WQ0029804_Report of the Review of the Annual Report_20220602

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
June 2, 2022
Ms. Courtney Driver, Utilities Director
Winston-Salem/Forsyth County Utilities Commission
P.O. Box 2511
Winston-Salem, North Carolina 27102
SUBJECT: 2021 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 2021 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 [e-mail].
Sincerely,
DoeuSiyned �by: L-ON T . Smgcr
1451349E225c 94EA...
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
encl: Compliance Inspection Report
cc: Forsyth County Environmental Health (Electronic Copy)
Mr. Bruce Casey, ORC — City of Winston-Salem (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
11:1E �_/
Dewm�.m a E.wo.memm o..nr V
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0029804 Effective: 05/01/20 Expiration: 06/30/26 Owner : City of Winston-Salem
SOC: Effective: Expiration: Facility: City of Winston-Salem DCAR
County: Forsyth 2801 Griffith Rd
Region: Winston-Salem
Contact Person: Bruce Michael Casey
Directions to Facility:
Winston Salem NC 27103
Title: Utilities Plant Supervisor Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/25/2022
Entry Time 09 OOAM Exit Time: 11:30AM
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)
Facility Status: II Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Treatment
In Sampling El Pathogen and Vector Attraction
(See attachment summary)
Page 1 of 4

Permit: WQ0029804 Owner - Facility:City of Winston-Salem
Inspection Date: 05/25/2022 Inspection Type : Annual Report Review
Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) received the 2021 Annual Report for the subject permit. A review of this report
conducted by DWR staff person Jim Gonsiewski reflects compliance with Permit Number WQ0029804.
A routine compliance evaluation inspection is planned to occur in the next 12 months.
Page 2 of 4

Permit: WO0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 05/25/2022 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*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)
Yes No NA NE
Yes No NA NE
❑ ❑ U ❑
❑ ❑■❑
El 0E0
❑ ❑•❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑❑❑
• ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ U ❑
❑ ❑■❑
❑ ❑■❑
❑ ❑ • ❑
❑ ❑■❑
O 01M0
❑ ❑ ❑•
• ❑ ❑ ❑
111000
• ❑ ❑ ❑
❑ ❑ ❑ .
Yes No NA NE
• ❑ ❑ ❑
•
111
❑ ❑■❑
❑ ❑■❑
❑ ❑•❑
O 01110
Page 3 of 4

Permit: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 05/25/2022 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:
Fecal Coliform, pH. TCLP, Residual Analyses
Is sampling adequate?
Is sampling representative?
Comment:
• ❑ ❑ ❑
•
• ❑ ❑ ❑
❑ ❑•❑
Yes No NA NE
•
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 4 of 4

Annual Report Review Class A Distribution Permit No. Wgao&q g 4
Reporting Period: e-" ,
Permit Details:
• Is 503?
• Class MA or [ B?
• Maximum Dry Tons Per Year: -(a 1-
• Number of acres permitted: —
• Number of fields in permit: r----
• Counties that land is permitted for: ----
• Monitoring Frequency for TCLP: - N\uo,\\ j
• 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 reported period?
• How many dry tons were produced and distributed? \S3
• Were the distributions within the permit -d amount?
• Were recipients information listed?
• Did it indicate compliance?
• Was form complete?
• Was it signed by the appropriate people?
1s
Et,(es No
Yes [No
aleg No
[ [INo
PYIes ❑No
Pee's ] No
2. Monitoring
•. Were the analyses conducted at the required frequency? EfIrd ]No
• Was an analyses taken for each source that was distributed? RI,efs(JNo
• Were the metals analyses reported on the Residual Sampling Summary Form?es ❑No
• Were the results reported in mg/kg? ['es No
• Were the pH's 6.0 or greater for each residual sample? U,Yes ]No
• Were the heavy metals within ceiling concentration permit limits? E '(� s
o Were the lab analyses attached? ai'fes
• Were all the required parameters tested? es ]No
• Was TCLP analysis conducted? fNo
• Were the TLCP contaminants within regulatory limits? es 1No
• Was a corrosivity, ignitability, and reactivity analysis conducted? [Yes ❑No

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 redu
and the vector attraction reduction option used?
• Was the appropriate documentation to show pathogen and vector attraction redu
report?
5 ❑No
on alternative
❑ No
uded in the
❑ No
• Was pathogen and vector attraction reduction demonstrated according to 90 CFR Part 503?0Yes❑No
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?
• 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:
f lAlternative 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?
T1Alternative 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
• Were logs submitted showing time and pH?
• Was the temperature corrected to 25°C (77°F)?
Yes ❑ No
Y s ❑No
es LJ No
]Yes
❑Yes
['Yes
❑Yes
❑Yes
12 or greater?
❑Yes
Yes
❑Yes
❑ No
No
No
❑ No
❑ No
❑ No
❑ No
❑No
❑ No
❑No
No
Alternative 5 — Process To Further Reduce Pathogens
flPFRP Composting
• Were the within -vessel method or static aerated pile methods used? ❑Yes No
• 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? ❑Yes ❑No
OR
• Was the windrow composting method used? ]Yes I INo
• 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? [Yes ! No
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? ❑Yes ❑No
• 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 (1763F)? fYes No

Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency?
nOption 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
' Were calculations correct?
nNo
❑ Yes LINo
❑Yes ❑No
❑ yes ❑No
and before application (Inspection)?
['Yes ❑No
❑ Yes ❑No
nOption 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 17%?
• Were lab sheets/calculations in report?
• Were calculations correct?
nOption 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%
• 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?
P Yes
]Yes
❑ Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑Yes
❑ No
❑ No
❑ No
❑No
[No
No
L No
No
❑Yes I_JNo
❑Yes No
❑Yes LJNo
with unchlorinated effluent?
['Yes [No
❑Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
[Yes ❑No
❑Yes ❑No
❑Yes [No
nOption 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 gram of total residual solids (dry
weight basis)? ❑Yes END
• Was the sampling holding time two hours? ❑Yes [No
• Was the test started within 15 minutes of sampling or aeration maintained? ❑Yes ❑No
nOption 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)?
['Yes ❑No
❑ Yes ❑No
❑Yes ❑No
❑Yes ['No
['Yes
❑Yes
❑ Yes
['Yes
[No
❑No
UNo
❑No

I Option 6 — Alkaline Stabilization
• Was the pH of the residuals raised to 12 or higher by the addition of alkali? f1Yes
• Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
[Yes
• Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? [Thies
• Was the pH corrected to 25°C (77°F)? I IYes
Option 7 — Drying of Stabilized Residuals
• Does the residuals contain any unstabilized residuals? 1 IYes
• Were the residuals mixed with any other materials? s'i o
• Were the residuals dried up to 75°70 total solids? es ❑No
II
11
11
No
No '
No
No
Option 8 — Drying of Unstabilized Residuals
• Were the residuals mixed with any other materials?
• Were the residuals dried to 90% total solids?
[hies
Yes
No
❑No
LIOption 9 — Injection
• Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
❑Yes 1_1 No
Yes I INo
E1Yes No
• Was injection done on pasture or hay field?
• Was injection done at time that crop was growing?
II
• If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? Yes ❑ No
4. General
• Was the report in the proper format?
• Was the annual report complete?
• Was the report submitted on time?
Pollutant
Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
Loading Rate
Below
Limit
Arsenic
75
'�% /
41
Cadmium
85
c/
�1500
39
(__---""
Copper
4300
Lead
840
300
Mercury
57
17
./
Molybdenum
75
N/A
J�
a/
Nickel
420
/
420
Selenium
100
V
'
/100
Zinc
7500✓/
2800
V
Pies I INo
®Yes ❑No
1LYes No

TCLP
Parameter
Belo{
rri
Parameter
Below
Licit
Parameter
Below
Li it
Arsenic (5.0)
RL
V
1,4-Dichlorobenzene (7.5)
t'
Nitrobenzene (2.0)
)
Barium (100.0)
✓
1,2-Dichloroethane (0.5)
V/
Pentachlorophenol (100.0) �✓
Benzene (0.5)
1,1-Dichloroethylene (0.7)
V
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
✓,
Selenium (5.0)
'✓
Carbon tetrachloride (0.5)
V
Endrin (0,02)
V
Silver (5.0)
Chlorodane (0.03)
✓
Hepatachlor (and its
epoxide) (0.008)
�/
Tetrachloroethylene (0.7)
/
Chlorobenzene (100.0)
c✓
Hexachlorobenzene (0.13)
*-/ ~
Toxaphene (0.5)
+V/
Chloroform (6.0)
1�
Hexachlorobutadiene (0.5)
✓
Trichloroethylene (0.5)
1/
Chromium (5.0)
Hexachloroethane (3.0)
✓
2,4,5-Trichlorophenol
(400.0)
�/
V1
v
m-Cresol (200.0)
, ✓
Lead (5.0)
I✓
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
�.!
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
✓
Mercury (0,2)
Vinyl Chloride (0.2)
Cresol (200.0)
1/
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl Ketone (200.0)
Residuals Analysis
Parameter
Analyzed For
Parameter
Analyzed For
Parameter
na zed For
Aluminum
n----
Mercury
'U
Potassium
Ammonia-
Nitrogen
Molybdenum
Selenium
V
Arsenic
k/
Nickel
✓/
Sodium
Cadmium
Nitrate-
Nitrite
Nitrogen
SAR
Calcium
1� 2
% TS t//
TKN
J
Copper
pH r V
Zinc
"1/
Lead
N/
Phosphorus ' ✓
Magnesium
✓
PAN