WQ0032723_Report of Non-Discharge Inspection_20211014

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
October 14, 2021
Scott Jewell
City of Reidsville
1100 Vance Street
Reidsville, North Carolina 27320
Subject: Compliance Evaluation Inspection
Reidsville WTP, Distribution of Class A Residuals
Permit No. WQ0032723
Rockingham County
Dear Mr. Jewell:
On September 17, 2021, staff of the North Carolina Division of Water Resources Winston-Salem
Regional Office (DWR) performed an announced routine compliance inspection of the City of
Reidsville distribution of Class A residuals program. This inspection was conducted by DWR
staff member Jim Gonsiewski. Mr. Brent Collins of EMA Resources was present during this
inspection. The inspection reflects compliance with the permit.
Please refer to the enclosed inspection report for additional observations and comments. If you
have any questions regarding this letter, please contact Jim Gonsiewski or me at [phone].
S incerely,
DocuSIpn.d by:`y
LOti T. JMAtP
146B4BE226CA4EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Brent Collins — EMA Resources (Electronic Copy)
Rockingham County Environmental Health (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0032723 Effective: 01/01/17 Expiration: 12/31/21 Owner : City of Reidsville
SOC: Effective: Expiration: Facility: Reidsville WTP
County: Rockingham 278 Reid Lake Rd
Region: Winston-Salem
Contact Person: R E Bobby Joyce
Directions to Facility:
Reidsville NC 27320
Title: ORC Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0046345 City of Reidsville - Reidsville WTP
Inspection Date: 09/17/2021
Entry Time 01:35PM Exit Time: 01:50PM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: Compliant Not Compliant
Question Areas:
▪ Miscellaneous Questions IIII Record Keeping MI Sampling
▪ Land Application Site Storage MI Transport
(See attachment summary)
Page 1 of 4

Permit: WQ0032723 Owner - Facility: City of Reidsville
Inspection Date: 09/17/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On September 17, 2021, staff of the North Carolina Division of Water Resources Winston-Salem Regional Office (DWR)
performed an announced routine compliance inspection of the City of Reidsville distribution of Class A residuals program.
This inspection was conducted by DWR staff member Jim Gonsiewski. Mr. Brent Collins of EMA Resources was present
during this inspection. The inspection reflects compliance with the permit.
Page 2 of 4

Permit: WO0032723 Owner - Facility: City of Reidsville
Inspection Date: 09/17/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Land Application
Distribution and Marketing
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: Samples were collected but the results have not been received.
Sampling
Describe sampling:
TCLP, nutrients, and metals.
Is sampling adequate?
Is sampling representative'?
Comment:
Transport
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?
Yes No NA NE
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
• ❑ ❑ ❑
11000
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Page 3 of 4

Permit: WQ0032723 Owner - Facility: City of Reidsville
Inspection Date: 09/17/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Does transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 173' bls.
Is application occurring at the time of the inspection?
Comment:
• ❑ ❑ ❑
Yes No NA NE
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Page 4 of 4

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information
Facility Name: Reidsvile WTP DCAR County: Rockingham
Permit No.: WQ00 32723
Owner: City of Reidsville
Plant ORC Name: Scott Jewell
Other Contact(s): Brent Collins EMA
Permit Issuance Date: 9/23/2016
Permit Expiration Date: 12/31/2021
Telephone No.:
Telephone No.: 336-399-3646
Facility Location (address, gps or directions): 278 Reid Lake Road, Reidsville, NC
Reason for Inspection
71 ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT n PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
Arrived on site at 9:20 AM 9/17/21. Met with Brent Collins, EMA. Pumping out of lagoon into
two 6,500-galon tanker trucks. Observed loading into one tanker. No spills or tracking of
residuals on or around the loading area or off the WTP facility. Driver had appropriate
paperwork. 09:45 AM moved to land application site.
Arrived at land application site at 10:10 AM. Two tractors were pulling 4,250 and 4,800 gallon
spreader units. Checked paperwork for tractors. All paperwork was on the vehicle with the
driver. Wached apreading. No runoff or ponding visible. All proper setbacks flagged and
maintained. No spillage noted at the transfer point from the tanjkers to the spreaders. Left
site at 10:40 AM.
Is a follow-up inspection necessary? ❑ Yes ® No
Primary Inspector: Jim Gonsiewski
Date of Inspection: 09/23/2021
Secondary Inspector:
Entry Time: 09:40 AM Exit Time: 10.40AM

