WQ0029804_Annual Report Review_20230823

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
Winston Salem NC 27103
Contact Person: Bruce Michael Casey Title: Utilities Plant Supervisor Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 08/08/2023 Entry Time 01:OOPM
Primary Inspector: Jim J Gonsiewski
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 05:OOPM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Annual Report Review
Permit Inspection Type: Distribution 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: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 08/08/2023 Inspection Type: Annual Report Review Reason for Visit: Routine
Inspection Summary:
On August 8, 2023, Division of Water Resources staff Jim Gonsiewski completed a review of the 2022 Annual Report. This
review reflected compliance with the subject permit.
Observations:
• Residual sampling was completed monthly. TCLP was completed on 6/6/2022.
• 7853.62 dry tons of residual pellets were produced. 5628.46 dry tons of the residual pellets were hauled off for land
application.
Page 2 of 4

Permit: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 08/08/2023 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)?
❑
❑ ❑ ❑
Are PAN balances being maintained?
0
❑ ❑ ❑
Are PAN balances within permit limits?
❑
❑ ❑
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?
❑
❑ ❑
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: WQ0029804 Owner - Facility: City of Winston-Salem
Inspection Date: 08/08/2023 Inspection Type: Annual Report Review Reason for Visit: Routine
e. Time/Temp on: ❑ ❑ 0 ❑
Digester (MCRT) ❑
Compost ❑
Class A lime stabilization ❑
f. Volatile Solids Calculations 0 ❑ ❑ ❑
g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ E ❑
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: Heat treating
Sampling Yes No NA NE
Describe sampling:
TCLP, Metals and Nutirnts
Is sampling adequate? ❑ ❑ ❑ ❑
Is sampling representative? ❑ ❑ ❑ ❑
Comment:
Page 4 of 4

Annual Report Review Class A Distribution Permit No. WQOO 29804
Reporting Period: 2022
Permit Details:
• Is 503 ® OR 257 ❑
• Maximum Dry Tons Per Year: 12264
• Monitoring Frequency for TCLP: Annually
• Monitoring Frequency for Residuals Analysis: Variable
• Monitoring Frequency for Pathogen & Vector Attraction Reduction: Variable
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
• Was a certification form submitted? ®Yes ❑No
• Was distribution conducted during the reported period? ®Yes ❑No
• How many dry tons were produced and distributed? 7853.62
• Were the distributions with the permitted amount? Yes
• Were recipient's information listed? Yes
• Did it indicate compliance? ®Yes ❑No
• Was form complete? ®Yes ❑No
• Was it signed by the appropriate people? ®Yes ❑No
2. Monitoring
• Were the analyses conducted at the required frequency?
®Yes
❑No
• Was an analyses taken for each source that was distributed?
®Yes
❑No
• Were the metals analyses reported on the Residual Sampling Summary Form?
®Yes
❑No
• Were the results reported in mg/kg?
®Yes
❑No
• Were the pH's 6.0 or greater for each residual sample?
®Yes
❑No
• Were the heavy metals within ceiling concentration permit limits?
®Yes
❑No
o Were the lab analyses attached?
®Yes
❑No
• Were all the required parameters tested?
®Yes
❑No
• Was TCLP analysis conducted?
®Yes
❑No
• Were the TLCP contaminants within regulatory limits?
®Yes
❑No
• 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? ®Yes ❑No
• Did the form indicate the period of coverage, the residual class, and the pathogen reduction alternative
and the vector attraction reduction option used? ®Yes ❑No
• Was the appropriate documentation to show pathogen and vector attraction reduction included in the
report? ®Yes ❑No
• Was pathogen and vector attraction reduction demonstrated according to 40 CFR Part 503?®Yes❑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? ®Yes ❑No
Were multiple samples taken? ®Yes ❑No
Was each sample less than 1000 MPN/gram of total solids? ®Yes ❑No
OR
❑Salmonella density
Was the sampling conducted at the required frequency? ❑Yes ❑No
Were multiple samples taken? ❑Yes ❑No
Was each sample less than 3 MPN/4 grams of total solids? ❑Yes ❑No
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? ❑Yes ❑No
Were logs submitted showing time and temperature? ❑Yes ❑No
Were temperatures within range for complete time period? ❑Yes ❑No
❑Alternative 2 — Alkaline Treatment
Were logs submitted showing time and temperature? ❑Yes ❑No
Was the pH raised to 12 or greater and maintained for 72 hours or longer? ❑Yes ❑No
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater?
❑Yes ❑No
Were logs submitted showing time and pH? ❑Yes ❑No
Was the temperature corrected to 25°C (771F)? ❑Yes ❑No
Alternative 5 — Process To Further Reduce Pathogens
❑PFRP 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 ❑No
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 800C (1760F)? ❑Yes ❑No

