WQ0002376_RLAP Inspection Report_20211216

ROY COOPER
Governor
ELIZABETH S. BISER
Sec, Nat y
S. DANIEL SMITH
Director
Summer Woodard — City Manager
City of Reidsville
1100 Vance Street
Reidsville, North Carolina, NC 27320
NORTH CAROLINA
Environmental Quality
December 16, 2021
Subject: Compliance Evaluation Inspection
City of Reidsville, Residuals Land Application Program
Permit No. WQ0002376
Rockingham County
Dear Ms. Woodard:
On November 30, 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's residuals land application 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,
CDocuSigned by:
L.OA. T. SMIttt
145849E22§C94EA...
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
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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

County: Rockingham
Region: Winston-Salem
Contact Person: Steven L Routh
Directions to Facility:
System Classifications: LA,
Primary ORC: Brent M Collins
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Compliance Inspection Report
Permit: WQ0002376 Effective: 06/04/20 Expiration: 12/31/26 Owner : City of Reidsville
SOC: Effective: Expiration: Facility: City of Reidsville RLAP
230 W Morehead St
Reidsville NC 27320
Title: Director of Public Works Phone: [phone]
Certification: 27651 Phone: [phone]
NC0024881 City of Reidsville - Reidsville WWTP
Inspection Date: 11/30/2021
Entry Time 10:10AM Exit Time: 11:45AM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
El Miscellaneous Questions 1.1 Sampling
MI Pathogen and Vector Attraction Transport
(See attachment summary)
Land Application Site
Page 1 of 4

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/30/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On November 30, 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's residuals land application program This
inspection was conducted by DWR staff member Jim Gonsiewski. Mr. Brent Collins of EMA Resources was present during
this inspection. Loading operations at the City of Reidsville WWTP and field application of residuals were obsereved.
The inspection reflects compliance with the permit.
Page 2 of 4

Permit: WQ0002376 Owner - Facility:City of Reidsville
Inspection Date: 11/30/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application ❑
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)
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:
TCLP, nutrients, metals, vecotr and pathogens
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?
Does transport vehicle appear to be maintained?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Yes No NA NE
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Page 3 of 4

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/30/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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 wl 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 1'/3' bls.
Is application occurring at the time of the inspection?
Comment: No monitoring wells required.
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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 B RESIDUALS LAND APPLICATION
General Information
Facility Name: Reidsville v.VTP
Permit No.: W00002376
Owner: City of Reidsville
Plant ORC Name: Scott Bryan
LA ORC / Contract Company: Brent Collins EMA
County: Rockingham
Permit Issuance Date: 06/04/20
Permit Expiration Date: 12/31/26
Telephone No.: 336-349-1100
Telephone No.: 336-399-3646
Other Contact(s): Telephone No.:
Facility Location (address, gps or directions): 407 Broad Street Reidsville
Reason for Inspection
ROUTINE E FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
On site at 10:10 AM. Met with Brent Collins, EMA. Met at the WVVTP. Four tankers/tractor trailers
(7,200-gallon tankers - numbers 101, 105, 107, 115). Observed one tanker loading up residuals from
the two 1,000,000-gallon concrete digesters. No spillage. No staining of the asphalt or tracking of
sludge out of the WVVTP observed. Discussed operations at the WVVTP. Left WVVTP and travelled out
to the land application site at 10:45 AM.
Arrived at application field (NC-RC-011-02) at 11:10 AM. A rain guage was observed attached to one of the
two tractors. Inspected the field. The terrain was slightly hilly with the slopes ranging from 0% to 6%. The
solids content in the residuals was 1.12%. The field was properly flagged. No runoff or ponding of residuals
from previous applications were observed. Two 4,200 gallon tractor -pulled spreaders (303 and 311) were
applying residuals. At 11:20 AM, the equipment was moved to NC-RC-012-01.
The O&M plan and the permit were present. The O&M plan was adequate. Each vehicle had an O&M plan
and maps. The residual spreading was good. No additional run off or ponding was observed during the
application. Proper buffers were maintained. Observed transfer of residuals from tankers to spreaders.
No problems noted.
Left the application fields at 11:45 AM.
Is a follow-up inspection necessary? ❑ Yes ® No
Primary Inspector: Jim Gonsiewski
Date of Inspection: 11/30/2020
Secondary Inspector:
Entry Time: 10:10 AM Exit Time: 11:45 AM

