WQ0002376_2021 Annual Report Review_20220812

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
August 12, 2022
Ms. Summer Woodard — City Manager
City of Reidsville
230 West Morehead Street
Reidsville, North Carolina 27320
Subject: 2021 Annual Report Review
City of Reidsville, Residuals Land Application Program
Permit No. WQ0002376
Rockingham County
Dear Ms. Woodard:
The Division of Water Resources (DWR) acknowledges receipt of your 2021 Annual Report for
the subject permit. A review of this report conducted by DWR staff person Jim Gonsiewski reflects
compliance with Permit Number WQ0002376.
A routine compliance evaluation inspection is planned to occur within the next 12 months. If you
have any questions regarding this letter, please contact Jim Gonsiewski or me at the letterhead
address or phone number or by email at [e-mail] or [e-mail].
Sincerely,
CDacuSlpned by:
LoN T. .5^44t;r
145B49E225094EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
encl: Compliance Inspection Report
cc: Rockingham County Environmental Health (Electronic Copy)
Brent Collins — EMA Resources, Inc. (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality I 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: WQ0002376 Effective: 04/25/22 Expiration: 12/31/26 Owner : City of Reidsville
SOC: Effective: Expiration: Facility: City of Reidsville Class B Residuals Program
County: Rockingham 230 W Morehead St
Region: Winston-Salem
Contact Person: Steven L Routh
Directions to Facility:
Reidsville NC 27320
Title: Director of Public Works Phone: [phone]
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0024881 City of Reidsville - Reidsville WWTP
Inspection Date: 07/15/2022
Entry Time 01:OOPM Exit Time: 03:OOPM
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: III Compliant ❑ Not Compliant
Question Areas:
I. Miscellaneous Questions Record Keeping Sampling
III Pathogen and Vector Attraction El Wells
(See attachment summary)
Page 1 of 4

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 07/15/2022 Inspection Type :Annual Report Review
Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) received the 2021 Annual Report for the subject permit. A review of this report
conducted by DWR staff person Jim Gonsiewski reflects compliance with Permit Number WQ0002376.
A routine compliance evaluation inspection is planned to occur within the next 12 months.
Page 2 of 4

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 07/15/2022 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
❑ ❑ . ❑
❑ ❑•❑
❑ ❑ • ❑
❑ ❑ • ❑
• ❑ ❑ ❑
■ ❑❑❑
O 0011
11000
• ❑ ❑ ❑
11000
• ❑ ❑ ❑
❑ ❑ ❑•
• ❑ ❑ ❑
■ ❑❑❑
❑ ❑ ❑•
• ❑ ❑ ❑
❑ ❑ ❑ •
❑ ❑❑■
• ❑ ❑ ❑
❑ ❑ ❑•
Yes No NA NE
❑ ❑❑■
0
• ❑ ❑ ❑
•
O 0110
❑ ❑■❑
❑ ❑ • ❑
Page 3 of 4

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 07/15/2022 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:
Sampling
Describe sampling:
Residuals, Metals, TCLP
Is sampling adequate?
Is sampling representative?
Comment:
00E10
MI1000
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 4 of 4

Annual Report Review Class B Land Application Permit No. WQO0j 6
Reporting Period:
Permit Details:
• Is 503?
• Class ❑A or LW/
• Maximum Dry Tons Per Year: 1
• Number of acres permitted: S ?,3, C (
• Number of fields in permit:.,,
• Counties that land is permitted for:(oe,1(iA,Is '
• Monitoring Frequency for TCLP: /lhn..u: t..b
• Monitoring Frequency for Residuals Analysis: lain, tice.4Qr 1,
• Monitoring Frequency for Pathogen & Vector Attraction Reduc tiu11: Le+rs-ei
• Groundwater monitoring: ❑Yes
es No
1. Annual Land Application Certification Form K• Was a certification form submitted?1 INo
w
• Was land application conducted during the reported year? es nNo
• Homany dry tons and dry tons per acre were applied? --{ d
'� S ,ot ) 4 6
• Were the applications within the permitted amount? fes ❑No
• Verify PAN if more than 10 tons/acre? _Yew. 7No
• Did it indicate compliance? ]Yds 7No
• Was it signed by the appropriate people? [+ 1-Y-cad ❑ No
2. Monitoring
• Were the analyses conducted at the required frequency? [A(e . No
• Was an analyses taken for each source that was land applied? es ❑No
• Were the metals analyses reported on the Residual Sampling Summary Form? IC es ❑No
• Were the results reported in mg/kg? [!,]'re ❑No
• Were the pH's 6.0 or greater for each residual sample? es 7No
• Were the heavy metals within ceiling concentration permit limits?4`es ❑No
o Were the lab analyses attached? e''(es ❑No
• Were all the required parameters tested? LgYes [1] No
• Was TCLP analysis conducted? [ ,`es ❑No
• Were the TLCP contaminants within regulatory limits? Ii2tes ❑No
• Was a corrosivity, ignitability, and reactivity analysis conducted? [("es El No
3. Field Summary
• Were all land application events recorded on the Ty 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?
lefc
es
Yes
• es
es
es
RYes
❑No
UNo
No
No
❑No
No
❑No
❑No
nNo
❑No
❑No
es UNo
❑No
❑No
es
II

