WQ0003035_Report of Compliance Evaluation Inspection_20210331

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 31, 2021
Ms. Melinda Ward, Wastewater Treatment Plant Superintendent
City of Eden
P.O. Box 70
Eden, North Carolina 27289
Subject: Compliance Evaluation Inspection
City of Eden, Residuals Land Application Program
Permit No. WQ0003035
Rockingham County
Dear Ms.. Ward:
On March 11, 2021 staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (DWR) performed an announced routine compliance inspection of the City of
Eden's residuals land application program. This inspection was conducted by DWR staff
member Jim Gonsiewski. Mr. Ryan Copeland of Synagro was present during this inspection.
The inspection reflects compliance with the permit.
Please refer to the enclosed inspection report for additional observations and comments. If you
have any questions regarding this letter, please contact Jim Gonsiewski or me at [phone].
Sincerely,
EDocuSI9ned by:
AM, -t JMRyCr
Lont"l ' n a'er
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Ryan Copeland - Synagro (Electronic Copy)
Rockingham County Environmental Health (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road. Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS B RESIDUALS LAND APPLICATION
General Information
Facility Name: City of Eden WVVTP County: Rockingham
Permit No.: W000 03035 Pertnit Issuance Date: 3/3/20
Owner: City of Eden
Plant ORC Name: Mike Vernon
Permit Expiration Date: 8/31/26
Telephone No.:
LA ORC / Contract Company: Ryan Copeland, Synagro Telephone No.: 336-607-4494
Telephone No.: 336-403-4324
Facility Location (address, gps or directions): 191 Mebane Bridge Road, Eden
Other Contact(s): Nate Roth, Synagro
Reason for Inspection
® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
Arrived at Eden VWVTP at 1:00 PM. Ryan Copeland, Synagro was at the facility. Discussed operations at the WWTP. The residuals were
pumped from the aeration basin to a Clean Bee Wastewater Treatment System. After treatment the resdivals are stored in a tank. The
residuals are then pmped up a hill to a tank at the the Synagro filter press. After the resudals are run through the press they are moved to a
residuals stroage area adjacent to the filter press. The area has a concrete floor and walls and is covered with a metal roof. Left VVWTP at
1:40 PM. Arrived at 2:15 PM. Inspected the field. The terrain was slightly hilly with slopes ranging from 3% to 6%. The solids content in the
residuals was 20.5%.
The field was properly flagged. No runoff or ponding of residuals from spreading was observed. One truck (15 cubic yard spreader) was
applying residuals. The O&M plan and the permit were present. The plan was adequate. The truck had an O&M plan and maps. The residual
spreading was good. No additional run off or ponding was observed. Proper buffers were maintained.
Left application field at 3:05 PM.
Is a follow-up inspection necessary? ❑ Yes ® No
Primary Inspector: Jim Gonsiewski
Date of Inspection: 3/11/21
Secondary Inspector:
Entry Time: 1:00 PM Exit Time: 3:05 PM

Non -Discharge Compliance Inspection Report
Residuals Generating Facility
Was the residuals generating facility inspected? ® Yes ❑ No
Residuals Storage:
Describe storage: Covered concrete pad
Number of days/weeks/months of storage: 90 days
Residuals Sampling: Y N NA NE
Is sampling adequate and representative for each sample type? ® ❑ ❑ ❑
Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP): Pathogens, Nutrients/Metals, TCLP
Transport Vehicle:
Is transport occurring at time of inspection?
Are necessary records (spill plan) present in vehicle? m of observed veh/cle(s):
Record Keeping and Reporting Information:
Is current permit and prior annual reports available upon request?
Has the facility been free of public complaints for the last 12 months?
TCLP analysis conducted and results available? Frequency? 12 1/yr or ❑ 1/permit cycle
Residuals metals and nutrient analysis conducted? Frequency? 1/yr (See permit for frequency)
Nutrient and metals loading calculations? (to determine most limiting parameter)
Do lab sheets support data reported on Residuals Analysis Summary?
Are PAN balance records available and within permit limits?
Are there nutrient (crop) removal practices in place?
Are hauling records available? (gal and/or tons hauled during calendar year to date)
Are field loading records available?
Are field inspections conducted and are records available?
Are soil sample results available?
Did soil results call for lime amendment? If so, are there records of application?
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2,000)?
Soil results indicate Na <0.5 meq/100 cm3, and Exchangeable Sodium Percentage (ESP) <15%?
Does the permit require groundwater monitoring?
Are groundwater lab results present?
There are no 2L GW standard violations indicated in the lab results?
N NA NE
® ❑ ❑ ❑
Y N NA NE
EEDE
UELIE
® ❑ ❑ ❑
❑ ❑ ❑ 2
EDDE
0002
2 ❑ ❑ ❑
WZ1000
O ❑ ❑ ❑
EDEE00
❑ ❑ ❑ ❑
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
Which Alternative was used to demonstrate compliance? Y N NA NE
Alternative 1 Fecal Coliform Density.
Were 7 samples collected and geometric mean <2 million mpn/cfu? ❑ ❑ ❑ ❑
❑ Alternative 2 Process to Significantly Reduce Pathogens (5 options)
❑ Alternative 3 Use of Equivalent to RSRP (Not commonly used - See White House Manual)
If Alternative 2 was used, select which Option was utilized and complete the section below.
❑ Option 1 - Aerobic Digestion Y N NA NE
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Was the time & temp. between 40 days at 68°F (20°C) and 60 days at 59° F (15°C)? ❑ ❑ ❑ ❑
❑ Option 2 - Air Drying
❑ Option 3 - Anaerobic Digestion
Are logs present showing time and temperature?
Was the time & temp. between 15 days at 95° F — 131° F (35°-55° C) and
60 days at >68° F (20° C)?
❑ Option 4 — Composting (Not commonly used - See White House Manual)
❑ Option 5 - Lime Stabilization
Are Togs present showing time and temperature?
Was the pH raised to >12 after two hrs of contact?
Was the temperature corrected to 25° C (77° F) (by calculation, NOT auto correct)?
Page 2 of 4
❑ ❑ ❑ ❑
ELIDE

