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HomeMy WebLinkAboutWQ0005763_Staff Report_20190204State of North Carolina Department of Environmental Quality Division of Water Resources Water Quality Permitting Regional Staff Report FORM: APSRSR 04-10 Page 1 of 4 February 4, 2019 To: DWR Water Quality Permitting Section Central Office Application No.: WQ0005763 Attn: Troy Doby Regional Login No.: From: Bev Price Asheville Regional Office I. GENERAL SITE VISIT INFORMATION 1. Was a site visit conducted? Yes or No a. Date of site visit: January 8, 2019 b. Site visit conducted by: Bev Price & Mikal Willmer c. Inspection report attached? Yes or No d. Person contacted: Stan Bryson, WWTP Superintendent and their contact information: 828-586-9318 sbrysontwsa@frontier.com e. Driving directions: I-40 west to Hwy. 74 west to Dillsboro. Hwy. 23 south to River Road. Facility is located at 1871 N. River Rd. II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit) 2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No If no, explain: 3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A If no, please explain: 4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A If no, please explain: 5. Is the proposed residuals management plan adequate? Yes No N/A If no, please explain: 6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A If no, please explain: 7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No If yes, attach a map showing conflict areas. 8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A If no, explain and recommend any changes to the groundwater monitoring program: 9. For residuals, will seasonal or other restrictions be required? Yes No N/A If yes, attach list of sites with restrictions (Certification B) DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C FORM: APSRSR 04-10 Page 2 of 4 III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A ORC: Certificate #: Backup ORC: Certificate #: 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? Yes or No If no, please explain: 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? Yes or No N/A If no, please explain: 4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? Yes or No N/A If yes, please explain: 5. Is the residuals management plan adequate? Yes or No If no, please explain: 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No N/A If no, please explain: 7. Is the existing groundwater monitoring program adequate? Yes No N/A If no, explain and recommend any changes to the groundwater monitoring program: 8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No If yes, attach a map showing conflict areas. 9. Is the description of the facilities as written in the existing permit correct? Yes or No If no, please explain: 10. Were monitoring wells properly constructed and located? Yes No N/A If no, please explain: 11. Are the monitoring well coordinates correct in BIMS? Yes No N/A If no, please complete the following (expand table if necessary): Monitoring Well Latitude Longitude ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ 12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW)? Yes or No Please summarize any findings resulting from this review: 2018 Annual Report Review will be conducted when received in the Asheville Regional Office 13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No If yes, please explain: 14. Check all that apply: No compliance issues Current enforcement action(s) Currently under JOC Notice(s) of violation Currently under SOC Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) 15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A If no, please explain: DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C FORM: APSRSR 04-10 Page 3 of 4 16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? Yes No N/A If yes, please explain: IV. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? Yes or No If yes, please explain: 2. List any items that you would like APS Central Office to obtain through an additional information request: Item Reason 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason 5. Recommendation: Hold, pending receipt and review of additional information by regional office Hold, pending review of draft permit by regional office Issue upon receipt of needed additional information Issue Deny (Please state reasons: ) 6. Signature of report preparer: Signature of APS regional supervisor: Date: DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C 2/4/2019 FORM: APSRSR 04-10 Page 4 of 4 V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS Sludge from three other Tuckaseigee Water & Sewer Authority facilities is brought to Jackson County WWTP #1. All sludge is placed in the upper digester where it is mixed/aerated and then moved to the lower digester for further mixing prior to pressing and drying. Notices of Deficiency (NOD) were issued for the 2016 & 2017 Annual Reports. NOD’s were related to the 90% moisture reduction requirement for Heat Drying and the temperature requirement (80 deg C or 176 deg F) for residuals exiting the dryer, respectively. The issue may have been related to a faulty temperature probe, improper placement of the thermometer or a broken thermometer cover plate. The thermometer/metal cover plate was replaced in 2017. Temperatures appeared to be meeting requirements but also appeared to be higher than normal. DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C February 04, 2019 Dan Harbaugh Tuckaseigee Water and Sewer Authority 1246 W Main St Sylva, NC 28779 SUBJECT: Compliance Inspection Report Tuckaseigee Water and Sewer Authority DCAR Non-discharge Permit No. WQ0005763 Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Tuckaseigee Water and Sewer Authority DCAR on 1/08/2019. 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. 