WQ0003824_Response to ARR_20200619

(tity of &a4am
P.O. Drawer 357
201 South Main Street
Graham, North Carolina 27253
Tel: [phone] Fax: [phone]
Lon Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
450 West Hanes Mill Road, Suite 300
Winston-Salem, INC 27105
June 18, 2020
Subject: Review of 2019 Annual Report
Dear Mr. Snider:
The City of Graham has reviewed the items of concern in your letter
regarding the 2019 Annual Report for the City of Graham Residuals Land
Application Program, Permit No. WQ0003824.
After much discussion between Cris Routh, ORC and Tonya Mann,
Utilities Director for the City of Graham, our response to the noted items are
as follows:
TtPm 1
The City of Graham will continue to monitor the documented fields for
concerns with the soil fertility parameters.
Item 2
The City of Graham has updated our 2020 Field Summary Forms and Metals
Field Loading Summary Forms to reflect the dominant soil series for each
field as listed in Permit Attachment B. Due to space constraints on each
form, the code for each soil series will be listed in space provided. Per a
June 3, 2020 e-mail from Caitlin Caudle, Environmental Specialist I at the
Winston-Salem Regional Office, The City of Graham will be using the code
Cg-ChA (Congaree-Chewacla soil complex) for Field 10. The City of Graham
is aware that this code is subject to change once the Alamance County soil
survey is completed.

Item 3
The City of Graham performs sludge analysis quarterly but reports our
application events on a monthly basis. This requires us to sometimes list
the quarterly Residuals Analysis results multiple times on the Metals Field
Loading Summary Forms in order to determine monthly Heavy Metal Field
Loadings results. Each monthly "Volume Applied per Acre" result from the
Field Summary Forms is reported on the Metals Field Loading Summary
Forms (chronologically by the month of application from left to right) in the
row labeled "Total DT/Ac./App Event". This requires quarterly Residuals
Analysis Data to be listed multiple times for each month within the
respective quarter of application in order to properly determine the total
Annual Heavy Metal Field Loadings for each metal.
Following a telephone conversation on June 16, 2020 between Cris Routh,
Plant Superintendent and Patrick Mitchell, Soil Scientist at the Winston-
Salem Regional Office, it was determined that Annual Heavy Metal Field
Loadings can be correctly calculated using a monthly or quarterly method.
At this time, the City of Graham will continue to calculate via monthly
application event data.
If you need any additional information regarding our 2019 Annual Report,
please contact me at 336.570.6721 or email [e-mail].
Sincerely,
,�� 6,-Z�6
Cris Routh
ORC, Plant Superintendent
City of Graham
Cc: Frankie Maness, City Manager
Tonya Mann, Utilities Director