Vector Attraction Reduction Review
• Was the sampling conducted at the required frequency?
®Yes ❑No
❑Option 1 — 38% Volatile Solids Reduction
Was there 38% reduction? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
Was the reduction on volatile solids (not total solids)? ❑Yes ❑No
Were the samples taken at beginning of digestion process and before application (Inspection)?
❑Yes ❑No
Were calculations correct? ❑Yes ❑No
❑Option 2 — 40-Day Bench Scale Test
Were residuals from anaerobically digested treatment (Inspection)? ❑Yes ❑No
Were residuals anaerobically digested in lab? ❑Yes ❑No
Was the test run for 40 days? ❑Yes ❑No
Was the test done between 300C (86°F) and 370C (990F)? ❑Yes ❑No
Was the reduction of on volatile solids (not total solids)? ❑Yes ❑No
Was the reduction less than 17%? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
Were calculations correct? ❑Yes ❑No
❑Option 3 — 30-Day Bench Scale Test
Were residuals from aerobically digested treatment (Inspection)? ❑Yes ❑No
Were residuals aerobically digested in lab? ❑Yes ❑No
Were residuals 2% or less total solids? ❑Yes ❑No
If not 2% total solids, was the test ran on a sample diluted to 2% with unchlorinated effluent?
❑Yes ❑No
Was the test run for 30 days? ❑Yes ❑No
Was the test done at 20°C (681F)? ❑Yes ❑No
Was the reduction of on volatile solids (not total solids)? ❑Yes ❑No
Was the reduction less than 15%? ❑Yes ❑No
Were lab sheets/calculations in report? ❑Yes ❑No
Were calculations correct? ❑Yes ❑No
❑Option 4 — Specific Oxygen Uptake Rate (SOUR)
Were residuals form aerobically digested treatment (Inspection)? ❑Yes ❑No
Were residuals 2% or less total solids (dry weight basis) (not diluted)? ❑Yes ❑No
Was the test done between 100C (50°F) and 30°C (861F)? ❑Yes ❑No
Was the temperature corrected to 200C (680F)? ❑Yes ❑No
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 ❑No
Was the sampling holding time two hours? ❑Yes ❑No
Was the test started within 15 minutes of sampling or aeration maintained? ❑Yes ❑No
❑Option 5 — 14-Day Aerobic Process
Were the residuals from aerobically digested treatment (Inspection)? ❑Yes ❑No
Were the residuals treated for 14 days? ❑Yes ❑No
Was the residuals temperature higher than 400C (104°F) for a 14-day period? ❑Yes ❑No
Was the average residuals temperature higher than 45°C (1130F)? ❑Yes ❑No

❑Option 6 — Alkaline Stabilization
Was the pH of the residuals raised to 12 or higher by the addition of alkali? ❑Yes ❑No
Did the pH of residuals remain at 12 or higher for two hours without the addition of more alkali?
❑Yes ❑No
Did the pH of residuals remain at 11.5 or higher for an additional twenty-two hours without the
addition of more alkali? ❑Yes ❑No
Was the pH corrected to 250C (770F)? ❑Yes ❑No
❑Option 7 — Drying of Stabilized Residuals
Does the residuals contain any unstabilized residuals? ❑Yes ®No
Were the residuals mixed with any other materials? ®Yes ❑No
Were the residuals dried up to 75% total solids? ®Yes ❑No
❑Option 8 — Drying of Unstabilized Residuals
Were the residuals mixed with any other materials? ❑Yes ❑No
Were the residuals dried to 90% total solids? ❑Yes ❑No
❑Option 9/10 — Injection/Incorporation
Was there any significant amount of residuals on land surface one hour after injection (Inspection)?
❑Yes ❑No
Was injection done on pasture or hay field? ❑Yes ❑No
Was injection done at time that crop was growing? ❑Yes ❑No
If Class A with respect to pathogen, were residuals injected with eight hours after discharge from
pathogen treatment? ❑Yes ❑No
Was incorporation done six hours after application (Inspection)? ❑Yes ❑No
4. General
• Was the report in the proper format? ®Yes ❑No
• Was the annual report complete? ®Yes ❑No
• Was the report submitted on time? ®Yes ❑No

