WQ0003035_Non-Discharge RLAP Inspection Report_20211119

ROY COOPER
Governor
ELIZABETH S. RISER
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
November 19, 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 November 10, 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,
Doouelgned by: CI �A 'T. SM2te
145849E225C94EA...
Lon T. Snider
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
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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

Compliance Inspection Report
Permit:WQ0003035 Effective: 04/01/20 Expiration: 08/31/26 Owner : City of Eden
SOC: Effective: Expiration: Facility: City of Eden RLAP
County: Rockingham 204 Mebane Bridge Rd
Region: Winston-Salem
Eden NC 27288
Contact Person: Terry Shelton Title: Phone: [phone]
Directions to Facility:
To go to the WWTP, from the Eden Town Hall, take Aiken Rd. North —0.75 mi to NC 14 and turn Right. Follow NC-14 South —3.5
miles to the WWTP (on Right).
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0025071 City of Eden - Mebane Bridge WWTP
Inspection Date: 11/10/2021 Entry Time 10:45AM
Exit Time: 12:10PM
Primary Inspector: Jim J Gonsiewski 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 El Not Compliant
Question Areas:
111 Miscellaneous Questions Record Keeping El Sampling
MI Land Application Site Transport
(See attachment summary)
Page 1 of 4

Permit: W00003035 Owner - Facility:City of Eden
Inspection Date: 11/10/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On November 10, 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. Loading operations at the City of Eden WWTP and field application of residuals were observed.
The inspection reflects compliance with the permit.
Page 2 of 4

Permit: WQ0003035 Owner - Facility: City of Eden
Inspection Date: 11/10/2021 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: Soil analyses not available.
Sampling
Describe sampling:
TCLP, Nutrients, Metals
Is sampling adequate?
Is sampling representative?
Comment:
Transport
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?
Yes No NA NE
•
Yes No NA NE
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Yes No NA NE
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Page 3 of 4

Permit: WO0003035 Owner - Facility:City of Eden
Inspection Date: 11/10/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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:
• ❑ ❑ ❑
Yes No NA NE
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Page 4 of 4

