WQ0001318_Compliance Evaluation Inspection_20200810

DocuSign Envelope ID: EF9218FD-80E2-4FD0-8529-BB751627D8DF
�9YY1�
ROY COOPER
NORTH CAROLINA
Governor
Environmental Quality
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
August 10, 2020
Mr. Tom Johnson - Water Resources Director
City of Lexington
28 West Center Street
Lexington, NC 27292
Subject: Compliance Evaluation Inspection
City of Lexington, Distribution of Class A Residuals
Permit No. WQ0001318
Davidson County
Dear Mr. Johnson:
On August 3, 2020, staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (Division) performed an announced routine compliance evaluation inspection of the
subject facility. This inspection was conducted by DWR staff persons Patrick Mitchell and Caitlin
Caudle. The inspection reflects compliance with Permit No. WQ0001318.
Please refer to the enclosed compliance inspection report form for additional observations and
comments. If you have any questions regarding this letter, please contact Patrick Mitchell or me at
the letterhead address or phone number, or by email at patrick.mitchellgncdenr� or
Ion. .
Sincerely,
DocuSigned by:
_T SMdCs•
o1i 19 &r, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Davidson County Environmental Health
DWR Laseriiche File WQ0001318
WSRO Electronic Files
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105
336-776-9800

Compliance Inspection Report
Permit: WQ0001318 Effective: 08/01/19 Expiration: 06/30/24 Owner: City of Lexington
SOC: Effective: Expiration: Facility: City of Lexington DCAR
County: Davidson 500 Glendale Rd
Region: Winston-Salem
Lexington NC 27292
Contact Person: Joseph Charles Shaffer Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: William Larry Waycaster
Secondary ORC(s):
On -Site Representative(s):
Certification: 997289 Phone:[phone]
Related Permits:
NC0055786 City of Lexington - Lexington Regional WWTP
Inspection Date: 08/03/2020 Entry Time 10:OOAM Exit Time: 12:OOPM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Inspection Type: Compliance Evaluation
Miscellaneous Questions Record Keeping
Sampling Pathogen and Vector Attraction
(See attachment summary)
Treatment
Storage
Page 1 of 4

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 08/03/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On August 3, 2020, WSRO staff conducted an inspection of the subject facility. Accompanying staff on the inspection was
Tom Johnson (Utilities Director), Steve Craver (Primary WWTP ORC) and Bill Waycaster (Compost ORC). Eglaentna Mineral
was present for lab records review only. The inspection found the facility to be compliant with the subject permit. Below is a
summary of notes from the inspection.
1. Records were found to be complete and in good order.
• Discussed sampling frequencies for belt press sludge and for Class A compost residuals.
• Discussed Fecal Coliform sampling procedures and retesting on the occasions where results reported 1,000 or greater
fecal counts. Maintain records and reporting notes for annual reports to clearly demonstrate compliance with Class A
2. Facility is doing within vessel composting and some windrow composting.
• Discussed both methods and reviewed records for each. Records reflect compliance with both methods.
3. Records indicate that 100% of compost residuals are picked up by recipients.
• Recommended obtaining signed utilization agreements from residuals recipients to have a clear track of who is responsible
for land application activities.
Page 2 of 4

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 08/03/2020 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Land Application
❑
Distribution and Marketing
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?
0
❑ ❑ ❑
Are current metals and nutrient analysis available?
0
❑ ❑ ❑
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?
❑
❑ 0 ❑
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: See summa
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 4

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 08/03/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on: 0 ❑ ❑ ❑
Digester (MCRT) ❑
Compost
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ M ❑
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: See summa
Sampling Yes No NA NE
Describe sampling:
Sludge = Composite grabs from belt press throughout day. Compost = Composite of grabs (collected —1 to
2 ft. deep in piles), Fecal is grab.
Is sampling adequate? 0 ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
Page 4 of 4