4. Pathogen and Vector Attraction Reduction
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
• Did the form(s) indicate the period of coverage, the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used?
Class B Pathogen Review
['Alternative 1 — Fecal Coliform Density
• Was the sampling conducted at the required frequency?
• Were seven samples taken?
• Was the geometric mean calculated and done correctly?
• Did the results show compliance (less than either 2,000,000 MPN/gram of total solids or 2,000,000
Colony Forming Units/gram of total solids)? i�'r`es P lNo
❑Alternative 2 — Use of Process to Significantly Reduce Pathogens (one of five)
N
I ]o
['Yes I- INo
• Was the sampling conducted at the required frequency? ❑Yes I INC
❑Aerobic Digestion
• Was it an aerobic process (Inspection)? ❑Yes
• Were logs submitted showing time and temperature? ❑Yes
• Were temperatures within range for complete time period? ❑Yes
• Was the time and temperature between 40 days at 20°C (68°F) and 60 days at 15°C (59°F)?
DYes
❑Air Drying
• Were the residuals on sand beds or pave or unpaved basins for three months? Dies
• Was the ambient temperature above 0°C (32°F) for two months? ❑Yes
• Were the residuals partially digested? ['Yes
• 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?
I
No
No
Li No
No
❑No
No
No
II
I
No
❑Yes ❑No
[Yes ❑No
❑Yes ❑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) LJYes 1 INo
Was it a composting procedure (not natural decay under uncontrolled conditions)?
❑Yes I INo
Were Togs submitted showing time and temperature? ❑Yes 1 INo
See White House Manual for additional requirements.
❑Lime Stabilization
• Was alkaline material added to residuals a form of lime (hydrated lime, quicklime, lime containing kiln
dust or fly ash)? [Dies ❑No
• Were logs submitted showing time and temperature? ❑Yes ❑No
• Was the pH raised to 12 after two hours of contact? ❑Yes ON()
• Were logs submitted showing time and pH? ❑Yes ❑No
• Was temperature corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑Yes ❑No
['Alternative 3 — Use of Processes Equivalent to RSRP
(Not commonly use. See White House Manual page 100-103, tables 11-1 and 11-2.)

Class B Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency? ❑Yes ❑No
nOption 1 — 38% Volatile Solids Reduction
• Was there 38% reduction? ❑Yes El No
• Were lab sheets/calculations in report? ['Yes ❑No
• Was the reduction on volatile solids (not total solids)? ❑Yes in No
• Were the samples taken at beginning of digestion process and before application (Inspection)?
❑Yes ❑No
• Were calculations correct? ['Yes ❑No
❑Option 2 — 40-Day Bench Scale Test
• Were residuals from anaerobically digested treatment (Inspection)? ❑Yes
• Was average temperature of the WWTP digester between 30°C (86°F) — 40°C (104°F)?
• 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
❑Yes
❑Yes
❑Yes
[]Yes
Yes
es
❑Yes
INo
No
No
No
No
No
No
No
nNo
❑No
[1]No
❑ No
on a sample diluted to 2% with unchlorinated effluent?
G,
• 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?
(Option 4 — Specific Oxygen Uptake Rate (SOUR)
• Were residuals form aerobically digested treatment (Inspection)?
• Were residuals ?% 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?
es es
II
No
❑No
❑No
es
s
❑ No
es ❑ No
es ❑ No
❑Yes []No
['Yes El No
❑Yes No
❑Yes ❑No
total residual solids (dry
❑Yes ❑No
['Yes ❑No
❑Yes []No
['Option 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)?
['Yes
❑Yes
plies
❑Yes
❑No
❑No
❑No
❑No

