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Home My WebLink AboutWQ0002376_Inspection Letter_20230311ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality March 6, 2024 Delivered electronically via email to: swoodard(d.)reidsvillenc.gov Summer Woodard — City Manager City of Reidsville 1100 Vance Street Reidsville, NC 27320 SUBJECT: 2023 Annual Report Review City of Reidsville RLAP Permit No. WQ0002376 Rockingham County Ms. Woodard: On March 7, 2024 Division of Water Resources staff Caitlin Caudle completed a review of the 2023 residuals annual report. This review mostly reflected compliance with the subject permit. The following item of concern was noted: • A review of available records shows that the Winston Salem Regional Office was not notified of land application activities at least twenty-four (24) hours in advance, some land application activities were only notified the day applications started. The Land Application Field Summary Form for RC-130-1 shows that land application occurred on February 16, 2023, but notification of applications to that field was received on February 20, 2023. As a reminder, per Permit Condition 111.3 the Winston Salem Regional Office shall be notified at least one business day in advance of conducting any land application activity. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact Caitlin Caudle at the letterhead address and phone number, or by email at caitlin.caudle(a-)-deg.nc.gov. Sincerely, Docu Signed by: E� � 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) Rockingham County Environmental Health (electronic copy) DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm 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: 03/07/2024 Entry Time 09:OOAM Primary Inspector: Caitli f ��u�cil(e gned by: Secondary Inspector(s): V, 8B834968199D49D_ Exit Time: 02:OOPM Phone: 336-776-9699 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: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 03/07/2024 Inspection Type: Annual Report Review Reason for Visit: Routine Inspection Summary: On March 7, 2024 Division of Water Resources staff Caitlin Caudle completed a review of the 2023 residuals annual report. This review mostly reflected compliance with the subject permit. The following item of concern was noted: • A review of available records shows that the Winston Salem Regional Office was not notified of land application activities at least twenty-four (24) hours in advance, some land application activities were only notified the day applications started. The Land Application Field Summary Form for RC-130-1 shows that land application occurred on February 16, 2023, but notification of applications to that field was received on February 20, 2023. As a reminder, per Permit Condition 111.3 the Winston Salem Regional Office shall be notified at least one business day in advance of conducting any land application activity. Ms. Caudle requested that the Week 5 calculation sheet for the 30 day bench scale test for Q3 be provided. The complete lab report was provided on 3/7/2024. Other observations: • Nutrient and metals samples were collected once per quarter on 1/5/2023, 4/5/2023, 7/6/2023, 10/3/2023. TCLP was collected 1 /5/2023. • PVR was completed quarterly with fecal samples and 30 day bench scale. • A total of 12 fields were applied to in the 2023 calendar year. • RC-12-2A, RC-12-213, RC-41-1, RC-119-1, and RC-1 30-1 all had a pH less than 6.0 with a lime recommendation. No Iim( applications were reported. Soil pH should be maintained above 6.0 to ensure optimum nutrient availability for crops. • Based on the most recent RYE values, the PAN for RC-118-2, soil series CgB2, is 209 Ibs/ac. The reported PAN was 220 Ibs/ac. The actual PAN applied was 42 Ibs/ac. • RC-130-1 has a dominant soil series of Mayodan. Mayodan is not listed in Rockingham County in the RYE database. The field is currently mapped as Clover after a temperature regime change updating the mapped soils. Clover is an acceptable alternative to Mayodan. • Field RC-12-2A incorrectly reported a biosolids application on May 4, 2023. Brent Collins, EMA, reviewed field records and confirmed that the biosolids application was actually June 4, 2023. A corrected Field Summary Form was provided. Page 2 of 4 Permit: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 03/07/2024 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? ❑ ❑ 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: WQ0002376 Owner - Facility: City of Reidsville Inspection Date: 03/07/2024 Inspection Type: Annual Report Review Reason for Visit: Routine e. Time/Temp on: ❑ ❑ ❑ ❑ Digester (MCRT) ❑ Compost ❑ Class A lime stabilization ❑ f. Volatile Solids Calculations ❑ ❑ ❑ ❑ g. Bench -top Aerobic/Anaerobic digestion results 0 ❑ ❑ ❑ 