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Home My WebLink AboutWQ0004563_Compliance Evaluation Inspection_20190403ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Mr. Kevin B. Greer, P.E. Asst. Public Services Director City of Hickory, P.O. Box 398 Hickory, North Carolina 28603-0398 Dear Mr. Greer: NORTH CAROLINA Environmental Quality April 3, 2019 Subject: 2019 Compliance Inspection Report Hickory Regional Composting Facility ORGRO Distribution Program Permit WQ0004563 Catawba County On March 27, 2019, the Mooresville Regional Office (MRO) completed a Compliance Inspection for the above -stated facility. The inspection included records review and residuals processing review of the Hickory Regional Composting Facility (RCF). We would like to thank Mr. Paul Spencer for his time and the facility tour. A couple areas of concern were noted during the inspection. First, facility maintenance needs attention as there are mechanical issues that need to be addressed at the RCF with regards to the Reactor Tunnels. Proper maintenance of the facility is requirement under Section III of the permit. Secondly, material storage continues to be near maximum capacity. We again urge additional contact with consortium members and others to assist with utilizing the class A material the facility produces. Lack of use of the material may result in bacterial regrowth and additional sampling may be needed to confirm that the material still meets class A requirements. The reporting of analytical values presented by Pace Analytical Laboratories are adequate. However, the MRO has emailed a spreadsheet to the plant operator to be able to complete the conversions from mg/Kg to lbs./ton as required to be reported in the Annual Report. The spreadsheet also provides a formula to be able to verify Sodium Absorption Ratio (SAR) and Plant Available Nitrogen and Exchangeable Sodium Percentage (ESP). As a reminder, please maintain current information for all contacts and ORC's associated with this permit. Changes can be made by submitting Water Pollution Control System Operator Designation Form as stipulated in NCAC 15A 8G .0201. A copy of the link has been attached to this email. Overall the facilities were found to be compliant with the permit. D Q North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROHNA � o.namremor �w.c�giuuei� /`� 704.663.1699 The attached reports should be self-explanatory. However, should you have any questions, please feel free to contact me at 704-235-2198 or by email at edward.watsongncdenr.gov. Sincerely, CA- DocuSigned by: 110 w N P44ft F161 FB69A2D84A3... Andrew H. Pitner, P.G. Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Compliance Inspection Report CC: Paul Spencer (via email) Compliance Inspection Report Permit: WQ0004563 SOC: County: Catawba Region: Mooresville Contact Person: Mick Berry Directions to Facility: Effective: 02/01/15 Expiration: 01/31/20 owner: City of Hickory Effective: Expiration: Facility: Hickory Regional Compost Facility and Catawba OR 3200 20th Ave SE System Classifications: Primary ORC: Paul Lee Spencer Secondary ORC(s): On -Site Representative(s): Title: City Manager Certification: 15831 Related Permits: NC0024279 City of Conover - Southeast WWTP NC0081370 City of Claremont - McLin Creek WWTP NC0032662 City of Claremont - North WWTP NC0040797 City of Hickory - Henry Fork WWTP NC0020401 City of Hickory - Northeast WWTP NC0024252 City of Conover - Northeast WWTP NC0039594 Town of Maiden - Maiden WWTP NC0036196 City of Newton - Clark Creek WWTP NC0025542 City of Hickory - Catawba WWTP Inspection Date: 03/27/2019 EntryTime: 10:10AM Primary Inspector: Edward Watson Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Pathogen and Vector Attraction Storage (See attachment summary) Newton NC 28658 Phone: 828-323-7412 Phone: 828-465-1401 Exit Time: 02:30PM Phone: Inspection Type: Compliance Evaluation Treatment Page 1 of 4 Permit: WQ0004563 Owner - Facility: City of Hickory Inspection Date: 03/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: This facility was initially permitted in June of 1991. According to NCDEQ records, the facility originally began construction in 1986. This nearly thirty -year -old facility is displaying significant wear. The drive chain in Reactor Tunnel 11 is not working properly and the pneumatic lines in several reactor tunnels are experiencing bleed -off and not allowing the reactor doors to operate correctly. As the Tunnel Reactors are an integral part of the