nOption 6 — Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? ❑Yes El No
• Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
['Yes fNo
• 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 flNo
• Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? ❑Yes I No
❑Option 7 — Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals? ❑Yes No
Were the residuals mixed with any other materials? ❑Yes No
• Were the residuals dried up to 75% total solids? ['Yes No
❑Option 8 — Drying of Unstabilized Residuals
• Were the residuals mixed with any other materials? ❑Yes No
• Were the residuals dried to 90% total solids? ❑Yes 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 [1]No
• If Class A with respect to pathogen, were residuals injected with eight.hours after discharge from
pathogen treatment? ❑Yes ❑No
• Was the,appropriate documentation to show pathogen and vector attraction reduction included in the
report?
11
❑Yes ❑ No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
❑Yes ❑ No
5. Soil Tests
• Was a Standard Soil Fertility Analysis conducted for each application field? 'mod
• Were all the required parameters reported? es ■
• Were the soil pH's 6.0 or greater for each application field? [Yes 'do No
• If no, was lime applied to those fields if recommended by the Agronomist? ,-[des---_� ❑No
• Were the copper and zinc indexes in the soil less than 2000 for each application field?,
es
• Was sodium less than 0.5 meq, and exchangeable sodium percentage (ESP) less than 1,5°4,?
6. General
• Was the report in the proper format?
• Was the annual report complete?
• Was the report submitted on time?
❑No
No
® es 1 )No
I✓TYes ❑ No
EI f s ❑No
�Ge ❑ No

Pollutant
Ceiling
Concentration
Below
Limit
Cumulative Pollutant
Loading Rate
Below
Limit
r/
kg/ha
Ibs/ac
Arsenic
75
°''
41
36
Cadmium
85
39
34
Copper
4300
✓
1500
1338
`1,
Lead
840
v----"'
300
267
V
Mercury
57
L-'
17
15
t./'
Molybdenum
75
✓
N/A
N/A
1/
Nickel
420
V
420
374
V1
✓
✓
Selenium
100
1../
100
89
Zinc
7500
✓
2800
2498
Parameter
Below
Limi
Parameter
Below
Limp
Parameter
Below
Limit
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
!---
Barium (100.0) '
✓
1,2-Dichloroethane (0.5)
r./
Pentachlorophenol (100.0)
\ _2
Benzene (0.5)
✓
1,1-Dichloroethylene (0.7) §/y
Pyridine (5.0)
Cadmium (1.0)
Z�/
2,4-Dinitrotoluene (0,13)
L/
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)
✓-
IV
Chlorobenzene (100.0)
/
Hexachlorobenzene (0.13)
:- -
Toxaphene (0.5)
Chloroform (6.0)
,/
Hexachlorobutadiene (0.5)
✓
Trichloroethylene (0.5)
•'�
'v
Chromium (5.0)
/7
Hexachloroethane (3.0)
✓
2,4,5-Trichlorophenol
(400.0)
m-Cresol (200.0)
)7
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
2,4,5-TP (Silvex) (1.0)
4---)
r�
ti✓
o-Cresol (200.01
�%
Lindane (0.4)
L/
p-Cresol (200.0)
Mercury (0.2)
V
Vinyl Chloride (0.2)
Cresol (200.q)
Methoxychlor (10.0)
1.✓
2,4-D (10.0) ,
gam'
Methyl ethyl Ketone (200.0)
-,----
Parameter
Analyzed
For,
Parameter
Analyzed For
Parameter
Analyzed For
Aluminum
✓
Mercury
t�
Potassium
✓
Ammonia-✓
Nitrogen
Molybdenum'
Selenium
,v/
Arsenic
Nickel
z✓
Sodium
Cadmium
4---'
Nitrate -Nitrite
Nitrogen
1.
SAR
Calcium
/
'✓
% TS
✓
TKN
'✓
Copper
p✓
pH
A/
Zinc
✓
Lead
v.-'
Phosphorus
.✓
Magnesium +✓
PAN +------
Parameter
Analyzgd For
Parameter
Analyzed For
Parameter
Analyz d For
Acidity
�/
ESP
1.----
Phosphorus
,/
Base Saturation
✓
Magnesium
✓
Potassium
Calcium
�/
Manganese
t..-�/<
Sodium
CEC
✓
% HM
✓9
Zinc
I----'
Copper
/
V
pH
`.''