Non -Discharge Compliance Inspection Report
Residuals Generating Facility
Was the residuals generating facility inspected?
Residuals Storage:
Describe storage: Two 1,000,000 - gallon concrete digesters.
Number of days/weeks/months of storage: 4-5 months
Residuals Sampling:
Is sampling adequate and representative for each sample type?
Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP): TCLP, metals/nutrients, pathogens, vectors
® Yes ❑ No
Transport Vehicle:
Is transport occurring at time of inspection?
Are necessary records (spill plan) present in vehicle? ID of observed vehicte(s): 101, 105, 107, 115, 211, 214
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? ® 1/yr or ❑ 1/permit cycle
Residuals metals and nutrient analysis conducted? Frequency? quartef+(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 PAN balance records available and within permit limits?
Are there nutrient (crop) removal practices in place?
Are hauling records available? (gal and/or tons hauled during calendar year to date)
Are field loading records available?
Are field inspections conducted and are records available?
Are soil sample results available?
Did soil results call for lime amendment? If so, are there records of application?
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2,000)?
Soil results indicate Na <0.5 meq/100 cm', and Exchangeable Sodium Percentage (ESP) <15%?
Does the permit require groundwater monitoring?
Are groundwater lab results present?
There are no 2L GW standard violations indicated in the lab results?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
Which Alternative was used to demonstrate compliance?
❑ Alternative 1 Fecal Coliform Density.
Were 7 samples collected and geometric mean <2 million mpn/cfu?
❑ Alternative 2 Process to Significantly Reduce Pathogens (5 options)
❑ Alternative 3 Use of Equivalent to RSRP (Not commonly used - See White House Manual)
IfAlternative 2 was used, select which Option was utilized and complete the section below.
❑ Option 1 - Aerobic Digestion
Are logs present showing time and temperature?
Was the time & temp. between 40 days at 68°F (20°C) and 60 days at 59° F (I5°C)?
❑ Option 2 - Air Drying
❑ Option 3 - Anaerobic Digestion
Are logs present showing time and temperature?
Was the time & temp. between 15 days at 95° F — 131° F (35°-55° C) and
60 days at >68° F (20° C)?
❑ Option 4 — Composting (Not commonly used - See White House Manual)
❑ Option 5 - Lime Stabilization
Are logs present showing time and temperature?
Was the pH raised to >12 after two hrs of contact?
Was the temperature corrected to 25° C (77° F) (by calculation, NOT auto correct)?
Page 2 of 4
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Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
El Option 1 - 38% Volatile Solids Reduction Y N NA NE
Are lab results and calculations present? DODD
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? DDDD
❑ Option 2 - 40-Day Bench Scale Test Y N NA NE
Were residuals from an anaerobic digester with average temp. 30°C — 40°C? ❑ ❑ ❑ ❑
Are lab results and calculations present? ❑ DOD
Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ ❑ ❑
Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? ❑ ODD
Was the reduction of on volatile solids (not total solids)? ❑❑ DDD
❑ ❑ ❑
Was the reduction less than 17%?
❑ Option 3 - 30-Day Bench Scale Test Y IN NA NE
Were residuals from aerobic digestion? ® DOD
Are lab results and calculations present? ❑ ® ❑ ❑
Were residuals 2% or less total solids? ® DOD
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? ❑ ❑ ❑
Was the test run for 30 days? NIODD
Was the test done at 20°C (68°F)? DDO
Was the reduction of on volatile solids (not total solids)? MOOD
Was the reduction less than 15%? NDDD
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑ ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ❑ DDO
Was the test done between 10°C (50°F) and 30°C (86°F)? DODD
Was the temperature corrected to 20°C (68°F)? ❑ DOD
Was the sampling holding time <2 hours? ❑ DDO
Was the test started within 15 minutes of sampling or aeration maintained? DODD
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? EDDO
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? DODD
Was the average residuals temperature higher than 45°C (113°F)? ❑ ODD
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? DODO
❑ 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? ❑ ❑ ❑ ❑
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali? DODD
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DODD
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? DODD
Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑
Were the residuals dried >75% total solids? DODD
❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? DODO
Were the residuals dried >90% total solids? LI ODD
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4