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
General Information
CLASS A RESIDUALS DISTRIBUTION
Facility Name: Lexington Compost Facility Davidson W I �a rsfkr8
Permit No.: WQ0001318 ty
Permit Issuance Date. August 1, 2019
Owner: City of Lexington June 30.2024 3
Plant OX-%%//
1 L�Q caner Permit Expiration Date:
RName: St��Telephone No. � Zyo - 2 yX'Pdt
Other COntact(s): Tomm J ohnson Utilities Director Telephone No.: Cell 336-479-5326, Office 336-357-5090
Facility Location (address, gps or directions): 500 Glendale Rd.; Hwy 52 S., to 1-285 to 1-85 N., Exit 91 L onto Cotton Grove Rd.,
LL onto Rd., (a) end. I-_ 1_ o- - . - - _ _ T
Reason for Insaection
® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
�r 20zo
o✓ ? 201 q k�� r� wcis lam fkr ,
Tia�king �P M^j • s ;� MtI•�
SAK r�lcwlt�� o{ IAb rAlt 537
1 �
�arM eAe,� 60 v( t' L h
9Pv�
r41;ti
Ty,�
2nl `] ljdr� 9e)
�5 "9 W� 2a1�
�we �....,„�wA2c� %�1•iP"� yam' .5ej �'% ��'"y'e��d
4r re��
Is a follow-up inspection necessary? ❑ Yes � No
Primary Inspector: P. Mitchell
Date of Inspection: August 3, 2020
Secondary Inspector: C. Caudle
Entry Time: 10:00 am Exit Time: 2: n

----
pvG
Non-Dischar Compliance inspection Report - —
Record Keening and Renortine Information: Y� N NA NE
Is current permit and prior annual reports available upon request? ❑ ❑ ❑
Has the facility been free of public complaints for the last 12 months ludg & Compost = 1/ r ❑ ❑ ❑
TCLP analysis conducted and results available? Frequency? ( ee permitforfrequency) ��❑ ❑ ❑
Residuals metals and nutrient analysis conducted? Frequency? (See permit for frequency) a ❑ ❑ ❑
Nutrient and metals loading calculations? (to determine most limiting rameter) ❑ ❑ ❑
Do lab sheets support data reported on Residuals Analysis Summary? Sludge = 1/permit ❑ ❑
Are distribution and/or hauling records available? Compost = 1/60 days (6xyr) ❑ ❑ ❑
Utilization Agreements established or Recipient Notifications available for review? ❑ ❑ ❑
Do the Utilization Agreements or Recipient Notifications contain minimum requirements? ❑ ❑
(Restrictionsfor land application, stockpiling, setback buffers, etc.)
If the Permittee applies bulk residuals, are field loading records available? ❑ ❑ ❑
If the Perm ittee applies bulk residuals, are field inspections conducted and are records available? ❑ ❑ ❑
Does residuals package label or Utilization agreement contain minimum info required by permit? ❑ ❑ ❑
(Name & address ofgenerator, statement of restrictions, nutrient contents) ,
Is an inspection log available containing record of residuals facility inspections, maintenance, f`�-'� ❑ ❑ ❑
and repairs?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
® Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency? (See permit for frequen�4 �d cy) �l ❑ ❑
Were multiple samples taken? 2. 5."-
) I e bA b t ❑
If Fecal Coliform, density <1,000 MPN/gram of total solids9 lan asa�t� ak ❑
If Salmonella, density <3 MPN/4 grams of total solids? 41)dl(Il, ❑
Select which treatment Alternative below was used to demonstrate Clas� compliance.
❑ Alternative 1 - Time/Temperature (See White House Manual for specific requirements) Y N NA NE
Were residuals maintained for correct time and temperature? ❑ ❑ ❑ ❑
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Are temperatures within range for complete time period? ❑ ❑ ❑ ❑
❑ Alternative 2 - Alkaline Treatment
Are logs present showing time and temperature?
Was the pH raised to 12 or greater and maintained for 72 hours or longer? ❑ ❑ O ❑
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater? El El
Are logs present showing time and pH? ❑ ❑ ❑ ❑
Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ ❑ ❑ ❑
® Alternative 5 - Process to Further Reduce Pathogens (PFRP) (Select the PFRP method below that was utilized]
® Composting, Select which method was used: _ n ,� ��^� 20Z0
® Within -Vessel Method or Static Aerated Pile Method 1`v
Were residuals temperatures maintained at >55°C (13 PF) for N NA NE
>3 consecutive days in the within -vessel or static aerated piles? ❑ ❑ ❑
® Windrow Composting Method k 2'a `
Were the residuals temperatures maintained at >55°C for at least
15 consecutive days in the windrow, and the windrow was turned a ❑ ❑ ❑
minimum of five times during this time�,� 1 � ys,� S -�-�(.
❑ Heat Drying d
Were the residuals dried by direct or indirect contact with hot gases and the ❑ ❑ ❑ ❑
moisture content of residuals reduced to <10%?
Did the temperature of the residuals or the wet bulb temperature of the gas ❑ ❑ ❑ ❑
in contact with the residuals as the residuals leave the dryer exceed 800C (1760F)?
❑ Other Alternative, Specify:
(See White House Manual)
Page 2 of 4

