WQ0010059_NOV-2024-PC-0400_CEIARR 2023_20240618

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED

June 18, 2024

Jeff Church, Director Public Utilities
City of Lenoir
Email: [e-mail]

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0400
Compliance Inspection Report
Annual Report Review 2023
Permit No. WQ0010059
City of Lenoir DCAR
Caldwell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Lenoir DCAR on June 18,
2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and
limitations specified in Non-discharge Permit No. WQ0010059. A summary of the findings and comments noted
during the inspection are provided in the enclosed copy of the inspection report.

The Annual Report Review inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following violation(s) were noted during the inspection:

Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Pathogen and Vector Attraction The 1st quarter pathogen and vector attraction reduction samples were not collected. _________________________________________________________________________________________________________________________________________________________________________
Record Keeping The 1st quarter residuals analysis samples were not collected. The following residuals
analyses were not analyzed for and reported, per permit condition IV.3: pH, and potassium. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law.
If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Compliance Evaluation Inspection Report

Ec: LF, Lisa Triplett (ORC)
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Compliance Inspection Report
Permit:WQ0010059 Effective:11/10/20 Expiration:10/31/26 Owner :City of Lenoir
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Caldwell
Asheville
Scott Hildebran
Effective:Expiration:Facility:City of Lenoir DCAR
1905 Broadland Rd
Lenoir NC 28645
Title:Phone:[phone]
From Hwy. 64 East in Lenoir turn right onto Southwest Blvd. Take the first exit off Southwest to Virginia ST. (left on Virginia St.)
Continue to Broadland Rd. on the right. Facility is approximately 1/2 mile on the left.
Secondary ORC(s):
828-757-2198Phone:[phone]Certification:Elisa Robbins TriplettPrimary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0023736 City of Lenoir - Gunpowder Creek WWTP
NC0023981 City of Lenoir - Lower Creek WWTP
NC0027286 Town of Blowing Rock - Blowing Rock WWTP
NC0044164 City of Lenoir - Lake Rhodhiss WTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/18/2024 10:00AM 01:00PM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/18/2024 Annual Report Review
City of Lenoir
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of the City of Lenoir’s DCAR Annual Report to
determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0010059.
The City produced approximately 1,365 dry tons of Class A product in 2023, and distributed approximately 821 dry tons.
Non-hazardous waste characterization is required once per permit cycle: The City sampled for TCLP, corrosivity, reactivity
and ignitability in July of 2021 and has met the permit requirement. All results were within regulatory requirements.
Pathogen Reduction (PR): PR is met via fecal coliform density reduction below 1,000 MPN/gram and PFRP Heat Drying. All
fecal results were less than 1,000 MPN/g and all dryer runs appear to meet or exceed the 80°C temperature requirement.
Quarterly PR samples were not collected in the 1st quarter of 2023.
Vector Attraction Reduction (VAR): Facility meets Pathogen Reduction requirement via VAR method-Drying of Unstabilized
Residuals. Bench sheets provided with the report indicated compliance with this method. Please note that temperature units
were not provided on the bench sheets.
Metals, Nutrients & Pollutants of Concern: Required frequency is based on tons distributed. The facility distributed 821 dry
tons of residuals in 2023 which required quarterly sampling. Note that samples were not collected in the 1st quarter. The
samples collected for the 2nd, 3rd, and 4th quarters were below ceiling and monthly concentration limits outlined in Section
II.4 of the permit. A few of the parameters listed in Section IV.3 were not included on form RSSF including: pH (only sampled
4th quarter but not provided on form), potassium (no samples collected), PAN (calculated for 2nd, 3rd, and 4th quarters but
not provided), and SAR (calculated for 4th quarter only but not provided). Based on sample results, calculated SAR values
were less than 10.
The following violations were noted:
•The 1st quarter residuals analysis were not collected. The following residuals analyses were not collected and reported at
the required frequencies, per permit condition IV.3: pH and potassium.
•The 1st quarter pathogen and vector attraction reduction samples were not collected.
The following issues were noted with the report:
•All SAR and PAN values were not calculated and provided on form RSSF.
•Temperature units were not provided on the bench sheets.
Page 2 of 4
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/18/2024 Annual Report Review
City of Lenoir
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping Yes No NA NE
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?
Class A residuals are distributed for public use. Residuals analysis were not collected for the
1st quarter, per permit requirements. Some required analyses were not performed - see
summary for details.
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)
Page 3 of 4
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/18/2024 Annual Report Review
City of Lenoir
Routine
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
PFRP heat drying is used to meet pathogen reduction. Note that quarterly PR samples were
not collected in the 1st quarter, per permit requirements. Please include temperature units on
future bench sheets.
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
VAR alternative 8 (drying of unstabilized residuals) is utilized.Comment:
Page 4 of 4
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Annual Report Review Class A Distribution Permit No. WQ00_________

Reporting Period: ___________

Permit Details:

• Is 503 OR 257
• Maximum Dry Tons Per Year: ________
• Monitoring Frequency for TCLP: ________
• Monitoring Frequency for Residuals Analysis: ________
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: ________

1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? Yes No
• Was distribution conducted during the reported period? Yes No
• How many dry tons were produced and distributed? ________
• Were the distributions with the permitted amount? ________
• Were recipient’s information listed? ________
• Did it indicate compliance? Yes No
• Was form complete? Yes No
• Was it signed by the appropriate people? Yes No

