WQ0036561_Inspection Letter_20240606

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 6, 2024
Delivered electronically via email to: johnsonra(c�danvilleva.gov
Alan Johnson — Director
City of Danville
279 Park Avenue
Danville, VA 24541
SUBJECT: Compliance Evaluation Inspection
Danville Residuals Land Application Program
Permit No. WQ0036561
Caswell County
Dear Mr. Johnson:
On May 29, 2024, Division of Water Resources staff Caitlin Williams conducted a routine
compliance inspection of the Danville Residuals Land Application Program. Brent Collins,
EMA Resources, was present during the entire inspection. A review of available records,
storage structures, transport vehicles, and land application activities was completed. This
review reflected compliance with the subject permit.
The following items of concern were noted:
Per Permit Condition 111.10 the Permittee shall ensure that the permit and
Division -approved Operation and Maintenance (O&M) Plan are available when
land applying residuals. All transport vehicles and land application vehicles had
a copy of the permit and O&M Plan, including the Spill Plan, available for
review. One transport vehicle had the 2018 permit and all O&M Plans reviewed
had an outdated contact number for the Winston Salem Regional Office. An
updated copy of the O&M Plan was provided on June 3, 2023. Please ensure
all vehicles have the most recent O&M Plan and most recent permit.
Per Permit Condition V.2 the Permittee shall inspect the Permittee's
treatment, storage, distribution, and application facilities to prevent malfunction,
facility deterioration, and operator errors that may result in discharges of wastes
to the environment, threats to human health, or public nuisances. During the
inspection, several groundhog holes and small trees were observed along the
berm dividing the two concrete lined storage basins. Please fill the holes and
remove the trees to prevent any future damage to the concrete liners.
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

Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact Caitlin Williams at the letterhead address and
phone number, or by email at caitlin.williams(a--)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: Brent Collins, EMA Resources (electronic copy)
Caswell County Environmental Health (electronic copy)
D North Carolina Department of Environmental Quality I Division of Water Resources
✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly

Compliance Inspection Report
Permit: WQ0036561 Effective: 07/10/23 Expiration: 05/31/30 Owner: City of Danville
SOC: Effective: Expiration: Facility: City of Danville Class B Residuals Program
County: Out of State 229 Northside Dr
Region: Winston-Salem
Danville VA 24540
Contact Person: Charles Richard Overby Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Brent M Collins
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/29/2024 Entry Time 09:30AM
Primary Inspector: Caitlin Williams
Secondary Inspector(s):
Certification: 27651 Phone:[phone]
Exit Time: 11:30AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Land Application Site Pathogen and Vector Attraction
Storage Transport
(See attachment summary)
Page 1 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 05/29/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On May 29, 2024, Division of Water Resources staff Caitlin Williams conducted a routine compliance inspection of the
Danville Residuals Land Application Program. Brent Collins, EMA Resources, was present during the entire inspection. A
review of available records, storage structures, transport vehicles, and land application activities was completed. This review
reflected compliance with the subject permit.
The following items of concern were noted:
• Per Permit Condition 111.10 the Permittee shall ensure that the permit and Division -approved Operation and Maintenance
(O&M) Plan are available when land applying residuals. All transport vehicles and land application vehicles had a copy of the
permit and O&M Plan, including the Spill Plan, available for review. One transport vehicle had the 2018 permit and all O&M
Plans reviewed had an outdated contact number for the Winston Salem Regional Office. An updated copy of the O&M Plan
was provided on June 3, 2023. Please ensure all vehicles have the most recent O&M Plan and most recent permit.
• Per Permit Condition V.2 the Permittee shall inspect the Permittee's treatment, storage, distribution, and application
facilities to prevent malfunction, facility deterioration, and operator errors that may result in discharges of wastes to the
environment, threats to human health, or public nuisances. During the inspection, several groundhog holes and small trees
were observed along the berm dividing the two concrete lined storage basins. Please fill the holes and remove the trees to
prevent any future damage to the concrete liners.
Field Observations:
CS-06-03
• Land application was taking place at the time of inspection, and during the previous week.
• All buffers were clearly marked.
• Vegetation was well established with fescue pasture.
• Land application was even with no evidence of ponding and runoff.
• PAN average of available data was 31lbs/6,200 gallons.
• Expected application rate was 3x6,200 gallons per acre.
CS-06-05
• The area that was newly cleared when permitted has established vegetation.
• Land application activities will move to this field once completed in 03.
Other observations:
• Biosolids were being land applied from Basin B.
• TCLP was sampled on 4/8/24.
• Fecal samples from 4/8/24, 4/22/24, and 5/6/24 were reviewed. All sample events reflected compliance with the permit.
• 30 day bench scale from 4/8/24 was reviewed and reflected compliance with the permit.
• Nutrient and metals samples from 4/8/24, 4/22/24, and 5/6/24 were reviewed. All sample events reflected compliance
with the permit.
• Field inspections and loading calculations were reviewed.
• Sampling is still completed by collecting grab samples from each catwalk to make a composite sample.
Page 2 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 05/29/2024 Inspection Type: Compliance Evaluation
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?
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?
0
❑ ❑ ❑
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 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 05/29/2024 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 0 ❑ ❑ ❑
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:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate? 0 ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Transport
Yes No NA NE
Is a copy of the permit in the transport vehicle? ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? ❑ ❑ ❑
Is the spill control plan satisfactory? ❑ ❑ ❑
Does transport vehicle appear to be maintained? 0 ❑ ❑ ❑
Comment: See summary.
Land Application Site Yes No NA NE
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?
Page 4 of 5

Permit: WQ0036561 Owner - Facility: City of Danville
Inspection Date: 05/29/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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?
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:
Page 5 of 5