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HomeMy WebLinkAboutWQ0039552_CEI_20220420ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Kenneth Gamble, Town Manager Town of Mocksville 171 North Clements Street Mocksville, NC 27028 NORTH CAROLINA Environmental Quality April 20, 2022 SUBJECT: Compliance Evaluation Inspection Town of Mocksville Distribution of Class A Residuals Program Permit No. WQ0039552 Davie County Dear Mr. Gamble: On April 14, 2022, Division of Water Resources staff Caitlin Caudle conducted a routine compliance inspection. Brent Collins and Roy Whitaker of EMA Resources, Inc. were present during the entire inspection. A review of available records and storage facilities were reviewed. This review reflected compliance with the subject permit. The following item of concern was noted: A. Per Permit Condition V.2 "prior to each bulk residuals land application event, the Permittee or his designee shall inspect the residuals storage, transport, and application facilities to identify malfunctions, facility deterioration and operator errors ... The permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken...." Mr. Collins stated that a record of field inspections is not available, but all fields are inspected and flagged with courtesy and required buffers prior to application activities. Moving forward, please keep a log of all field inspections prior to the commencement of land application activities. GDE NORTH CAROLINA ' omm mr� ep..of o�.i North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Please refer to the enclosed inspection report for additional comments and observations. If you have any questions regarding this letter please contact me or Caitlin Caudle at the letterhead address or phone number, or by email at lon.snider@ncdenr.gov or caitlin.caudle@ncdenr.gov. Sincerely, 1- DocuSiiggned by: %A. l . c%n.1�Gf 145B49E225C94 EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Brent Collins, EMA Resources, Inc. (electronic copy) Davie County Environmental Health (electronic copy) Laserfiche File WQ0039552 WSRO Electronic Files D_E NORTH CARCLINA gaparMeM of Environment,/quay North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105 336.776.9800 Compliance Inspection Report Permit: WQ0039552 Effective: 11/17/17 Expiration: 10/31/22 Owner : Town of Mocksville SOC: Effective: Expiration: Facility: Town of Mocksville DCAR County: Davie 771 Sanford Ave Region: Winston-Salem Contact Person: Roy L Whitaker Directions to Facility: Mocksville NC 27028 Title: Phone: 336-751-1441 System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/14/2022 Primary Inspector: Caitlin Caudle Secondary Inspector(s): Entry Time 10:OOAM Exit Time: 12:45PM Phone: 336-776-9699 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: WQ0039552 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On April 14, 2022, Division of Water Resources staff Caitlin Caudle conducted a routine compliance inspection. Brent Collins and Roy Whitaker of EMA Resources, Inc. were present during the entire inspection. A review of available records and storage facilities were reviewed. This review reflected compliance with the subject permit. The following item of concern was noted: A. Per Permit Condition V.2 "prior to each bulk residuals land application event, the Permittee or his designee shall inspect the residuals storage, transport, and application facilities to identify malfunctions, facility deterioration and operator errors ... The permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken...." Mr. Collins stated that a record of field inspections is not available, but all fields are inspected and flagged with courtesy and required buffers prior to application activities. Moving forward, please keep a log of all field inspections prior to the commencement of land application activities. 188 dry tons/year is permitted with no intention of increasing or decreasing this amount. Residuals are produced from the sediment basin and filters. Liquid residuals are land applied at agronomic rates. Based on the residuals analysis results provided for 1/24/2022, the residuals contain 4.78 Ibs PAN/ton. Two concrete storage basins (275,000 gallons each) are used for storage, with at least 365 days of storage. Residuals were last hauled at the end of the previous calendar year. Residuals are likely to be hauled again during the next budget year. Ms. Caudle requested that the field summary form be provided for this last application event as application fields are included in the Davie County Class B permit. Mr. Collins stated that all bulk residuals are land applied on fields included in permits managed by EMA because of existing landowner agreements to accept residuals. If bulk residuals are applied to fields not included in a permit a utilization agreement will be signed. Ms. Caudle requested that she be notified during the next application event to review application activities. Page 2 of 3 Permit: WQ0039552 Owner - Facility:Town of Mocksville Inspection Date: 04/14/2022 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 El • Yes No NA NE ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page 3 of 3