WQ0003824_2021 Annual Report Review_20220324

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Ms. Tonya Mann, Utilities Director
City of Graham
P.O. Box 357
Graham, NC 27253
NORTH CAROLINA
Environmental Quality
March 24, 2022
SUBJECT: Review of the 2021 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 2021 Annual Report for the subject facility. It is our understanding
that the residuals from the Graham Water Treatment Plant are now handled by Synagro under a
separate permit. This review was completed by DWR staff person Jim Gonsiewski. Review of
the subject report reflects compliance with the Permit No. WQ0003824.
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 Jim
Gonsiewski or me at the letterhead phone number or address, or by email at
jimgonsiewskinncdenr.gov or lon.snider(2i ncdenr.gov.
Sincerely,
Qocu8tgned by:
1 T. 6 3Mal4`
145B49E225C94EA..
Lon T. Snider
Regional 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)
Alamance County Environmental Health (Electronic Copy)
Laserfiche File WQ0003824
WSRO Electronic Files
1)1
Department of Enrinonnialls, ew9h�
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I 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: 03/15/2022 Entry Time 09:15AM
Exit Time: 11:30AM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
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:
1.1 Miscellaneous Questions Record Keeping 111 Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 03/15/2022 Inspection Type :Annual Report Review
Reason for Visit: Routine
Inspection Summary:
Staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR) completed a review of the
2021 Annual Report for the subject facility. It is our understanding that the residuals from the Graham Water Treatment Plant
are now handled by Synagro under a separate permit. This review was completed by DWR staff person Jim Gonsiewski. No
site visit was conducted as part of this insepction event. Review of the subject report reflects compliance with the Permit No.
WQ0003824.
Page 2 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 03/15/2022 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:
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
Yes No NA NE
❑ ❑ • ❑
❑ ❑■❑
❑ ❑ • ❑
❑ ❑•❑
❑ ❑❑■
• ❑ ❑ ❑
• ❑ ❑ ❑
I11000
U ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑•
❑ ❑■❑
❑ ❑•❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑
■ ❑❑❑
❑ ❑■❑
Yes No NA NE
❑ ❑ ❑
• ❑ ❑ ❑
O 0110
❑ ❑•❑
0
❑ ❑•❑
Page 3 of 4

Permit: WQ0003824 Owner - Facility: City of Graham
Inspection Date: 03/15/2022 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:
❑ ❑ II ❑
❑ ❑ • ❑
❑ ❑ • ❑
Yes No NA NE
•
Page 4 of 4

Annual Report Review Class B Land Application Permit No. WQ00 `) 3 c -\"c
Reporting Period: )L) �1
Permit Details:
• Is 503? ‘JC- I les
• Class ❑A or ?
• Maximum Dry Tons Per Year: `', C C CM ., S 6
• Number of acres permitted: 70 r'g�'� W W�
• Number of fields in permit:
• Counties that land is permitted for: A (c, Yvka v. c c-
• Monitoring Frequency for TCLF'd.\ n r\IAGki • Monitoring Frequency for Residuals Analysis: Ai 6 nIALJ
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: A. n nuat WTP, Work c
• Groundwater monitoring: Yes
1. Annual Land Application Certification Form
• Was a certification form submitted?
• Was land application conducted during the reported year? ��
• How many dry tons and dry tons per acre were applied? Ft°+
• Were the applications within the permitted amount?
• Verify PAN if more than 10 tons/acre?
• Did it indicate compliance?
• Was it signed by the appropriate people?
2. Monitoring
• Were the analyses conducted at the required frequency?
• Was an analyses taken for each source that was land applied?
• Were the metals analyses reported on the Residual Sampling Summary Form?
• Were the results reported in mg/kg?
• Were the pH's 6.0 or greater for each residual sample?
• Were the heavy metals within ceiling concentration permit limits?
o Were the lab analyses attached?
• Were all the required parameters tested?
• Was TCLP analysis conducted?
• Were the TLCP contaminants within regulatory limits?
• Was a corrosivity, ignitability, and reactivity analysis conducted?
3. Field Summary
• Were all land application events recorded on the FSF and MFLS forms?
• How many fields were applied on this year?
• Was a Field Summary Form submitted for each field?
• Was the Regional Office notified prior to each land application event?
• Were all the residuals applied to permitted land?
• Were all the residuals applied from permitted sources?
• Were the field loading rates for each metal and PAN calculated (year to date)?
• Were the cumulative pollutant loading rates calculated?
• Were the calculations correct?
• Were the PAN loading rates within permit limits?
• Were the heavy metal cumulative pollutant loading rates within permit limits?
• Were the residuals applied on a suitable crop?
• Were the applications conducted during the crop's growing season?
• Were the Field Summary Forms complete?
• Was lime application on Field Summary Form?
No
wU)T
KNo
(des No
PS'es ❑ No
Q<'es ❑ No
Yes RC
rYes [No
alYes No
I— es No
Yes No
L]Yes No
I rites No
F Yes ❑No
L2Yes ❑No
RYes ❑No
IvYes 1 INo
✓PiYes ❑ No
I —Yes f No
'1es I INo
►Qles ❑No
LhYes No
I—VYes n No
R'Yes ❑ No
RYes ❑No
[Yes ❑No
LJYes ❑No
✓}Yes No
✓Yes No
❑-Yes No
Yes No
v}Yes No
,-RYes ❑No
{e�- No