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. If you should have any questions, please do not hesitate to contact me at 828-296-4500 or via email at bev.price@ncdenr.gov. Sincerely, Beverly Price, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: WQS ARO Server Stan Bryson LF G:\WR\WQ\Jackson\Wastewater\Non-discharge\Tuckaseigee Water & Sewer Authority\Inspections\January 8, 2019 CEI Facility\20190204_WQ0005763_CEI DocuSign Envelope ID: C376AC66-96B8-4C90-BCCD-7B1B8B3C7012DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Compliance Inspection Report Permit:WQ0005763 Effective:09/11/14 Expiration:07/31/19 Owner :Tuckaseigee Water and Sewer Authority SOC: Contact Person: Region: County: Directions to Facility: Jackson Asheville Dan Harbaugh Effective:Expiration:Facility:Tuckaseigee Water and Sewer Authority DCAR 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 Stan D Bryson 828-586-9318 On-Site Representative(s): Related Permits: NC0063321 Tuckaseigee Water and Sewer Authority - TWSA Plant #3 NC0087602 Tuckaseigee Water and Sewer Authority - Whittier WWTP NC0020214 Tuckaseigee Water and Sewer Authority - TWSA WWTP#2 NC0039578 Tuckaseigee Water and Sewer Authority - Jackson County WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 01/08/2019 10:00AM 12:00PM Beverly Price 828-296-4500 Mikal Willmer Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Distribution of Residual Solids (503) Compliance Evaluation Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Pathogen and Vector Attraction (See attachment summary) Page:1 DocuSign Envelope ID: C376AC66-96B8-4C90-BCCD-7B1B8B3C7012DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 01/08/2019 Compliance Evaluation Tuckaseigee Water and Sewer Authority Routine Inspection Summary: Beverly Price of the Asheville Regional Office (ARO) conducted a facility inspection on January 8, 2019. The inspection was conducted to determine whether the facility is being operated and maintained in compliance with non-discharge permit No. WQ0005763. Stan Bryson, TWSA Wastewater Treatment Plant Operations Superintendent, was present for the inspection. Inspectors Mikal Willmer and Tim Heim, with the ARO, assisted in the inspection. The permit is up for renewal. The renewal application was being prepared at the time of the inspection. The facility maintains an extensive Operations/Maintenance Plan. Safety measures should be added to the O&M Plan. See permit condition III.2.c. The Spill Response Plan is found on the last page of the Non-Hazardous Manifest. The facility maintains an extensive Utilization Agreement: Section b.v. should be changed to read: Biological residuals shall not be stockpiled for more than 30 days prior to application. See permit condition III. 10.b.ii. Add to Section b.xv. – Any field that is in a USDA no-till program shall be exempted from meeting this vegetative cover requirement. See permit condition III.8.i. Sludge from Cashiers Plant #3 WTTP, Sylva Plant #2 and the Whittier Sanitary District WWTP are hauled to the Jackson County WWTP. Combined sludges are thickened in the upper digester then moved to the lower digester for further mixing & aeration prior to dewatering and drying. Mr. Bryson indicated that the residuals storage silo was full, and some material may need to be landfilled to provide more storage. Approximately 50 dry tons of residuals were hauled to the landfill in 2018. Mr. Bryson indicated that there had been issues with the dryer discharge temperature probe and that service for the unit is difficult as the original manufacturer has gone out of business. The discharge temperature probe and housing were replaced in 2017; current temperatures apprear to be meeting requirements but appear slightly higher than normal. Contact information for possible assistance from other manufacturers/permitted facilities was sent to Mr. Bryson following the inspection. Page:2 DocuSign Envelope ID: C376AC66-96B8-4C90-BCCD-7B1B8B3C7012DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 01/08/2019 Compliance Evaluation Tuckaseigee Water and 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? Residuals Analysis Summary Form & TCLP analysis will be reviewed in 2018 Annual Report Review. 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 DocuSign Envelope ID: C376AC66-96B8-4C90-BCCD-7B1B8B3C7012DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0005763 01/08/2019 Compliance Evaluation Tuckaseigee Water and Sewer Authority 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 Seven fecal coliform samples were analyzed.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 Hot oil dryerComment: Sampling Yes No NA NE Describe sampling: Bacteria samples are collected from the silo prior to distribution. Quarterly percent solids/metals/nutrient samples are collected from the silo prior to distribution. Samples are collected each day for each dryer run to determine compliance with Vector Attraction Reduction Alternative 8 (drying to 90% solids) and Pathogen Reduction (PFRP - Heat Drying). Is sampling adequate? Is sampling representative? Comment: Page:4 DocuSign Envelope ID: C376AC66-96B8-4C90-BCCD-7B1B8B3C7012DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Certificate Of Completion Envelope Id: C376AC6696B84C90BCCD7B1B8B3C7012 Status: Completed Subject: Please DocuSign: 20190204_WQ0005763_CEI_Draft.docx, 20190204_WQ0005763_CEI_Draft.pdf Source Envelope: Document Pages: 5 Signatures: 1 Envelope Originator: Certificate Pages: 2 Initials: 2 Beverly Price AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 2/4/2019 12:05:19 PM Holder: Beverly Price Bev.Price@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Beverly Price bev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: 2/4/2019 12:10:01 PM Viewed: 2/4/2019 12:10:12 PM Signed: 2/4/2019 12:10:37 PM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign Mikal Willmer mikal.willmer@ncdenr.gov Environmental Specialist North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Drawn on Device Using IP Address: 149.168.204.10 Sent: 2/4/2019 12:10:37 PM Viewed: 2/4/2019 12:12:41 PM Signed: 2/4/2019 12:12:58 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 2/4/2019 12:10:38 PM Certified Delivered Security Checked 2/4/2019 12:12:42 PM Signing Complete Security Checked 2/4/2019 12:12:58 PM Completed Security Checked 2/4/2019 12:12:58 PM DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Payment Events Status Timestamps DocuSign Envelope ID: 6C472287-77E5-4EC1-A2E8-0A9983D11F3C Certificate Of Completion Envelope Id: 6C47228777E54EC1A2E80A9983D11F3C Status: Completed Subject: Please DocuSign: 20190204_WQ0005763_STFRPT.docx, 20190204_WQ0005763_CEI.pdf Source Envelope: Document Pages: 11 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 0 Beverly Price AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 2/4/2019 12:30:29 PM Holder: Beverly Price Bev.Price@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Beverly Price bev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: 2/4/2019 12:36:08 PM Viewed: 2/4/2019 12:36:29 PM Signed: 2/4/2019 12:36:45 PM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 149.168.204.10 Sent: 2/4/2019 12:36:48 PM Viewed: 2/4/2019 12:38:00 PM Signed: 2/4/2019 12:38:11 PM Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 2/4/2019 12:36:48 PM Certified Delivered Security Checked 2/4/2019 12:38:00 PM Signing Complete Security Checked 2/4/2019 12:38:11 PM Completed Security Checked 2/4/2019 12:38:11 PM Payment Events Status Timestamps