[NOTE: Eastside WATER and NPDES violations/consent order/compliance issues are HERE. The public records dropbox folder is HERE.]
Eastside Wastewater Treatment Plant’s 2024 Air Emissions Report shows the amount of toxic and hazardous vapors released into Guilford and Randolph county’s air increased significantly over calendar year 2023.
The increases averaged 45% across the board. Outliers were LEAD, which increased +451% over 2023; Nickel, which increased +380%, Particulate Matter (PM2.5) which increased +250%, and Nitrous Oxide which increased +100%. MERCURY air emissions increased +46% over 2023; Methane + 50%; Volatile Organic Compounds +20%; Beryllium +46%; Cadmium +46%; Chromium +49%; Chromic acid +46%; Formaldehyde +46%; Hydrochloric acid +44%; Xylene +46%; Benzene +24%; Napthalene +7% (966 lbs per year); Arsenic +7%. Eastside is just one of at least 100 industrial facilities polluting the air in Jamestown, High Point and Greensboro. Here’s the report:
MAY 2025: Eastside has an “Alternative Mercury Monitoring Plan” with the U.S. Environmental Protection Agency that requires quarterly mercury testing and reporting, and establishes a minimum mercury removal efficiency rate of 70% for Eastside. In April and May 2025, Eastside submitted the results of the quarterly reports for Q4 2024, Q1 2025 and Q2 2025. In all three tests, Eastside fell short of meeting the minimum efficiency rate of 70%.
The notes in the red “FAIL” boxes are ours – we have been asked numerous times to highlight the key points in these inspection and compliance reports to make it easier for readers to understand:
The EPA’s requirement that Eastside always achieve “a minimum removal efficiency of 70%” is to prove the system is able to meet the mercury emission standard “during non-test events.” In May 2024, after Eastside failed to meet the 70% minimum, Eastside had to replace its “mercury-saturated modules” per the terms of the Alternative Monitoring Plan. This is a screenshot of that discussion, from the NCDEQ inspector’s notes:
In an August 8, 2024 letter to Derrick Boone, the NCDEQ said “Guilford County has triggered increment tracking under PSD for PM 10 and SO2.” [Here’s what that means: PSD (“PREVENTION OF SIGNIFICANT DETERIORATION”) is the maximum allowable increase of an air pollutant that is allowed to occur. Deviations help identify significant deterioration of air quality in that area.]
JUNE 2024: Back in March of 2023, local residents submitted Public Comments concerning the renewal of Eastside’s air emissions permit. Despite their concerns, Eastside’s air emissions permit was renewed for one year in May 2023. On June 11, 2024, it was renewed for another FOUR years, despite operating at near-capacity with a wastewater NPDES permit that has been expired since 2018.
Two weeks after that 4-year air permit was signed, an NCDEQ staffer wrote a letter to Eastside’s air emissions technician notifying him that Eastside had under-reported some of its hazardous and toxic pollutants due to a mathematical “error” that decreased the numbers by a factor of 2,000:
An Environmental Specialist with the NCDEQ said of the calculations: “The originally submitted TAP (toxic air pollutants) and HAP (hazardous air pollutant) emissions (lbs) calculations from the sewage sludge incinerator were erroneously divided by 2,000. After corresponding with Mr. McCullock and the (Eastside) facility, revised calculations were submitted to multiply these values back by 2,000 for the appropriate pounds value.”
This is Eastside’s corrected 2023 Emission Summary exactly as it is “Recorded in ED” and entered in the North Carolina Public Records (the red marks are ours):
The NCDEQ form shows year over year increases in Arsenic emissions of +893%; Napthalene +95,842%; Benzene +45%; Chromium +3,113%; Manganese +4,494%; Mercury +5,140%; Nickel +6,312%; Chloroform +163,459%; DEPH +163,800%; 1,4-Dichlorobenzene +163,730%; Formaldehyde +533%; Hydrochloric Acid +64,416%; Selenium +4,078%; Sulfuric Acid +163,639%; Toluene +356%; Polycyclic Organic Matter +95,764%.