Non -Discharge Compliance Inspection Report
Land Application Site(s)
Were application site(s) inspected? Ifso, please list Site ID(s) below.
Application Site ID(s): NC-RC-011-02, NC-RC-012-01
®Yes No
Is application occurring at the time of inspection? ® Yes ❑ No If no, note the date of the last event:
Was the Division notified of the application event(s)? ® Yes ❑ No
Weather Conditions:
® Sunny ❑ Partly Cloudy ❑ Cloudy ❑ Overcast ❑ Stormy
❑ Windy (wind direction: ) ® Breeze ❑ Calm
® No Precipitation ❑ Drizzle 0 Rain ❑ Cloudburst (If applicable, precipitation measurement:
Is there a rain gauge onsite? ® Yes ❑ No
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? ® Yes ❑ No
❑ >80
Application Observations: [Type of application: ® Liquid ❑ Cake ❑ Other
Application Site —Field ID(s): NC-RC-012-01
Intended Crop: Fescue
Application Rate (tons or gallons/acre):
Nutrient Content: 1.12%
PAN Requirement: 209 Ibs/ac
13,000 gallons/acre
% of total field area utilized or anticipated for this event? 90
Application occurring at time of visit: ® Yes ❑ No
Application Method: ® Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes 0 No ® N/A
Vegetative Buffer description: ❑None ®Grass ❑Crop 0 Shrub
['Tree 0 Other
Current Field Conditions:
0 Bare 0 Stubble 0 Planted Ftaspue ® Pasture
Soil Condition:
® Dry 0 Moist ❑ Wet 0 Saturated
® Not -Frozen 0 Frost 0 Frozen 0 Snow -Covered
Slope: ® 0-3% ® 3-6% ❑ 6-10% ❑ I0-18% 0 >18%
Odor: I None ❑ Mild ❑ Moderate ❑ Strong
Vectors: ® 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/residences?
Sufficient setbacks from surface waters?
Slopes >l0% avoided (Surface App.) ?
Slopes>18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
Biosolids visible on surface?
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-off is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
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El DOD
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Y N NA NE
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MEIEID
WOOD
Application Site —Field ID(s): -
Intended Crop: _ PAN Requirement: Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
%oftotal field area utilized or anticipated for this event?
Application occurring at time of visit: ❑ Yes 0 No
Application Method: 0 Surface 0 Incorp/Injection
Incorporation/Injection during visit: ❑ Yes 0 No 0 N/A
Vegetative Buffer description: ❑None ❑Grass 0Crop ❑ Shrub
['Tree 0 Other
Current Field Conditions:
❑ Bare ❑ Stubble Cl Planted (crop) ❑ Pasture
Soil Condition:
❑ Dry ❑ Moist ❑ Wet ❑ Saturated
❑ Not -Frozen 0 Frost 0 Frozen ❑ Snow -Covered
Slope: ❑ 0-3% ❑ 3-6% 0 6-10% 0 10-18% ❑ >18%
Odor: 0 None 0 Mild 0 Moderate ❑ Strong
Vectors: 0 None ❑ Few 0 Many 0 Excessive
Application Details: Y N NA NE
Application areas clearly marked? ❑ 0 El 0
Application within authorized area? 0 0 El ❑
Application method appropriate? ❑ ❑ ❑ ❑
Application is even (no ponding)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells/residences? ❑ 0 0 0
Sufficient setbacks from surface waters? 0 ❑ 0 ❑
Slopes >10% avoided (Surface App.)? ❑ ❑ ❑ ❑
Slopes >I8%avoided (Incorp/Inject)? 0 ❑ 0 El
Incorp./Injection within time -frame? ❑ ❑ ❑ ❑
Biosolids visible on surface? 0 0 0 0
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-otl is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
DODO
DODD
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Y
N NA NE
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