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: Page 4 of 4 Meritech, Inc. Environmental Laboratory Laboratory Certification No. 165 Contact: Brent Collins Client: EMA Resources, Inc 755 Yadkinville Road Mocksville, NC 27028 Report Date: 8/9/2023 Date Sample Rcvd: 7/6/2023 Vector Attraction Reduction / Aerobically Digested Sludge (30 Day Test) Meritech Work Order # 07062303 Sample: Reidsville Composite 7/6/23 Total Solids Volatile Solids % Volatile Solids Week 1 1.03 0.75 0.734 Week 2 0.98 0.72 0.737 Week 3 0.90 0.67 0.744 Week 4 1.12 0.84 0.7S3 Week 5 0.84 0.62 0.731 Van Kleek Reduction (%): 1.29 I hereby certify that 1 have reviewed and approve these data. Laboratory Representative 642 Tamco Road, Reidsville, North Carolina 27320 tel.(336)342-4748 fax.(336)342-1522 5 C ■ N io O Q C y � H A > � n � C G o � v U O n N _ a.i 9 b �Ny �R�yy U 4� U U O O n c� L II O �+ H O F rn « \ { A ,\ AZI) 2) �\ § ! ! \. 704 } } LA ..\ \\ Ong (} }\ \} E2 «» ( � e 0 N � Ia � n 0 0 w AIt OI9 N � k k u o y o I 19 6 ti tl ri a Mt IMmff F III I�bl I a ?tv tv I E222�« _ � ) \�/ � - `ƒ CL }0 / �2 � - - ° - 3 ; « / \ _ �o - �` $ 0a 2 f m R _`[) 7 , ,§ \ \ \ ( \ ol \ § x a § ( } ] E ( . (/ G § _ § - ( z - _ = n Ln ! \ _ rl \ _ ( « n _ § �\ E 9 �f2 � \ \ \ ( { , \k -{ cr ;_r$ 9 0 ° � \ ANNUAL METALS FIELD LOADING SUMMARY FORM* Attach this form to the corresponding Field Loading Summary Form to be submitted in Annual Report Facility Name: City of Reidsville Total Dry Tons Applied (Annual): Permit #: WQ0002376 Cation Exchange Capacity (non 503 only): Operator: Harry Sharpe Owner: Lawrence McCollum Predominant Soil Series: Acres Used: 3.52 Acres Permitted: 3.52 Site #: RC012 Field #: 2.96 RnB 2A Residual Analysis Data (Heavy Metals and Total Phosphorus use mg/kg, % Solids use Raw Percent #): RUMPTWIP Com- posite Date Total Phos- phorus Annual Heavy Metal Field Loadings (Calculated in lbs/acre): TotalMED Event 1 1� � 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1•• 1 11 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 11• �� 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1 1 1 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1 1 11 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 11 � 1 1 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1 �� 1 1 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1 1 1� � 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 1•• ®� 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 1 111 Total ' 1111 1111 1111 1111 1111 1111 1111 1111 1111 1111 1111 "I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations". 1/25/2024 Signature of Land Applier Date DENR FORM MFLSF (12/2006) ANNUAL LAND APPLICATION FIELD SUMMARY FORM PLEASE MAKE A COPY OF THIS BLANK FORM TO BE COMPLETED AND SUBMITTED FOR EACH FIELD APPLIED ON PLACE A "N/A" IN A BLANK OR BOX WHEN NOT APPLICABLE. Facility Name: City of Reidsville WQ Permit #: WQ0002376 Field #: 2A Acres Utilized: 3.52 Land Owner: Lawrence McCollum Annual Dry Tons Applied: 2.96 Site #: RC012 Acres Permitted: 3.52 Operator: Harry Sharpe Predominant Soil Series: RnB Cation Exchange Capacity (non 503): 0 Crop 1 Name: Fescue -Hay Crop 1 Max. PAN: 167 Crop 2 Name: Crop 2 Max. PAN: o ., M Volume applied (enter one) Solids/ Liquid Cu. Yds Gallons " �" Solids Volume Applied per Acre (Dry Tons/Ac) Residual Sources (NpDES #, WQ#, Fert., Animal Waste, etc) Soil Cond. (Dry, e ' Moist) Precip. Past 24 Hrs. inches co w * 2 * o' w �; * N TKN mg/kg Z o as o CD Z. mg/kg Nitrate and Nitrite mg/kg PAN Applied PP lbs/acre ( ) Name of Crop Type Receiving Residual Application Crop 1 Crop 2 Crop 1 Crop 2 6/4 45500 1.56 0.841 Reidsville WWTP Dry <.5" S 0.5 0.3 77900 14400 72.6 44.268 NA Fescue 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 0.000 1 0.000 0.000 0.000 0.000 Residuals Applications totals on FORM FSF supp ( attach FORM FSF supp to this form): TOTAL&: 01 45500 As Cd Cu Cr Pb Hg Mo Ni Se Zn P -4472681 0.000 Lime Applied Annuallbs/acre 0.044 0.009 0.373 0.072 0.107 0.002 0.012 0.033 0.044 1.425 41.545 1 Date lbs/ac Prior Years Cumulative lbs/ac 0.128 0.024 1.049 0.189 0.26 0.002 0.065 0.079 0.132 3.374 Current Cumulative lbs/ac 0.172 0.033 1.422 0.261 0.367 0.004 0.077 0.112 0.176 4.799 Permitted C. P. L. R.**** 1 36 1 34 1 1338 1 1 267 1 15 1 1 374 1 89 1 2498 Permit PAN Limit 1 st/2nd Crop 167 "I certify, under penalty of law, that this document was prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." *Application Method: S - Surface, IN - Injection, INC - Incorporation 1/25/2024 **Volatilization Rate: Surface - 0.5, Injection/Incorporation - 1.0 Signature of Land Applier Date *** Mineralization Rates: Compost -0.1, anaerobially digested -0.2, aerobically digested -0.3, raw sludge -0.4 ****C.P.L.R.: Cumulative Pollutant Loading Rate DENR FORM FSF (12/2006)