WQ0031314_Residual Annual Report 2019 Review_20200707

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ROY COOPER = n
Governor
MICHAEL S.REGAN ` r a.n
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
July 7, 2020
Mr. Bill Brewer
Winston-Salem/Forsyth County Utilities Commission
Post Office Box 2511
Winston-Salem,North Carolina 27102
SUBJECT: Notice of Deficiency(NOD-2020-PC-0375)
2019 Annual Report Review
Swann WTP,Neilson WTP,and Thomas WTP
Distribution of Class A Water Treatment Plant Residuals
Permit No. WQ0031314
Forsyth County
Dear Mr. Brewer:
The Division of Water Resources (DWR) acknowledges receipt of your 2019 Annual Report for the subject
permit. A review of this report was conducted by DWR staff person Jim Gonsiewski. The following
deficiency was noted from the review:
Attachment A of the Permit states that the yearly maximum dry tons to be distributed annually from the Neilson
WTP is 1,499 dry tons. A total of 2,334.69 dry tons from the Neilson WTP were distributed in 2019. This is
an exceedance of 835.69 dry tons for the year.
Please provide a response to this letter within 30 days of receipt by your office indicating the corrective actions
taken to address this deficiency. If you anticipate this condition occurring again,this office recommends that
you apply for a permit modification to increase the permit limit. If this exceedance occurs again without a
permit modification, a Notice of Violation may be issued.
If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski at (336)
776-9800 or via email at jim.wrisiewski(a,ncdenr�.
Sincerely,
[DocuSigned
by:
sMdG-
LoriZnider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ—WSRO
cc: Forsyth County Environmental Health(Electronic Copy)
Courtney Driver—City of Winston-Salem(Electronic Copy)
WSRO Electronic Files
Laserfiche Files
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105
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^^•^r arr,eemBe�r pu01� 336.776.9800

Compliance Inspection Report
Permit:WQ0031314 Effective: 03/01/16 Expiration: 02/28/21 Owner: City of Winston-Salem
SOC: Effective: Expiration: Facility: P.W. Swann WTP
County: Forsyth 2800 River Rdg Rd
Region: Winston-Salem
Winston Salem NC 27103
Contact Person:Bill Brewer Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
NC0086011 City of Winston-Salem -Neilson WTP
NC0086762 City of Winston-Salem -P.W. Swann WTP
NC0079821 City of Winston-Salem -R.A.Thomas WTP
Inspection Date: 07/02/2020 Entry Time 01:OOPM Exit Time: 03:30PM
Primary Inspector:Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution of Residual Solids(503 Exempt)
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Sampling Pathogen and Vector Attraction
Transport
(See attachment summary)
Page 1 of 3

Permit: WQ0031314 Owner-Facility:City of Winston-Salem
Inspection Date: 07/02/2020 Inspection Type:Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) received the 2019 Annual Report for the subject permit. A review of this report was
conducted by DWR staff person Jim Gonsiewski. The following deficiency was noted from the review:
Attachment A of the Permit states that the yearly maximum dry tons to be distributed annually from the Neilson WTP is
1,499 dry tons. A total of 2,334.69 dry tons from the Neilson WTP were distributed in 2019. This is an exceedance of
835.69 dry tons for the year.
It was recommended that the facility send a response within 30 days of receipt indicating the corrective actions taken to
address this deficiency. If it is anticipated that this condition will occurr again, the DWR recommended that the facility apply
for a permit modification to increase the permit limit. If this exceedance occurs again without a permit modification, a Notice
of Violation may be issued.
A total of 2671 dry tons of residuals were land applied from the Swann amd Neison facilities.A Notice of Deficiency
(NOD-2020-PC-0375)was issued for exceeding the maximum permitted dry tons foom the Neilsen WTP.
Page 2 of 3

Permit: WQ0031314 Owner-Facility:City of Winston-Salem
Inspection Date: 07/02/2020 Inspection Type:Annual Report Review Reason for Visit: Routine
Type Yes No NA NE
Distribution and Marketing ❑
Land Application ❑
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) 0 ❑ ❑ ❑
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 Yes No NA NE
Describe sampling:
Residual and TCLP sampling.
Is sampling adequate? ❑ ❑ ❑
Is sampling representative? ❑ ❑ ❑
Comment:
Transport Yes No NA NE
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:
Page 3 of 3

