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Home My WebLink AboutWQ0014136_Compliance Evaluation Inspection_20181212Ploy COOPER Cmww MICHAEL S. REGAN S__q_y L. NDA CULPEPPER Infer Dbwur Mr. David Treme Director of Public Utilities Town of Mooresville Post Office Box 878 Mooresville, North Carolina 28115 Dear Ms. Treme: NORTH CAROLINA Empfronraental Quarrry December 12, 2018 Subject: Compliance Inspection Report Permit No. WQ0014136 Land Application of Residual Solids (503) Mooresville, Iredell County Mooresville Regional Office (MRO) staff, performed a compliance evaluation inspection on December 5, 2018, for permit WQ0014136. The MRO would like to extend its appreciation to Mr. Jamie Levis and his crew for their time and assistance during this site visit. Enclosed you will find the report for the compliance inspection. This permit, which was historically considered as a backup to provide residuals handling options, expired on June 30, 2018. The Town of Mooresville submitted a permit renewal application to the Non -discharge permitting group in Raleigh in January 10, 2018. That permit renewal application was returned in February, after Town failed to respond to a January 12, 2018, additional information request. It is our understanding that there has been discussion by the Town of Mooresville staff whether this permit should be renewed or not. Alternatives include: • If you wish to renew the permit, please resubmit a renewal application as soon as feasible taking note of the information requested in the January 12, 2018, letter. • Permit rescission. The Town would need to make a written request for permit rescission. If land application is later determined to be warranted, then the Town could become associated with another land application permit as a residual source; land application activities would occur under that permit's authority. As this permit has been in limbo for several months, the MRO is requesting that the Town of Mooresville make a decision on the direction that it wishes to pursue. Please notify the MRO with your decision regarding the renewal or rescission of this permit to avoid further actions being taken by the Division. iaw North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115 704.663.1699 The report should be self-explanatory. Should you have any questions regarding this report, feel free to contact Edward Watson at edward.watson(a)_ncdner.gov, or 704-235-2198. Sincerely, Docu Signed by: F161FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources Attachment: Compliance Inspection Report CC: Jamie Levis, Town of Mooresville (via email) Compliance Inspection Report Permit: WQ0014136 SOC: County: Iredell Region: Mooresville Contact Person: David Treme Directions to Facility: System Classifications: LA, Primary ORC: Secondary ORC(s): On -Site Representative(s): Effective: 07/06/09 Expiration: 06/30/18 owner: Town of Mooresville Effective: Expiration: Facility: Town of Mooresville Residuals Land Application Prol, Town Of Mooresville PO Box 878 Mooresville NC 281150878 Title: Public Utilities Director Certification: Related Permits: NC0046728 Town of Mooresville - Rocky River WWTP Inspection Date: 12/05/2018 Entry Time: 09:30AM Primary Inspector: Edward Watson Secondary Inspector(s): Maria Schutte Reason for Inspection: Routine Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping (See attachment summary) Phone: 704-662-3188 Phone: Exit Time: 12:15PM Phone: Inspection Type: Compliance Evaluation Land Application Site Page: 1 Permit: WQ0014136 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Permit WQ0014136 was established as a backup permit for the land application (LA) of Class B residuals. The permit had land dedicated for LA in the event that the Town of Mooresville required a field to be able to apply class B residuals. It was determined that the land associated with this permit has been sold by the Town of Mooresville for development currently leaving no permitted fields available for LA purposes. This permit expired on June 30, 2018. An application for renewal was received by the Raleigh Non- Discharge permitting group in January 2018. An additional information request letter was sent to the Town on January 12, 2018, noting items required to be submitted. Recieving no response from the Town, the renewal application was returned in February 2018. With an expired permit and no submitted renewal application, the Town needs to make a decision about retaining the permit or not to avoid compliance issues. Currently, the Town of Mooresville has been having the residual materials sent to a private landfill with transport by Synagro for disposal as the Class A (covered under WQ0036723) residuals process is down for repair of the belt in the incinerator. A separate report for WQ0036723 will be sent. Analytical data required by the landfill for the disposal was present and in order. Disposal tickets for the past 12 months were reviewed during the site visit. The Town is reminded that an annual report for 2018 activities would still need to be submitted in 2019 Page: 2 Permit: WQ0014136 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Distribution and Marketing ❑ Land Application 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? ❑ 0 ❑ ❑ Comment: Most of the questions do not pertain to this permit. This is a back-up LA permit that has never been used. Land Application Site Yes No NA NE Is a copy of the permit on -site during application events? ❑ ❑ ❑ Is the application site in overall good condition? ❑ ❑ ❑ Is the site free of runoff/ponding? ❑ ❑ ❑ If present, is the application equipment in good operating condition? ❑ ❑ ❑ Are buffers being maintained? ❑ ❑ 0 ❑ Are limiting slopes buffered? 10% for surface application ❑ ❑ ❑ 18% for subsurface application ❑ ❑ ❑ Page: 3 Permit: WQ0014136 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are there access restrictions and/or signs? ❑ ❑ ❑ Is the application site free of odors or vectors? ❑ ❑ ❑ Have performance requirements for application method been met? For injection? ❑ ❑ ❑ For incorporation? ❑ ❑ ❑ Does permit require monitoring wells? ❑ ❑ ❑ Have required MWs been installed? ❑ ❑ ❑ Are MWs properly located w/ respect to RB and CB? ❑ ❑ ❑ Are MWs properly constructed (including screened interval)? ❑ ❑ ❑ Is the surrounding area served by public water? ❑ ❑ ❑ If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? ❑ ❑ ❑ Are soil types consistent w/ Soil Scientist report/evaluation? ❑ ❑ ❑ Is the water table greater than 173' bls. ❑ ❑ ❑ Is application occurring at the time of the inspection? ❑ 0 ❑ ❑ Comment: During the site visit, it was discovered that the land dedicated to this permit has been sold by the Town of Mooresville for development. The MRO was to notified of the land being removed from the permit. Page: 4