WQ0029804_Non-Discharge Annual Report Review_20210629

ROY COOPER
Governor
JOHN NICHOLSON
interim Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 29, 2021
Ms. Courtney Driver, Utilities Director
Winston-Salem/Forsyth County Utilities Commission
P.O. Box 2511
Winston-Salem, North Carolina 27102
SUBJECT: 2020 Annual Report Review
Winston-Salem/Forsyth County Utilities Commission
Thermal Biosolids Drier Management Facility/Residuals Distribution Program
Permit No. WQ0029804
Forsyth County
Dear Ms. Driver:
The Division of Water Resources (DWR) acknowledges receipt of your 2020 Annual Report for the
subject permit. A review of this report conducted by DWR staff person Jim Gonsiewski reflects
compliance with Permit Number WQ0029804.
If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski
at [phone] or via email at iim.gonsiewski(aincdenr.gov.
Sincerely,
CDocuSlgmd by:
,. 4..J,1.Q,y�,ak.
0D2D3CE3F1B7456... C/
Jennifer F. Graznak
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
cc: Forsyth County Environmental Health (Electronic Copy)
Mr. Bruce Casey, ORC — City of Winston-Salem (Electronic Copy)
Ms. Diane Herndon, Back-up ORC — City of Winston-Salem (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
D_E
336.776.9800
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

Permit: WQ0029804
SOC:
County: Forsyth
Region: Winston-Salem
Compliance Inspection Report
Effective: 05/01/20
Effective:
Contact Person: Bruce Michael Casey
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Expiration: 06/30/26
Expiration:
Owner : City of Winston-Salem
Facility: City of Winston-Salem DCAR
2801 Griffith Rd
Title: Utilities Plant Supervisor
Inspection Date: 06/24/2021 Entry Time 02:30PM
Primary Inspector: Jim J Gonsiewski
Secondary Inspector(s):
Certification:
Reason for Inspection: Routine
Permit Inspection Type: Distribution of Residual Solids (503)
Facility Status: • Compliant ❑ Not Compliant
Question Areas:
Winston Salem NC 27103
Exit Time: 05:15PM
Phone: [phone]
Phone:
Phone: [phone]
Inspection Type: Annual Report Review
▪ Miscellaneous Questions Record Keeping
▪ Sampling Pathogen and Vector Attraction
(See attachment summary)
Treatment
Page 1 of 4

Permit: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 06/24/2021 Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) acknowledges receipt of your 2020 Annual Report for the subject permit. A review
of this report conducted by DWR staff person Jim Gonsiewski reflects compliance with Permit Number W00029804.
A total of 6276 tons of residuals were produced in 2020.
Page 2 of 4

Permit: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 06/24/2021 Inspection Type : Annual Report Review
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations'?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
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*
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*
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)
10E6 CFU/dry gram
10E6 CFU/dry gram
Yes No NA NE
Yes No NA NE
❑ ❑ U ❑
❑ ❑•❑
❑ ❑•❑
❑ ❑ • ❑
O 0011
❑ ❑ ❑ •
❑ ❑ ❑•
11000
O 01110
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑•❑
11000
• ❑ ❑ ❑
❑ ❑ ❑•
• ❑ ❑ ❑
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Yes No NA NE
• ❑ ❑ ❑
El
❑ ❑•❑
❑ ❑■❑
001110
0
O 000
Page 3 of 4

Permit: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 06/24/2021 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
Comment:
Treatment
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Comment: Thermal drying of residuals.
Sampling
Describe sampling:
TCLP, metals, and nutrients.
Is sampling adequate?
Is sampling representative?
Comment:
• ❑ ❑ ❑
0
▪ ❑ ❑ ❑
O 0110
Yes No NA NE
•
Yes No NA NE
• ❑ ❑ ❑
■ ❑❑❑
Page 4 of 4

eft
Annual Report Review Class A Distribution v- C'
Reporting Period: ao �)_ U
Permit Details: i/,) Cs4 Oaf), c
• Is 503?`? es,
• Class A or B?
• Maximum Dry Tons Per Year: 1 %.Q.4 ,.
• Number of acres permitted:
.—
• Number of fields in permit: ---
• Counties that land is permitted for:
• Monitoring Frequency for TCLP:r r i 4N
• Monitoring Frequency for Residuals Analysis:
• Monitoring Frequency for Pathogen & Vector Attraction Reduction:
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted?
• Was distribution conducted during the rep rted period? yes
• How many dry tons were produced and distributed? to6, S'
• Were the distributions with the permitted amount? yes
• Were recipients information listed?\-k5
• Did it indicate compliance? }tc S-
• Was form complete?Nl e-S
• Was it signed by the appropriate people? )1es
2. Monitoring
,, J
• Were the analyses conducted at the required frequency? '
• Was an analyses taken for each source that was distributed? ,eS
• Were the metals analyses reported on the Residual Sampling ummary Form?
e.
• Were the results reported in mg/kg?
• Were the pH's 6.0 or greater for each residual sample? 9e.4
• Were the heavy metals within ceiling concentration permit limits?
Were the lab analyses attached? sZy
• Were all the required parameters tested?
• Was TCLP analysis conducted? Y::2J
• Were the TLCP contaminants within regulatory limits? Y.
• Was a corrosivity, ignitability, and reactivity analysis conducted?
Y,,.,,(a
3. Pathogen and Vector Attraction Reduction t�
• Was a signed copy of the Pathogen and Vector Attraction Reduction Form submitted? `1/,e,s,
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction
alternative and the vector attraction reduction option used? V .e
• Was the ap o riate documentation to show pathogen and vector atiTraction reduction included
in the report?e-S
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503? y
Class A Pathogen Review
To be Class A, residuals shall meet either fecal Coliform density or salmonella density.

Fecal Coliform density
• Was the sampling conducted at the required frequency?
Were multiple samples taken?Y LS
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?
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?
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
• 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?
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 (86°F) and 37°C (99°F)?
• Was the reduction of on volatile solids (not total solids)?
• Was the reduction less than I7%?
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 (68°F)?
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 (50°F) 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 grain 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 (104°F) for a 14-day period?
• Was the average residuals temperature higher than 45°C (113°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)?

Option 7 — Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals?ice
• Were the residuals mixed with any other materials?( $
• Were the residuals dried up to 75% total solids`? 1
Option 8 — Drying of Unstabilized Residuals 11
• Were the residuals mixed with any other materials?
• Were the residuals dried to 90% total solids?
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?
• Was the annual report complete? )I .es-
• Was the report submitted on time?/es.