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Home My WebLink AboutWQ0006245_NOD-2019-PC-0105_20190430ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director CERTIFIED MAIL RETURN RECEIPT REQUESTED RECEIPT # 7018 0360 0002 2099 0881 NORTH CAROLINA Environmental Quality April 30, 2019 Mr. Mr. Andy Smith, Operations Manager City of Statesville P.O. Box 1111 Statesville, North Carolina 28687 Subject: NOTICE OF DEFICIENCY NOD-2019-PC-0105 City of Statesville Permit WQ0006245 Sta—Lime Distribution Program Iredell County Dear Mr. Smith: The Mooresville Regional Office (MRO) has received and reviewed the 2018 Annual Report (AR) for the above permit. The Annual Report is not in compliance with the permit. The review of the Annual Report revealed continued reporting deficiencies that have been identified in reviews of previously submitted Annual Reports. Condition III.3(4), requires that the wastewater effluent be sampled for the following parameters: • Plant Available Nitrogen (PAN, by calculation) • Sodium Absorption Ration (SAR, by calculation) These parameters continue to be inconsistently reported by the contract laboratory. The contract laboratory submitted PAN and SAR calculation correctly for May 22, 2018, in work order number 8050101-1. This should be used as a template for how PAN and SAR calculations should be presented in future Annual Reports. 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 To avoid additional compliance issues, please submit the corrected values for PAN and SAR within ten days of receipt of this notification. This permit expires on September 30, 2020. Please be sure to submit the permit renewal application at least 180 days prior to the permit expiration date. 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, DocuSigned by: A4•QZtw N P44,14 F161FB69A2D84A3... 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: Mr. Ken Galloway (via email) Compliance Inspection Report Permit: WQ0006245 SOC: County: Iredell Region: Mooresville Contact Person: Andy Smith Effective: 04/02/15 Expiration: 09/30/20 owner: City of Statesville Effective: Expiration: Facility: City of Statesville Sta-Lime Processing Facility and C 693 Bell Farm Rd Title: Statesville NC 28687 Phone: 704-878-3438 Directions to Facility: From the intersection of 1-77 North and NC Hwy. 70, travel east on NC Hwy. 70 to Bell Farm Road. Turn left and travel north on Bell Farm Road to the Fourth Creek WWTP. The WWTP is on the right-hand side of the road. System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 04/26/2019 Entry Time: 08:OOAM Exit Time: 12:OOPM Primary Inspector: Edward Watson Phone: Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Distribution of Residual Solids (503) Facility Status: ❑ Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 Permit: WQ0006245 Owner - Facility: City of Statesville Inspection Date: 04/26/2019 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: Even though the data for PAN and SAR parameters are presented in the report, the presentation of these values remains inconsistent. This same issue was noted in the 2017 AR and NOD-2018-PC-0145 was issued in an attempt to address permit condition issue. Unfortunately, this issue has not been completely rectified. Attachment A of the permit indicates the required sampling frequency for parameters such as PAN, SAR, TCLP, etc. Neither the PAN or SAR calculations are being consistently submitted in the report. PRISM has submitted calculation sheets for both PAN and SAR for Work Order Number 8050101-1. The PAN and SAR calculations should all be presented in this manner. Please use this particular WO as a template for presentation of PAN and SAR values. Page 2 of 4 Permit: WQ0006245 Owner - Facility: City of Statesville Inspection Date: 04/26/2019 Inspection Type : Annual Report Review 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: This is an AR review only. A CEI site visit occurred in January of 2018. Hauling records for the Sta-Lime material was determined by volume applied through 2018. TCLP ispresented in the report. This data appears to be complete and in compliance with the requirements of the permit. The Deresentation of the data for both PAN and SAR oarameters were Doorly Dresented in the AR. 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 ❑ Page 3 of 4 Permit: WQ0006245 Owner - Facility: City of Statesville Inspection Date: 04/26/2019 Inspection Type : Annual Report Review Reason for Visit: Routine 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 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 ❑ ❑ 0 ❑ Comment: PVAR is achieved through lime stabilization. The Alkaline Stabilization records are present in the AR. The records state that Time and Temperature requirements have been met in accordance with permit conditions. The lime stabilization records appear to be in order for 2018. 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 ❑ Comment: Time on temp. and pH indicate reduction is compliant with the permit. Sampling Yes No NA NE Describe sampling: Samples are collected by composite sampling throughout the as presented in the PFRP logs for locations where samples were collected. PFPR sheets indicate where the samples were collected to indicate composite sampling occurred. Is sampling adequate? ❑ ❑ ❑ Is sampling representative? 0 ❑ ❑ ❑ Comment: Based on the lime stabilization records, sampling appears to be representative. Page 4 of 4