JANUARY-JUNE, 2023: NCDEQ Division of Air Quality Regional Supervisor Ray Stewart cites SEVEN NOTICES OF VIOLATIONS dating back to August 2020, all with financial penalties. The latest Notice of Violation follows the submission of Eastside’s semi-annual “Deviations Report” for the period 1/1/2023 through 6/30/2023:
APRIL 16, 19 and 26, 2023: Too much Carbon Monoxide emitted into the air, plus FOUR operational violations.
NOVEMBER, 2022: Eastside was fined for an excessive emission of Carbon Monoxide that occurred on August 7, 2022.
AUGUST 2022 inspection: “The facility appeared not to be operating in compliance with the Air Quality standards and regulations. As per Condition 2.1.A.2, which pertains to regulation 2D.024 “New Source Performance Standards,” the facility shall maintain the pressure drop across the sorbet polymer catalyst composite material adsorber (CD-04) at least 0.18 inches of water. During the inspection conducted by Mr. Barker on July 16, 2021, he observed records from February 1, 2021 and following, with thirty-nine (39) 12-hour blocks in which this minimum pressure drop limit was not maintained at 0.18 inches of water. It should be noted that this permit condition does not specify a time frame for recording the pressure drops across the adsorber only that not maintaining the pressure drop across the adsorber at least 0.18 inch of H20 will be deemed in noncompliance. The facility is recording these pressure drops in 12-hour blocks. For not meeting the minimum pressure drop limit for the adsorber, the facility is in violation of this permit condition and will be issued a NOTICE OF VIOLATION/NOTICE OF RECOMMENDATION FOR ENFORCEMENT.”
APRIL 18, 2022: the facility was issued a NOTICE OF VIOLATION and NOTICE OF RECOMMENDATION FOR ENFORCEMENT for the reporting of one exceedance of the Carbon Monoxide emission limit (64 ppmvd, corrected to 7% O2, 24-hour block average) pursuant to 15A NCAC 02D .1204 – Sewage Sludge Incineration Units and Air Permit No. 08074, Specific Condition 2.1.A.4.a. The DAQ received a response from the facility on May 12, 2022, stating that the exceedance was caused by a short-term CO increase due to starting up the blower and running it only from 11:29 AM to 11:38 AM for testing purposes on November 18, 2021. Therefore, the incinerator did not operate long enough on that date to lower the average CO emissions for that day. This exceedance was addressed as part of the facility’s SOC, which was issued on July 18, 2022.
MARCH 31, 2022: Eastside was issued a NOTICE OF VIOLATION for their second occurrence of exceeding the 12-month window for internal inspections of the bagfilter (CD-02) over their sand storage silo (ES-02). This was deemed a violation of Condition 2.1.B.1.c.ii, of Air Quality Permit 08074T15. This NOV also stated that, “Except for the 12-hour average values that were recorded during the facility’s stack testing on September 21, 2021, and October 7, 2021, your facility reported thirty (30) 12-hour block averages during which the pressure drop readings for the wet scrubber (CD-01) were below the minimum pressure drop limit previously established in Air Quality Permit 08074T15. By failing to maintain the minimum pressure drop, you were in violation of 15A NCAC 02D.1204, as referenced by permit condition 2.1.A.4.e of Air Quality Permit 08074T15.” This was in reference to the facility’s deviation report that was received on January 28, 2022. This NOV also stated that, “This office acknowledges that your facility submitted a permit modification application on November 19, 2021, to account for the updated operating limits established during the stack testing conducted on September 21-22, 2021, and October 7, 2021.” This was then addressed through the issuance of the facility’s SOC. The violation was resolved upon receipt of a response from the facility on April 7, 2022.
