HomeMy WebLinkAboutWQ0003504_Compliance Evaluation Inspection_20230105
North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office
3800 Barrett Drive 1628 Mail Service Center Raleigh, North Carolina 27699-1628
919.791.4200
January 5, 2023
Donald F. Greeley – Director of Waste Management
City of Durham
101 City Hall Plaza
Durham, NC 27701
Subject: Compliance Evaluation Inspection
Permit Number: WQ0003504
City of Durham RLAP
Land Application of Class B Residuals
Durham County
Mr. Greeley,
On January 4, 2023 Chris Smith of the Raleigh Regional Office conducted a compliance evaluation
inspection of the City of Durham RLAP Land Application of Class B Residuals program, Permit No.
WQ0003504. The purpose of this inspection was to ensure compliance with the subject permit. During
the inspection the cooperation and assistance provided by Charles Cocker, Roy Whitaker, and David
Ackley was helpful and appreciated.
The current permit was issued on November 23, 2020 and expires May 31, 2026.
The ORC is John Dodson and the backup ORC is Charles Cocker. Charles Cocker manages the day to day
activities covered under the permit. Durham is responsible for pathogen reduction and vector attraction
reduction. EMA Resources, Inc. does the remainder of the required analyses. All analyses have been
done per permit requirements. TCLP analyses is conducted yearly. Metals and nutrients are analyzed
six times per year. SAR levels are very low. There are no analyses that show any residuals are near
permit limit concentrations with the exception of high zinc levels in soils at several land app fields. The
high zinc fields have historically been used for application of poultry litter which is known to be high in
zinc and copper.
Residuals are kept under cover at the Durham facilities. They are trucked the fields and dumped on the
ground by EMA Resources, Inc. A loader on site fills a spreader hauled by a tractor. Residuals are
surface applied. Residuals are not left to sit overnight without being spread. Areas where residuals are
dumped prior to spreading are reseeded after the application equipment has left the site.
The facility maintains the required records of all land application events. They have been submitting
annual reports with proper analysis for metals, non-hazardous determination, and pathogen and vector
attraction reduction. Pathogen Reduction is demonstrated by fecal analyses prior to land application.
Vector Attraction Reduction is met with alternative 1 – volatile solids reduction.
Fields GR-5-1 to GR-5-6 were visited during the inspection, but no residuals were being applied. The
most recent land application was in November 2022. An any case, heavy rains would have prevented
DocuSign Envelope ID: 8CC0396F-CCD8-4CB0-8E88-07F20A423912
WQ0003504
Durham
January 5, 2023
Page 2 of 2
North Carolina Department of Environmental Quality Division of Water Resources Raleigh Regional Office
3800 Barrett Drive 1628 Mail Service Center Raleigh, North Carolina 27699-1628
919.791.4200
proper land application during the inspection. The fields visited had a healthy, recently cut crop of
fescue on them. Application records were reviewed and found to be in compliance with permit
conditions.
On the day of the inspection, the facility appeared to be operating in compliance with the permit
requirements of WQ0003504.
If you have any questions about this inspection or this letter, please contact Chris Smith at
chris.smith@ncdenr.gov or 919-791-4200.
Sincerely,
Vanessa E. Manuel
Assistant Regional Supervisor
Water Quality Regional Operations Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc: Laserfiche
DocuSign Envelope ID: 8CC0396F-CCD8-4CB0-8E88-07F20A423912