WQ0031314_Residual Annual Report 2019 Review Response_20200707

Winston-Salem/Forsyth County
Uti I ities
Water•Wastewater•Solid Waste
P.W.Swann Water Treatment Plant,2800 River Ridge Road,Pfafftown,NC 27040
O:336-727-8000,F:336-946-2574,wskutilities.org
July 13, 2020
Mr. Lon T. Snider—Regional Supervisor
NC DEQ-Water Quality regional Operations Section
450 West Hanes Mill Road
Suite 350
Winston-Salem, NC 27105
Subject: Notice of Deficiency(NOD-2020-PC-3075)
2019 Annual Permit Review
Swann WTP, Neilson WTP and Thomas WTP
Distribution of Class A Water Treatment Plant Residuals
Permit No. WQ0031314
Forsyth County
Dear Mr. Snider,
This letter is in response to your Notice of Deficiency(NOD-2020-PC-3075) letter dated July 7, 2020
regarding an exceedance of the Neilson WTP's permit distribution limit of 1,499 dry tons of residuals.
This hauling event represents residuals generated over a 34-month period for an average annual
production rate of 824 dry tons per year([2,334.69 DT's_34 months] X 12 Months). Lagoon#2 was in
service from January 2016 until April 2017 and lagoon#3 was in service from April 2017 until October
2018. Under normal circumstances at the Neilson Plant, one lagoon is clean and ready for service, one
lagoon is drying and one lagoon is in service. During the 2015 and 2017 calendar years, the Neilson WTP
did not distribute any residuals, which created a "backlog"that was caught up in 2019 by hauling more
than one lagoon.The residuals hauled in calendar year 2019 eliminated any backlog and we have
returned to our normal schedule. In addition we will be applying for a major modification to our permit
for the Neilson WTP requesting a generating limit of 2,500 dry tons to eliminate this from being an issue
should we be presented with the same situation in the future. Our existing permit expires in February
2021 and I am currently preparing the renewal application.
If you have any questions regarding this matter, please contact me at 336-397-7727.
Sincerely,
William C. Brewer
Water Treatment Superintendent
City Council:Mayor Allen Joines;Denise D.Adams,Mayor Pro Tempore,North Ward;Dan Besse,Southwest Ward;Robert C.Clark,West Ward;John C.Larson,
South Ward;Jeff Maclntosh,Northwest Ward;Morticia'Tee-Tee"Parmon,Northeast Ward;Annette Scippio,East Ward;James Taylor,Jr.,Southeast Ward;
City Manager:Lee D.Garrity
County Commissioners:David R.Plyler,Chair;Don Martin,Vice Chair;Fleming El-Amin;Ted Kaplan;Richard V.Linville;Tonya McDaniel;Gloria D.Whisenhunt;
Call 311 or 336-727-8000 County Manager:Dudley Watts,Jr.
Winston-Salem/Forsyth County Utility Commission:Randall S.Tuttle,Chair;L.Wesley Curtis,Jr.,Vice Chair;Harold E.Day;Tom Griffin;Yvonne H.Hines;
[e-mail] Duane Long;Hugh W.Jernigan;Chris Parker;James Ruffin;Donald R.Stewart;Allan Younger