WQ0010059_Compliance Evaluation Inspection_20181030

North Carolina Department of Environmental Quality | Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

October 30, 2018

Radford Thomas
City of Lenoir
PO Box 958
Lenoir, NC 28645

SUBJECT: Compliance Inspection Report
City of Lenoir, Lenoir Blends Processing Facility and Distribution Program
Annual Report Review (2017)
Non-discharge Permit No. WQ0010059
Caldwell County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the City of Lenoir, Lenoir
Blends Processing Facility and Distribution Program on 6/29/2018. 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. The findings and comments noted during this inspection are
provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

North Carolina Department of Environmental Quality | Division of 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 me at 828-296-4500 or via email at
[e-mail].

Sincerely,

Beverly Price, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Elisa Triplett
WQS ARO Server
LF

Compliance Inspection Report
Permit:WQ0010059 Effective:08/01/15 Expiration:07/31/20 Owner :City of Lenoir
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Caldwell
Asheville
Elisa Triplett
Effective:Expiration:Facility:City of Lenoir Lenoir Blends Processing Facility and Distribution Program
1905 Broadland Rd
Lenoir NC 28645
Title:Phone:[phone]Wastewater Treatment Plant Superintendent
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):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Elisa Robbins Triplett 828-757-2198
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
06/29/2018 09:00AM 10:00AM
Beverly Price 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Follow-up
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Pathogen and Vector Attraction
(See attachment summary)
Page:1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/29/2018 Annual Report Review
City of Lenoir
Follow-up
Inspection Summary:
The inspection (2017 Annual Report Review) was conducted by Beverly Price of the Asheville Regional Office.
The following information was missing from the report:
1. Lab sheets for the following metals were missing: Arsenic, Lead, Selenium
2. Pasteurization time/temperature logs not submitted.
3. Vector Attraction Reduction analysis: 24 hour pH readings were missing for 4/12/17 & 5/2/17 analyses; 24 hour pH
readings were complete for all other analyses.
4. The volume (dry tons) of residuals that were distributed to the public in 2017.
An Additional Information Request will follow.
The following additional information was received on 8/3/2018 and a review was completed on 9/24/2018:
1. Laboratory data from PACE Analytical showed Arsenic, Selenium and Lead results from 2017 were compliant with permit
requirements.
2. Pasteurization time and temperature logs were submitted. The log showed that lime was added at 3am on 4/12/17; lime
was out beginning 9am on the 4/12/17.
3. The permittee indicated that the 24-hour pH readings for 4/12/2017 & 5/2/2017 were not recorded.
Note: The Pasteurization log showed that lime was added at 3am but the facility was out of lime at 9am on 4/12/17. The
pastuerization logs showed compliant temperatures from 4/3-12/17 and 5/1-3/17. The Corrected pH Final Product logs
showed compliant data from 4/3-11/17 and 5/1/17 but no 24-hour readings on 4/12 and 5/2, 2017. Based on
recommendations from the EPA Environmental Regulations and Technology, Control of Pathogens and Vector Attraction in
Sewage Sludge, to demonstrate compliance on a given day, several time-composite samples each covering about 5 minutes
should be collected, and pH measured. The procedure should be repeated several times during the course of a 2-week
period. (Section 10.7 Number of Samples)
4. The Distribution Form was resubmitted showing the volume of residuals submitted during April/May 2017.
Distribution 2017: 112 DT residuals were distributed during April/May 2017. 81.92 DT produced in 2016 were distributed
during February/March 2017. All other residuals were taken to the Foothills Landfill in Lenoir, NC.
TCLP was done in 2016; it is required once per permit cycle. Metals analyses appeared to be compliant with permit limits.
Pathogen/Vector Attraction Reduction requirements are met using Fecal Coliform Density, Pasteurization and Alkaline
Stabilization.
Page:2
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/29/2018 Annual Report Review
City of Lenoir
Follow-up
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?
Residual Analysis Summary Form: Transposition error for Copper & ChromiumComment:
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)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page:3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010059
06/29/2018 Annual Report Review
City of Lenoir
Follow-up
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Vector Attraction Reduction analysis: 24 hour pH reading was missing for 4/12/17 & 5/2/17
analysis; 24 hour pH readings were complete for all other analyses. Several samples were
collected for the monitoring period.
Comment:
Page:4