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ Option 1 - 38 /o Volatile Solids Reduction Y
Are lab results and calculations present? ❑
Was the reduction on volatile solids (not total solids)? ❑
Were samples collected at correct locations? ❑
(beginning of digestion process & before land application)
Was there a >38% reduction? ❑
❑ Option 2 - 40-Day Bench Scale Test
Were residuals from anaerobic digestion?
Are lab results and calculations present?
Was the test anaerobically digested in lab, and test run for 40 days?
Was the test done between 300C (86°F) and 370C (990F)?
Was the reduction of on volatile solids (not total solids)?
Was the reduction less than 17%?
❑ Option 3 - 30-Day Bench Scale Test
Were residuals from aerobic digestion?
Are lab results and calculations present?
Were residuals 2% or less total solids?
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent?
Was the test run for 30 days?
Was the test done at 20°C (68°F)?
Was the reduction of on volatile solids (not total solids)?
Was the reduction less than 15%?
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test)
Were residuals form aerobic digestion?
Were residuals <2% total solids (dry weight basis) (not diluted)?
Was the test done between 10°C (507) and 30°C (86°F)?
Was the temperature corrected to 20°C (68°F)?
Was the sampling holding time <2 hours?
Was the test started within 15 minutes of sampling or aeration maintained?
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? K \ , I
c
® Option 5 - 14-Day Aerobic Process
Were the residuals from aerobic digestion?
Was the average residuals temperature higher than 45°C (113°F)?
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period?
Y
❑ Option 6 - Alkaline Stabilization
Was the pH of the residuals raised to >12 and maintained for two hours
without addition of more alkali?
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
without the addition of more alkali?
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)?
N
NA
NE
❑❑
❑❑
o
❑
❑
❑
❑
❑
❑
Y
N
NA
NE
❑
❑
❑
❑
❑
❑
❑
❑
Y
N
NA
NE
❑
❑
°❑
°❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
❑
Y
N
NA
NE
°❑
❑
o
o
N
NA
NE
N
NA
NE
01
❑ Option 7 - Drying of Stabilized Residuals
Y
N
NA
NE
The residuals do not contain unstabilized residuals?
❑
❑
❑
❑
Were the residuals mixed with any other materials? If so, what?
❑
❑
❑
❑
Were the residuals dried >75% total solids?
❑
❑
❑
❑
❑ Option 8 - Drying of Unstabilized Residuals
Y
N
NA
NE
Were the residuals mixed with any other materials?
❑
❑
❑
❑
Were the residuals dried >90% total solids?
❑
❑
❑
❑
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4

