WQ0016966_Annual Report Review_20230821

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Angel Jenkins, Town Manager
Town of Denton
P.O. Box 306
Denton, NC 27329
NORTH CAROLINA
Environmental Quality
August 21, 2023
SUBJECT: Notice of Deficiency (NOD-2023-PC-0222)
2022 Annual Report Review
Town of Denton, Land Application Program
Permit No. WQ0016966
Davidson County
Dear Ms. Jenkins:
On August 14, 2023, Division of Water Resources staff Jim Gonsiewski completed a review of
the 2022 Annual Report. This review mostly reflected compliance with the subject permit. The
following item of concern was noted:
Calcium, SAR, and pH were not included on the Residual Summary Form (RSF). Calcium and
SAR were provided after Mr. Gonsiewski contacted Troy Branch, ORC, to request this
additional information. Moving forward please refer to Permit Condition IV.3 for all
parameters that must be included on the Residual Sample Summary Form.
Pease refer to the enclosed compliance inspection report for additional observations and comments.
If you have any questions concerning this letter, you may contact Ms. Caitlin Caudle or me at
[phone].
Sincerely,
EDocuSigned by:
Loti -T. SMdU'
1-"49E225C94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Enc: Inspection Report
Cc: Davidson County Environmental Health (Electronic Copy)
Troy Branch - ORC (Electronic Copy)
Zach Key — US Biosolids (Electronic Copy)
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm,

Annual Report Review Class B Land Application Permit No. WQOO 16966
Reporting Period: 2022
Permit Details:
1
• Is 503 ® OR 257 ❑
• Maximum Dry Tons Per Year: 360
• Number of acres permitted: 127
• Number of fields in permit: 15
• Counties that land is permitted for: Davidson
• Monitoring Frequency for TCLP: Annually
• Monitoring Frequency for Residuals Analysis: Annually
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: Annually
• Groundwater monitoring:
Annual Land Application Certification Form
• Was a certification form submitted?
• Was land application conducted during the reported year?
• How many dry tons and dry tons per acre were applied? 34.15/1.24
• Were the applications within the permitted amount?
• Verify PAN if more than 10 tons/acre?
• Did it indicate compliance?
• Was it signed by the appropriate people?
2. Monitoring
• Were the analyses conducted at the required frequency?
• Was an analyses taken for each source that was land applied?
• Were the metals analyses reported on the Residual Sampling Summary Form?
• Were the results reported in mg/kg?
• Were the pH's 6.0 or greater for each residual sample?
• Were the heavy metals within ceiling concentration permit limits?
o Were the lab analyses attached?
• Were all the required parameters tested?
• Was TCLP analysis conducted?
• Were the TLCP contaminants within regulatory limits?
• Was a corrosivity, ignitability, and reactivity analysis conducted?
3. Field Summary (Class B Supplemental Field Form)
• Were all land application events recorded on the FSF and MFLS forms?
• How many fields were applied on this year?
• Was a Field Summary Form submitted for each field?
• Was the Regional Office notified prior to each land application event?
• Were all the residuals applied to permitted land?
• Were all the residuals applied from permitted sources?
• Were the field loading rates for each metal and PAN calculated (year to date)?
• Were the cumulative pollutant loading rates calculated?
• Were the calculations correct?
• Were the PAN loading rates within permit limits?
• Were the heavy metal cumulative pollutant loading rates within permit limits?
• Were the residuals applied on a suitable crop?
• Were the applications conducted during the crop's growing season?
• Were the Field Summary Forms complete?
• Was lime application on Field Summary Form?
❑Yes
VNo
®Yes
❑No
®Yes
❑No
®Yes
❑Yes
®Yes
®Yes
®Yes
®Yes
®Yes
®Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No
❑No

