WQ0021632_Staff Report_20220725

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
July 25, 2022
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Erick Saunders
Application No.: WQ0021362
Facility name: Burlington Class A
From: Caitlin Caudle
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 7/21/2022
b. Site visit conducted by: C. Caudle
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Shane Fletcher and their contact information: (336) 675 - 5927
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? n Yes ❑ No ® N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Is the residuals management plan adequate? ® Yes or ❑ No
4. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
5. Is the existing groundwater monitoring program adequate? n Yes ❑ No ® N/A
6. Are there any setback conflicts for existing treatment, storage and disposal sites? ['Yes or ® No
7. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
8. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: ARs have been compliant with permit.
9. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
10. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? n Yes n No n N/A
If no, please explain:
11. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
['Yes ❑ No® N/A
FORM: WQROSSR 04-14 Page 1 of 2

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: ) DocuSigned by:
3. Signature of report preparers lit
Dec / gn.d by:
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Signature of regional supervisor:
Date: 7/2 5 / 2 02 2 145B49E225C94EA...
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See attached inspection report for observations from the site visit.
All material from the South plant is going to the belt press and being hauled by McGill. No compost is being made.
All material from the Mackintosh WTP is being land applied on fields in Alamance County.
Footnote 6 needs to be kept in the Attachment A for the Mackintosh WTP.
FORM: WQROSSR 04-14 Page 2 of 2

Compliance Inspection Report
Permit: WQ0021632 Effective: 01/01/18 Expiration: 12/31/22 Owner : City of Burlington
SOC: Effective: Expiration: Facility: City of Burlington DCAR
County: Alamance 2471 Boywood Rd
Region: Winston-Salem
Contact Person: Robert C Patterson
Graham NC 27253
Title: Phone: [phone]
Directions to Facility:
Take NC Hw. 87 South off of 1-85 (Exit 147). Proceed on NC Hwy. 87 South, and bear left onto Swepsonville Road. At Boywood
Road, bear right. The entrance to the WWTP is 0.25 miles on the right
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0023876 City of Burlington - Southside WWTP
NC0083828 City of Burlington - J.D. Mackintosh, Jr. WTP
Inspection Date: 07/21/2022
Entry Time 10:05AM Exit Time: 12:30PM
Primary Inspector: Caitlin Caudle Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: II Compliant Not Compliant
Question Areas:
▪ Miscellaneous Questions Record Keeping Treatment
▪ Sampling
(See attachment summary)
Page 1 of 4

Permit: WQ0021632 Owner - Facility: City of Burlington
Inspection Date: 07/21/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On July 21, 2022, Division of Water Resources staff Caitlin Caudle conducted a compliance inspection. DWR staff Seren
Homer accompanied Ms. Caudle on the inspection. Shane Fletcher, Residuals Management Coordinator, was present
during the entire inspection. A review of records, belt press, residuals storage, and water treatment plant storage ponds was
completed. This review reflected compliance with the subject permit.
Compost was last made in May of 2020. All residuals from the belt press are shipped to McGill. There is no plan to make
compost in the immediate future. Only one digestor at the South Plant is used on a regular basis. There are three round
digestors and two square digestors, all other digestors remain empty. The WWTP ORC will waste into the digestor for a
week and the belt press will be run for three days. Approximately 300,000 gallons of residuals are processed in a week. The
pump that sends residuals from the digestor to the belt press is in the basement of Building I, where the digestor is.. The
South plant sludge will be sampled once a year in case residuals have to be land applied under the Class B permit.
Other observations:
• Hauling records were available for the spring/summer hauling event. Mr. Fletcher stated that another hauling event will
start in August.
• Synagro manages all field loading records and nutrient and pollutant loading calculations.
• Synagro will get a Utilization Agreement from each landowner.
• Mr. Fletcher stated that he will collect fecal samples from the compost if any was made.
• A static aerated pile method was used to make compost. Compost piles were built around corrugated pipes which sent
forced air through the pile. Biofilters are present to remove the foul odors from the forced air.
• There are approximately 500 loads of 6,200 gallons in each of the 2 storage ponds at the WTP. Each storage pond has
approximately one year of storage.
• There is a one acre covered concrete pad that all belt press material is stored on. The immediate dumping area has a
concrete berm that keeps the residuals from flowing. There is also another area that has a berm for additional storage.
• A composite grab sample is collected from the WTP storage ponds before hauling starts and during hauling.
• Hauling and application was not occurring at the time of inspection.
• Residuals from the WTP are now toploaded on a circle drive rather than beside the storage ponds.
• The WTP produces an alum sludge.
• The Ed Thomas WTP sludge is sent to the East plant and mixed with sludge to be land applied.
• Mr. Fletcher stated that there are funds available to purchase another belt press.
Page 2 of 4

Permit: WQ0021632 Owner - Facility: City of Burlington
Inspection Date: 07/21/2022 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:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: See comments.
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page 3 of 4

Permit: WQ0021632 Owner - Facility: City of Burlington
Inspection Date: 07/21/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Yes No NA NE
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Page 4 of 4