The URL can be used to link to this page

Home My WebLink AboutWQ0003824_Residual Annual Report 2019 Review_20200602ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Ms. Tonya Mann, City of Graham P.O. Box 357 Utilities Director Graham, NC 27253 NORTH CAROLINA Environmental Quality June 2, 2020 SUBJECT: Review of the 2019 Annual Report City of Graham, Residuals Land Application Program Permit No. WQ0003824 Alamance County Dear Ms. Mann: The Division of Water Resources (DWR) acknowledges receipt of your 2019 annual report for the subject permit. A review of this report was conducted by DWR staff person Caitlin Caudle. Review of the subject report reflects compliance with the Permit No. WQ0003824. The following items of concern were noted: 1. Soil sample results indicated that field 6 had elevated zinc levels above 2000; and fields 1, 2, 4, 5, and 7 had zinc levels above 1000. Sodium and exchangeable sodium percentage (ESP) levels in soils were also elevated in some fields. Please monitor these soil fertility parameters to ensure they do not continue to increase. Also, please ensure that properly collected composite soil samples are tested for representative results. NCDA has a guidance document for sampling large areas on their website. 2. The Field Summary Form and Metals Field Loading Summary Forms included in the report listed "Mineral" for the soil series. Please list the predominant soil series that is included in your Permit Attachment B on future reporting forms. 3. Metals Field Loading Summary Forms listed the residuals analysis results multiple times for some sampling events. Please only list data from each sampling event once to prevent over reporting of metals loading. D North Carolina Department of Environmental Quality I Division of Water Resources EQ�p Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 NORTH CAROLINA � o•o•°"•mme""°"^•"vin"•i� /� 336.776.9800 An announced routine compliance inspection is planned to be scheduled within the next 12 months. If you have any questions regarding this letter, please contact Patrick Mitchell or me at (336) 776- 9801. Sincerely, DocuSiTgned<by: mgcr 145B49E225C94EA... Lon Snider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO cc: Mr. Cris Routh, Plant Superintendent -City of Graham- crouth@cityofgraham.com Mr. Nate Roth-Synagro, - rroth@synagro.com Alamance County Environmental Health Laserfiche File WQ0003824 WSRO Electronic Files Compliance Inspection Report Permit: WQ0003824 Effective: 12/01/19 Expiration: 10/31/25 Owner: City of Graham SOC: Effective: Expiration: Facility: City of Graham RLAP County: Alamance 1204 E Gilbreath St Region: Winston-Salem Graham NC 272530357 Contact Person: David W Lawson Title: Phone: 336-570-6721 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0021211 City of Graham - Graham WWTP NC0045292 City of Graham - Graham / Mebane WTP Inspection Date: 06/01/2020 Entry Time 10:OOAM Exit Time: 12:OOPM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Patrick Mitchell Reason for Inspection: Routine Inspection Type: Annual Report Review Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment Sampling Land Application Site Pathogen and Vector Attraction (See attachment summary) Page 1 of 5 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 06/01/2020 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: A review of the 2019 annual report was completed on 06/01/2020. The annual report reflects compliance with the subject permit. A site visit was not included with this inspection. The following items of concern were noted: 1. Field 6 had elevated zinc levels above 2000; and fields 1, 2, 4, 5, and 7 had zinc levels above 1000. Fields 1, 2, 4, 5, 6, and 7 had elevated zinc levels above 1000. Sodium and exchangeable sodium percentage (ESP) were also elevated in SOME fields. Please monitor these soil fertility parameters to ensure they do not continue to increase. 2. Please list the predominant soil series on each Field Summary Form and Metals Field Loading Summary Form. Predominant soil series can be found in the Attachment B of the subject permit 3. Metals Field Loading Summary Forms listed residuals analysis data multiple times per sampling event. Please only list data from each sampling event once. *Follow-up inspection is needed to review vegetative cover in fields. Is Johnson Grass still the predominant crop? If so, is a second crop being planted during cool months? Page 2 of 5 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 06/01/2020 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? ❑ ❑ 0 ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ 0 ❑ Are there any GW quality violations? ❑ ❑ 0 ❑ Is GW-59A certification form completed for facility? ❑ ❑ 0 ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? 0 ❑ ❑ ❑ a. TCLP analysis? 0 ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? 0 ❑ ❑ ❑ Are PAN balances being maintained? 0 ❑ ❑ ❑ Are PAN balances within permit limits? 0 ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ 0 ❑ Are there pH records for the land application site? 0 ❑ ❑ ❑ Are nutrient/crop removal practices in place? 0 ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? 0 ❑ ❑ ❑ Are hauling records available? ❑ ❑ 0 ❑ Are hauling records maintained and up-to-date? ❑ ❑ 0 ❑ # Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑ Comment: 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 ❑ d. Salmonella (Class A, all test must be < 3MPN/4 gram day) ❑ ❑ ❑ ❑ Page 3 of 5 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 06/01/2020 Inspection Type: Annual Report Review Reason for Visit: Routine e. Time/Temp on: ❑ ❑ ❑ ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations ❑ ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ❑ ❑ 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 ❑ Comment: Sampling Yes No NA NE Describe sampling: Is sampling adequate? ❑ ❑ ❑ Is sampling representative? ❑ ❑ ❑ Comment: Land Application Site Yes No NA NE Is a copy of the permit on -site during application events? ❑ ❑ ❑ Is the application site in overall good condition? ❑ ❑ ❑ Is the site free of runoff/ponding? ❑ ❑ ❑ If present, is the application equipment in good operating condition? ❑ ❑ ❑ Are buffers being maintained? ❑ ❑ ❑ Are limiting slopes buffered? 10% for surface application ❑ ❑ ❑ 18% for subsurface application ❑ ❑ ❑ Are there access restrictions and/or signs? ❑ ❑ ❑ Is the application site free of odors or vectors? ❑ ❑ ❑ Have performance requirements for application method been met? For injection? ❑ ❑ ❑ Page 4 of 5 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 06/01/2020 Inspection Type: Annual Report Review For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 173' bls. Is application occurring at the time of the inspection? Comment: Reason for Visit: Routine ❑❑❑■ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ❑❑■❑ ■❑❑❑ ❑❑❑■ ❑❑❑■ Page 5 of 5