WQ0010059_CEIARR_NOD2022PC0073_20220511

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED

May 11, 2022

Lisa Triplett
Email: [e-mail]
City of Lenoir

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2022-PC-0073
Annual Report Review 2021
Permit No. WQ0010059
City of Lenoir DCAR
Caldwell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Lenoir DCAR Annual Report
on May 4, 2022. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non-discharge Permit No. WQ0010059. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.

The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following deficiency was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
Pathogen and Vector Attraction Permittee did not demonstrate vector attraction reduction was met for several batches of
residuals distributed per Section IV.4 of the permit. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. The Asheville Regional Office acknowledges the City has provided Division staff with the corrective
measures that have already been taken and changes that will be implemented moving forward.
If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at
[e-mail].

Sincerely,

G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: LF

DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8
Compliance Inspection Report
Permit:WQ0010059 Effective:11/10/20 Expiration:10/31/26 Owner :City of Lenoir
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Caldwell
Asheville
Scott Hildebran
Effective:Expiration:Facility:City of Lenoir DCAR
1905 Broadland Rd
Lenoir NC 28645
Title:Phone:[phone]
From Hwy. 64 East in Lenoir turn right onto Southwest Blvd. Take the first exit off Southwest to Virginia ST. (left on Virginia St.)
Continue to Broadland Rd. on the right. Facility is approximately 1/2 mile on the left.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0023736 City of Lenoir - Gunpowder Creek WWTP
NC0023981 City of Lenoir - Lower Creek WWTP
NC0027286 Town of Blowing Rock - Blowing Rock WWTP
NC0044164 City of Lenoir - Lake Rhodhiss WTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
05/04/2022 09:00AM 10:30AM
Mikal Willmer 828-296-4686
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
05/04/2022 Annual Report Review
City of Lenoir
Routine
Inspection Summary:
Mikal Willmer, with the Asheville Regional Office, conducted a review of the City of Lenoir’s DCAR Annual Report on May 4,
2022. This review was conducted to determine whether the facility processed and monitored all residuals in compliance with
Permit No. WQ0010059.
The City landfilled all residuals until approximately September and distributed approximately 105.2 dry tons to the public
through December. In future submittals, the landfilled residuals do not need to be included on the Distribution and Marketing
Form. A narrative statement in the cover letter indicating the dry tons sent to the landfill is adequate.
Non-hazardous waste characterization is required once per permit cycle: The City sampled for TCLP, corrosivity, reactivity
and ignitability in July of 2021 and has met the permit requirement. All results appeared to meet regulatory requirements.
Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 1,000 MPN/gram and PFRP Heat Drying. All
fecal results were less than 1,000 MPN/g and all dryer runs appear to meet or exceed the 80°C temperature requirement.
Vector Attraction Reduction (VAR): Facility meets Pathogen Reduction requirement via VAR method-Drying of Unstabilized
Residuals. Several of the dryer runs were less than 90% total solids and were not reprocessed or landfilled. The final
product must be greater than or equal to 90% total solids before distribution when processing unstabilized residuals. The
City has implemented corrective action and reviewed the requirements with operations personnel to ensure the product is
either reprocessed, dried further or landfilled if it does not meet permit requirements.
Metals, Nutrients & Pollutants of Concern: Required frequency is based on tons distributed. Facility distributed <319 dry
tons of residuals in 2021 which required annual sampling. Pollutants of concern appeared to be less than ceiling and
monthly concentration limits outlined in Section II.4 of the permit. Parameters listed in Section IV.3 were sampled and
analyzed. SAR values were less than 10.
Page 2 of 4
DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
05/04/2022 Annual Report Review
City of Lenoir
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
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?
Class A residual distributed for public use.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)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page 3 of 4
DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
05/04/2022 Annual Report Review
City of Lenoir
Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
PFRP heat drying is used to meet pathogen reduction.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
Utilize vector attraction reduction method "drying of unstabilized residuals".Comment:
Page 4 of 4
DocuSign Envelope ID: 484287B4-D81D-4D46-AEF8-6B4080F70FD8