WQ0016966_NOD-2022-PC-0132_20220825

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
August 25, 2022
W. Kelly Craver, Interim Town Manager
Town of Denton
P.O. Box 306
Denton, NC 27239
SUBJECT: Notice of Deficiency (NOD-2022-PC-0132)
Compliance Evaluation Inspection
Town of Denton Residuals Land Application Program
Permit No. WQ0016966
Davidson County
Dear Mr. Craver:
On August 8, 2022, Division of Water Resources conducted a compliance evaluation
inspection. Troy Branch and Steve Abercrombie of the Town of Denton were present
during the entire inspection. An in -office review of records was completed. An on -site
review of storage facilities and the application site was completed. This review mostly
reflected compliance with the subject permit. The following deficiency was noted:
A. Permit Condition 111.3 requires "the Permittee shall notify the Winston Salem
Regional Office at least one day in advance of conducting any land application
activity." The Office was notified the day application activities commenced. Failure
to notify the Office as required was also noted in a Notice of Violation and Notice
of Intent to Enforce dated July 29, 2021. Moving forward, notify the Winston
Salem Regional Office at least one day in advance of planned application
activities.
The following item of concern was noted:
• Permit Condition IV.3 lists all metal and nutrients that must be sampled for at a
frequency established in Attachment A. A review of the provided analysis showed
that arsenic and calcium were not analyzed for as part of the metals and nutrients.
Arsenic was analyzed in the TCLP analysis but was reported as mg/L. Please
analyze the residuals produced for calcium before the end of the calendar
year.
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
and phone number, or by email at lon.snider(a�ncdenr.gov or [e-mail].
Sincerely,
DocuSiiggned by:by�
%A. l . c%n.11Cf
"- 145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Enc: Inspection Report
Cc: Troy Branch, ORC (electronic copy)
Steve Abercrombie, Back Up ORC (electronic copy)
Davidson County Environmental Health (electronic copy)
Laserfiche File WQ0016966 (electronic copy)
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: WQ0016966 Effective: 04/14/20
SOC: Effective:
County: Davidson
Region: Winston-Salem
Contact Person: Zach D Key
Directions to Facility:
System Classifications: LA,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0026689
NC0082949
Town of
Town of
Inspection Date: 08/08/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Reason for Inspection: Routine
Expiration: 09/30/26
Expiration:
Title:
Denton - Denton WWTP
Denton - Denton WTP
Entry Time 01:20PM
Certification:
Owner : Town of Denton
Facility: Town of Denton RLAP
300 Council Access Rd
Denton NC 27239
Exit Time: 02:11PM
Phone: [phone]
Phone:
Phone: [phone]
Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant
Question Areas:
▪ Miscellaneous Questions
▪ Sampling
▪ Storage
(See attachment summary)
Not Compliant
▪ Record Keeping
▪ Land Application Site
▪ Treatment
▪ Pathogen and Vector Attraction
Page 1 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 08/08/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On August 8, 2022, Division of Water Resources conducted a compliance evaluation inspection. Troy Branch and Steve
Abercrombie of the Town of Denton were present during the entire inspection. An in -office review of records was completed.
An on -site review of storage facilities and the application site was completed. This review mostly reflected compliance with
the subject permit. The following deficiency was noted:
A. Permit Condition 111.3 requires "the Permittee shall notify the Winston Salem Regional Office at least one day in advance
of conducting any land application activity." The Office was notified the day application activities commenced. Failure to
notify the Office as required was also noted in a NOV NOI dated July 29, 2021. Moving forward, notify the Winston Salem
Regional Office at least one day in advance of planned application activities.
The following item of concern was noted:
• Permit Condition IV.3 lists all metal and nutrients that must be sampled for at a frequency established in Attachment A
A review of the provided analysis showed that arsenic and calcium were not analyzed for as part of the metals and nutrients.
Arsenic was analyzed for in the TCLP analysis but was reported as mg/L. Please analyze the residuals produced for
calcium before the end of the calendar year.
Field Observations 2-05:
• Residuals were visible on the surface.
• Two houses were buffered and shown on the application map.
• A ditch was buffered that is not shown on the application map.
• A sign was at the field entry point.
• Application appeared to be even with no ponding or runoff.
• Application occurred on 8/4/2022. Only 0.25in of rain fell on Saturday.
Other observations:
• Oxidation Ditch ❑ 4 clarifiers ❑ 2 digestors ❑ Chlorination E Dechlorination ❑ Lick Creek
• A liquid residual is spread.
• Lime stabilization is used for pathogen and vector reduction.
• About 20 loads at 6,000 gallons are produced every 3-4 months. An application event typically lasts 6hrs.
• The wastewater treated at the WWTP is mostly domestic with a single industry.
• 2 digestors are used for residuals storage. The large digestor is —72,000 gallons and the small digestor is—30,000
gallons. The digestors are connected and allowed to equalize. Clarifiers 1 and 2 waste to the small digestor and 3 and 4
waste to the large digestor.
• Both digestors have liquid lime added.
• Residuals are pumped from the larger digestor and top loaded into tankers. The back pressure from the smaller digestor
will equalize the levels.
• The smaller digestor has a large amount of solids built up around the side walls. Mr. Branch stated that this digestor is
older and the amount of solids present is less than what was present in the past. The solids do not appear to be interfering
with the aerator.
• All fields are fescue pasture or hay.
• All samples are collected from the larger digestor as the digestors are considered a single unit.
• The Mr. Branch and Mr. Abercrombie will visit the application site on the day of application to ensure the application
area is marked and application is even.
• Field loading records have day of field condition
Page 2 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 08/08/2022 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
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▪ ❑ ❑ ❑
Yes No NA NE
O 000
O 000
O 000
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O 000
Page 3 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 08/08/2022 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:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Land Application Site
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?
❑ ❑ ❑ ❑
El
El El El El
El El El El
Yes No NA NE
•
El
•
El
Yes No NA NE
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Yes No NA NE
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Page 4 of 5

Permit: WQ0016966 Owner - Facility:Town of Denton
Inspection Date: 08/08/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
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:
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Page 5 of 5