WQ0003824_Compliance Evaluation Inspection_20210702

DocuSign Envelope ID: BB421770-05DD-4793-8084-9601D2F44F94
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Ms. Tonya Mann, Utilities Director
City of Graham
P.O. Box 357
Graham, NC 27253
NORTH CAROLINA
Environmental Quality
July 2, 2021
Subject: Compliance Evaluation Inspection
City of Graham, Residuals Land Application Program
Permit No. WQ0003824
Alamance County
Dear Ms. Mann:
On June 3 and June 15, 2021, staff of the North Carolina Division of Water Resources Winston-
Salem Regional Office (DWR) conducted announced routine compliance inspections of the
subject residuals land application program. The compliance inspections were conducted by
DWR staff person Patrick Mitchell. The inspections reflect compliance with Permit No.
WQ0003824.
Please refer to the enclosed compliance inspection reports for a summary of the findings and
comments noted during the inspections. 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
[e-mail] or [e-mail].
Sincerely,
DocuSigned by:
OD4D3CE3FJ B7456..
Jennifer Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc: June 3, 2021 - Compliance Inspection Report (Residuals Source Inspection)
June 15, 2021 - Compliance Inspection Report (Land Application Site Inspection)
cc: Mr. Cris Routh, Plant Superintendent - City of Graham (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: [phone]
Certification: 994839 Phone: [phone]
NC0021211 City of Graham - Graham WWTP
NC0045292 City of Graham - Graham / Mebane WTP
Inspection Date: 06/03/2021
Entry Time 09:30AM Exit Time: 11:15AM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Jordan Burbage
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
▪ Miscellaneous Questions Record Keeping Treatment
▪ Sampling Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 06/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On June 3, 2021, WSRO staff conducted a routine compliance inspection of the subject facility. This inspection consisted of
a review of the WWTP residuals source facility and records only due to heavy rain occurring at time of inspection and no
field activities. Mr. Cris Routh accompanied staff on the inspection. The inspection reflects compliance with the subject
permit. Below is a summary of notes from the inspection.
- The presence of an aerobic digester at the WWTP was confirmed as part of the SOUR test utilized to meet VAR
requirements.
- WWTP residuals sampling procedures and locations were reviewed and found to be satisfactory.
- WWTP residuals sampling results for Quarter #1 were reviewed during the inspection and found to meet regulatory limits
(nutrients, metals, pathogen & vector). The annual TCLP analysis has not been conducted yet for 2021. *CHECK NEXT
INSPECTION
- Soil sampling for 2021 has not been conducted yet. *CHECK NEXT INSPECTION
- Hauling records and field inspection logs were found to be present and up to date.
A follow-up inspection is planned for review of land application site activities and for review of the WTP residuals source
facility.
Page 2 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 06/03/2021 Inspection Type : Compliance Evaluation
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
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Yes No NA NE
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Yes No NA NE
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Page 3 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 06/03/2021 Inspection Type : Compliance Evaluation
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: See summary.
Sampling
Describe sampling:
See field notes.
Is sampling adequate?
Is sampling representative?
Comment: See summary.
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Yes No NA NE
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Yes No NA NE
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Page 4 of 4

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: [phone]
Certification: 994839 Phone: [phone]
NC0021211 City of Graham - Graham WWTP
NC0045292 City of Graham - Graham / Mebane WTP
Inspection Date: 06/15/2021
Entry Time 09:30AM Exit Time: 12:OOPM
Primary Inspector: Patrick Mitchell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Land Application Site Transport
(See attachment summary)
Page 1 of 3

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 06/15/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On June 15, 2021, WSRO staff conducted an inspection of land application activities for the subject facility. A subsequent
review of additional information received in a June 16, 2021, email was completed. This inspection completed in conjunction
with the June 3, 2021 inspection of the WWTP residuals source facility. Mr. Cris Routh accompanied staff on the inspection.
The inspection reflects compliance with the subject permit. Below is a summary of notes from this review.
1. Residuals transport vehicle #959 was reviewed and found to be compliant at time of inspection.
2. The representative at the WTP source facility indicated that WTP residuals are now primarily handled through Synagro's
Class A residuals permit and the dedicated fields serve as a backup.
3. Setbacks to the residence located across road near entrance to sit was measured using range finder. Range finder
measurements show the land application buffer markers to be 405 feet. There was question raised recently if land
application buffers met the minimum 400 ft. setback.
4. Field #5 was actively being land applied at time of inspection. Field #1 was reportedly spread prior to the inspection (first
week or two of June).
5. The following items were requested during the inspection and subsequently received in an email:
• A copy of records for the most recent calibration of land application equipment Records indicate calibration was
completed May 2019.
• A copy of crop yield records for year 2020 as required in permit. Records indicate 559 round bales of hay were harvested
during year 2020 from fields that received land application during the year. Requested the required crop yield records be
provided in annual reports moving forward.
• A copy of residuals analysis results for quarter #2 (i.e., analysis used for land application activities at time of inspection).
Results provided.
6. A review of land application loading rates at time of inspection; see info below and resulting loading rate.
• Observed one load (2,800 gallons) spread in Field #5. The width of spreading was approx. 17 ft. and the length was
estimated to be approx. 1,500 ft. using GIS measurement. This results in a surface area applied of approx. 0.59 acres.
Therefore, based upon the land application rates observed during the inspection, there would be a loading rate of approx.
4,754.8 gallons/acre applied to the field.
• Using the residuals analysis results provided following the inspection in the 6/16/2021 email, the PAN concentration of the
residuals being land applied was 2,601.6 mg of PAN/kg and the dry tons spread per load is 0.2825 or 0.398 dry tons/acre.
Using the information provided and the calculation results listed above, results in an estimated agronomic loading rate of
2.07 lbs. of PAN/acre that was being land applied to Field #5 at the time of inspection. Facility representatives indicated
their normal operations is to divide the number of loads land applied to the field by the acreage to determine the loading to
fields, and that a running total is maintained throughout the year to ensure no overloading occurs.
7. Vegetative cover present in the fields was found to be improved (overseeded with fescue) but still had Johnson grass
present. However, with this being inside the active growing season for Johnson grass cover was found to be acceptable.
Continue to monitor for year-round vegetative cover in fields.
8. The topsoil present in application fields may be compacted. Recommend that the fields be aerated to improve infiltration
rates and health of vegetative cover. This will help prevent ponding and runoff from occurring.
9. Due to time constraints and tall grass present in fields, the topsoils were not reviewed in detail as related to any potential
ESP and SAR effects.
A surface water sampling event is planned to occur this summer for the two surface water features that originate on the land
application site.
Page 2 of 3

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 06/15/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application •
Transport Yes No NA NE
Is a copy of the permit in the transport vehicle? • ❑ ❑ ❑
Is a copy of the spill control plan in the vehicle? • ❑ ❑ ❑
Is the spill control plan satisfactory? • ❑ ❑ ❑
Does transport vehicle appear to be maintained? • ❑ ❑ ❑
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment: See summary.
Yes No NA NE
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Page 3 of 3