WQ0031314_Report of Non-Discharge DCAR Inspection_20210414

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
April 14, 2021
Ms. Courtney Driver — Utilities Director
Winston-Salem/Forsyth County Utilities Commission
P.O. Box 2511
Winston-Salem, North Carolina 27107
Subject: Compliance Evaluation Inspection
Swann WTP, Neilson WTP, and Thomas WTP
Distribution of Class A Water Treatment Plant Residuals
Permit No. WQ0031314
Forsyth County
Dear Ms. Driver:
On March 23, 2021 staff of the North Carolina Division of Water Resources (DWR) Winston-Salem
Regional Office performed a compliance inspection of the subject distribution of Class A water treatment
plant residuals program. This inspection was conducted by DWR staff member Jim Gonsiewski. Mr.
David O'Brien of EMA was present during this inspection. The inspection reflects compliance with the
permit.
Our office appreciates your diligence in properly maintaining your residuals distribution program. Please
refer to the enclosed inspection report for additional observations and comments. If you have any
questions regarding this letter, please contact me or Jim Gonsiewski at [phone] or via email at
[e-mail].
Sincerely,
EDocuSIgned by:
.—oA. T. 5M1tt•
145B49E225C94EA..
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
enc.: Compliance Inspection Report
cc: Bill Brewer — City of Winston-Salem (Electronic Copy)
David O'Brien - EMA (Electronic Copy)
Roy Whitaker — EMA (Electronic Copy)
Forsyth County Environmental Health (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
DE
O,pu4eMI01 G,.W no W UnF�
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit:WQ0031314 Effective: 11/18/20 Expiration: 08/31/27 Owner : Winston-Salem/Forsyth County Utilities
Commission
SOC: Effective: Expiration: Facility: Winston-Salem/Forsyth County Utilities Commi:
County: Forsyth
Region: Winston-Salem
Contact Person: William C Brewer
Directions to Facility:
Title: Phone: [phone]
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0079821 City of Winston-Salem - R.A. Thomas WTP
NC0086011 City of Winston-Salem - Neilson WTP
Inspection Date: 03/23/2021 Entry Time 10:05AM
Exit Time: 11:25AM
Primary Inspector: Jim J Gonsiewski Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Distribution of Residual Solids (503 Exempt)
Facility Status: • Compliant ❑ Not Compliant
Question Areas:
▪ Miscellaneous Questions
▪ Transport
(See attachment summary)
Sampling Land Application Site
Page 1 of 4

Permit: WQ0031314 Owner - Facility: Winston-Salem/Forsyth County Utilities Commission
Inspection Date: 03/23/2021
Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On March 23, 2021 staff of the North Carolina Division of Water•Resources Winston-Salem Regional Office (DWR) performed
an announced routine compliance inspection of the City of Eden's residuals land application program This inspection was
conducted by DWR staff member Jim Gonsiewski. Mr. David O'Brien of EMA was present during this inspection. The
inspection reflects compliance with the permit.
The application field was adjacent to the stockpile, was properly flagged and the buffers were maintained. One spreader and
one loader were operating at the site. .
Page 2 of 4

Permit: WQ0031314 Owner - Facility:Wnston-Salem/Forsyth County Utilities Commission
Inspection Date: 03/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Sampling
Describe sampling:
TCLP, Metals, Nutrients
Is sampling adequate?
Is sampling representative?
Comment:
Transport
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:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition'?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition'?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
111000
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑❑❑
❑ ❑•❑
❑ ❑■❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑❑■❑
❑ ❑ • ❑
❑ ❑■❑
❑ ❑•❑
❑ ❑•❑
❑ ❑•❑
❑ ❑ ❑•
❑ ❑ ❑•
Page 3 of 4

Permit: WO0031314 Owner - Facility: Winston-Salem/Forsyth County Utilities Commission
Inspection Date: 03/23/2021
Inspection Type : Compliance Evaluation Reason for Visit: Routine
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment:
■ ❑❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Page 4 of 4

