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Home My WebLink AboutWQ0002376_Compliance Evaluation Inspection_20230621ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality June 21, 2023 Delivered via email to: swoodard(a)-reidsvillenc.gov Summer Woodard — City Manager City of Reidsville 1100 Vance Street Reidsville, NC 27230 SUBJECT: Compliance Evaluation Inspection Reidsville RLAP Permit No. WQ0002376 Rockingham County Dear Ms. Woodard: On June 5, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection. Brent Collins, EMA Resources, was present during the entire inspection. A review of records, storage units, transportation vehicles, application fields, and application equipment was completed. This review reflected compliance with the subject permit. The following item of concern was noted: A. One storage basin has a thick crust and floating vegetated mat on top of the biosolids. This mat moves with the biosolids level in the basin. A ten -foot tree and other well established vegetation were present. Facility staff stated biosolids are transferred from the basin with the mat to the other basin during application events. Per Condition V.2 the Permittee shall inspect the Permittee's residuals processing, storage, transport, and application facilities to prevent malfunctions, facility deteriorations, and operator errors... The vegetated mat can potentially damage the pumps and mixing equipment, and the integrity of the storage structure. The vegetated mat also prevents a thorough inspection of the storage structure. Steps should be taken to remove the vegetated mat and prevent another mat from forming. North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 NoanicaaouNn oep.m.m or em�nmen� Qualm 336.776.9800 Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact me or Caitlin Caudle at the letterhead address and phone number, or by email at jenn ..graznak deg.nc.gov or Caitlin.caudle(c).deg.nc.gov. Sincerely, DocuSigned by: OD2D3CE3F1 B7456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Brent Collins, EMA Resources (electronic copy) Mourice Brothers, WWTP ORC (electronic copy) Rockingham 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 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly Compliance Inspection Report Permit: WQ0002376 Effective: 04/25/22 Expiration: 12/31/26 Owner: City of Reidsville SOC: Effective: Expiration: Facility: City of Reidsville Class B Residuals Program County: Rockingham 230 W Morehead St Region: Winston-Salem Reidsville NC 27320 Contact Person: Steven L Routh Title: Director of Public Works Phone: 336-349-1070 Directions to Facility: System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0024881 City of Reidsville - Reidsville WWTP Inspection Date: 06/05/2023 Entry Time 09:30AM Primary Inspector: Caitlin Cr68B834968199D49D_. I��°elllluSigned�b�y�:A�f Secondary Inspector(s): ""'ruv' Exit Time: 11:20AM Phone: 336-776-9699 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Sampling Land Application Site Pathogen and Vector Attraction Storage Transport (See attachment summary) Page 1 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 06/05/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On June 5, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted a routine compliance inspection. Brent Collins, EMA Resources, was present during the entire inspection. A review of records, storage units, transportation vehicles, application fields, and application equipment was completed. This review reflected compliance with the subject permit. The following item of concern was noted: A. One storage basin has a thick crust and floating vegetative mat on top of the biosolids. This mat moves with the biosolids level in the basin. A ten -foot tree and other well established vegetation were present. Facility staff stated biosolids are transferred from the basin with the mat to the other basin during application events. Per Condition V.2 the Permittee shall inspect the Permittee's residuals processing, storage, transport, and application facilities to prevent malfunctions, facility deteriorations, and operator errors... The vegetated mat can potentially damage the pumps and mixing equipment, and the integrity of the storage structure. The vegetated mat also prevents a thorough inspection of the storage structure. Steps should be taken to remove the vegetated mat and prevent another mat from forming. Field RC-11-1 • The field had recently been cut for hay. • All buffers were clearly marked. • Application was even with no evidence of ponding or runoff. • The staging area was within the application area. Field RC-12-1 • Application activities were completed last week. • All buffers were clearly marked. • Application was even with no evidence of ponding or runoff. • No odor or vectors were noted. Other observations: • A belt press and covered storage pad are available if needed. To date, the belt press has not been used since installed. • A top loader is used to load tanker trucks. A storm drain is in the curb downslope of the loader. Facility staff stated that the storm drain feeds back into the storage basin. • The basins have up to 6 months of storage. • Mr. Collins uses a sludge judge to collect biosolids samples from multiple locations around the basin to make a composite sample. Currently, Mr. Collins is collecting samples quarterly. • Nutrients and metals analysis, fecal analysis, 30-day bench scale, and TCLP analysis for Quarter 2 were provided to Ms. Caudle prior to the inspection. TCLP was completed on 1 /5/2023, and all others completed on 4/5/2023. • The rain gauge is on the spreader tanker. • Application rate was 2-3 tankers/ac, with the nutrient content being 22.6 Ibs PAN/tanker. • The most recent permit removed the requirement to have a sign posted at the entrance of each application field. All application fields viewed during this inspection are private property with no places of assembly or dwellings. Page 2 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 06/05/2023 Inspection Type: Compliance Evaluation 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? ❑ ❑ 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? ❑ ❑ ❑ 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? ❑ ❑ ❑ 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 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 06/05/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine e. Time/Temp on: ❑ ❑ ❑ ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations 0 ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ ❑ ❑ Comment: Sampling Yes No NA NE Describe sampling: Is sampling adequate? ❑ ❑ ❑ Is sampling representative? 0 ❑ ❑ ❑ Comment: Transport Yes No NA NE Is a copy of the permit in the transport vehicle? 0 ❑ ❑ ❑ 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: Land Application Site Yes No NA NE Is a copy of the permit on -site during application events? 0 ❑ ❑ ❑ 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? ❑ ❑ ❑ Page 4 of 5 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 06/05/2023 Inspection Type: Compliance Evaluation Reason for Visit: Routine 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: Page 5 of 5