Pollutant Limits
Pollutant
Ceiling
Concentration
Below
Limit
Cumulative
Pollutant
LoadingRate
Below
Limit
Arsenic
75
x
41
x
Cadmium
85
x
39
x
Copper
4300
x
1500
x
Lead
840
x
300
Mercury
57
x
17
x
Molybdenum
75
x
N/A
x
Nickel
420
x
420
x
Selenium
100
x
100
x
Zinc
7500
x
2800
x
TCLP
Parameter
Below
Limit
Parameter
Below
Limit
Parameter
Below
Limit
Arsenic 5.0
x
14-Dichlorobenzene 7.5
x
Nitrobenzene 2.0
x
Barium 100.0
x
1 2-Dichloroethane 0.5
x
Pentachloro phenol 100.0
x
Benzene 0.5
x
1,1-Dichloroeth lene 0.7
x
Pyridine 5.0
x
Cadmium 1.0
x
2 4-Dinitrotoluene 0.13
x
Selenium 5.0
x
Carbon tetrachloride 0.5
x
Endrin 0.02
x
Silver 5.0
x
Chlorodane (0.03)
X
Hepatachlor (and its
epoxide) 0.008
X
Tetrachloroethylene (0.7)
X
Chlorobenzene 100.0
x
Hexachlorobenzene 0.13
Toxa hene 0.5
Chloroform 6.0
x
Hexachlorobutadiene 0.5
x
Trichloroeth lene 0.5
x
Chromium (5.0)
X
Hexachloroethane (3.0)
X
2,4,5-Trichlorophenol
400.0
X
m-Cresol 200.0
x
Lead 5.0
x
2 4 6-Trichloro phenol 2.0
x
o-Cresol 200.0
x
Lindane 0.4
x
2,4,5-TP Silvex 1.0
x
-Cresol 200.0
x
Mercury 0.2
x
Vinyl Chloride 0.2
x
Cresol 200.0
x
Methox chlor 10.0
x
2,4-D 10.0
x
Methyl ethyl Ketone 200.0
x
Residuals Analysis
Parameter
Analyzed For
Parameter
Analyzed For
Parameter
Analyzed For
Aluminum
x
Mercury
x
Potassium
x
Ammonia-
Nitrogen
X
Molybdenum
X
Selenium
X
Arsenic
Nickel
x
Sodium
Cadmium
X
Nitrate-
Nitrite
Nitrogen
X
SAR
X
Calcium
x
% TS
x
TKN
x
Copper
x
pH
x
Zinc
x
Lead
x
Phosphorus
x
Magnesium
x
PAN
x

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
August 21, 2023
Ms. Courtney Driver - Utilities Director
Winston-Salem/Forsyth County Utilities Commission
Post Office Box 2511
Winston-Salem, North Carolina 27102
SUBJECT: 2022 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:
On August 8, 2023, Division of Water Resources staff Jim Gonsiewski completed a review of the 2022
Annual Report. This review reflected compliance with the subject permit.
Please refer to the enclosed inspection report for additional comments and observations. If you have any
questions concerning this letter, you may contact Ms. Caitlin Caudle or me at [phone].
Sincerely,
EcB]igned by:
Tt.J
M
di
59E25 EA
Lon T. nider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Inspection Report
cc: Forsyth County Environmental Health (Electronic Copy)
Mr. Keith Jones - Assistant Utility Plant Superintendent, City of Winston-Salem (Electronic Copy)
Mr. Mark Solan — Utilities Plant Supervisor — Dryer Facility, City of Winston-Salem (Electronic Copy)
Ms. Bonnie McKee — Utilities Plant Supervisor — Manson Meads Laboratory, City of Winston-Salem
(Electronic Copy)
Mr. Devin Shields — Waste Residuals Technician, City of Winston-Salem (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
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