Non -Discharge Compliance Inspection Report
Record Keeping and Reporting Information:
Is current permit and prior annual reports available upon request?
Has the facility been free of public complaints for the last 12 months?
TCLP analysis conducted and results available? Frequency? (See permit for frequency)
Residuals metals and nutrient analysis conducted? Frequency? (See permit for frequency)
Nutrient and metals loading calculations? (to determine most limiting parameter)
Do lab sheets support data reported on Residuals Analysis Summary?
Are distribution and/or hauling records available?
Utilization Agreements established or Recipient Notifications available for review?
Do the Utilization Agreements or Recipient Notifications contain minimum requirements?
(Restrictions for land application, stockpiling, setback buffers. etc.)
If the Permittee applies bulk residuals, are field loading records available?
If the Permittee applies bulk residuals, are field inspections conducted and are records available?
Does residuals package label or Utilization agreement contain minimum info required by permit?
(Name & address of generator. statement of restrictions, nutrient contents)
Is an inspection log available containing record of residuals facility inspections, maintenance,
and repairs?
Y N NA
❑ ❑
O DD
O DDODD
DOD
O DD
F2❑ ❑
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❑ ❑ 0
ODD
® ❑ ❑ ❑
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❑❑❑oEQE❑❑4
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
❑ Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency? (See permit for frequency) ODDE
Were multiple samples taken? ❑ EDE
If Fecal Coliform, density <1,000 MPN/gram of total solids? ❑ ODD
If Salmonella, density <3 MPN/4 grams of total solids? ❑ ODD
Select which treatment Alternative below was used to demonstrate Class A compliance.
❑ Alternative 1 - Time/Temperature (See White House Manual for specific requirements)
Were residuals maintained for correct time and temperature?
Are logs present showing time and temperature?
Are temperatures within range for complete time period?
Y' N NA NE
DOE
❑ ❑ ❑ ❑
ID ODE
❑ Alternative 2 - Alkaline Treatment
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Was the pH raised to 12 or greater and maintained for 72 hours or longer? ❑ ❑ ❑ ❑
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater? ❑ ❑ ❑ ❑
Are logs present showing time and pH? ❑ ODE
Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ DOD
El Alternative 5 - Process to Further Reduce Pathogens (PFRP) [Select the PFRP method below that was utilized]
❑ Composting, Select which method was used:
❑ Within -Vessel Method or Static Aerated Pile Method
Were residuals temperatures maintained at >55°C (131°F) for Y N NA NE
>3 consecutive days in the within -vessel or static aerated piles? DODO
❑ Windrow Composting Method
Were the residuals temperatures maintained at >55°C for at least
15 consecutive days in the windrow, and the windrow was turned a
minimum of five times during this time?
❑ Heat Drying
Were the residuals driedby direct or indirect contact with hot gases and the ❑ ❑ ❑ ❑
moisture content of residuals reduced to <10%?
Did the temperature of the residuals or the wet bulb temperature of the gas ❑ El El ❑
in contact with the residuals as the residuals leave the dryer exceed 80°C (176°F)?
❑ Other Alternative, Specify: (See White House Manual)
Page 2 of 4

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ Option 1 - 38% Volatile Solids Reduction
Are lab results and calculations present?
Was the reduction on volatile solids (not total solids)?
Were samples collected at correct locations?
(beginning of digestion process & before land application)
Was there a >38% reduction?
Y N NA NE
DODD
DODO
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❑ Option 2 - 40-Day Bench Scale Test Y N NA NE
Were residuals from anaerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ ❑ ❑ ❑
Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ ❑ ❑
Was the 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%? ❑ ❑ ❑ ❑
❑ Option 3 - 30-Day Bench Scale Test Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ ❑ ❑ ❑
Were residuals 2% or less total solids? ❑ ❑ ❑ ❑
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? DODO
Was the test run for 30 days? DODO
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%? LIDO ❑
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals form aerobic digestion? ❑ ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ❑ LI
Was the test done between l0°C (50°F) and 30°C (86°F)? ❑ DDD
Was the temperature corrected to 20°C (68°F)? ❑ ❑ ❑ ❑
Was the sampling holding time <2 hours? ❑ ❑ ❑ ❑
Was the test started within 15 minutes of sampling or aeration maintained? ❑ DOD
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? ❑ ❑ ❑ ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? DODO
Was the average residuals temperature higher than 45°C (113°F)? ❑ ❑ ❑ ❑
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? ❑ ❑ ❑ ❑
❑ Option 6 - Alkaline Stabilization Y N NA NE
Was the pH of the residuals raised to >12 and maintained for two hours
without addition of more alkali? DODO
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
without the addition of more alkali? DODD
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DODO
['Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? DODO
Were the residuals mixed with any other materials? If so, what? DODD
Were the residuals dried >75% total solids? ❑ ODD
❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑
Were the residuals dried >90% total solids? ❑ ❑ ❑ ❑
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4

