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HomeMy WebLinkAboutWQ0031314_Compliance Evaluation Inspection Report_20221219ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality December 19, 2022 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 Distribution of Class A Water Treatment Plant Residuals Permit No. WQ0031314 Forsyth County Dear Ms. Driver: On November 22, 2022 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. Brent Collins 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 (336) 776-9800 or via email at j im.gonsiewski@ncdenr.gov. Sincerely, CDocuSlgned by; Loti -T. 5..44er 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) Christopher Triplett — City of Winston-Salem (Electronic Copy) Roy Whitaker - EMA (Electronic Copy) Brent Collins — EMA (Electronic Copy) Forsyth County Environmental Health (Electronic Copy) WSRO Electronic Files Laserfiche Files IHD_E� Deparlmert al EwtrmNry\ nnentnl pu North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 W. Hanes Mill Rd, 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: 336-727-8000 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: 11/22/2022 Entry Time 10:15AM Exit Time: 11.50AM Primary Inspector: Jim J Gonsiewski Phone: 336-776-9704 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Distribution of Residual Solids (503 Exempt) Facility Status: 111 Compliant ❑ Not Compliant Question Areas: II Miscellaneous Questions Sampling Land Application Site II Transport (See attachment summary) Page 1 of 4 Permit: WQ0031314 Owner - Facility:wnston-Salem/Forsyth County Utilities Commission Inspection Date: 11/22/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On November 22, 2022 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. Brent Collins of EMAwas present during this inspection. The inspection reflects compliance with the permit. The operations at the Swann WTP and the application field in Davie County were very well run. No spillage or tracking of residuals on roads was observed in either area. No ponding or runoff were observed in the application area. Page 2 of 4 Permit: WO0031314 Owner - Facility: Winston-Salem/Forsyth County Utilities Commission Inspection Date: 11/22/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Distribution and Marketing Land Application Sampling Describe sampling: Four residual samples were collected duting the application event. 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 0 • Yes No NA NE • ❑ ❑ ❑ •❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ MI ❑ ❑ ❑ Yes No NA NE ▪ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑❑❑ ❑ ❑ • ❑ ❑ ❑•❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑•❑ ❑ ❑■❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ U ❑ ❑ ❑•❑ ❑ 11100 ❑ ❑•❑ Page 3 of 4 Permit: WQ0031314 Owner - Facility: Winston-Salem/Forsyth County Utilities Commission Inspection Date: 11/22/2022 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: No public water in the area. ❑ ❑ ❑• • ❑ ❑ ❑ ▪ ❑ ❑ ❑ Page 4 of 4 Other Contact(s): Brent Collins - EMA Owner: City of Winston-Salem 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 VVTP County: Forsyth Permit No.: WQ00 31314 Permit Issuance Date: 11/18/2020 Permit Expiration Date: 813v2o27 Plant ORC Name: Christopher Triplett Telephone No.: 336-727-8000 Telephone No.: 336-399-3646 Facility Location (address, gps or directions): Swann WTP - 2800 River Ridge Road Pfafftown. Staging and application area was an agricultural field on Yadkin Valley Road in Davie County. Reason for Inspection ® ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other: Comments (attach additional pages as necessary) On site at 10:15 AM on 11/22/2022 at the staging area for the residuals from the Swann WTP at 2800 River Ridge Road in Pfafftown. The loading and transport of the