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS A RESIDUALS DISTRIBUTION
General Information
Facility Name: Winston-Salem WrP County: Forsyth
Permit No.: WQ00 31314 Permit Issuance Date: 11/18/2020
Owner: City of Winston-Salem Permit Expiration Date: 6/31/2027
Plant ORC Name: Gabe Sparks Telephone No.: 336-727-8000
Other Contact(s): David O'Brien - EMA Telephone No.: 336-399-6684
Facility Location (address, gps or directions): WTP - 5725 Frye Bridge Road, Clemmons. Staging and application area was 1060
1060 Bombay Road, Denton.
Reason for Inspection
M ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
On site at 10 AM at the staging area for the residuals from the Neilson WTP at 1060 Bombay Road in Denton. The
excavation, transport and staging of the residuals was observed on 1/20/2021. The residuals were stored on
a large concrete pad at a former fabric facility. Met with David O'Brien, Operations Manager for EMA. One
operator was at the site. He was loading and spreading the residuals.
Observed the spreading of the residuals. There was one loader and one spreader (Kuhn - 610 cu ft capacity)
spreading. The fields were adjacent to the pad, so the spreader was loaded and was at the field (Field 2) within
5 minutes. The field was properly flagged and buffers were maintained. Left site at 11:25 AM.
Is a follow-up inspection necessary? ❑ Yes M No
Primary Inspector: Jim Gonsiewski Secondary Inspector:
Date of Inspection: 3/23/2021 Entry Time: 10:00 AM Exit Time: 11:25 PM

Non -Discharge Compliance Inspection Report
Record Keeping and Reporting Information:
Is current permit and prior annual reports available upon request?
Has the facility been free of public complaints for the last 12 months?
TCLP analysis conducted and results available? Frequency? ,ly a""" (See permit for frequency)
Residuals metals and nutrient analysis conducted? Frequency? _ (See permit for frequency)
Nutrient and metals loading calculations? (to determine most limiting parameter)
Do lab sheets support data reported on Residuals Analysis Summary?
Are distribution and/or hauling records available?
Utilization Agreements established or Recipient Notifications available for review?
Do the Utilization Agreements or Recipient Notifications contain minimum requirements?
(Restrictions for land application, stockpiling, setback buffers, etc.)
If the Permittee applies bulk residuals, are field loading records available?
If the Permittee applies bulk residuals, are field inspections conducted and are records available?
Does residuals package label or Utilization agreement contain minimum info required by permit?
(Name & address of generator, statement of restrictions, nutrient contents)
Is an inspection log available containing record of residuals facility inspections, maintenance,
and repairs?
❑❑®❑❑®®®®i
N NA NE
DOO
DOD
DOD
EDO
❑ ❑
O DE
❑ ❑ ❑
DMO
❑ ® ❑
DNO000
O DD
O DD
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative.
❑ Fecal Coliform density or ❑ Salmonella density to demonstrate pathogen requirements. Y N NA NE
Was sampling conducted at the permit required frequency? (See permit for frequency) DODO
Were multiple samples taken? DODD
If Fecal Coliform, density <1,000 MPN/gram of total solids? ❑ ODD
If Salmonella, density <3 MPN/4 grams of total solids? ❑ ❑ ❑ ❑
Select which treatment Alternative below was used to demonstrate Class A compliance.
❑ Alternative 1 - Time/Temperature (See White House Manual for specific requirements) Y N NA NE
Were residuals maintained for correct time and temperature? ❑ ❑ ❑ ❑
Are logs present showing time and temperature? DODO
Are temperatures within range for complete time period? ❑ ❑ ❑ ❑
❑ Alternative 2 - Alkaline Treatment
Are logs present showing time and temperature? ❑ DOD
Was the pH raised to 12 or greater and maintained for 72 hours or longer? ❑ 0 0 0
Was the temperature 52°C (126°F) for 12 hours or longer while the pH was 12 or greater? ❑ ❑ ❑ ❑
Are logs present showing time and pH? DODD
Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ ❑ ❑ ❑
❑ Alternative 5 - Process to Further Reduce Pathogens (PFRP) [Select the PFRP method below that was utilized]
❑ Composting, Select which method was used:
❑ Within -Vessel Method or Static Aerated Pile Method
Were residuals temperatures maintained at>55°C (131°F) for Y N NA NE
>3 consecutive days in the within -vessel or static aerated piles? ❑ ❑ ❑ ❑
❑ Windrow Composting Method
Were the residuals temperatures maintained at >55°C for at least
15 consecutive days in the windrow, and the windrow was turned a
minimum of five times during this time?
❑ ❑ ❑ ❑
❑ Heat Drying
Were the residuals dried by direct or indirect contact with hot gases and the 0 ❑ ❑ ❑
moisture content of residuals reduced to <10%?
Did the temperature of the residuals or the wet bulb temperature of the gas ❑ ❑ ❑ ❑
in contact with the residuals as the residuals leave the dryer exceed 80°C (176°F)?
❑ Other Alternative, Specify: (See White House Manual)
Page 2 of 4

