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Home My WebLink AboutWQ0013263_Compliance Evaluation Inspection_20231214ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality December 14, 2023 Delivered via email to: amy.davis(a)-townofboone.net Amy Davis — Town Manager Town of Boone P.O. Box 192 Boone, NC 28607 SUBJECT: Compliance Evaluation Inspection Town of Boone, High Country Drying Facility Permit No. WQ0013263 Watauga County Dear Ms. Davis: On December 12, 2023 Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection of the Town of Boone Distribution of Class A Residuals Program. Kenneth Howell and Mike Everette, Town of Boone, were present during the entire inspection. A review of available records, residuals processing facility, and storage structures was completed. This review reflected compliance with the subject permit. The following items of concern were noted: A. Per Permit Conditionlll.9 the Permittee shall notify all third -party entities receiving bulk Class A residuals that land application activities occurring on the third-party's property shall meet ... Permit Condition 11.7.a. and 111.8. Please update the information sheet provided to third -party recipients to include the updated requirements in Permit Condition 111.8. B. Permit Condition 111.2 lists all information to be included in the Operation and Maintenance Plan. Please update the Operation and Maintenance Plan based on the required information in the above referenced permit condition. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, contact Ms. Caudle at the letterhead address and phone number, or by email at Caitlin.caudle(aD_deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F167456_. Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Mike Everette, Town of Boone (electronic copy) Kenneth Howell, Town of Boone (electronic copy) Watauga County Environmental Health (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 1 Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm Compliance Inspection Report Permit: WQ0013263 Effective: 10/01/19 Expiration: 12/31/24 Owner: Town of Boone SOC: Effective: Expiration: Facility: Town of Boone DCAR County: Watauga 201 Casey Ln Region: Winston-Salem Boone NC 286070192 Contact Person: Mike Everett Title: Chief Operator Phone: 828-268-6270 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): Certification: On -Site Representative(s): On -site representative Kenneth Paul Howell Related Permits: NC0020621 Town of Boone - Jimmy Smith WWTP Inspection Date: 12/12/2023 Entry Time 10:08AM Primary Inspector: Caitlin u PecuSignedby: Secondary Inspector(s): rulti l�D_ 8B834968199D49D... Kristen Potwora Reason for Inspection: Routine Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Phone: Exit Time: 11:OOAM Phone: 336-776-9699 Inspection Type: Compliance Evaluation Miscellaneous Questions Record Keeping Sampling Pathogen and Vector Attraction (See attachment summary) Treatment Storage Page 1 of 4 Permit: WQ0013263 Owner - Facility: Town of Boone Inspection Date: 12/12/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On December 12, 2023 Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection of the Town of Boone Distribution of Class A Residuals Program. Kenneth Howell and Mike Everette, Town of Boone, were present during the entire inspection. A review of available records, residuals processing facility, and storage structures was completed. This review reflected compliance with the subject permit. The following items of concern were noted: A. Per Permit Conditionlll.9 the Permittee shall notify all third -party entities receiving bulk Class A residuals that land application activities occurring on the third-party's property shall meet ... Permit Condition 11.7.a. and 111.8. Please update the information sheet provided to third -party recipients to include the updated requirements in Permit Condition 111.8. B. Permit Condition 111.2 lists all information to be included in the Operation and Maintenance Plan. Please update the Operation and Maintenance Plan based on the required information in the above referenced permit condition. Ms. Caudle discussed the upcoming permit renewal with Mr. Howell and provided additional information related to the permit renewal on 12/12/2023. Other observations: • Kenneth Howell will be managing the residuals program as Mike Everette will be retiring soon. • Residuals are distributed to farms for application to pasture and hay fields. • Nutrients and metals, and fecals are sampled quarterly. Samples were last collected on 10/4/2023 and fecals analyzed on 10/19/2023. • TCLP was last analyzed in 2022. • The drier is run weekly. Each shift does regular maintenance checks on the drier when operational. • Maintenance personnel record all major repairs. • A UV disinfection system is being installed. Ms. Caudle reminded Mr. Howell that an updated flow plan must be submitted with the permit renewal application. • A polymer is added to the stabilized residuals before being pressed and dried. • Residuals are stored on a covered concrete pad before distribution. Approximately 500 tons can be stored, equivalent to six months to a year of storage. • Newly made residuals are isolated until all pathogen and vector attraction reduction requirements are met. • Samples are collected from final drier products. • Flow at the WWTP averages 2.5 MGD. • Two 800,000 gallon digestors are used to store stabilized residuals before being dewatered and dried. Page 2 of 4 Permit: WQ0013263 Owner - Facility: Town of Boone Inspection Date: 12/12/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Land Application ❑ Distribution and Marketing 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? ❑ ❑ ❑ Are PAN balances within permit limits? ❑ ❑ 0 ❑ Has land application equipment been calibrated? ❑ ❑ 0 ❑ 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? ❑ ❑ ❑ Are hauling records available? 0 ❑ ❑ ❑ Are hauling records maintained and up-to-date? 0 ❑ ❑ ❑ # 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) 0 ❑ ❑ ❑ 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: WQ0013263 Owner - Facility: Town of Boone Inspection Date: 12/12/2023 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 Yes No NA NE Check all that apply Aerobic Digestion ❑ Anaerobic Digestion ❑ Alkaline Pasteurization (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost ❑ Drying Beds ❑ Other Comment: Heat Drying Sampling Yes No NA NE Describe sampling: Is sampling adequate? 0 ❑ ❑ ❑ Is sampling representative? 0 ❑ ❑ ❑ Comment: Page 4 of 4