residuals was observed. Met with Brent Collins of EMA and Christopher Triplett, Assistant Water Plant Superintendent. Mr. Triplett is also the acting operator in responsible charge (ORC) for the facility. One operator was operating the pump to Toad the 6,500 gallon tankers. According to Mr. Collins, four tankers were hauling that day. The residuals were liquid with a solids content of 3.2%. No tracking of the residuals was observed either at the loading point or on the roads leading off site. At 10:30 AM left the plant to travel to the application field. Arrived at the residual application field on Yadkin Valley Road in Davie County at 10:55 AM. Two tractors were pulling two spreader trailers. No tracking of residuals was observed on the roads in to and out of the field. Observed the loading of the trailers and the spreading of the residuals. The spreading was good with no ponding or runoff was observed. The buffers were maintained. Left site at 11:50 AM. Is a follow-up inspection necessary? ❑ Yes ® No Primary Inspector: Jim Gonsiewski Date of Inspection: 3/23/2021 Secondary Inspector: Entry Time: 10:15 AM Exit Time: 11:50 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? �i1 P t (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? (Nance & address of generator, statement of restrictions, nutrient contents) Is an inspection log available containing record of residuals facility inspections, maintenance, and repairs? ❑❑®❑❑®®®®� 183 N NA ❑ ❑ ❑ ❑ ❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ • Fl ❑ ❑ ❑ ❑ ❑ ❑ ❑ ® ❑ ❑ ❑ ❑ Pathogen and Vector Attraction Reduction Records Pathogen Reduction: Requires both pathogen density demonstration and Class A treatment alternative. ❑ Fecal Coliform density or El Salmonella density to demonstrate pathogen requirements. Was sampling conducted at the permit required frequency? (See permit for frequency) Were multiple samples taken? If Fecal Coliform, density <1,000 MPN/gram of total solids? If Salmonella, density <3 MPN/4 grams of total solids? ❑❑❑®®❑❑❑❑4 Y N NA NE ❑ ❑ ❑ ❑ O DOD D ❑ ❑ ❑ D ❑ ❑ ❑ 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? DODD Are logs present showing time and temperature? ❑ ❑ ❑ ❑ Are temperatures within range for complete time period? ❑ ❑ ❑ ❑ El Alternative 2 - Alkaline Treatment Are logs present showing time and temperature? ❑ ❑ ❑ ❑ Was the pH raised to 12 or greater and maintained for 72 hours or longer? ❑ ❑ ❑ El 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? ❑ ❑ ❑ ❑ Was the temperature corrected to 25°C (77°F) by calculation, NOT autocorrect? ❑ ❑ 0 ❑ ❑ 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? ❑ ❑ ❑ El ❑ 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 ❑ ❑ El 0 moisture content of residuals reduced to <10%? Did the temperature of the residuals or the wet bulb temperature of the gas ❑ 0 ❑ ❑ 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. ❑ Option 1 - 38% Volatile Solids Reduction Y N NA NE Are lab results and calculations present? DODO Was the reduction on volatile solids (not total solids)? DODO Were samples collected at correct locations? 0 ❑ 0 ❑ (beginning of digestion process & before land application) Was there a >38% reduction? ❑ ❑ ❑ ❑ ❑ Option 2 - 40-Day Bench Scale Test Y N NA NE Were residuals from anaerobic digestion? ❑ 0 ❑ 0 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)? ❑ ❑ ❑ 0 Was the reduction of on volatile solids (not total solids)? ❑ ❑ ❑ ❑ Was the reduction less than 1 7%? ❑ ❑ ❑ ❑ ❑ Option 3 - 30-Day Bench Scale Test Y N NA NE Were residuals from aerobic digestion? ❑ ❑ ❑ ❑ Are lab results and calculations present? ❑ ❑ ❑ ❑ Were residuals 2% or less total solids? ❑ ❑ ❑ 0 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) Y N NA NE Were residuals form aerobic digestion? ❑ DOD 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? ❑ ❑ ❑ 0 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)? ❑ ODE ❑ Option 5 - 14-Day Aerobic Process Y N NA NE Were the residuals from aerobic digestion? DODO Was the average residuals temperature higher than 45°C (113°F)? ❑ ❑ ❑ ❑ Were the residuals treated for 14 days and temperature maintained higher than 40°C (104°F) for the 14-day period? DODO ❑ 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? DODD Did the pH of residuals remain at > 11.5 an additional twenty-two hours without the addition of more alkali? ❑ ❑ ❑ ❑ Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DODO ❑ Option 7 - Drying of Stabilized Residuals Y N NA NE The residuals do not contain unstabilized residuals? ❑ ❑ ❑ ❑ Were the residuals mixed with any other materials? Ifso, what? ❑ ❑ ❑ ❑ Were the residuals dried >75% total solids? ❑ ❑ ❑ ❑ ❑ Option 8 - Drying of Unstabilized Residuals Y N NA NE Were the residuals mixed with any other materials? ❑ ❑ ❑ ❑ Were the residuals dried >90% total solids? ❑ ❑ ❑ ❑ ❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual) Page 3 of 4 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: Nutrients, Metals Y N NA NE ® ❑ ❑ ❑ Transport Vehicle: Y N Is transport occurring at time of inspection? ® ❑ Are necessary records (i. tRE 60 it & Rill plan) present in vehicle? ID of observed vehicle(s): ® ❑ Trucklranker nu bars: 003l120, 6171 6, 609/140, 6 /125. Application Site(s) Were application site(s) inspected? If so, please complete info below. ® Yes ❑ No Is application occurring at the time of inspection? If no, note the date of the last event: Weather Conditions: ❑ Sunny ® Partly Cloudy ❑ Windy (wind direction: _ ) ® No Precipitation ❑ Drizzle ❑ Cloudy ® Breeze ❑ Rain ❑ Overcast ❑ Calm ❑ Cloudburst ❑ Stormy NA ® Yes ❑ No (If applicable, precipitation measurement: NE Weather Notes (i.e. Significant Changes, Forecasts, etc): Temp. (° F): ❑ <32 ❑ 32 — 40 ® 40 — 60 ❑ 60 — 80 Permit and Spill Plan onsite during application? ® Yes ❑ No ❑ >80 Application Observations: [Type of application: ® Liquid ❑ Cake (> 15% total solids) ❑ Other Site Owner(s): Forrest Breedove Intended Crop: Corn, Hay PAN Requirement: Application Rate (tons or gallons/acre): 13000 9e11 ecre (9mu)_. 19,500 crop Nutrient Content: 26 Ibs/6,500 gallons Ibslac Application occurring at time of visit: IN Yes El No Application Method: ® Surface ❑ Incorp/Injection Incorporation/Injection during visit: ❑ Yes 0 No ® N/A Vegetative Buffer description: ❑None ®Grass (g3Crop 0 Shrub tgi Tree ❑ Other Current Field Conditions: 0 Bare ® Stubble ❑ Planted (croo) ❑ Pasture Soil Condition: ® Dry 0 Moist ❑ Wet 0 Saturated 0 Not -Frozen 0 Frost 0 Frozen ❑ Snow -Covered Slope: IN 0-3% ❑ 3-6% 0 6-10% 0 I0-18% ❑ >18% Odor: ® None ❑ Mild 0 Moderate ❑ Strong Vectors: ® None ❑ Few 0 Many ❑ Excessive Application Details: 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? Biosolids run-off is prevented? Y N NA NE ROOD ® ❑ ❑ ❑ EDDO a❑❑❑ 1 ❑ ❑ ❑ ❑x ❑ ❑ ❑ ❑x ❑ ❑ O ❑ ❑a❑ O 0000000 ® ❑ ❑ ❑ O 000 Site Owner(s): Intended Crop: PAN Requirement: Ibslac Application Rate (tons or gallons/acre): Nutrient Content: Application occurring at time of visit: 0 Yes 0 No Application Method: ❑ Surface ❑ Incorp/Injection Incorporation/Injection during visit: 0 Yes 0 No 0 N/A Vegetative Buffer description: ['None ❑Grass ❑Crop ❑ Shrub ❑ Tree 0 Other Current Field Conditions: 0 Bare ❑ Stubble ❑ Planted cro Soil Condition: ❑ Dry 0 Moist 0 Wet ❑ Saturated 0 Not -Frozen ❑ Frost ❑ Frozen 0 Snow -Covered Slope: ❑ 0-3% ❑ 3-6% 0 6-10% 0 10-18% ❑ >18% Odor: 0 None 0 Mild ❑ Moderate ❑ Strong 0 Pasture Vectors: ❑ None 0 Few 0 Many 0 Excessive Application Details: 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? Biosolids run-off is prevented? Y N NA NE O 000 O 000 O 000 O 000 O 000 0000 O 000 O 000 O 000 O 000 O 000 O 000 Page 4 of 4