DECEMBER 13, 2021: Eastside was issued a NOTICE OF VIOLATION and NOTICE OF RECOMMENDATION FOR ENFORCEMENT for operating with an expired Title V permit. Air Quality Permit No. 08074T15 expired November 30, 2021. The facility’s permit renewal application was received by the DAQ on October 25, 2021. This submission failed to meet the six-month prior to permit expiration deadline. Therefore, there was no permit shield. On July 18, 2022, a Special Order of Consent (SOC) was finalized between the facility and the DAQ. The facility is now operating under this SOC until a new permit is issued to the facility, or December 31, 2022, whichever comes first. This SOC stated that the facility agrees to pay the DAQ a civil penalty in the amount of $24,000. The facility was required to pay the civil penalty within 30 days of the effective date of the SOC. A letter was issued to the facility on July 26, 2022, to acknowledge that the payment has been received. This violation will be resolved upon issuance of the facility’s air permit.
JULY, 2021: The facility was inspected and found to be in violation of 15A NCAC 2D.524 for failing to meet the minimum pressure drop of 0.18 inches of water across the sorbent polymer catalyst composite material adsorber (CD-04).” The facility was also found to be in violation of 15A NCAC 2D .1204 “Sewage Sludge and Sludge Incinerators,” for recording 23 pressure drop readings for the wet scrubber (CD-01) below the pressure drop limit and one liquid pH reading for the wet scrubber (CD-01) below the limit. On January 21, 2022, the facility was assessed $44,364 for these violations (Case #2021-060). On February 24, 2022, a remission request was received from the facility. On March 18, 2022, a response from the DAQ was issued to the facility stating that the assessment had been modified to a total amount of $22,364. On April 13, 2022, a letter was issued to the facility acknowledging payment.
APRIL 23, 2021: Eastside was issued a NOTICE OF VIOLATION and NOTICE OF RECOMMENDATION FOR ENFORCEMENT for having three exceedances of the CO emission limit. The exceedances occurred on September 14, 2020, October 31, 2020, and December 10, 2020. These exceedances were conveyed in the facility’s semi-annual report postmarked on January 27, 2021. In their response, the facility stated that corrective actions were taken for all three exceedances. The case number for this enforcement package was 2021-017. The facility was assessed $12,457 on July 29, 2021. Payment was received.
MARCH 5, 2021: Eastside was issued an NOTICE OF VIOLATION for failing to comply with the operating limits depicted in Air Quality Permit No. 08074T14. In the facility’s deviation report, received at the DAQ on January 27, 2021, the facility noted two temperature values below the minimum combustion chamber operating temperature averaged over a 12-hour block, nineteen pressure drop readings for the wet scrubber (CD-01) below the minimum pressure drop averaged over a 12-hour block and one hundred pressure drop readings of the sorbent polymer catalyst composite material adsorber (CD-04) below the minimum pressure drop averaged over a 12-hour block. This NOV also incorporated any exceedances of the operating limits in January 2021, which the facility also reported. In the facility’s response they stated that the low operating temperatures resulted from an increase in the moisture content of the sludge fed into the incinerator. The facility also indicated that the lower pressure drops were due to feeding less sewage sludge into the incinerator than during their most recent performance testing. This violation was resolved upon receipt of the response from the facility on March 17, 2021.
DECEMBER 16, 2020: Eastside was issued a NOTICE OF DEFICIENCY for failing to submit an application for the revision of Air Quality Permit No. 08074T14. The facility conducted a performance test on their incinerator (ES-01) on September 15-16, 2020. A permit application to modify their operating limits based on the results of their performance test was due by November 15, 2020 and was not received until January 14, 2021. No further action was taken upon receipt of the application.
AUGUST 20, 2020: the facility was issued a NOTICE OF VIOLATION for exceeding the performance test combustion temperature of the fluidized bed sewage sludge incinerator (ES-01) by more than 20%. At that time, the most recent performance test was conducted in December of 2019. The maximum combustion temperature during this test was 1,299°F. Therefore, with the 20% buffer added to this, the maximum combustion temperature limit was set at 1,559°F. In March of 2020, there were eight exceedances of this combustion temperature limit. This was deemed a violation of 40 CFR Part 503, Subpart E, “Standards for the Use or Disposal of Sewage Sludge: Incineration” as referenced in Condition 2.1.A.5 of Air Quality Permit 08074T13.