2. Monitoring
• Were the analyses conducted at the required frequency? Yes No
• Was an analyses taken for each source that was distributed? Yes No
• Were the metals analyses reported on the Residual Sampling Summary Form? Yes No
• Were the results reported in mg/kg? Yes No
• Were the pH’s 6.0 or greater for each residual sample? Yes No
• Were the heavy metals within ceiling concentration permit limits? Yes No
o Were the lab analyses attached? Yes No
• Were all the required parameters tested? Yes No
• Was TCLP analysis conducted? Yes No
• Were the TLCP contaminants within regulatory limits? Yes No
• Was a corrosivity, ignitability, and reactivity analysis conducted? Yes No

10059
2023
1671
1365 produced, 821 distributed
once per permit cycle
quarterly
quarterly
yes
yes
Comment: Did not collect 1st of the quarterly samples. All residuals are combined and they are only required to collect samples from the blended residuals. The following were not reported on the RSSF form: pH, PAN, potassium, SAR.SAR and PAN values were calculated as follows:2nd quarter: SAR (1.05), PAN (1,130 mg/kg)3rd quarter: SAR (1.21), PAN (12,800 mg/kg)4th quarter: SAR (1.08), PAN (2,092 mg/kg)The City sampled for TCLP, corrosivity, reactivity and ignitability in July of 2021 and has met the permit requirement. All results met regulatory requirements.
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
3. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? Yes No
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? 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

Class A Pathogen Review

To be Class A, residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 1000 MPN/gram of total solids? Yes No

OR

Salmonella density
· Was the sampling conducted at the required frequency? Yes No
· Were multiple samples taken? Yes No
· Was each sample less than 3 MPN/4 grams of total solids? Yes No

To be Class A, residuals shall meet one of the following alternatives:

Alternative 1 – Time/Temperature
· Were the residuals maintained for correct time and temperature? Yes No
· Were logs submitted showing time and temperature? Yes No
· Were temperatures within range for complete time period? Yes No

Alternative 2 – Alkaline Treatment
· Were logs submitted showing time and temperature? Yes No
· Was the pH raised to 12 or greater and maintained for 72 hours or longer? Yes No
· Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
Yes No
· Were logs submitted showing time and pH? Yes No
· Was the temperature corrected to 25°C (77°F)? Yes No

Alternative 5 – Process To Further Reduce Pathogens
PFRP Composting
· Were the within-vessel method or static aerated pile methods used? Yes No
· Was the residuals temperature maintained at 55°C (131°F) or higher for three consecutive days or
longer in the within-vessel method or static aerated pile method? Yes No
OR
· Was the windrow composting method used? Yes No
· Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or longer in the
windrow method, and the windrow turned a minimum of five times during this time? Yes No
PFRP Heat Drying
· Was the residuals dried by direct or indirect contact with hot gases and the moisture content of
residuals reduced to 10% or lower? Yes No
· Did the temperature of the residuals or the of the wet bulb temperature of the gas in contact with the
residuals as the residuals leave the dryer exceed 80°C (176°F)? Yes No

Comments: Please include temperature units on the Temperature and %Solids of Dry Product bench sheet included with the report.
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Vector Attraction Reduction Review

• Was the sampling conducted at the required frequency? Yes No

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
· Were residuals anaerobically digested in lab? Yes No
· Was the test run for 40 days? Yes No
· Was the test done between 30°C (86°F) and 37°C (99°F)? 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 (68°F)? 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 (86°F)? Yes No
· Was the temperature corrected to 20°C (68°F)? 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 (113°F)? Yes No

DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
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 without the
addition of more alkali? Yes No
· Was the pH corrected to 25°C (77°F)? 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

4. 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
Comment: Note that quarterly Pathogen Reduction samples were not collected in the 1st quarter.
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04
Pollutant Limits
Pollutant Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic 75 41
Cadmium 85 39
Copper 4300 1500
Lead 840 300
Mercury 57 17
Molybdenum 75 N/A
Nickel 420 420
Selenium 100 100
Zinc 7500 2800

TCLP
Parameter Below
Limit
Parameter Below
Limit
Parameter Below
Limit
Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0)
Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0)
Benzene (0.5) 1,1-Dichloroethylene (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) Toxaphene (0.5)
Chloroform (6.0) Hexachlorobutadiene (0.5) Trichloroethylene (0.5)
Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol
(400.0)

m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0) Mercury (0.2) Vinyl Chloride (0.2)
Cresol (200.0) Methoxychlor (10.0)
2,4-D (10.0) Methyl ethyl Ketone (200.0)

Residuals Analysis
Parameter Analyzed For Parameter Analyzed For Parameter Analyzed For
Aluminum Mercury Potassium
Ammonia-
Nitrogen
Molybdenum Selenium
Arsenic Nickel Sodium
Cadmium Nitrate-
Nitrite
Nitrogen
SAR
Calcium % TS TKN
Copper pH Zinc
Lead Phosphorus
Magnesium PAN

y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
y
NS
y
y
NS
y
y
y
y
y
DocuSign Envelope ID: DF5A5928-4920-489E-A001-03BA3DD9AC04