WQ0036561_Inspection Letter_20220721

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 21, 2022
Mr. Alan Johnson, Director
Division of Water and Wastewater Management
City of Danville
279 Park Avenue
Danville, Virginia 24541
SUBJECT: Compliance Evaluation Inspection
City of Danville Residuals Land Application Program
Permit No. WQ0036561
Caswell County
Dear Mr. Johnson:
On June 30, 2022, Division of Water Resources staff Caitlin Caudle conducted a
compliance evaluation inspection. Brent Collins, EMA Resources, was present during
the entire inspection. A separate review of residual analysis was completed. A review of
storage structures, transport vehicles, active application site, and past application sites
was completed. This review mostly reflected compliance with the subject permit. The
following item of concern was noted:
A. Per Permit Condition 111.13 public access controls shall be posted at each
application site. At the time of inspection, no signs were posted to limit public
access. Mr. Collins stated that signs will be acquired and posted at all application
sites and provided photos of signs at each field applied on. Moving forward,
please ensure that sings are posted per Permit Condition 111.13.
B. There was a house next to CS-7-1 that was actively under renovation and was
not habitable at the time of inspection with no evidence of anyone in residence.
Residuals were applied within the 400ft buffer as marked on the map. The
buffered area was flagged. The presence of a well is not marked on the
application map. Moving forward, all maps need to be up to date and show
all wells, ephemeral, intermittent, and perinea) streams, springs, lakes,
ponds, and other surface drainage features. All required setbacks and the
application maps should be adhered to at all times.
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, please contact me or Caitlin Caudle at the
letterhead address or phone number, or by email at lon.snider(a�ncdenr.gov or
[e-mail].
Sincerely,
DocuSigned by:by�
%11w. l ig5M.dGr
"- 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 (electronic copy)
Caswell County Environmental Health (electronic copy)
Laserfiche File WQ0036561
WSRO Electronic Files
DE
NORTH CAROLINA
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: WQ0036561 Effective: 08/31/18 Expiration: 07/31/23 Owner : City of Danville
SOC: Effective: Expiration: Facility: City of Danville RLAP
County: Out of State 229 Northside Dr
Region: Winston-Salem
Contact Person: Charles Richard Overby
Directions to Facility:
Danville VA 24540
Title: Phone: [phone]
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/30/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 12:51PM Exit Time: 03:OOPM
Phone: [phone]
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
II Land Application Site Pathogen and Vector Attraction Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 06/30/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On June 30, 2022, Division of Water Resources staff Caitlin Caudle conducted a compliance evaluation inspection. Brent
Collins, EMA Resources, was present during the entire inspection. A separate review of residual analysis was completed. A
review of storage structures, transport vehicles, active application site, and past application sites was completed. This review
mostly reflected compliance with the subject permit. The following item of concern was noted:
A. Per Permit Condition 111.13 public access controls shall be posted at each application site. At the time of inspection, no
signs were posted to limit public access. Mr. Collins stated that signs will be acquired and posted at all application sites
and provided photos of signs at each field applied on. Moving forward, please ensure that sings are posted per Permit
Condition 111.13.
B. There was a house next to CS-7-1 that was actively under renovation and was not habitable at the time of inspection
with no evidence of anyone in residence. Residuals were applied within the 400ft buffer as marked on the map. The buffered
area was flagged. The presence of a well is not marked on the application map. Moving forward, all maps need to be up to
date and show all wells, ephemeral, intermittent, and perineal streams, springs, lakes, ponds, and other surface drainage
features. All required setbacks should be adhered to at all times.
Other observations:
• High copper values were present in NC-CS-06-03 and NC-CS-06-02.
• Higher zinc values were present in NC-CS-10-05 and CS-14-01.
• Four sample events were completed for pathogen reduction, vector reduction, metals, and nutrient analysis. All samples
were collected before application started.
• Residuals were being hauled from Basin B.
• CS-14-1 had chicken litter stockpiled in the field. Livestock were being kept in this pasture to exclude them from the
other fields on this property.
• Only two sites have been applied on so far. CS-14 did not have a sign posted. CS-7-1 did not have a sign posted.
• Sampled are collected from the catwalks and mixed to make a composite sample.
• The Kenworth with a 6,500 gallon tanker hauling residuals to the site did not have a current permit or spill plan. One was
provided to the driver while on site.
• A field inspection form was developed after the last inspection and is now completed before residuals are applied to each
site.
• CS-14-3 and PS2-2 had lime recommendations on the last soil samples provided with the 2021 annual report. Mr.
Collins stated he was unsure if lime had been applied to these fields in the 2022 calendar year as the City of Danville
handles the billing. PS2-2 may need a lime application in the next few years as the pH is 5.5. As pH nears 5 aluminum
toxicity may develop.
• Fecal coliform and 30-day bench scale were used for PVR.
• Liquid residuals are being applying at 2-3 6,500 gallon tankers/acre. The PAN rate being used in 43 Ibs/6,500 gallon
tanker.
• Application at CS14-1 and CS14-2 were even with no signs of runoff or ponding. Buffers were still flagged and
appropriate.
• Application at CS-7-1 were even with no signs of runoff or ponding. Buffers were appropriate.
• The maps for this permit will need to be updated with the permit renewal. They are outdated and do not accurately
represent the current field conditions.
Page 2 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 06/30/2022 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:
Pathogen and Vector Attraction
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)
Yes No NA NE
El
•
Yes No NA NE
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
•
❑ ❑ ❑
❑ ❑ • ❑
▪ ❑ ❑ ❑
•
❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
•
• ❑ ❑ ❑
•
O 000
O 000
O 000
Page 3 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 06/30/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench -top Aerobic/Anaerobic digestion results
Comment:
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
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? • ❑ ❑ ❑
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 ❑ ❑ • ❑
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? ❑ ❑ • ❑
Page 4 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 06/30/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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 173' bls.
Is application occurring at the time of the inspection?
Comment:
❑ ❑ • ❑
❑ ❑ • ❑
Page 5 of 5