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Home My WebLink AboutWQ0003487_Compliance Evaluation Inspection_20190919ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Scott Creech Environmental Coordinator Novozymes North America, Inc. 77 Perry Chapel Church Road Franklinton, NC 27525 Mr. Creech, NORTH CAROLINA Entrim mental Quality September 19, 2019 Subject: Compliance Evaluation Inspection Novozymes Residuals Processing Facility and Distribution Program Distribution of Class A Industrial Byproduct Residuals Permit WQ0003487 Franklin County On September 18, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation inspection of the Distribution of Class A Residuals program located at Novozymes. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, your assistance and cooperation was helpful and appreciated. Also present was Mads Thaysen, Director of Operations, Emily Hon and Jelena Cvetic El Barigi of the environmental group. At the Novozymes facility located in Franklin County, the facility is permitted to distribute up to 41,000 dry tons per year of Class A Industrial Byproduct residuals. A maximum of 37,720 dry tons of residuals may be generated from spent biomass and 3,280 dry tons of residuals may be generated from Wastewater Treatment Activated Sludge (WAS) per year. WAS residuals are generated under permit W00002806 which was also inspected on the above date. This compliance evaluation inspection consisted of the following: • Review of the permit; • Review of the owner/facility information; • Review of the previous year's annual report; • Disposal event records, residual sampling forms/lab analytical results, pathogen and vector attraction reduction forms, TCLP analyses, etc. The current permit was issued September 9, 2016 and expires November 30, 2021. North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional office 1 3600 Barrett Drive I Raleigh, North Carolina 27609 waWun\ ' 919.791.4200 A review of the 2018 Annual Report indicates Novozymes distributed 15,349 dry tons in calendar year 208. The total volume of residuals included 1,689 dry tons of bulking agent (hydrated lime), 876 dry tons of WAS, and 12,784 dry tons of SBM (spent biomass). Most residuals were distributed via truck to various persons for agricultural uses. A smaller amount of residuals are land -applied near the Novozymes facility. The residuals created under permit W00003487 consist primarily of enzyme fermentation spent biomass solids (non -biological), which are combined with lesser amounts of primary clarifier sludge (non - biological), and WAS. Per the permit, the monitoring frequency for metals and nutrients is based on the total dry tonnage generated per year. In 2018, metals and nutrients were analyzed once per month as required. Monitoring frequency for pathogen and vector attraction reductions was completed once per quarter for residuals generated from WAS. The Class A pathogen review (Salmonella density) and the Alkaline Stabilization for vector attraction indicate compliance with permit requirements. Monitoring for non -hazardous characteristics (TCLP) is not required by this permit. Components of the residuals generation and treatment system as well as some components of the Class A residuals management system were inspected and no issues were noted. No permit condition violations were noted during the September 18, 2019 compliance inspection and records review. The facility appears to be compliant with all permit conditions. If you have questions or comments about the inspection, or this report, please contact Rick Trone at 919- 7914200 or via email at rick.trone@ncdenr.gov c ereolich, L.G. Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report Cc: RRO/SWP Files Central Files Compliance Inspection Report Permit: WO0003487 Effective: 06/07/17 Expiration: 11/30/21 Owner: Novozymes North America Inc SOC: Effective: Expiration: Facility: Novozymes Residuals Processing Facility and Distal County: Franklin 77 Perry Chapel Church Rd Region: Raleigh Franklinton NC 27525 Contact Person: Angela Walsh Title: Phone: 919-494-7056 Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Certification: Phone: Related Permits: WO0002806 Novozymes North America Inc - Novozymes Franklin County Facility Inspection Date: 09/18/2019 EntryTime: 10:OOAM Exit Time: 10:30AM Primary Inspector: Rick V Trone Phone: 919-791-4200 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Distribution of Residual Solids (503 Exempt) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping (See attachment summary) Page 1 of 3 peril: W00003487 Owner- Facility: Novozymes North America Inc Inspection Date: 09/laf2019 Inspection Type : Compliance Evaluation Reason far Visit: Routine Inspection Summary: On September 18, Rick Trone of the Raleigh Regional Office conducted a compliance evaluation Inspection of the Distribution of Class A Residuals program located at Novozymes. The purpose of this Inspection was to ensure compliance with the subject permit. During the inspection, your assistance and cooperation was helpful and appreciated. Also present was Mads Thaysen, Director of Operations, Emily Hon and Jelena Cvelic El Barigi of the environmental group. Al the Novozymes facility located in Franklin County, the facility is permitted to distribute up to 41,000 dry tons per year of Class A Industrial Byproduct residuals. A maximum of 37,720 dry tons of residuals may be generated from spent biomass and 3,280 dry tons of residuals may be generated from Wastewater Treatment Activated Sludge (WAS) per year. WAS residuals are generated under permit W00002806 which was also inspected on the above date. This compliance evaluation inspection consisted of the following: -Review of the permit; -Review of the owner/facility Information; -Review of the previous year's annual report; -Disposal event records, residual sampling forms/lab analytical results, pathogen and vector attraction reduction forms, TCLP analyses, etc. The current permit was Issued September 9, 2016 and expires November 30, 2021. A review of the 2018 Annual Report Indicates Novozymes distributed 15,349 dry tons in calendar year 208. The total volume of residuals included 1,689 dry tons of bulking agent (hydrated lime), 876 dry tons of WAS, and 12,784 dry tons of SBM (spent biomass). Most residuals were distributed via truck to various persons for agricultural uses. A smaller amount of residuals are land -applied near the Novozymes facility. The residuals created under permit W00003487 consist primarily of enzyme fermentation spent biomass solids (non -biological), which are combined with lesser amounts of primary clarifier sludge (non -biological), and WAS. Per the permit, the monitoring frequency for metals and nutrients Is based on the total dry tonnage generated per year. In 2018, metals and nutrients were analyzed once per month as required. Monitoring frequency for pathogen and vector attraction reductions was completed once per quarter for residuals generated from WAS. The Class A pathogen review (Salmonella density) and the Alkaline Stabilization for vector attraction indicate compliance with permit requirements. Monitoring for non -hazardous characteristics (TCLP) is not required by this permit. Components of the residuals generation and treatment system as well as some components of the Class A residuals management system were inspected and no issues were noted. No permit condition violations were noted during the September 18, 2019 compliance Inspection and records review. The facility appears to be compliant with all permit conditions. Page 2 of 3 permit: WO0003487 Owner -Facility: Novozymes North America Inc Inspection Date: 09/18/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine Tvoa Land Application Distribution and Marketing Record Keeping 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? Comment: Yes No NA NE Yes No NA NE ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ■❑❑❑ ❑ ❑ ❑ ❑❑■❑ ■❑❑❑ ❑ ❑ ❑ ❑❑CIE ❑❑❑■ ❑❑❑■ ■❑❑❑ ❑ ❑ ❑ ■O❑❑ ■❑❑❑ ■❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑❑■❑ Page 3 of 3