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Home My WebLink AboutWQ0013116_Compliance Evaluation Inspection_20190206 February 06, 2019 David Foster, Public Services Director Town of Waynesville PO Box 100 Waynesville, NC 28786 SUBJECT: Compliance Inspection Report Town of Waynesville Class A Distribution Program Non-discharge Permit No. WQ0013116 Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Town of Waynesville Class A Distribution Program on 1/11/2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0013116. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". Two issues noted during the inspection: 1. Additional on-site storage for residuals on the concrete pad is limited. If storage on the ground, i.e. on grass, is required, it will need to be covered by a tarp. 2. The solids handling equipment (anaerobic digester & thickeners) should be included in any evaluation related to WWTP upgrades. DocuSign Envelope ID: D99AFF63-9A48-4D57-83DA-A483E664D712 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 LF Mark Jones G:\WR\WQ\Haywood\Wastewater\Non-discharge\Town of Waynesville\Inspections\January 11, 2019 CEI\20190206_WQ0013116_CEI DocuSign Envelope ID: D99AFF63-9A48-4D57-83DA-A483E664D712 Compliance Inspection Report Permit:WQ0013116 Effective:07/20/16 Expiration:06/30/21 Owner :Town of Waynesville SOC: Contact Person: Region: County: Directions to Facility: Haywood Asheville David Foster Effective:Expiration:Facility:Town of Waynesville Class A Distribution Program 566 Walnut Trl Rd Waynesville NC 28785 Title:Phone:828-456-3706Public Services Director I-40 to 19-23 South toward Waynesville. Take exit 103 to Hwy 209 N. Turn right on Walnut Trail Road., cross 2 cattle grates, turn left to WWTP. Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: 24 hour contact name Mark Jones 828-452-4685 On-site representative Mark Jones 828-452-4685 On-Site Representative(s): Related Permits: NC0025321 Town of Waynesville - Waynesville WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 01/11/2019 10:00AM 11:45AM 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: D99AFF63-9A48-4D57-83DA-A483E664D712 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0013116 01/11/2019 Compliance Evaluation Town of Waynesville Routine Inspection Summary: Inspectors Beverly Price and Mikal Willmer of the Asheville Regional Office (ARO) conducted a compliance evaluation inspection of the Town of Waynesville’s residuals facility on January 11, 2019. The inspection was conducted to determine compliance with the non-discharge permit WQ0013116. Mark Jones, ORC and Jeff Evans, ORC were present and assisted with the inspection. The estimated volume of residuals currently stored on-site is 1000 dry tons. The covered storage area is full; the remaining residuals are stored on concrete but uncovered. The current situation allows for any leachate runoff to be routed back to the head of the WWTP; however, additional room for storage on concrete is limited. If residuals need to be stored on the ground, i.e. on grass, they will need to be covered with a tarp. The ORC reports that the Town is looking at the following options for disposal: landfilling, grants for purchasing a spreader that would be available for use by Haywood County Cooperative Extension and grants that would help pay for the cost of spreading by local farmers. The ARO is aware of the challenges the Town faced with distribution during 2018. For residuals that have been stockpiled for an extended period, it is recommended that the material be resampled for bacteria as it should be monitored as close to the time of distribution as possible. More than one sample per monitoring period should be analyzed to better represent the residuals for that period. Staff are updating the Operation & Maintenance Plan and the Utilization Agreement. Utilization Agreements for 2018 will be addressed during the 2018 Annual Report Review. As noted in the August 21, 2018 WWTP inspection, the thickeners and anaerobic digester are undersized for the facility. These components should be added to any engineering assessments for future upgrades to the WWTP. Page:2 DocuSign Envelope ID: D99AFF63-9A48-4D57-83DA-A483E664D712 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0013116 01/11/2019 Compliance Evaluation Town of Waynesville 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? Residual Sampling Summary Form and TCLP analyses will be evaluated when the 2018 Annual Report is reviewed. Approximately 456 dry tons of residuals were distributed in 2018. 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: D99AFF63-9A48-4D57-83DA-A483E664D712 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0013116 01/11/2019 Compliance Evaluation Town of Waynesville 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 A cursory review of the pathogen/vector attraction reduction data was conducted. Fecal coliform data and temperature requirements appear to be compliant. A complete review of the 2018 monitoring data will be conducted when the 2018 Annual Report is reviewed. 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 Belt-pressComment: Sampling Yes No NA NE Describe sampling: Samples are collected from the conveyor belt for pH analyses. Grab samples are collected from the finished lime stabilized pile after pH/time/temperature requirements have been met. Grab samples are then composited for analysis for nutrients/metals/TCLP/bacteria. Is sampling adequate? Is sampling representative? For bacteria monitoring: It is highly recommended that the number of samples be increased to seven per monitoring event and that samples be collected over a two-week period to ensure a more representative sample. It is also highly recommended that any residuals that are stockpiled longer than the required monitoring frequency period be resampled for bacteria prior to distribution. The ORC has already arranged to have the number of fecal coliform samples increased to seven for the first quarter of 2019. Comment: Page:4 DocuSign Envelope ID: D99AFF63-9A48-4D57-83DA-A483E664D712 Certificate Of Completion Envelope Id: D99AFF639A484D5783DAA483E664D712 Status: Completed Subject: Please DocuSign: 20190206_WQ0013116_CEI_cover ltr.docx, 20190206_WQ0013116_CEI_draft.pdf Source Envelope: Document Pages: 6 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 2/6/2019 12:05:31 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: 2/6/2019 12:06:53 PM Viewed: 2/6/2019 12:07:04 PM Signed: 2/6/2019 12:07:23 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: 2/6/2019 12:07:24 PM Viewed: 2/6/2019 12:09:20 PM Signed: 2/6/2019 12:09:41 PM Freeform Signing 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 2/6/2019 12:07:24 PM Certified Delivered Security Checked 2/6/2019 12:09:20 PM Signing Complete Security Checked 2/6/2019 12:09:41 PM Completed Security Checked 2/6/2019 12:09:41 PM Payment Events Status Timestamps