l
Annual Report Review Class A Distribution
Reporting Period:
Permit Details:Vj
Is 503? N-c)
Class A or B?
Maximum Dry Tons Per Year:
Number of acres permitted:
Number of fields in permit: �--
Counties that land is permitted for:
Monitoring Frequency for TCLP: -r ,,\ 7 L1� t `�
Monitoring Frequency for Residuals Analysis:Q& d k�r Y�r7J
Monitoring Frequency for Pathogen&Vector Attraction ction: yW-,C
1. Class A Annual Distribution and M keting/Surface Disposal Certification Form
Was a certification form submitted? a
Was distribution conducted during the reported period?
How many dry tons were produced and distributed?
Were the distributions with the permitted amount?
Were recipients information listed? &✓-f.
Did it indicate compliance?
Was form complete? �Q
Was it signed by the appropriate people?yc-s
2. Monitoring
Were the analyses conducted at the required frequency?
Was an analyses taken for each source that was distributed? Y
Were the metals analyses reported on a Residual Sampling Summary Form?
ported
Were the results re in mg/kg?je� n
Were the pH's 6.0 or greater for each residual sample?n
Were the heavy metals within ceiling concentration permit limits?y��
Were the lab analyses attached?
Were all the required parameters tested'.
Was TCLP analysis conducted? (� r---Q7 `(1./
Were the TLCP contaminants within regulatory limits?
Was a corrosivity, ignitability,and reactivity analysis conducted?
3. Pathogen and Vector Attraction Reduction
Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted?
Did the form indicate the period of coverage,the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used?
Was the appropriate documentation to show pathogen and vector'attraction reduction included
in the report?
Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?
Class A Pathogen Review
To be Class A,residuals shall meet either fecal Coliform density or salmonella density.

I
Fecal Coliform density
Was the sampling conducted at the required frequency?
Were multiple samples taken?
Was each sample less than 1000 MPN/gram of total solids?
OR
Salmonella density
Was the sampling conducted at the required frequency?
Were multiple samples taken?
Was each sample less than 3 MPN/4 grams of total solids?
i
To be Class A,residuals shall meet one of the following alternatives:
Alternative 1 —Time/Temperature
Were the residuals maintained for correct time and temperature?
Were logs submitted showing time and temperature?
Were temperatures within range for complete time period?
f
Alternative 2—Alkaline Treatment
Were logs submitted 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?
Were logs submitted showing time and pH?
Was the temperature corrected to 25°C (77°F)?
Alternative 5 —Process To Further Reduce Pathogens
PFRP Composting
Were the within-vessel method or static aerated pile methods used?
Was the residuals temperature maintained at 55°C (131°F)or higher for three
consecutive days or longer in the within-vessel method or static aerated pile method?
OR
Was the windrow composting method used?
Was the residuals temperature maintained at 55°C or higher for 15 consecutive days or
longer in the windrow method, and the windrow turned a minimum of five times during
this time?
PFRP Heat Drying j
Was the residuals dried by direct or indirect contact with hot gases and the moisture
content of residuals reduced to 10% or lower?
• Did the temperature of the residuals or the of the wet bulb temperature of the gas in
contact with the residuals as the residuals leave the dryer exceed 80°C(176°F)?
Vector Attraction Reduction Review
Was the sampling conducted at the required frequency?
k
Option 1 —38%Volatile Solids Reduction
Was there 38%reduction?
Were lab sheets/calculations in report?
Was the reduction on volatile solids(not total solids)?

Were the samples taken at beginning of digestion process and before application
(Inspection)?
Were calculations correct?
Option 2—40-Day Bench Scale Test
Were residuals from anaerobically digested treatment(Inspection)?
Were residuals anaerobically digested in lab?
Was the test run for 40 days?
Was the test done between 30°C(86T) and 37°C (99°F)?
Was the reduction of on volatile solids(not total solids)?
Was the reduction less than 17%?
Were lab sheets/calculations in report?
Were calculations correct?
Option 3 —30-Day Bench Scale Test
Were residuals from aerobically digested treatment(Inspection)?
Were residuals aerobically digested in lab?
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?
Was the test run for 30 days?
Was the test done at 20°C (687)?
Was the reduction of on volatile solids(not total solids)?
Was the reduction less than 15%?
Were lab sheets/calculations in report?
Were calculations correct? `
Option 4—Specific Oxygen Uptake Rate(SOUR)
Were residuals form aerobically digested treatment(Inspection)?
Were residuals 2% or less total solids(dry weight basis)(not diluted)?
Was the test done between 10°C (50T) and 30°C (86°F)?
Was the temperature corrected to 20°C (68°F)?
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of total
residual solids(dry weight basis)?
Was the sampling holding time two hours?
Was the test started within 15 minutes of sampling or aeration maintained?
Option 5— 14-Day Aerobic Process
Were the residuals from aerobically digested treatment(Inspection)?
Were the residuals treated for 14 days?
Was the residuals temperature higher than 40°C (104T)for a 14-day period?
Was the average residuals temperature higher than 45°C(I13'F)?
Option 6—Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali?
Did the pH of residuals remain at 12 or higher for two hours without the addition of
more alkali?
Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours
without the addition of more alkali?
Was the pH corrected to 25°C (77°F)?

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t,.
Option 7—Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals?
Were the residuals mixed with any other materials?
Were the residuals dried up to 75%total solids?
Option 8—Drying of Unstabilized Residuals
Were the residuals mixed with any other materials?
Were the residuals dried to 90%total solids? j
Option 9—Injection
• Was there any significant amount of residuals on land surface one hour after injection
(Inspection)?
Was injection done on pasture or hay field?
Was injection done at time that crop was growing?
If Class A with respect to pathogen,were residuals injected with eight hours after
discharge from pathogen treatment?
4.General
Was the report in the proper format? Q
Was the annual report complete? �s
Was the report submitted on time?
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