4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? ®Yes ❑No
• Did the form(s) indicate the period of coverage, the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used? ®Yes ❑No
Class B Pathogen Review
❑Alternative 1 — Fecal Coliform Densit
Was the sampling conducted at the required frequency? ❑Yes ❑No
Were seven samples taken? ❑Yes ❑No
Was the geometric mean calculated and done correctly? ❑Yes ❑No
Did the results show compliance (less than either 2,000,000 MPN/gram of total solids or 2,000,000
Colony Forming Units/gram of total solids)? ❑Yes ❑No
Alternative 2 — Use of Process to Sianificantiv Reduce Pathogens (one of five
Was the sampling conducted at the required frequency? ❑Yes ❑No
❑Aerobic Digestion
Was it an aerobic process (Inspection)? ❑Yes ❑No
Were logs submitted showing time and temperature? ❑Yes ❑No
Were temperatures within range for complete time period? ❑Yes ❑No
Was the time and temperature between 40 days at 200C (68°F) and 60 days at 150C (590F)?
❑Yes ❑No
❑Air Drying
Were the residuals on sand beds or pave or unpaved basins for three months? ❑Yes ❑No
Was the ambient temperature above 0°C (32°F) for two months? ❑Yes ❑No
Were the residuals partially digested? ❑Yes ❑No
Were residuals exposed to atmosphere during two months above 0°C (not snow covered)?
❑Yes ❑No
❑Anaerobic Digestion
'Was it an anaerobic process (Inspection)? ❑Yes ❑No
'Were logs submitted showing time and temperature? ❑Yes ❑No
•Were temperatures within range for complete time period? ❑Yes ❑No
'Was the time and temperature between 15 days at 35°C (95°F) to 550C (131°F) and 60 days at 20°C
(680F)? ❑Yes ❑No
❑Composting (usually will be Class A when composting is used) ❑Yes ❑No
Was it a composting procedure (not natural decay under uncontrolled conditions)?
❑Yes ❑No
Were logs submitted showing time and temperature? ❑Yes ❑No
See White House Manual for additional requirements.
®Lime Stabilization
Was alkaline material added to residuals a form of lime (hydrated lime, quicklime, lime containing kiln
dust or fly ash)? ®Yes ❑No
Were logs submitted showing time and temperature? ®Yes ❑No
Was the pH raised to 12 after two hours of contact? ®Yes ❑No
Were logs submitted showing time and pH? ®Yes ❑No
Was temperature corrected to 250C (77°F) (by calculation, NOT auto correct)? ❑Yes ❑No
❑Alternative 3 — Use of Processes Equivalent to RSRP
(Not commonly use. See White House Manual page 100-103, tables 11-1 and 11-2.)

Class B Vector Attraction Reduction Review
Was the sampling conducted at the required frequency? ❑Yes ❑No
I (Option 1 — 38% Volatile Solids Reduction
Was there 38% reduction? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
Was the reduction on volatile solids (not total solids)? ❑Yes ❑No
Were the samples taken at beginning of digestion process and before application (Inspection)?
❑Yes ❑No
Were calculations correct? ❑Yes ❑No
❑Option 2 — 40-Day Bench Scale Test
Were residuals from anaerobically digested treatment (Inspection)? ❑Yes ❑No
Was average temperature of the WWTP digester between 30°C (86°F) — 40°C (1041F)?
❑Yes ❑No
Were residuals anaerobically digested in lab? ❑Yes ❑No
Was the test run for 40 days? ❑Yes ❑No
Was the lab bench -scale test done between 30°C (86°F) and 37°C (991F)? ❑Yes ❑No
Was the reduction of on volatile solids (not total solids)? ❑Yes ❑No
Was the reduction less than 17%? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
Were calculations correct? ❑Yes ❑No
❑Option 3 — 30-Day Bench Scale Test
Were residuals from aerobically digested treatment (Inspection)?
❑Yes
❑No
Were residuals aerobically digested in lab?
❑Yes
❑No
Were residuals 2% or less total solids?
❑Yes
❑No
If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
❑Yes
❑No
Was the test run for 30 days?
❑Yes
❑No
Was the test done at 20°C (681F)?
❑Yes
❑No
Was the reduction of on volatile solids (not total solids)?
❑Yes
❑No
Was the reduction less than 15%?
❑Yes
❑No
Were lab sheets/calculations in report?
❑Yes
❑No
Were calculations correct?
❑Yes
❑No
❑Option 4 — Specific Oxygen Uptake Rate (SOUR)
Were residuals form aerobically digested treatment (Inspection)?
❑Yes
❑No
Were residuals 2% or less total solids (dry weight basis) (not diluted)?
❑Yes
❑No
Was the test done between 10°C (50°F) and 30°C (861F)?
❑Yes
❑No
Was the temperature corrected to 20°C (681F)?
❑Yes
❑No
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total residual solids
(dry
weight basis)?
❑Yes
❑No
Was the sampling holding time two hours?
❑Yes
❑No
Was the test started within 15 minutes of sampling or aeration maintained?
❑Yes
❑No
❑Option 5 — 14-Day Aerobic Process
Were the residuals from aerobically digested treatment (Inspection)? ❑Yes ❑No
Were the residuals treated for 14 days? ❑Yes ❑No
Was the residuals temperature higher than 40°C (104°F) for a 14-day period? ❑Yes ❑No
Was the average residuals temperature higher than 45°C (1131F)? ❑Yes ❑No

