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Home My WebLink AboutWQ0003824_Annual Report_20240506ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director V., STATE Y�o�wvt�' NORTH CAROLINA Environmental Quality May 6, 2024 Delivered via email to: tmann(a)cityofgraham.com Ms. Tonya Mann, Utilities Director City of Graham P.O. Box 357 Graham, NC 27253 SUBJECT: 2023 Residuals Annual Report Review City of Graham, Residuals Land Application Program Permit No. WQ0003824 Alamance County Dear Ms. Mann: On May 1, 2024, Division of Water Resources staff Kristen Potwora completed a review of the 2023 Residuals Annual Report for permit WQ0003824. This review reflected 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 at the letterhead address, by phone at 336-776-9697, or by email at kristen.potwora(a)-deg.nc.gov or jenny.graznak(a)deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F187456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO enc: 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) D � North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH f:ARD_INA new tmFnW.nbio�a\ /� 336.776.9800 Compliance Inspection Report Permit: WO0003824 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 Graham NC 272530357 Contact Person: David W Lawson Title: Phone: 336-570-6721 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0021211 City of Graham - Graham WWTP NC0045292 City of Graham - Graham / Mebane WTP Inspection Date: 05/01/2024 Entry Time 08:OOAM Primary Inspector: Kristen Potwora Secondary Inspector(s): / l tz,� /—d tJ62Cc� Exit Time: 01:OOPM Phone: 336-776-9800 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: Miscellaneous Questions Record Keeping Treatment Sampling Pathogen and Vector Attraction (See attachment summary) Page 1 of 4 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/01/2024 Inspection Type : Annual Report Review Reason for Visit: Routine Inspection Summary: On May 1, 2024, Division of Water Resources staff Kristen Potwora completed a review of the 2023 Residuals Annual Report for permit W00003824. This review reflected compliance with the subject permit. Observations: • On the Annual Land Application Certification Form, DWR staff calculated 151.91 total dry tons applied during 2023, but 151.296 total dry tons were reported. • Biosolids from the City of Graham WWTP were land applied in all twelve months during 2023. • Effective January 1, 2021, ferric sludge from the City of Graham WWTP is applied on land provided by Synagro Southeast Inc. Those results are no longer included in the annual report, but the metal loadings are added to the 2023 accumulated metal totals. • Sludge analysis, fecal and sour sampling was performed during March, May, August, and October of 2023. • TCLP was sampled in October 2023. • Soil analysis for all fields was completed in August 2023. Page 2 of 4 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/01/2024 Inspection Type : Annual Report Review Reason for Visit: 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 Permit: WQ0003824 Owner - Facility: City of Graham Inspection Date: 05/01/2024 Inspection Type : Annual Report Review Reason for Visit: Routine e. Time/Temp on: ❑ ❑ 0 ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations ❑ ❑ On g. Bench -top Aerobic/Anaerobic digestion results 1111011 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? 0 ❑ ❑ ❑ Comment: Page 4 of 4