permitted treatment system, they are required to be maintained under the Maintenance and Up -Keep portion of the permit. Section III, OPERATION and MAINTENANCE REQUIREM ENTS(2)(a)(b). The permittee shall maintain and Approved O&M Plan, at the minimum, shall include Operational Functions and Maintenance Schedules. During the site visit, it was observed that the area immediately behind the reactor has become worn due to the front-end loader being used to remove the compost from the reactor tunnels. If this area is to become paved in the future to aid with compost removal, consideration should be made to add run-off controls to the paving design to avoid fluid from the reactor tunnel from entering into the storm -drain located near the back of the property boundary. In the interim, it was suggested that hay bales be placed in the area where run-off water from the reactor tunnels may enter the drainage feature that is connected to the storm -water outfall to aid with preventing solids from entering the Stormwater drainage ditch. It was also noted that there were insect larvae and small flies present in a standing water portion of the drainage ditch at the culvert pipe of the Stormwater outfall that should be treated to prevent insect breeding. The curing pad remains full of compost. There is a concern that composted material sitting on the pad for an extended period of time may allow re -growth of coliform bacteria and thereby, causing that compost to no longer be considered to be a class A product. As stipulated the White House manual, Chapter6, Table 6-3 MONITORING CONSDIERATIONS FOR KEY PARAMETERS, Pathogens Class A, Because regrowth of Fecal Coliform and Salmonella Sp. can occur, monitoring should be done sufficiently close to the time of biosolids use or disposal so data are available and no additional regrowth occurs: (a) Before land application or surface disposal, or (b) When biosolids are prepared for sale or giveaway in a bag or other container for land application, or (c) When biosolids are prepared to meet EQ requirements. Once destroyed, enteric viruses and viable helminth ova do not regain viability. As a measure of QA/QC, it was suggested that samples be collected from the older compose piles to have them analyzed for fecal coliform growth. If re -growth was to be determined to the extent that the composted no longer could be considered to be a class A product, the compost could not be distributed to the public. The operator was encouraged to seek other end users for this Class A product. Additional cooperation between consortium members and the composting facility to aid the composting facility with marketing the compost as a soil supplement would likely aid in the reduction of the need to store large quantities of compost on site. These could include the Catawba Ag, Extension, NCDOT, Land Application Companies, manure brokers/fertilizer companies for the agriculture industry, County and City Parks Depts.,etc. Page 2 of 4 Permit: WQ0004563 Owner - Facility: City of Hickory Inspection Date: 03/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: 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? ❑ ❑ 0 ❑ Comment: This is a distribution permit. Nutrient/crop removal practices are not able to be reviewed. Hauling records are reviewed based on material distributed by the facility. Pathogen and Vector Attraction Yes No NA NE a. Fecal coliform SM 9221 E (Class A or B) 0 ❑ ❑ ❑ 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 of 4 Permit: WQ0004563 Owner - Facility: City of Hickory Inspection Date: 03/27/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ❑ ❑ e. Time/Temp on: 0 ❑ ❑ ❑ Digester (MCRT) ❑ Compost Class A lime stabilization ❑ f. Volatile Solids Calculations 0 ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ 0 ❑ Comment: PVAR reduction is performed in a reactor tunnel for an average time of 28 days. Several sample ports located allong the tunnel reactor allow for samples to be collected to determine PVAR. Treatment Check all that apply Yes No NA NE Aerobic Digestion Anaerobic Digestion ❑ Alkaline Pasteurization (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost Drying Beds ❑ Other ❑ Comment: The pre-treated residuals are delivered to the composting facility where a saw dust amendment is added at a one-to-one ratio and the blended mixture is placed into the reactor tunnels to obtain the final reduction and product a composted product. Continued reduction occurs on the open-air drying pad. Page 4 of 4