WQ0003824_Annual Report_20230822

ROY COOPER
Governor

North Carolina Department of Environmental Quality | Division of Water Resources
Winston-Salem Regional Office | 450 W. Hanes Mill Rd, Suite 300 | Winston-Salem, North Carolina 27105
336.776.9800

ELIZABETH S. BISER
Secretary RICHARD E. ROGERS, J R.
Director

NORTH CAROLINA
Environmental Quality
August 22, 2023

Delivered via email to: [e-mail]

Ms. Tonya Mann, Utilities Director
City of Graham
P.O. Box 357
Graham, NC 27253

SUBJECT: 2022 Residuals Annual Report Review
City of Graham, Residuals Land Application Program
Permit No. WQ0003824
Alamance County

Dear Ms. Mann:

Division of Water Resources staff Kristen Potwora completed a review of the 2022
Residuals Annual Report. This review reflects compliance with the subject permit.

Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact Kristen Potwora by phone at [phone]
or by email at [e-mail].

Sincerely,

Lon 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)
Mr. Nate Roth-Synagro, (Electronic Copy)
Alamance County Environmental Health (Electronic Copy)
Compliance Inspection Report
Permit:WQ0003824 Effective:12/01/19 Expiration:10/31/25 Owner :City of Graham
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Alamance
Winston-Salem
David W Lawson
Effective:Expiration:Facility:City of Graham RLAP
1204 E Gilbreath St
Graham NC 272530357
Title:Phone:[phone]
Secondary ORC(s):
336-578-3264Phone:[phone]Certification:Tonya Ane' MannPrimary ORC:
LA,System Classifications:
On-Site Representative(s):
Related Permits:
NC0021211 City of Graham - Graham WWTP
NC0045292 City of Graham - Graham / Mebane WTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
08/18/2023 08:00AM 11:00AM
Kristen Potwora 336-776-9800
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Land Application of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Sampling Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0003824
08/18/2023 Annual Report Review
City of Graham
Routine
Inspection Summary:
On August 18, 2023, Division of Water Resources staff Kristen Potwora completed a review of the 2022 Annual Report for
WQ0003824. This review reflects compliance with the subject permit.
Other Observations –
•Effective 1/1/21, sludge from the City of Graham Water Treatment Plant is applied on land provided by Synagro
Southeast Inc and those results are no longer included in this report.
•The Alamance County Soil Survey (ACSS) was updated several years ago, resulting in many of the soil map units in the
Attachment B being removed or renamed in the NC State Realistic Yield Expectations (RYE) database. TaB, DbB, GaB2,
Cg and Congaree-Chewacla soil complex are no longer represented in Alamance County.
Page 2 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0003824
08/18/2023 Annual Report Review
City of Graham
Routine
Type Yes No NA NE
Distribution and Marketing
Land Application
Record Keeping Yes No NA NE
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 Yes No NA NE
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)
Page 3 of 4
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0003824
08/18/2023 Annual Report Review
City of Graham
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 Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment:
Sampling Yes No NA NE
Describe sampling:
Is sampling adequate?
Is sampling representative?
Comment:
Page 4 of 4