WQ0018688_CEI and 2021 Annual Report Review_20220408

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Bill Trudnak, Public Works Director
Town of Dallas
700 E. Ferguson Street
Dallas, North Carolina 28034
Dear Mr. Trudnak:
NORTH CAROLINA
Environmental Quality
April 8, 2022
via Email
Subject: Non -Discharge Permit Inspection
And Acknowledgement of Receipt - 2021 Annual Report
Town of Dallas WTP - Permit # WQ0018688
Distribution of Water Treatment Plant Residuals
Gaston County
Staff of the Mooresville Regional Office (MRO) conducted an inspection for the referenced residuals permit on
March 17th, 2022, in conjunction with follow-up for a recent NPDES (NC0082694) inspection and violation.
Correspondence related to your NPDES permit was managed separately. The MRO would like to thank your
plant staff for their assistance onsite, by phone and email communication.
The electronic copy of the referenced 2021 Annual Report was received on February 24th, 2022 and stated there
was no Land Application or Distribution conducted in 2021. Hauling records received by email from Mr. Foreman
on March 18th and April 6th, 2022, show residuals were landfilled in 2022 and 2019. Delay of residuals
management, improper maintenance of drying beds and reduced freeboard levels in ponds / lagoon(s) were
noted as contributing factors to the recent wastewater discharge and violation(s) addressed under the NPDES
permit. In addition, the non -discharge program recommends continued berm maintenance of lagoons include the
removal of woody or excessive vegetation.
This distribution permit is currently expired. Per conversation with Mr. Foreman, Dallas staff has
communicated with Zach Key at U.S. Biosolids the possibility of being added as a source under their permit and
eventually rescinding this permit. These permitting steps will be managed, if not already underway, via staff at
our Non -Discharge permitting office in Raleigh. You may contact that Branch Supervisor at:
[e-mail] with questions.
The attached report(s) should be self-explanatory; however, you may contact Maria Schutte by phone (704-235-
2184) or email ([e-mail]) with questions.
Sincerely,
DocuSigned by:
114.01414w H P:ze.
F161FB69A2D84A3...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0018688 Inspection Report(s)
CC: Zackery Foreman, WTP ORC, Town of Dallas (email)
Zach Key, LA Contractor, U.S. Biosolids (email)
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1601 East Center Avenue, Suite 301 I Mooresville, NC 28115
704.663.1699
D_E QNORTH CAROLINA
Depshnanl of Emimnment Monti"'

Compliance Inspection Report
Permit: WO0018688 Effective: 08/01/15 Expiration: 07/31/20 Owner : Town of Dallas
SOC: Effective: Expiration: Facility: Town of Dallas WTP Residuals Distribution Prol
County: Gaston 210 N Holland St
Region: Mooresville
Contact Person: Rick Coleman
Directions to Facility:
Dallas NC 280342749
Title: Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/17/2022
Primary Inspector: Maria Schutte
Secondary Inspector(s):
Entry Time 01:40PM Exit Time: 02:10PM
Phone: [phone]
Ori A Tuvia
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Storage
(See attachment summary)
Page 1 of 3

Permit: WQ0018688 Owner - Facility: Town of Dallas
Inspection Date: 03/17/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted an inspection for the referenced residuals permit on March 17th,
2022, in conjunction with follow-up for a recent NPDES (NC0082694) inspection and violation. Correspondence related to
your NPDES permit was managed separately. The MRO would like to thank your plant staff for their assistance onsite, by
phone and email communication.
The electronic copy of the referenced 2021 Annual Report was received on February 24th, 2022 and stated there was no
Land Application or Distribution conducted in 2021. Hauling records received by email from Mr. Foreman on March 18th and
April 6th, 2022, show residuals were landfilled in 2022 and 2019. Delay of residuals management, improper maintenance of
drying beds and reduced freeboard levels in ponds / lagoon(s) were noted as contributing factors to the recent wastewater
discharge and violation(s) addressed under the NPDES permit. In addition, the non -discharge program recommends
continued berm maintenance of lagoons include the removal of woody or excessive vegetation.
This distribution permit is currently expired. Per conversation with Mr. Foreman, Dallas staff has communicated with Zach
Key at U.S. Biosolids the possibility of being added as a source under their permit and eventually rescinding this permit.
These permitting steps will be managed, if not already underway, via staff at our Non -Discharge permitting office in Raleigh.
You may contact that Branch Supervisor at: [e-mail] with questions.
Page 2 of 3

Permit: WQ0018688 Owner - Facility: Town of Dallas
Inspection Date: 03/17/2022 Inspection Type : Compliance Evaluation
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: Permit is not utilized for application or distribution. Dispose in landfill, when hauling is
conducted. Additional information received and violation issued under NPDES permit indicate
facility is not hauling solids or maintaining residuals processing areas in manner to best
manage all permits. See summary and cover letter. Reference NPDES permit NC0082694 for
violation(s).
Yes No NA NE
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Yes No NA NE
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Page 3 of 3

Compliance Inspection Report
Permit: WO0018688 Effective: 08/01/15 Expiration: 07/31/20 Owner : Town of Dallas
SOC: Effective: Expiration: Facility: Town of Dallas WTP Residuals Distribution Prol
County: Gaston 210 N Holland St
Region: Mooresville
Contact Person: Rick Coleman
Directions to Facility:
Dallas NC 280342749
Title: Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/16/2022
Primary Inspector: Maria Schutte
Secondary Inspector(s):
Entry Time 01:55PM Exit Time: 02:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Page 1 of 3

Permit: WQ0018688 Owner - Facility: Town of Dallas
Inspection Date: 03/16/2022
Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted an inspection for the referenced residuals permit on March 17th,
2022, in conjunction with follow-up for a recent NPDES (NC0082694) inspection and violation. Correspondence related to
your NPDES permit was managed separately. The MRO would like to thank your plant staff for their assistance onsite, by
phone and email communication.
The electronic copy of the referenced 2021 Annual Report was received on February 24th, 2022 and stated there was no
Land Application or Distribution conducted in 2021. Hauling records received by email from Mr. Foreman on March 18th and
April 6th, 2022, show residuals were landfilled in 2022 and 2019. Delay of residuals management, improper maintenance of
drying beds and reduced freeboard levels in ponds / lagoon(s) were noted as contributing factors to the recent wastewater
discharge and violation(s) addressed under the NPDES permit. In addition, the non -discharge program recommends
continued berm maintenance of lagoons include the removal of woody or excessive vegetation.
This distribution permit is currently expired. Per conversation with Mr. Foreman, Dallas staff has communicated with Zach
Key at U.S. Biosolids the possibility of being added as a source under their permit and eventually rescinding this permit.
These permitting steps will be managed, if not already underway, via staff at our Non -Discharge permitting office in Raleigh.
You may contact that Branch Supervisor at: [e-mail] with questions.
Page 2 of 3

Permit: WQ0018688 Owner - Facility: Town of Dallas
Inspection Date: 03/16/2022
Inspection Type : Annual Report Review
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?
Yes No NA NE
•
•
Yes No NA NE
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❑ ❑•❑
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Comment: This was a review of the 2021 annual report only, which indicated there was not activity
conducted under this permit in 2021. See summary and cover letter for additional information
gathered after this review and the facility inspection.
Page 3 of 3