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
0 Option 1 - 38% Volatile Solids Reduction
Are lab results and calculations present?
Was the reduction on volatile solids (not total solids)?
Were samples collected at correct locations?
(beginning of digestion process & before land application)
Was there a >38% reduction?
['Option 2 - 40-Day Bench Scale Test
Were residuals from anaerobic digestion?
Are lab results and calculations present?
Was the test anaerobically digested in lab, and 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%?
❑ Option 3 - 30-Day Bench Scale Test
Were residuals from aerobic digestion?
Are lab results and calculations present?
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%?
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test)
Were residuals form aerobic digestion?
Were residuals <2% 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 sampling holding time <2 hours?
Was the test started within 15 minutes of sampling or aeration maintained?
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? ❑ 0 0 0
Was the average residuals temperature higher than 45°C (113°F)? ❑ 0 0 0
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? ❑ ❑ ❑ 0
O Option 6 - Alkaline Stabilization Y N NA NE
Was the pH of the residuals raised to > 12 and maintained for two hours
without addition of more alkali? 0 0 0 ❑
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
without the addition of more alkali? ❑ 0 0 0
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? 0 0 0 ❑
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? ❑ 0 0 0
Were the residuals mixed with any other materials? If so, what? 0 0 ❑ 0
Were the residuals dried >75% total solids? ❑ ❑ 0 0
❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? OECD
Were the residuals dried >90% total solids? DODD
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4
Y N NA NE
❑ ❑ ❑ 0
❑ 0 0 0
DODO
O ❑ 0
l' N NA
O 0 0
O 0 ❑
O 0 0
❑ 0 0
❑ 0 ❑
❑ ❑ 0
Y N NA
❑ ❑ ❑
O ❑ ❑
O ❑ ❑
❑❑❑❑❑❑ - ❑❑❑❑❑
NE
0
0
NE
O ❑ ❑
❑ 0 ❑
O 0 0
O 0 0
O 0 0
N NA NE
0 0 0
O 0 0
❑ 0 0
O 0 0
O 0 0
O 0 0
O 0 0

