WQ0031314_Report of Review of Annual Report_20210701

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 1, 2021
Mr. Bill Brewer
Winston-Salem/Forsyth County Utilities Commission
Post Office Box 2511
Winston-Salem, North Carolina 27102
SUBJECT: 2020 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 2020 Annual Report for the
subject permit. A review of this report conducted by DWR staff person Jim Gonsiewski reflects
compliance with Permit Number WQ0031314.
If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski
at [phone] or via email at jim.gonsiewski(a,ncdenr.gov.
Sincerely,
DoeuSIgned by:
0D2D3CE3F1B7458...
Jennifer F. Graznak
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
encl: Compliance Inspection Report
cc: Forsyth County Environmental Health (Electronic Copy)
Courtney Driver — City of Winston-Salem (Electronic Copy)
WSRO Electronic Files
Laserfiche Files
oepnr,rin . bnGw.n.mr OW
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West !lanes Mill Road, Suite 3001 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
NC0086011
City of Winston-Salem - R.A. Thomas WTP
City of Winston-Salem - Neilson WTP
Inspection Date: 07/01/2021
Entry Time 08:OOAM Exit Time: 02:OOPM
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: 1.1 Compliant Not Compliant
Question Areas:
II Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0031314 Owner - Facility: Winston-Salem/Forsyth County Utilities Commission
Inspection Date: 07/01/2021
Inspection Type : Annual Report Review Reason for Visit: Routine
Inspection Summary:
The Division of Water Resources (DWR) received the 2020 Annual Report for the subject permit. A review of this report
conducted by DWR staff person Jim Gonsiewski reflects compliance with Permit Number W00031314.
Atotal of 207.05 dry tons of residuals from the Swann WTP and 338.8 dry tons of residuals from the Neilson WTP were land
applied in 2020. 316.31 dry tons of residuals were hauled from the Thomas WTP to the Hanes Mill Road Landfill.
pH in the four residual samples from the Neilson WTP was detected at levels from 5.5 to 5.8. Residual pH from this facility
should be monitored closely in future sampling and application events.
Page 2 of 3

Permit: WQ0031314
Owner - Facility: Winston-Salem/Forsyth County Utilities Commission
Inspection Date: 07/01/2021 Inspection Type : Annual Report Review
Reason for Visit: Routine
Page 3 of 3

Annual Report Review Class A Distribution
Reporting Period D
Permit Details: \A) c3z. 00 }�
•Is503.
• Class or�?
• Maximum Dry Tons Per Year:t1 00 0 CAW a nh � ) U ;e1Sr,,n Q.S'�? © cx-Nus -- `�7 0\
• Number of acres permitted:..... )
• Number of fields in permit:
• Counties that land is permitted for: �--•
Monitoring Frequency for TCLP: b h tz r ckA, c.} P
- Monitoring Frequency for Residuals Analysis: 9 u_a f`•-&-c,1,c_
• Monitoring Frequency for Pathogen & Vector Attraction Re
ction c'Z. IF:-L"( .p,(m�;
1. Class A Annual Distribution and Marketing/Surface Disposal Certification Form
- Was a certification form submitted? \'ct�
- Was distribution conducted during the reported period?
- How many dry tons were produced and distributed? cony-.
- Were the distributions with the permitte amount?
• Were recipients information listed? ! 2 S
• Did it indicate compliance? 'f 3 -�
• Was form complete t S
- Was it signed by the appropriate people? / • s
2. Monitoring
• Were the analyses conducted at the required frequency?
Was an analyses taken for each source that was distributed? `/ems
• Were the metals analyses reported on the Residual Sampling Summary Form?�-e
• Were the results reported in mg/kg? Viz S-
• Were the pH's 6.0 or greater for each residual sample? iJ cD ,'� g
• Were the heavy metals within ceiling concentration permit limits? �e s '
Were the lab analyses attached?kS •
• Were all the required parameters tested?‘14-S
• Was TCLP analysis conducted? Y ' --,Gr-SuJct
• Were the TLCP contaminants within regulatory limits?
• Was a corrosivity, ignitability, and reactivity analysis conducted?y
3. Pathog and Vector Attraction Reduction
• Was a signe opy of the Pathogen and Vector Attraction Reduction Form submitted?
• Did the form in ate the period of coverage, the residual class, and the pathogen reduction
alternative and the ve attraction reduction option used?
Was the appropriate docu ntation to show pathogen and vector attraction reduction included
in the report?
• Was pathogen and vector attractio eduction demonstrated according to 40 CFR Part 503?
JJ;
is
Class A Pathogen Review
To be Class A, residuals shall meet either feeal 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:
AIternative 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 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 (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 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 (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?
• 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?
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? IDS
• Was the annual report complete? yea.s-
• Was the report submitted on time?`ye
S