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
El Option 1 - 38% Volatile Solids Reduction Y N NA NE
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 Y N NA NE
Were residuals from an anaerobic digester with average temp. 30°C — 40°C? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ ❑ ❑ ❑
Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ ❑ ❑
Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? ❑ ❑ ❑ ❑
Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑
Was the reduction less than 17%? ❑ ❑ ❑ ❑
0 Option 3 - 30-Day Bench Scale Test Y N NA NE
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) Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ❑ ❑ ❑ ❑
Was the test done between 10°C (50°F) 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)? ❑ ❑ ❑ ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
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? ❑ ❑ ❑ ❑
❑ Option 6 - Alkaline Stabilization Y N NA NE
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
(i.e. 24 hours total) without the addition of more alkali? ❑ ❑ ❑ ❑
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑ ❑ ❑ ❑
O 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? ❑ ❑ ❑ ❑
Were the residuals dried >75% total solids? ❑ ❑ ❑ ❑
0 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
Land Application Site(s)
Were application site(s) inspected? If so, please list Site ID(s) below. ® Yes ❑ No
Application Site ID(s): NC-RC-117
Is application occurring at the time of inspection? ® Yes ❑ No If no, note the date of the last event:
Was the Division notified of the application event(s)? ® Yes ❑ No
Weather Conditions:
® Sunny D Partly Cloudy ❑ Cloudy ❑ Stormy
® Windy (wind direction: ) ® Breeze
® No Precipitation ❑ Drizzle ❑ Rain
Is there a rain gauge onsite? ® Yes ❑ No
❑ Overcast
❑ Calm
❑ Cloudburst
(If applicable, precipitation measurement:
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60 ❑ >80
Permit and Spill Plan onsite during application? ® Yes
060-80
❑ No
Application Observations: [Type of application: ❑ Liquid ® Cake
❑ Other
Application Site —Field ID(s): NC-RC-117
Intended Crop: Fescue. pasture PAN Requirement: 15.6 Ibs/ac
Application Rate (tons or gallons/acre): 14 tons
Nutrient Content: 73 it's
% of total field area utilized or anticipated for this event? 10o
Application occurring at time of visit: ® Yes 0 No
Application Method: ® Surface 0 Incorp/Injection
Incorporation/Injection during visit: 0 Yes 0 No ® N/A
Vegetative Buffer description: ❑None ®Grass ❑Crop ❑ Shrub
®Tree ❑ Other
Current Field Conditions:
0 Bare 0 Stubble ❑ Planted (crop)
Soil Condition:
® Dry ❑ Moist 0 Wet ❑ Saturated
❑ Not -Frozen 0 Frost ❑ Frozen ❑ Snow -Covered
Slope: 0 0-3% ® 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: ❑ None ® Mild ❑ Moderate ❑ Strong
Vectors: ® None 0 Few ❑ Many 0 Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells/residences?
Sufficient setbacks from surface waters?
Slopes > I0% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
Biosolids visible on surface?
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-off is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
® Pasture
Y N NA NE
❑ ❑ ❑
❑ ❑❑
❑❑❑
§01710
❑ ❑❑
❑❑❑0D
❑ ❑00
IQ
000
Y N NA NE
• DDD
DDEJ
• ❑ ❑ ❑
• ❑❑❑
❑ ❑ ❑ 0
Y N NA NE
0000
V000
1Z❑❑❑
6:1(000
Application Site —Field ID(s):
Intended Crop: PAN Requirement: Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
% of total field area utilized or anticipated for this event?
Application occurring at time of visit: 0 Yes ❑ No
Application Method: ❑ Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ❑ N/A
Vegetative Buffer description: ❑None ❑Grass ❑Crop ❑ Shrub
❑Tree 0 Other
Current Field Conditions:
❑ Bare 0 Stubble 0 Planted (crop) ❑ Pasture
Soil Condition:
❑ Dry 0 Moist 0 Wet ❑ Saturated
0 Not -Frozen ❑ Frost ❑ Frozen 0 Snow -Covered
Slope: D 0-3% ❑ 3-6% 0 6-10% ❑ 10-18% 0 >18%
Odor: 0 None ❑ Mild ❑ Moderate 0 Strong
Vectors: 0 None ❑ Few ❑ Many 0 Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells/residences?
Sufficient setbacks from surface waters?
Slopes >10% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
Biosolids visible on surface?
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-off is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
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❑ ❑❑❑
❑ ❑❑❑
❑ ❑ ❑ ❑
❑ ❑❑❑
❑ ❑❑❑
DEIOD
DODD
❑ ❑❑❑
❑ ❑❑❑
Y N NA NE
EICIOD
DODO
❑ ❑❑❑
DODO
DEIDO
1" N NA NE
❑ ❑❑❑
❑ ❑ ❑ ❑
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Page 4 of 4