❑Option 6 — Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali? ®Yes ❑No
Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
®Yes ❑No
Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali? ®Yes ❑No
Was the pH corrected to 250C (77°F) (by calculation, NOT auto correct)? ❑Yes ❑No
❑Option 7 — Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals? ❑Yes ❑No
Were the residuals mixed with any other materials? ❑Yes ❑No
Were the residuals dried up to 75% total solids? ❑Yes ❑No
❑Option 8 — Drying of Unstabilized Residuals
Were the residuals mixed with any other materials? ❑Yes ❑No
Were the residuals dried to 90% total solids? ❑Yes ❑No
❑Option 9/10 — Injection/Incorporation
Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
❑Yes ❑No
Was injection done on pasture or hay field? ❑Yes ❑No
Was injection done at time that crop was growing? ❑Yes ❑No
If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? ❑Yes ❑No
Was incorporation done six hours after application (Inspection)? ❑Yes ❑No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? ❑Yes ❑No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
❑Yes ❑No
5. Soil Tests (Class B Supplemental Field Form)
• Was a Standard Soil Fertility Analysis conducted for each application field?
®Yes
❑No
• Were all the required parameters reported?
®Yes
❑No
• Were the soil pH's 6.0 or greater for each application field?
®Yes
❑No
• If no, was lime applied to those fields if recommended by the Agronomist?
❑Yes
❑No
• Were the copper and zinc indexes in the soil less than 2000 for each application field?
®Yes
❑No
• Was sodium less than 0.5 meq, and exchangeable sodium percentage (ESP)
less than 15%?
®Yes
❑No
6. General
• Was the report in the proper format?
❑Yes
❑No
• Was the annual report complete?
❑Yes
❑No
• Was the report submitted on time?
❑Yes
❑No

Pollutant Limits
Pollutant
Ceiling
Concentration
Below
Limit
Cumulative Pollutant
Loading Rate
Below
Limit
kg/ha
Ibs/ac
Arsenic
75
41
36
Cadmium
85
39
34
Copper
4300
1500
1338
Lead
840
300
267
Mercury
57
17
15
Molybdenum
75
N/A
N/A
Nickel
420
420
374
Selenium
100
100
89
Zinc
7500
2800
2498
TCLP
Parameter
Below
Limit
Parameter
Below
Limit
Parameter
Below
Limit
Arsenic 5.0
1,4-Dichlorobenzene 7.5
Nitrobenzene 2.0
Barium 100.0
12-Dichloroethane 0.5
Pentachloro henol 100.0
Benzene 0.5
1 1-Dichloroeth lene 0.7
Pyridine 5.0
Cadmium 1.0
2,4-Dinitrotoluene 0.13
Selenium 5.0
Carbon tetrachloride 0.5
Endrin 0.02
Silver 5.0
Chlorodane (0.03)
Hepatachlor (and its
epoxide) 0.008
Tetrachloroethylene (0.7)
Chlorobenzene 100.0
Hexachlorobenzene 0.13
Toxa hene 0.5
Chloroform 6.0
Hexachlorobutadiene 0.5
Trichloroeth lene 0.5
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol
400.0
m-Cresol 200.0
Lead 5.0
2,4,6-Trichloro henol 2.0
o-Cresol 200.0
Lindane 0.4
2 4 5-TP Silvex 1.0)
-Cresol 200.0
Mercury 0.2
Vinyl Chloride 0.2
Cresol 200.0
Metho chlor 10.0
2,4-D 10.0
Methyl ethyl Ketone 200.0
Residuals Analysis
Parameter
Analyzed
For
Parameter
Analyzed For
Parameter
Analyzed For
Aluminum
x
Mercury
x
Potassium
x
Ammonia-
Nitrogen
X
Molybdenum
X
Selenium
X
Arsenic
x
Nickel
x
Sodium
x
Cadmium
X
Nitrate -Nitrite
Nitrogen
X
SAR
Calcium
% TS
x
TKN
x
Copper
x
pH
Zinc
x
Lead
x
Phosphorus
x
Magnesium
x
PAN
x
Soils Analysis
Parameter
Analyzed For
Parameter
Analyzed For
Parameter
Analyzed For
Acidity
ESP
Phosphorus
Base Saturation
Magnesium
Potassium
Calcium
Manganese
Sodium
CEC
% HM
Zinc
Copper
pH