Additionally, the facility had not conducted the performance test of the three 2,000 kW dual use generators (ES-03, ES-04, and ES-05) within three years of the previous performance test. The generators had last been tested in March of 2017 and were not re-tested again until April 2020. This was deemed a violation of 40 CFR Part 63, Subpart ZZZZ. In response to the combustion temperature exceedance, the facility replied and stated that the maximum temperature during the December 2019 stack test was 1,316 °F.
Therefore, the 20% buffer should have allowed a maximum temperature limit of 1,579°F, which none of the temperatures exceeded. The facility admitted to missing the three-year deadline for testing the generators. No further action was taken at that time.
From the 2020 report: “The facility shall submit a compliance report semi-annually. All instances of noncompliance with the requirements of this permit must be clearly identified. The last report was received on July 29, 2020 with the required information. It should be noted that the facility stated that there were no deviations or noncompliance issues in the report. Since the performance testing of the generators was not done within 3 years of the previous test, the facility was in noncompliance. Therefore, the semi-annual report was inaccurate, and the NOTICE OF VIOLATION will request the facility to correct and resubmit the report.”
AUGUST 2, 2019: Eastside was issued a NOTICE OF VIOLATION for failing to record the pressure drop across the catalyst for the dual use generator (ES-05) for the month of June 2019. This was a violation of Condition 2.1.C.3 of Air Quality Permit No. 08074T12 to keep records of the monthly measurements of the pressure drop across the catalyst. This violation was reported in the facility’s semi-annual report, which was received at the WSRO-DAQ on August 1, 2019. The facility responded and stated that the CPMS data logger was mistakenly not restarted in June of 2019. In July of 2019, the corrective action was taken to restart the data logger, and no further action was taken.
JUNE 30, 2017: Eastside was issued an NOD for failing to record the monthly inspections of bag filter CD-02 in April and May of 2017. These inspections were reportedly conducted, but not documented.
From the 7/16/2021 report: June 30, 2017 – “… While the inspections were conducted, they were not recorded.”
From the 8/12/2020 report: June 30, 2017 – “… While the inspections were conducted, they were not recorded.” These are the actual quotes pulled from the report. We highlighted key discussion items in red:
The red “NOTE” above is our addition in order to highlight a key point: with more waste comes more pollutants, and with more people comes more waste
Permit Issues
Eastside has a 1,000-gallon diesel fuel oil storage tank on-site that is not listed in the permit.
MARCH 12, 2020: Eastside was issued a NOTICE OF VIOLATION and NOTICE OF RECOMMENDATION FOR ENFORCEMENT for having three exceedances of the Carbon Monoxide emission limit (64 ppmvd, corrected to 7% O2, 24-hour block average), pursuant to 40 CFR Part 62, Subpart LLL, as referenced by Condition 2.1.A.5 of Air Permit No. 08074T12. The reported exceedances occurred on August 28, 2019, August 29, 2019, and November 18, 2019. The exceedances were reported as part of the facility’s semi-annual report dated January 30, 2020. The facility stated that corrective actions were taken for all three exceedances. The case number for this enforcement package was 2020-014. The facility was assessed $12,449.00 on September 18, 2020. This was paid on October 9, 2020.
OCTOBER 28, 2019: Eastside was issued a NOTICE OF VIOLATION and NOTICE OF RECOMMENDATION FOR ENFORCEMENT for having two exceedances of the CO emission limit (64 ppmvd, corrected to 7% O2, 24-hour block average), pursuant to 40 CFR Part 62, Subpart LLL, as referenced by Condition 2.1.A.5 of Air Permit No. 08074T12. The exceedances occurred on January 20, 2019 and March 3, 2019. These exceedances were conveyed in the facility’s report dated July 30, 2019. In the facility’s response, it was stated that the exceedances occurred during startup of the incinerator (ES-01) during the 23:00 hour on Sundays. With no other process runtimes during the day, the daily block averages were negatively affected by brief periods of excess CO emissions during start-up. The facility stated that they will begin their start-up processes earlier in the day moving forward. The case number for this enforcement package was 2019-083. The facility was assessed $8,449.00 on January 31, 2020. This civil penalty was paid on February 6, 2020.