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Home My WebLink AboutWQ0003824_2020 Annual Report Review_20210513DocuSign Envelope ID: 6E4C5A76-F56A-4415-A829-D7F1 BC71 B20A ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director Ms. Tonya Mann, Utilities Director City of Graham P.O. Box 357 Graham, NC 27253 NORTH CAROLINA Environmental Quality May 13, 2021 SUBJECT: Review of the 2020 Annual Report City of Graham, Residuals Land Application Program Permit No. WQ0003824 Alamance County Dear Ms. Mann: Staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR) has completed a review of the 2020 Annual Report for the subject facility. This review was completed by DWR staff person Patrick Mitchell. Review of the subject report reflects compliance with the Permit No. WQ0003824. A routine compliance inspection is planned to be scheduled within this inspection calendar year. Please refer to the enclosed compliance inspection report form for additional observations and comments for the review. If you have any questions regarding this letter, please contact Patrick Mitchell or me at the letterhead phone number or address, or by email at patrick.mitchell@ncdenr.gov or lon.snider@ncdenr.gov. Sincerely, .-DocuSigned by: L-o, JMJCt' 14 9E2caer, ons`m5C94 Kegional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO enc: Compliance Inspection Report cc: Mr. Cris Routh, Plant Superintendent -City of Graham (Electronic Copy) Mr. Nate Roth-Synagro, (Electronic Copy) Alamance County Environmental Health (Electronic Copy) Laserfiche File WQ0003824 WSRO Electronic Files _1121,..„E\93 North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 3001 Winston-Salem, North Carolina 27105 336.776.9800 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 Contact Person: David W Lawson Directions to Facility: System Classifications: LA, Primary ORC: Crispian T. Routh Secondary ORC(s): On -Site Representative(s): Related Permits: Graham NC 272530357 Title: Phone: 336-570-6721 Certification: 994839 Phone: 336-570-6721 NC0021211 City of Graham - Graham WWTP NC0045292 City of Graham - Graham / Mebane WTP Inspection Date: 05/12/2021 Entry Time 09:OOAM Exit Time: 11:30AM Primary Inspector: Patrick Mitchell Phone: 336-776-9698 Secondary Inspector(s): 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 ▪ Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/12/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: On May 12, 202, WSRO staff conducted a review of the subject facility's 2020 Annual Report. The report reflects compliance with the subject permit. No site visit was made as part of this inspection event. Below is a summary of notes from this review. • The Sodium Adsorption Ratio (SAR) was reported as elevated for some residuals sampling (i.e. 6.27 — 8.49). While this is below the permit limit of 10.0, elevated SAR levels can have negative impacts to soils and crop health. It should be noted that the 2019 soil sampling results showed elevated Sodium and Exchangeable Sodium levels in soils of some fields. Request Permittee continue to monitor sodium levels in residuals, crop health and sodium levels in land application fields soils. Review crop and soils health at land application fields next onsite inspection. • Review aerobic digester at WWTP as part of the Specific Oxygen Uptake Rate (SOUR test) used to meet vector attraction requirements next onsite inspection. An onsite inspection is planned within this inspection year. Page 2 of 4 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/12/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Type Distribution and Marketing Land Application Record Keeping Is GW monitoring being conducted, if required? Are GW samples from all MWs sampled for all required parameters? Are there any GW quality violations? Is GW-59A certification form completed for facility? Is a copy of current permit on -site? Are current metals and nutrient analysis available? Are nutrient and metal loading calculating most limiting parameters? a. TCLP analysis? b. SSFA (Standard Soil Fertility Analysis)? Are PAN balances being maintained? Are PAN balances within permit limits? Has land application equipment been calibrated? Are there pH records for alkaline stabilization? Are there pH records for the land application site? Are nutrient/crop removal practices in place? Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? Are hauling records maintained and up-to-date? # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? Comment: See summary. Pathogen and Vector Attraction a. Fecal coliform SM 9221 E (Class A or B) 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) Yes No NA NE El • Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ Yes No NA NE ❑ ❑•❑ • ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page 3 of 4 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/12/2021 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: See summary. Treatment Check all that apply Aerobic Digestion Anaerobic Digestion Alkaline Pasteurization (Class A) Alkaline Stabilization (Class B) Compost Drying Beds Other Comment: Yes No NA NE • Page 4 of 4