WQ0011260_Compliance Evaluation Inspection_20181121

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

November 21, 2018

Rick Hensley, Mayor
Town of Old Fort
38 Catawba Avenue
Old Fort, NC 28762

SUBJECT: Compliance Inspection Report
Annual Report (2017) Review
Town of Old Fort Class A Wastewater Residuals Distribution Program
Non-discharge Permit No. WQ0011260
McDowell County

Dear Mayor Hensley:

The North Carolina Division of Water Resources completed a review of the 2017 Annual Report for the Town
of Old Fort’s Class A Residuals Distribution Program on 11/09/2018. This inspection was conducted to
verify that the facility is operating in compliance with the conditions and limitations specified in
Non-discharge Permit No. WQ0011260. The findings and comments noted during this inspection are
provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report".

The following issues were noted in the review inspection:

 A Standard Soil Fertility Analysis is not required by the permit; however, it is recommended to ensure
the receiver site maintains a minimum pH of 6 or greater. See Permit Condition III. 8.h.

 The analytical report from Research & Analytical Laboratories, Inc. indicated that Ammonia Nitrogen &
Total Kjeldahl Nitrogen were analyzed out of hold time due to a laboratory error. According to the
analysis date, pH was also analyzed out of hold time. Any analyte flagged for not meeting hold times
should be re-analyzed if possible.

North Carolina Department of Environmental Quality | Division of Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500
 The lime feed rate should be adjusted to keep the final product pH under 12.5.

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 II
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Ec: Tony West
WQS ARO Server
LF

G:\WR\WQ\McDowell\Wastewater\Non-discharge\Town of Old Fort\Inspections\20181121_WQ0011260_CEIARR.docx
Compliance Inspection Report
Permit:WQ0011260 Effective:02/01/15 Expiration:01/31/20 Owner :Town of Old Fort
SOC:
Contact Person:
Region:
County:
Directions to Facility:
McDowell
Asheville
Anthony Glenn West
Effective:Expiration:Facility:Town of Old Fort Class A Wastewater Residuals Distribution Program
US 70
Old Fort NC 28762
Title:Phone:[phone]ORC
From ARO: Take I-40 East to Exit 72 (Old Fort/Hwy. 70 E.) Continue on Hwy. 70 E. to Collins & Aikman. Turn right at Collins &
Aikman and follow paved road around behind C&A until you come to WWTP.
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Anthony Glenn West 828-652-8843
On-Site Representative(s):
Related Permits:
NC0021229 Town of Old Fort - Old Fort WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/09/2018 10:30AM 11:30AM
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 Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page:1
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0011260
11/09/2018 Annual Report Review
Town of Old Fort
Routine
Inspection Summary:
The 2017 Annual Report Review was conducted by Beverly Price of the Asheville Regional Office.
24.1 Dry Tons of residuals were distributed to one individual in 2017. Those residuals were produced in 2016 and sampled
for metals and nutrients in December 2016. Based on the data submitted, Ceiling and Monthly Average Concentration limits
for metals were met. Fecal coliform analyses were done in February 2017 prior to distribution.
26.71 dry tons of residuals were produced in 2017. Those residuals were sampled in December 2017. Based on the data
submitted, Ceiling and Monthly Average Concentration limits for metals were met. Fecal coliform analyses were
conducted in 2018 prior to distribution.
Class A Pathogen Reduction is accomplished via a Process to Further Reduce Pathogens (PFRP) - pasteurization and
Fecal Coliform Density testing. Vector Attraction Reduction (VAR) is accomplished via Alternative #6, Alkaline
Stabilization. It is recommended that lime feeds be adjusted to try and keep the final product pH under 12.5. Pathogen and
VAR appear to have been met according to the data submitted.
TCLP/Ignitability/Corrosivity/Reactivity are required once per permit cycle. Those analyses were completed in 2015.
Residuals recipient information was provided.
The intended use for residuals distributed in 2017 was for corn. Agronomic rates based on Realistic Yield Expectations
(RYE) for corn silage/grain should be determined and used for bulk distributions when applicable.
A Standard Soil Fertility Analysis is not required by the permit; however, it is recommended to ensure the receiver site has a
mininum pH 6.
The analytical report from Research & Analytical Laboratories, Inc. indicated that Ammonia Nitrogen & Total Kjeldahl
Nitrogen were analyzed out of hold time due to a laboratory error. According to the analysis date, pH was also analyzed out
of hold time. Any analyte flagged for not meeting hold times should be re-analyzed if possible.
Page:2
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0011260
11/09/2018 Annual Report Review
Town of Old Fort
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?
Metals and nutrient analyses are from 2016 & 2017.
Application was not during a seasonal restriction window.
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)
Temperature corrected
Page:3
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0011260
11/09/2018 Annual Report Review
Town of Old Fort
Routine
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:
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
PasteurizationComment:
Page:4