4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? TKS
• Did the form(s) indicate the period of coverage, the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used? y
Class B Pathogen Review
nAlternative 1 — Fecal Conform Density
• Was the sampling conducted at the required frequency?
• Were seven samples taken?
• Was the geometric mean calculated and done correctly?
1'Yes ❑No
D'Ye ❑No
es ❑No
• Did the results show compliance (less than either 2,000,000 MPN/gram of total solids pr 2,000,000
Colony Forming Units/gram of total solids)? ID'S No
(Alternative 2 — Use of Process to Significantly Reduce Pathogens (one of five)
• Was the sampling conducted at the required frequency?
riAerobic Digestion
• Was it an aerobic process (Inspection)?
• Were logs submitted showing time and temperature?
• Were temperatures within range for complete time period?
• Was the time and temperature between 40 days at 20°C (68°F) and 60
['Yes
❑ Yes
❑ Yes
Yes
No
❑ No
❑ No
❑No
days at 15°C (59°F)?
Yes ❑ No
[Air Drying
• Were the residuals on sand beds or pave or unpaved basins for three months? [Yes
• Was the ambient temperature above 0°C (32°F) for two months? nYes
• Were the residuals partially digested? 1 IYes
• Were residuals exposed to atmosphere during two months above 0°C (not snow covered)?
❑ Yes
❑ Anaerobic Digestion
•Was it an anaerobic process (Inspection)?
•Were logs submitted showing time and temperature?
'Were temperatures within range for complete time period?
No
❑ No
❑ No
No
❑ Yes ❑No
jYes
❑Yes No
❑ No
•Was the time and temperature between 15 days at 35°C (95°F) to 55°C (131°F) and 60 days at 20°C
(68°F)? ❑Yes ❑No
['Composting (usually will be Class A when composting is used) ['Yes ❑No
Was it a composting procedure (not natural decay under uncontrolled conditions)?
❑ Yes ❑ No
Were logs submitted showing time and temperature? flYes ❑No
See White House Manual for additional requirements.
❑ Lime Stabilization
• Was alkaline material added to residuals a form of lime (hydrated lime,
dust or fly ash)?
• Were logs submitted showing time and temperature?
• Was the pH raised to 12 after two hours of contact?
• Were logs submitted showing time and pH?
• Was temperature corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑Yes
I
Alternative 3 — Use of Processes Equivalent to RSRP
(Not commonly use. See White House Manual page 100-103, tables 11-1 and 11-2.)
quicklime, lime containing kiln
Yes No
['Yes ['No
nYes ❑ No
['Yes No
No
I1