Non -Discharge Compliance Inspection Report
Residuals Storage:
Describe storage: Two 2,500,000 gallon settling lagoons.
Number of days/weeks/months of storage: 1 year
Residuals Sampling:
Is sampling adequate and representative?
Describe Sampling: TCLP, Metals, Nutrients
Y N NA NE
Transport Vehicle: Y N NA NE
Is transport occurring at time of inspection? ❑ ❑ ❑
Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed vehicle(s): 0 ❑ ❑ ❑
Application Site(s)
Were application site(s) inspected? If so, please complete info below.
Is application occurring at the time of inspection? If no, note the date of the last event:
Weather Conditions:
❑ Sunny ❑ Partly Cloudy ❑ Cloudy
❑ Windy (wind direction: ) ❑ Breeze
allo Precipitation ❑ Drizzle ❑ Rain
® Overcast
® Calm
❑ Cjpudburst
® Yes ❑ No
❑ Stormy
®Yes No
(If applicable, precipitation measurement:
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ❑ 40 — 60 0 60 — 80
Permit and Spill Plan onsite during application?
Application Observations: [Type of application:
0 Yes ❑ No
El >80
Liquid ❑ Cake (> 15% total solids) ❑ Other
Site Owner(s): RC-1401 (Field 5)
Intended Crop: PAN Requirement: Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
Application occurring at time of visit: ® Yes 0 No
Application Method: ® Surface 0 Incorp/Injection
Incorporation/Injection during visit: ❑ Yes D No ® N/A
Vegetative Buffer description: ❑None ®Grass ['Crop ❑ Shrub ❑
Tree ❑ Other
Current Field Conditions:
❑ Bare 0 Stubble 0 Planted
Soil Condition:
® Dry 0 Moist ❑ Wet 0 Saturated
O Not -Frozen 0 Frost 0 Frozen 0 Snow -Covered
Slope: ❑ 0-3% ® 3-6% 0 6-IO% 0 10-18% 0 >18%
Odor: 0 None 0 Mild 0 Moderate ❑ Stronp
Vectors: la None 0 Few 0 Many ❑ Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells?
Sufficient setbacks from surface waters?
Slopes>10% avoided (Surface App.) ?
Slopes>18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
No evidence of shallow GW?
Tracking is prevented?
Biosolids run-off is prevented?
(crop) 0 Pasture
Y N NA NE
12000
110000
0000000
O 000
O 000
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• ❑ ❑ ❑
❑❑ 00
❑❑ 0
Site Owner(s):
Intended Crop: PAN Requirement:
Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
Application occurring at time of visit: 0 Yes 0 No
Application Method: 0 Surface 0 Incorp/Injection
Incorporation/Injection during visit: 0 Yes 0 No ❑ N/A
Vegetative Buffer description: ['None ❑Grass 0Crop ❑ Shrub ❑
Tree 0 Other
Current Field Conditions:
0 Bare 0 Stubble ❑ Planted (crop) ❑ Pasture
Soil Condition:
❑ Dry 0 Moist 0 Wet 0 Saturated
❑ Not -Frozen ❑ Frost 0 Frozen 0 Snow -Covered
Slope: ❑ 0-3% 0 3-6% ❑ 6-IO% ❑ 10-18% ❑ >18%
Odor: 0 None ❑ Mild 0 Moderate 0 Strong
Vectors: 0 None ❑ Few 0 Many 0 Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells?
Sufficient setbacks from surface waters?
Slopes > 10% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
No evidence of shallow GW?
Tracking is prevented?
Biosolids run-off is prevented?
1 N NA NE
O 000
O 000
O 000
O 000
O 000
L IMO
O 000
O 000
O 000
O 000
O ❑❑❑
O 000
Page 4 of 4