Non -Discharge Compliance Inspection Report
Residuals Storage:
Describe storage: Concrete pad
Number of days/weeks/months of storage: 3 months
Residuals Sampling:
Is sampling adequate and representative?
Describe Sampling: TCLP, Nutrients, Metals
Transport Vehicle:
Is transport occurring at time of inspection?
Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed vehicte(s): PF 151
Application Site(s)
Were application site(s) inspected? If so, please complete info below. ® Yes
Is application occurring at the time of inspection? If no, note the date of the last event:
Weather Conditions:
❑ Sunny ❑ Partly Cloudy ® Cloudy ❑ Overcast
❑ Windy (wind direction: ) ❑ Breeze ® Calm
® No Precipitation ❑ Drizzle ❑ Rain ❑ Cloudburst
❑ No
❑ Stormy
Y N
NA NE
❑ ❑
Y N NA NE
❑ ❑ ❑
® ❑ ❑ ❑
® Yes ❑ No
(1f applicable, precipitation measurement:
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32 ❑ 32 — 40 ®40 — 60 ❑ 60 — 80 ❑ >80
Permit and Spill Plan onsite during application? ® Yes ❑ No
A ! lication Observations: T • e of a . s lication: Li . uid Cake > 15% total solids ■ Other
Site Owner(s): Frank Small #2
Intended Crop: Com
PAN Requirement:
Application Rate (tons or gallons/acre):
Nutrient Content:
Ibs/ac
Application occurring at time of visit: ® Yes ❑ No
Application Method: ® Surface ❑ Incorp/injection
Incorporation/Injection during visit: 0 Yes ❑ No ® N/A
Vegetative Buffer description: [None ®Grass ®Crop 0 Shrub 0
Tree ❑ Other
Current Field Conditions:
❑ Bare ® Stubble ❑ Planted (crop) 0 Pasture
Soil Condition:
® Dry ❑ Moist ❑ Wet 0 Saturated
❑ Not -Frozen 0 Frost ❑ Frozen 0 Snow -Covered
Slope: ®0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑ >18%
Odor: ® None ❑ Mild 0 Moderate ❑ Strong
x
Vectors: ® None ❑ Few ❑ Many ❑ Excessive
Application Details: Y N NA NE
Application areas clearly marked? ❑x ❑ ❑ ❑
Application within authorized area? ® 0 ❑ ❑
Application method appropriate? © ❑ ❑ ❑
Application is even (no ponding)? (] ❑ ❑ ❑
Sufficient setbacks from wells? OEIZO
Sufficient setbacks from surface waters? ID ❑ ❑ ❑
Slopes >10% avoided (Surface App.) ? ❑x ❑ ❑ ❑
Slopes >18% avoided (Incorp/Inject) ? ❑ ❑ (I ❑
Incorp./Injection within time -frame? 0 0 ® ❑
No evidence of shallow GW? (] ❑ ❑ ❑
Tracking is prevented? ® ❑ ❑ ❑
Biosolids run-off is prevented? ❑x ❑ ❑ ❑
Site Owner(s):
Intended Crop: PAN Requirement:
Application Rate (tons or gallons/acre):
Ibsiac
Nutrient Content:
Application occurring at time of visit: ❑ Yes ❑ No
Application Method: 0 Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ❑ N/A
Vegetative Buffer description: ❑None ['Grass ❑Crop ❑ Shrub ❑
Tree ❑ Other
Current Field Conditions:
❑ Bare ❑ Stubble 0 Planted (crop) ❑ Pasture
Soil Condition:
❑ Dry ❑ Moist ❑ Wet 0 Saturated
O Not -Frozen ❑ Frost ❑ Frozen 0 Snow -Covered
Slope: 0 0-3% ❑ 3-6% ❑ 6-10% ❑ 10-18% ❑>18%
Odor: 0 None 0 Mild ❑ Moderate ❑ Strong
Vectors: 0 None ❑ Few ❑ Many ❑ Excessive
Application Details: \ N NA NE
Application areas clearly marked? ❑ ❑ ❑ ❑
Application within authorized area? ❑ ❑ ❑ ❑
Application method appropriate? ❑ ❑ ❑ ❑
Application is even (no ponding)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells? ❑ ❑ ❑ ❑
Sufficient setbacks from surface waters? ❑ ❑ ❑ ❑
Slopes>10% avoided (Surface App.) ? ❑ ❑ ❑ ❑
Slopes>18% avoided (Incorp/Inject) ? ❑ ❑ ❑ ❑
Incorp./Injection within time -frame? ❑ ❑ ❑ ❑
No evidence of shallow GW? ❑ ❑ ❑ ❑
Tracking is prevented? ❑ ❑ ❑ ❑
Biosolidsrun-offis prevented? ❑ ❑ ❑ ❑
Page 4 of 4