Class B Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency?
Option 1 — 38% Volatile Solids Reduction
• Was there 38% reduction?
• Were lab sheets/calculations in report?
• Was the reduction on volatile solids (not total solids)?
• Were the samples taken at beginning of digestion process
• Were calculations correct?
nYes
II
fNo
Yes ❑No
Yes No
Yes ❑ No
and before application (Inspection)?
❑Yes No
Yes No
❑Option 2 — 40-Day Bench Scale Test
• Were residuals from anaerobically digested treatment (Inspection)? Dies
• Was average temperature of the WWTP digester between 30°C (86°F) — 40°C (104°F)?
❑ Yes
Yes
❑Yes
❑ Yes
Yes
Yes
fYes
nYes
• Were residuals anaerobically digested in lab?
• Was the 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%?
• Were lab sheets/calculations in report?
• Were calculations correct?
Option 3 — 30-Day Bench Scale Test
• Were residuals from aerobically digested treatment (Inspection)?
• Were residuals aerobically digested in lab?
• Were residuals 2% or less total solids?
• If not 2% total solids, was the test ran on a sample diluted to 2%
• 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%?
• Were lab sheets/calculations in report?
Were calculations correct?
❑No
II
No
No
❑ No
❑ No
❑No
No
fI
LNo
nNo
Yes I INo
❑Yes I INo
Yes ❑No
II
with unchlorinated effluent?
Yes ❑ No
Yes No
nYes No
fYes n No
UYes No
nYes No
❑Yes El No
Option 4 — Specific Oxygen Uptake Rate (SOUR)
• Were residuals form aerobically digested treatment (Inspection)?
• Were residuals 2% or less 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 SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
weight basis)?
• Was the sampling holding time two hours?
• Was the test started within 15 minutes of sampling or aeration maintained?
I-fes ❑No
es ❑No
Yes ❑ No
J.Yes I )No
total residual solids (dry
,Yes ❑No
Rees ❑No
4IAs No
IiOption 5 — 14-Day Aerobic Process
• Were the residuals from aerobically digested treatment (Inspection)?
• Were the residuals treated for 14 days?
• Was the residuals temperature higher than 40°C (104°F) for a 14-day period?
• Was the average residuals temperature higher than 45°C (113°F)?
nYes
Yes
❑Yes
nYes
II
No
No
❑ No
No

Option 6 — Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? Yes
• Did the pH of residuals remain at 12 or higher for two hours without the addition of more
• ❑Yes
Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali? ❑Yes
• Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? I Yes
Option 7 — Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals?
• Were the residuals mixed with any other materials?
• Were the residuals dried up to 75% total solids?
nOption 8 — Drying of Unstabilized Residuals
• Were the residuals mixed with any other materials?
• Were the residuals dried to 90% total solids?
Yes
Yes
❑ Yes
❑ Yes
Yes
II
No
alkali?
❑No
❑No
No
❑No
No
❑No
II
No
No
❑Option 9 — Injection
• Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
['Yes ❑ No
• Was injection done on pasture or hay field? Yes No
• Was injection done at time that crop was growing? ❑Yes No
• If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? ❑Yes U No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report?
Yes
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
IYes
Il
No
nNo
5. Soil Tests
• Was a Standard Soil Fertility Analysis conducted for each application field? des No
• Were all the required parameters reported? E 'e ❑No
• Were the soil pH's 6.0 or greater for each application field? es No
• If no, was lime applied to those fields if recommended by the Agronomist? EtYes� - - { INo
• Were the copper and zinc indexes in the soil less than 2000 for each application field?
Lyres LiNo
• Was sodium less than 0.5 meq, and exchangeable sodium percentage (ESP) less thar) 15%?
FLIU'es
6. General
• Was the report in the proper format?
• Was the annual report complete?
• Was the report submitted on time?
❑No
JYes No
Imes I INo
Yes I INo
ILA

Pollutant
Ceiling
Concentration
Below
Limit
Cumulative Pollutant
Loading Rate
Below
Limit
kg/ha
lbs/ac
Arsenic
75
41
36
Cadmium
85
39
34
Copper
4300
1500
1338
Lead
840
300
267
Mercury
57
17
15
Molybdenum
75
N/A
N/A
Nickel
420
420
374
Selenium
100
100
89
Zinc
7500
2800
2498
TCLP
Parameter
Below
Limit
Parameter
Below
Limit
Parameter
Below
Limit
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (5.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlorodane (0.03)
Hepatachlor (and its
epoxide) (0.008)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Hexachlorobenzene (0.13)
Toxaphene (0.5)
Chloroform (6.0)
Hexachlorobutadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol
(400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl Chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl Ketone (200.0)
Residuals Analysis
Parameter
Analyzed
For
Parameter
Analyzed For
Parameter
Analyzed For
Aluminum
Mercury
Potassium
Ammonia-
Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite
Nitrogen
SAR
Calcium
% TS
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
PAN
Soils Analysis
Parameter
Analyzed For
Parameter
Analyzed For
Parameter
Analyzed For
Acidity
ESP
Phosphorus
Base Saturation
Magnesium
Potassium
Calcium
Manganese
Sodium
CEC
% HM
Zinc
Copper
pH