WQ0001990_NOV-2024-PC-0423_20240702_CEIARR

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

July 02, 2024

Bo Weichel, Assistant Manager Town
Town of Valdese
PO Box 339
Valdese, NC 28690

SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0423
Permit No. WQ0001990
Town of Valdese Class A Residuals Composting Program
Compliance Inspection Report
Annual Report Review 2023
Burke County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Town of Valdese Class A
Residuals Composting Program on July 2, 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. WQ0001990. 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 _________________________________________________________________________________________________________________________________________________________________________ Record Keeping Ammonia was not analyzed in the 3rd quarter. _________________________________________________________________________________________________________________________________________________________________________
Record Keeping Fourth quarter samples were not collected. It should be noted that the 4th quarter results
provided with the 2023 Annual Report were collected in February 2024. _________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820

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.

To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice
of Violation regarding your plans or measures to be taken to address the indicated violations and other identified
issues, if applicable.

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, Lonnie Laird (ORC, Superintendent)
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
Compliance Inspection Report
Permit:WQ0001990 Effective:07/01/24 Expiration:06/30/32 Owner :Town of Valdese
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Burke
Asheville
Christopher John Bortnick
Effective:Expiration:Facility:Town of Valdese Class A Residuals Composting Program
2100 Lake Rhodhiss
Valdese NC 28690
Title:Phone:[phone]
From downtown Valdese, take 70E to left on Laurel Street, right on Lovelady Road, left on Lake Rhodiss Dirve, WWTP is located at
the end of the road.
Secondary ORC(s):
828-874-6763Phone:[phone]Certification:Lonnie LairdPrimary ORC:
System Classifications:
On-Site Representative(s):
Related Permits:
NC0041696 Town of Valdese - Lake Rhodhiss WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
07/02/2024 10:00AM 02:00PM
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: 4B96D536-AC9F-4469-9A42-453CD02BA820
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001990
07/02/2024 Annual Report Review
Town of Valdese
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a review of the Town of Valdese’ s 2023 DCAR Annual Report
to determine whether the facility processed and monitored all residuals in compliance with Permit No. WQ0001990.
The Town distributed approximately 310 dry tons of Class A Compost to customers in 2023. Please resume submitting the
dry tons calculation worksheet and/ or include the conversion on the customer distribution sheet.
Pathogen Reduction (PR) is met via fecal coliform density reduction below 1,000 MPN/g and through PFRP Option E:
composting. The static aerated piles appeared to exceed 55°C for at least three consecutive days. The Town is currently
collecting one fecal sample and a duplicate every quarter. All reported results are less than 1,000 MPN/g. It is
recommended multiple fecal samples are collected over a two-week period to obtain a better representation of the residual
quality.
Vector Attraction Reduction (VAR): VAR is met via the 14-day aerobic process (Option 5). All constructed piles appeared to
exceed 40°C for at least 14 consecutive days and had an average temperature that exceeded 45°C.
Metals, Nutrients & Pollutants of Concern: Values were below the monthly and ceiling concentration limits for Class A
products. All metals and nutrient parameters were analyzed per section IV.3 of the permit, except for Ammonia in the 3rd
quarter. It should be noted that “4th quarter” samples were collected in February 2024. PAN & SAR balances are being
calculated and maintained quarterly, although backup calculations were not provided. SAR values for 2023 were below 10.
Metals and Nutrients under section IV.3 will be required on the source residuals before the end of the permit cycle.
Non-Hazardous Waste Characterization: Please note that the non-hazardous waste characterization of the source residuals
was removed from the permit as of 2022. Non-hazardous waste characterization of the distributed product will need to be
collected before the permit expires in 2023.
The following issues were noted with the report:
•All supplemental lab reports were missing with the original submittal but were provided upon request. Please include these
with future submittals.
•The PAN and SAR calculations were not provided with the report. In some cases, PAN/SAR calculations did not match
what was provided on form RSSF.
•On form RSSF, please include the MQL value (i.e. <0.05 vs *) for results that are below lab limits.
•The fecal coliform results provided on form PVRF do not match the bench sheets. Minimum is 49, geometric mean is 113,
and maximum is 485.
The following violation was noted:
•Fourth quarter samples were not collected. It should be noted that the 4th quarter results provided with the 2023 Annual
Report were collected in February 2024.
•Ammonia was not analyzed in the 3rd quarter.
Page 2 of 4
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001990
07/02/2024 Annual Report Review
Town of Valdese
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. Fourth quarter samples were not collected. It
should be noted that the 4th quarter results provided with the 2023 Annual Report were
collected in February 2024. Ammonia was not analyzed in the 3rd quarter. Lab reports were
not provided with original submittal but provided upon request. 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: 4B96D536-AC9F-4469-9A42-453CD02BA820
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001990
07/02/2024 Annual Report Review
Town of Valdese
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
It should be noted that the fecal coliform results provided on form PVRF do not match the
bench sheets. See summary for details.
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
Bench sheets for composting were provided.Comment:
Page 4 of 4
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
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

01990
2023
2500
once per permit cycle
Annually
Annually
309.62
yes
yes
Comments: -For samples below MQL, please provide value i.e. "<3.1" on form RSSF. -Lab reports not included with original submission but were provided after submittal.-Fourth quarter samples were not collected, and it should be noted that results provided were collected in February 2024.-TCLP not sampled but only required once per permit cycle (before 06/2032).-PAN and SAR calcuations not provided. Some calculations varied from what was provided: -PAN 4/13: 142 mg/kg; 5/30: 1,484 mg/kg; 3/11: 366 mg/kg -SAR 3/11: 0.21-Ammonia was not sampled for in October 2023.
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
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

Comment: Fecal density values were reported incorretly on form PVRF. Minimum is 49, geo. mean is 122, and maximum is 485.
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
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: 4B96D536-AC9F-4469-9A42-453CD02BA820
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
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820
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
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y
y
y
y
y
y
y
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y
y
y
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y
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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
DocuSign Envelope ID: 4B96D536-AC9F-4469-9A42-453CD02BA820