Non -Discharge Compliance Inspection Report
Residuals Store e: I
Describe storage: 6 ;e JJ Wed 4. Ar
Number of days/weeks/months of storage: Al2-- r
Residuals Sampling: y N NA NE
Is sampling adequate and representative? / II ❑ ❑ ❑
A Describe Sampling: = or oc or 11 ewe cis
olk Transport Vehicle: 60 s)4_ N N NE
Is transport occurring at time of inspection? "`T I ❑ ❑ ❑
pp' Q Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed vehicte(s): ❑ ❑ Ell r+" Application Sites) N�
Rr Were application site(s) inspected? Ifso, please complete info below. ❑ Yes *No
lication occurring at the time of inspection? If no, note the date of the last event: ❑ Ye No
Weather o
❑ Sunny ❑Part
❑ Cloudy
❑ Windy (winddirec")
eeu
❑ No Precipitation ,:Drizzle
❑ RaiWeather
Notes (i.e. Signihan
recasts, etc):Temp.
(° F): ❑ <32— 40
❑ 40 — 60
Permit and an onsite during application? ❑ Yes
A ication Observations: ITvpe of annlicatinn•
F Lim
mcenaeaop: PAN Requirement:
Ibs/ac
Application a (tons or gallons/acre):
Nutrient Content:
Application occurring at t e ofvisit: ❑Yes ❑ No
Application Method: ❑ Surfac [ncorp/Injection
Incorporation/Injection during visit: es ❑ No ❑ N/A
Vegetative Buffer description: ❑None ❑ ❑Crop ❑ Shrub ❑
Tree ❑ Other
Current Field Conditions:
❑ Bare ❑Stubble ❑Planted (crool ❑ P
e
Soil Condition:
❑ Dry ❑Moist [I Wet ❑Saturated
❑ Not -Frozen ❑ Frost ❑ Frozen ❑ Snow -Covered
Slope: ❑ 0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: ❑ None ❑ Mild ❑ Moderate ❑ Strong
Vectors: [I None ❑ Few ❑Many ❑ Excessive
Application Details: Y
NA
NE
Application areas clearly marked?
❑
❑
❑
Application within authorized area? ❑
❑
❑
❑
Application method appropriate? ❑
❑
❑
❑
Application is even (no ponding)? ❑
❑
❑
❑
Sufficient setbacks from wells? ❑
❑
❑
❑
Sufficient setbacks from surface wa ? ❑
❑
❑
❑
Slopes>10%avoided (Surface p.)? ❑
❑
❑
❑
Slopes>l8%avoided(in /Inject)? ❑
❑
❑
❑
lncorpAnjection wi time -frame? ❑
❑
❑
❑
No evidence of low GW? ❑
❑
❑
❑
Tracking i evented? ❑
❑
❑
❑
Bio s run-off is prevented? ❑
❑
❑
❑
❑ Overcast
Cloudburst (If applicable, precipitation measurement: —J
❑ 60 — 80 ❑
❑ No
d F— Cake (> 15% 1
Site Owner(s):
Intended Crop: PAN Require
Application Rate (tons or gallons/acre):
Nutrient Content:
Application occurring at time ofvisit: [I Yes El
Application Method: ❑ Surface ❑ Incorp/ln' tion
❑ Incorporation/Injection during visit: es ❑ No ❑ N/A
Vegetative Buffer description: one ❑Grass ❑Crop ❑ Shrub ❑
Tree ❑ Other
Current Field Conditio
❑ Bare ❑ Stubbl Planted (crop) ❑ Pasture
Soil Conditio
❑ Dry oist ❑ Wet ❑ Saturated
`❑ No rozen ❑ Frost ❑ Frozen ❑ Snow -Covered
S 0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: None ❑ Mild ❑ Moderate ❑ Strong
Vectors: ❑ Name, ❑ Few ❑ Many ❑ Excessive
Application Details:
Y
N
NA NE
Application areas clearly mar ?
❑
❑
❑
❑
Application within authorized area.
Cl
❑
❑
❑
Application method appropriate?
❑
❑
❑
❑
Application is even (no ponding)?
❑
❑
❑
❑
Sufficient setbacks from wells?
❑
❑
❑
❑
Sufficient setbacks from surface waters?
❑
❑
❑
❑
Slopes >10% avoided (Surface App.) ?
❑
❑
❑
Slopes >18%avoided (Incorp/inject)?
❑
❑
Incorp./Injection within time -frame?
❑
❑
❑
No evidence of shallow GW?
❑
❑
❑
Tracking is prevented?
❑
❑
Biosolids run-offis prevented?
❑
❑
❑
Page 4 of 4
ie ,
�4
hn:1t`, �fes I1i'l8 � ,t
��►*y�- � a..e �r� Ali � /ayes
r