WQ0001318_Staff Report_20230215

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
February 15, 2024
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00001318
Attn: Erick Saunders Facility name: Lexington Class A
From: Caitlin Caudle
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 2/5/2024
b. Site visit conducted by: C. Caudle and K. Potwora
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Will Hodges and their contact information: wdhodgesklexin onnc.gov
III■W4K110Q112ZT41101111f.�uto) 7101[OFNIC/7OMO12711► WAVILIW.1199N[ak%I113eki
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
2. Are the design, maintenance, and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
4. Is the residuals management plan adequate? ® Yes or ❑ No
5. Are there any setback conflicts for existing treatment, storage, and disposal sites? ❑ Yes or ® No
6. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
7. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: All ARRs and CEIs are compliant but 2019.
8. Has a review of compliance history been completed (CEI's)? ® Yes or ❑ No
9. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
10. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? 2018 AR resulted in an NOV that was rectified
through the NOV response.
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
11. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ❑No®N/A
FORM: WQROSSR 04-14 Page 1 of 2

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
/�D—Signed by:
3. Signature of report preparer:
Signature of regional supervisor:
Date: 2/15/2024
M►TA11J17YY[170/.30:iX"1130F.3IVIIFRW2:7*i/IBUTAI10403 y
4.
• Residuals are pumped from the digestor at the WWTP and mixed with polymer before being pressed. Residuals
are wasted from the clarifier, enter a DAF unit, continue treatment in the digestor.
• Ms. Caudle advised the approved use document provided to compost recipients may need to be updated to reflect
the most recent permit conditions.
FORM: WQROSSR 04-14 Page 2 of 2

Compliance Inspection Report
Permit: WQ0001318 Effective: 08/14/20 Expiration: 06/30/24 Owner: City of Lexington
SOC: Effective: Expiration: Facility: City of Lexington DCAR
County: Davidson 500 Glendale Rd
Region: Winston-Salem
Lexington NC 27292
Contact Person: Will Hodges Title: Utility Plant Supervisor Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0055786 City of Lexington - Lexington Regional WWTP
Inspection Date: 02/05/2024 Entry Time 10:OOAM Exit Time: 11:40AM
Primary Inspector: Kristen Potwora Phone: [phone]
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Inspection Type: Compliance Evaluation
Miscellaneous Questions Record Keeping
Sampling Pathogen and Vector Attraction
Transport
(See attachment summary)
Treatment
Storage
Page 1 of 4

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 02/05/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On February 5, 2024, Division of Water Resources staff Kristen Potwora and Caitlin Caudle conducted a scheduled routine
compliance inspection of the City of Lexington DCAR (compost). Steve Craver (Primary WWTP ORC), Bill Waycaster
(Compost ORC), Will Hodges (Utility Plant Supervisor), and Reed Blackburn (Assistant Water Resources Director) were
present during the inspection of the compost facility at the Lexington Regional Wastewater Treatment Plant Eglantina
Minerali (Lab Supervisor), Will Hodges, and Reed Blackburn were present for lab records review. The inspection found the
facility to be compliant with the subject permit.
The following items of concern were noted:
• Hard copies of the Operation and Maintenance Plan and Spill Control Plan were not present at the compost facility.
Permit Condition 111.2 requires the Permittee to maintain a Division -approved Operation and Maintenance Plan that includes
the Spill Control provisions . Moving forward, hard copies of the Operation and Maintenance Plan and Spill Plan should be
available on hand.
• The Acceptable Use document must be updated to reflect the most recently issued permit and provided to all compost
recipients. As stated in Permit Condition 111.9, the Permittee shall notify all third -party entities receiving bulk Class A
residuals that land application activities occurring on the third-party's property shall meet the requirements in Permit
Condition 11.7.a. and 111.8. In the past, an Acceptable Use document was provided to recipients. Please note that Permit
Conditions 11.7.and 111.8 are likely to be updated with the upcoming permit renewal.
Compost produced at the Lexington Regional WWTP goes directly from the digester to the belt press, where a polymer is
added to create a cake -like material. The cake residuals are mixed with leaves, woodchips, recycled sludge and sometimes
sand. The compost mixture is placed into one of four bays that are mechanically mixed. It takes around 15-18 days from
start to finish inside the bays before the compost material is placed into 8 lanes of windrows stored on drying beds. Rows 1
and 2 are mixing zones, 3 through 6 are active treatment zones, while 7 and 8 are screened zones of finished compost. The
drying beds contain at least six months' worth of storage. Once completed, customers may pick up from the facility. The
Lexington Regional WWTP no longer delivers or land applies compost. Storm drains on site all go to the second stage at
the WWTP, which is back at the head of the plant. The maintenance employees take care of all inspection logs containing
records of residuals facility inspections, maintenance, and repairs.
Page 2 of 4

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 02/05/2024 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Land Application
❑
Distribution and Marketing
Record Keeping
Yes No NA NE
Is GW monitoring being conducted, if required?
❑
❑ 0 ❑
Are GW samples from all MWs sampled for all required parameters?
❑
❑ 0 ❑
Are there any GW quality violations?
❑
❑ 0 ❑
Is GW-59A certification form completed for facility?
❑
❑ 0 ❑
Is a copy of current permit on -site?
0
❑ ❑ ❑
Are current metals and nutrient analysis available?
0
❑ ❑ ❑
Are nutrient and metal loading calculating most limiting parameters?
0
❑ ❑ ❑
a. TCLP analysis?
0
❑ ❑ ❑
b. SSFA (Standard Soil Fertility Analysis)?
❑
❑ 0 ❑
Are PAN balances being maintained?
❑
❑ 0 ❑
Are PAN balances within permit limits?
❑
❑ 0 ❑
Has land application equipment been calibrated?
❑
❑ 0 ❑
Are there pH records for alkaline stabilization?
❑
❑ 0 ❑
Are there pH records for the land application site?
❑
❑ 0 ❑
Are nutrient/crop removal practices in place?
❑
❑ 0 ❑
Do lab sheets support data reported on Residual Analysis Summary?
0
❑ ❑ ❑
Are hauling records available?
❑
❑ 0 ❑
Are hauling records maintained and up-to-date?
❑
❑ 0 ❑
# Has permittee been free of public complaints in last 12 months?
0
❑ ❑ ❑
Has application occurred during Seasonal Restriction window?
❑
❑ 0 ❑
Comment:
Pathogen and Vector Attraction
Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
0
❑ ❑ ❑
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

Permit: WQ0001318 Owner - Facility: City of Lexington
Inspection Date: 02/05/2024 Inspection Type: Compliance Evaluation Reason for Visit: Routine
e. Time/Temp on: 0 ❑ ❑ ❑
Digester (MCRT) ❑
Compost
Class A lime stabilization ❑
f. Volatile Solids Calculations ❑ ❑ 0 ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ M ❑
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? 0 ❑ ❑ ❑
Is sampling representative? 0 ❑ ❑ ❑
Comment:
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? ❑ ❑ 0 ❑
Comment:
Page 4 of 4