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Home My WebLink AboutWQ0001318_Review of 2020 Annual Report_20210609DocuSign Envelope ID: ABE320BA-ADOB-4C8A-9A4F-EFCC8E28DBBA ROY COOPER Governor JOHN NICHOLSON Interim Secretary S. DANIEL SMITH Director Mr. Tom Johnson, Water Resources Director City of Lexington 28 West Center Street Lexington, NC 27292 i IAT, .4 ' NORTH CAROLINA Environmental Quality June 9, 2021 Subject: Review of the 2020 Annual Report City of Lexington, Distribution of Class A Residuals Permit No. WQ0001318 Davidson County Dear Mr. Johnson: 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. WQ0001318. As a reminder, Permit No. WQ0001318 requires that a toxicity characteristic leaching procedure (TCLP) be completed for both the Source Residuals and the final Class A Compost Residuals Product at minimum one time for each within the current permit cycle (i.e., both due by June 30, 2024). The 2020 Annual Report provided TCLP results for "Sludge". It is this office's understanding that the "sludge" sample represents the source residuals and not the final Class A compost product. Please ensure that at least one TCLP test is completed for the Class A compost product by June 30, 2024. The 2020 Annual Report did not provide any data related to Windrow Composting. As a reminder, Windrow Composting method has different requirements for meeting Pathogen Reduction requirements. If Windrow Composting is conducted within a given calendar year, separate reporting data must be provided in annual reports to demonstrate compliance with this method. If Windrow Composting occurred in year 2020, please submit the required data to this office within 30 days of receipt of this letter. 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, LtDocuSignedigby:by� o., l . JMiter 4 49 225 4EA. LonSnider, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO cc: Davidson County Environmental Health (Electronic Copy) Laserfiche File WQ0001318 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: WQ0001318 Effective: 08/14/20 Expiration: 06/30/24 Owner : City of Lexington SOC: Effective: Expiration: Facility: City of Lexington DCAR County: Davidson 500 Glendale Rd Region: Winston-Salem Contact Person: Joseph Charles Shaffer Directions to Facility: Lexington NC 27292 Title: Phone: 336-357-5090 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0055786 City of Lexington - Lexington Regional WWTP Inspection Date: 06/09/2021 Entry Time 09:30AM 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: Distribution of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Treatment II Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 Permit: WQ0001318 Owner - Facility: City of Lexington Inspection Date: 06/09/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: On June 9, 2021, WSRO staff conducted a review of the subject facility's 2020 Annual Report. No site visit was made as part of this inspection event. The report reflects compliance with the subject permit. • Remind Permittee a TCLP analysis is required for the Class A Compost Product within this permit cycle (i.e., by 6/30/2024). • Some Fecal Coliform results provided in the report did not pass the pathogen limit of 1,000 MPN. However, the report and results indicated that these residuals were re -composted and subsequently resampled with passing results included in the report. • No windrow composting was reported in the 2020 report. Check next inspection to see if any windrow composting is occurring. Page 2 of 4 Permit: WQ0001318 Owner - Facility: City of Lexington Inspection Date: 06/09/2021 Inspection Type : Annual Report Review Reason for Visit: Routine Type Land Application Distribution and Marketing 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: WQ0001318 Owner - Facility: City of Lexington Inspection Date: 06/09/2021 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: 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