes 0 No Application Method: 0 Surface ❑ Incorp/Injection Incorporation/Injection during visit: 0 Yes ❑ No ❑ N/A Vegetative Buffer description: :None ['Grass ['Crop 0 Shrub ❑Tree ❑ Other Current Field Conditions: 0 Bare 0 Stubble 0 Planted (crop) 0 Pasture Soil Condition: ❑ Dry ❑ Moist ❑ Wet 0 Saturated ❑ Not -Frozen 0 Frost 0 Frozen 0 Snow -Covered Slope: 0 0-3% ❑ 3-6% 0 6-10% 0 IO-18% 0 >18% Odor: ❑ None 0 Mild 0 Moderate 0 Strong Vectors: 0 None ❑ Few ❑ Many ❑ Excessive Application Details: Application areas clearly marked? Application within authorized area? Application method appropriate? Application is even (no ponding)? Sufficient setbacks from wells/residences? Sufficient setbacks from surface waters? Slopes > 10% avoided (Surface App.) ? Slopes>18% avoided (Incorp/Inject) ? Incorp./Injection within time -frame? Biosolids visible on surface? Site Restrictions Public access is restricted / Signage present? Grazing restrictions are met? Transfer of biosolids is in permitted area? No evidence of shallow GW? Sufficient timing for harvest restrictions? Off Site Transport Tracking is prevented? Biosolids run-off is prevented? Windblown biosolids prevented? Vegetative buffers exist? Y N NA NE O 000 O 000 O 000 O 000 O 000 O 000 O 000 O 000 ❑ ❑❑D ❑ ❑❑❑ Y N NA NE O 000 O 000 O 000 O 000 O 000 Y N NA NE O 000 O D DO O 000 ❑ ❑❑a Page 4 of 4