Compliance Inspection Report
Permit: WQ0016966 Effective: 04/14/20 Expiration: 09/30/26 Owner : Town of Denton
SOC: Effective: Expiration: Facility: Town of Denton RLAP
County: Davidson 300 Council Access Rd
Region: Winston-Salem
Denton NC 27239
Contact Person: Zach D Key Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0026689 Town of Denton - Denton WWTP
NC0082949 Town of Denton - Denton WTP
Inspection Date: 08/14/2023 Entry Time 08:OOAM
Primary Inspector: Jim J Gonsiewski
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 01:20PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Sampling
Pathogen and Vector Attraction Wells
(See attachment summary)
Page 1 of 4

Permit: WQ0016966 Owner - Facility: Town of Denton
Inspection Date: 08/14/2023 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
On August 14, 2023, Division of Water Resources staff Jim Gonsiewski completed a review of the 2022 Annual Report. This
review mostly reflected compliance with the subject permit.
The following item of concern was noted:
• Calcium, SAR, and pH were not included on the Residual Summary Form (RSF). Calcium and SAR were provided after Mr.
Gonsiewski contacted Troy Branch, ORC, to request this additional information. Moving forward please refer to Permit
Condition IV.3 for all parameters that must be included on the Residual Sample Summary Form.
Other observations:
• Residuals and TCLP sampling were completed on 3/30/2022.
• SAR was not included on the RSF but was calculated to be 7.91 by the Denton staff.
• pH was not included on the RSF. Troy Branch, ORC, stated that the pH is measured after lime stabilization.
• 34.15 dry tons of residuals were applied.
Page 2 of 4

Permit: WQ0016966 Owner - Facility: Town of Denton
Inspection Date: 08/14/2023 Inspection Type: Annual Report Review
Reason for Visit: Routine
Type
Yes No NA NE
Distribution and Marketing
❑
Land Application
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑
❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑ 0 ❑
Are there any GW quality violations?
❑
❑ 0 ❑
Is GW-59A certification form completed for facility?
❑
❑ 0 ❑
Is a copy of current permit on -site?
0
❑ ❑ ❑
Are current metals and nutrient analysis available?
0
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
0
❑ ❑ ❑
a. TCLP analysis?
0
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
0
❑ ❑ ❑
Are PAN balances being maintained?
0
❑ ❑ ❑
Are PAN balances within permit limits?
0
❑ ❑ ❑
Has land application equipment been calibrated?
❑
❑ ❑
Are there pH records for alkaline stabilization?
0
❑ ❑ ❑
Are there pH records for the land application site?
0
❑ ❑ ❑
Are nutrient/crop removal practices in place?
0
❑ ❑ ❑
Do lab sheets support data reported on Residual Analysis Summary?
0
❑ ❑ ❑
Are hauling records available?
❑
❑ ❑
Are hauling records maintained and up-to-date?
❑
❑ ❑
# Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ ❑
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

Permit: WQ0016966 Owner - Facility: Town of Denton
Inspection Date: 08/14/2023 Inspection Type: Annual Report Review
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:
Nutrients, metals, TCLP.
Is sampling adequate?
Is sampling representative?
Comment:
Reason for Visit: Routine
❑ ❑ ❑ ❑
■❑❑❑
❑ ❑ ❑ ❑
Yes No NA NE
Page 4 of 4