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 WV TP
Permit No.: WQ00 03035
Owner: City of Eden
Plant ORC Name: Melinda Ward
LA ORC / Contract Company: Nate Roth, Synagro
Other Contact(s): Ryan Copeland, Synagro
County: Rockingham
Permit Issuance Date: 313/20
Permit Expiration Date: 8/31/26
Telephone No.: 336-6271009
Telephone No.: 336-403-4324
Telephone No.: 336-607- 4494
Facility Location (address, gps or directions): 191 Mebane Bridge Road, Eden
Reason for Inspection
® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
Arrived at Eden VWVfP at 10:45AM. Ryan Copeland with Synagro was at the facility. Discussed operations at the VWVfP. The facility
was filling in the digester basin at the time of the site visit since it was no longer needed. Two spreader trucks were originally transporting
residuals from the concrete pad storage area. One truck was down at the time of the site visit. Left VWVTP at 11:10 AM for the application
feld in Pelham, NC. Arrived at 11:40 AM. Inspected the field. The terrain was relatively flat with slopes ranging from 0% to 3%.
The solids content in the residuals was 22.03%.
n
The field was properly flagged. No runoff or ponding of residuals from spreading was observed. One spreader truck (with an 8030 Slinger)'
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 runoff or ponding was observed. Buffers were properly maintained.
Left application field at 12:10 PM.
Is a follow-up inspection necessary? ❑ Yes ® No
Primary Inspector: Jim Gonsiewski
Secondary Inspector:
Date of Inspection: 11/10/21 Entry Time: 10:45 AM Exit Time. 4 10 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:
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? ID of observed vehicle(s): 52 210
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? ❑ 1/yr or ® 1/permit cycle
Residuals metals and nutrient analysis conducted? Frequency? (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 cm', and Exchangeable Sodium Percentage (ESP) <I5%?
Does the permit require groundwater monitoring?
Are groundwater lab results present?
There are no 2L GW standard violations indicated in the lab results?
Y N NA NE
❑ ❑ ❑
Y N NA
Y N NA
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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? 0 ❑ ❑ ❑
El 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
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 (I5°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 logs 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
Y N NA NE
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Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ 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)? 0 ❑ ❑ ❑
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? ❑ ❑ 0 0
Are lab results and calculations present? ❑ ❑ ❑ 0
Was the test anaerobically digested in lab, and test run for 40 days? ❑ 0 0 ❑
Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? 0 0 0 ❑
Was the reduction of on volatile solids (not total solids)? 0 0 0 0
Was the reduction less than 17%? ❑ 0 0 ❑
❑ Option 3 - 30-Day Bench Scale Test Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ 0 ❑ ❑
Were residuals 2% or less total solids? ❑ 0 0 ❑
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? ❑ 0 0 ❑
Was the test run for 30 days? 0 0 0 ❑
Was the test done at 20°C (68°F)? 0 ❑ ❑ ❑
Was the reduction of on volatile solids (not total solids)? 0 ❑ 0 0
Was the reduction less than 15%? ❑ ❑ ❑ ❑
® Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals from aerobic digestion? p ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ® ❑ ❑ ❑
Was the test done between 10°C (50°F) and 30°C (86°F)? ® ❑ ❑ 0
Was the temperature corrected to 20°C (68°F)? ® ❑ ❑ 0
Was the sampling holding time <2 hours? V ❑ ❑ ❑
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)? V ❑ 0 0
❑ 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)? ❑ ❑ 0 0
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? 0 ❑ ❑ 0
0 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? ❑ 0 ❑ ❑
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? ❑ ❑ ❑ 0
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑ ❑ ❑ ❑
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? 0 0 0 ❑
Were the residuals mixed with any other materials? 0 ❑ 0 0
Were the residuals dried >75% total solids? 0 ❑ ❑ 0
❑ Option 8 - Drying of Unstabilized Residuals Y N NA N E
Were the residuals mixed with any other materials? ❑ 0 0 0
Were the residuals dried >90% total solids? 0 0 0 0
❑ 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? Ifso, please list Site ID(s) below. ® Yes ❑ No
Application Site ID(s): NC-RC-45-1A
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 ❑ Partly Cloudy ❑ Cloudy ❑ Overcast ❑ Stormy
❑ Windy (wind direction: ) ❑ Breeze ® Calm
® No Precipitation ❑ Drizzle ❑ Rain ❑ Cloudburst (If applicable, precipitation measurement:
Is there a rain gauge onsite? ® Yes ❑ No
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60
Permit and Spill Plan onsite during application? ® Yes
® 60-80
❑ No
❑ >80
Application Observations: [Type of application: ❑ Liquid ® Cake ❑ Other
Application Site —Field ID(s): NC-RC-45-1A
Intended Crop: Fescue, pasture PAN Requirement: 177
Application Rate (tons or gallons/acre): 5 tons/acre
Nutrient Content: 48 Ibs PAN! WI
Ibs/ac
% of total field area utilized or anticipated for this event? 100
Application occurring at time of visit: ® Yes ❑ No
Application Method: (a Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ® N/A
Vegetative Buffer description: ❑None ®Grass ❑Crop ❑ Shrub
®Tree ❑ Other
Current Field Conditions:
❑ Bare 0 Stubble ❑ Planted term) la Pasture
Soil Condition:
is Dry 0 Moist ❑ Wet 0 Saturated
❑ Not -Frozen 0 Frost 0 Frozen ❑ Snow -Covered
Slope: 0 0-3% ❑ 3-6% ❑ 6-10% 0 IO-18% 0 >18%
Odor: 0 None ® Mild 0 Moderate 0 Strong
Vectors: ❑ 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
O 000
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Y N NA NE
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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: ❑ Yes ❑ No
Application Method: 0 Surface 0 Incorp/Injection
Incorporation/Injection during visit: ❑ Yes 0 No ❑ N/A
Vegetative Buffer description: ❑None ❑Grass ['Crop 0 Shrub
❑Tree ❑ Other
Current Field Conditions:
❑ Bare 0 Stubble 0 Planted (crop) ❑ Pasture
Soil Condition:
❑ Dry ❑ Moist 0 Wet 0 Saturated
❑ Not -Frozen 0 Frost ❑ Frozen 0 Snow -Covered
Slope: ❑ 0-3% ❑ 3-6% ❑ 6-10% 0 10-18% ❑ >18%
Odor: 0 None ❑ Mild 0 Moderate ❑ Strong
Vectors: 0 None 0 Few ❑ Many 0 Excessive
Application Details: Y N NA NE
Application areas clearly marked? 0000
Application within authorized area? 0 0 0 ❑
Application method appropriate? 0000
Application is even (no ponding)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells/residences? 0000
Sufficient setbacks from surface waters? 0000
Slopes > 10% avoided (Surface App.) ? DODO
Slopes>18%avoided (Incorp/Inject)? DODD
Incorp./Injection within time -frame? 0000
Biosolids visible on surface? 0000
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-otT is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
❑ ❑❑❑
O 000
O 000
O 000
O 000
Y N NA NE
0000
O 000
O 000
O ❑ ❑ ❑
Page 4 of 4