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HomeMy WebLinkAboutWQ0005763_NOD-2018-PC-0115_20180313 State of North Carolina | Environmental Quality | Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 March 13, 2018 Dan Harbaugh Tuckaseigee Water & Sewer Authority 1246 W Main St Sylva, NC 28779 SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2018-PC-0115 Annual Report (2016) Review Permit No. WQ0005763 Jackson County WWTP Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Jackson County WWTP on December 18, 2017. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0005763. 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 deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Pathogen and Vector Attraction Alternative 5 - PFRP - Heat Drying - 90% moisture reduction requirement not met on 8 separate sampling events. _________________________________________________________________________________________________________________________________________________________________________ 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, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388 State of North Carolina | Environmental Quality | Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Stan Bryson WQS ARO Server LF 20180313_WQ0005763_NOD2018PC0115.rtf DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388 Compliance Inspection Report Permit:WQ0005763 Effective:09/11/14 Expiration:07/31/19 Owner :Tuckaseigee Water & Sewer Authority SOC: Contact Person: Region: County: Directions to Facility: Jackson Asheville Dan Harbaugh Effective:Expiration:Facility:Jackson County WWTP 1871 N River Rd Sylva NC 28779 Title:Phone:828-586-5189 Ext.203Executive Director Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: 24 hour contact name Stan D Bryson 828-586-9318 On-Site Representative(s): Related Permits: NC0063321 Tuckaseigee Water & Sewer Authority - TWSA Plant #3 NC0087602 Tuckaseigee Water & Sewer Authority - Whittier WWTP NC0020214 Tuckaseigee Water & Sewer Authority - TWSA WWTP#2 NC0039578 Tuckaseigee Water & Sewer Authority - Jackson County WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 12/18/2017 03:00PM 04:00PM Beverly Price 828-296-4500 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 Pathogen and Vector Attraction (See attachment summary) Page:1 DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 12/18/2017 Annual Report Review Tuckaseigee Water & Sewer Authority Routine Inspection Summary: The inspection consisted of a review of the 2016 Annual Report. The review was conducted by Beverly Price of the Asheville Regional Office. 54 dry tons of residuals were distributed in 2016. 90.09 tons of residuals were hauled in 2016 by private contractor to: R&B Landfill - operated by Waste Management Inc. 610 Frank Bennett Road Homer Ga. 30080 Residuals were monitored for metals/nutrients/TCLP/Ignitability/Corrosivity/Reactivity - Analytical results appeared to be compliant with permit conditions. Pathogen Reduction verification via Fecal Coliform Density: requirements were met. Two fecal coliform samples collected from the silo in November exceeded the limit for Class A residuals. Three additional samples were collected and results were compliant. Pathogen/Vector Attraction Reduction verification via Alternative #5 - Heat Drying - Eight dryer runs appeared to not meet the moisture reduction requirement of 90%. Page:2 DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 12/18/2017 Annual Report Review Tuckaseigee Water & Sewer Authority 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? 54 dry tons of residuals were distributed to the public in 2016 - hauling records were provided. 90.09 tons of residuals were landfilled in 2016. Hauling tickets were not provided in the Annual Report but are available upon request per Stan Bryson. 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 DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 12/18/2017 Annual Report Review Tuckaseigee Water & Sewer Authority 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 Comment: Page:4 DocuSign Envelope ID: E29416A5-FF92-4DEA-8B76-75EE30C6E388