WQ0021632_Additional Information Request_20220915

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
September 15, 2022
SHANE FLETCHER — RESIDUALS MANAGEMENT COORDINATOR
CITY OF BURLINGTON
POST OFFICE BOX 1358
BURLINGTON, NORTH CAROLINA 27216
Subject: Application No. WQ0021632
Additional Information Request
City of Burlington Class A
Residuals Program
Distribution of Class A Residuals
Alamance County
Dear Mr. Fletcher:
Division of Water Resources' Central and Regional staff has reviewed the application package
received June 27, 2022. However, additional information is required before the review may be completed.
Please address the items on the attached pages no later than the close of business on October 17, 2022.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through E, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with an
electronic response submitted to my attention at: https://edocs.deq.nc.�zov/Forms/NonDischarfze-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
�2GC%�d6Ki �Cd e;Gr�,G�
Erick Saunders, Engineer
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Robert "Nate" Roth — Synagro Central, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
oepammem of eammamemai uuahty /`� 919.707.9000

Mr. Shane Fletcher
September 15, 2022
Page 2 of 2
A. Cover Letter:
1. No comments.
B. Application Fee:
1. No comments.
C. Distribution of Class A Residuals (FORM: DCAR 06-16) Application:
1. The responses to application items III.4, and IV.3. through IV.6. all state "Source Specific" because
of the difference between the operating procedures for the composting program and the water
treatment plant distribution program. These items shall be addressed individually for each program
in an updated DCAR form.
2. Application item IV.2. is to be completed if residuals are to be mixed with other materials. The
composting program would meet this requirement. This item shall be completed in an updated
DCAR form.
D. Operation and Maintenance Plan (O&M Plan):
The submitted Operations and Maintenance Plan appears to only address the O&M relevant to the
land application of water treatment plant residuals by the land application contractor, describing
bulk land application activities of liquid residuals. This does not address O&M requirements for
the composting equipment and processes described in the cover page of the permit, which is
functionally a separate Class A program that is covered under this same permit. A separate O&M
Plan shall be provided for the composting program meeting the requirements of 15A NCAC 02T
.1110.
E. Residuals Source Certification (FORM: RSC 06-16) Form:
The RSC Summary form lists that the South Burlington WWTP (previously listed as the Southside
WWTP) is being renewed for 2,700 dry tons per year (DT/yr). The previous permit's Attachment
A stated that the maximum DT/yr from the Southside WWTP residuals generating facility was 450
DT/yr, while the maximum DT/yr of compost that can be distributed is 2,250 DT/yr. However, the
compost maximum DT/yr includes both the 450 DT/yr from the Southside WWTP and amendments
added in the composting process (i.e. there is 1,800 DT/yr of amendment material included in this
value). The RSC Summary form shall be updated to provide separate maximum DT/yr values for
the South Burlington WWTP residuals generating facility and compost to be distributed. If these
values exceed what was in the previous permit, a permit major modification shall be made with the
associated fee. Additionally, the quantitative justification shall be updated if needed based on any
changes.
2. On page 7 of 31 of the lab results from the American Testing Technologies' February 24, 2022
TCLP report, there is a pH result for the "# 1 Digester Land App" that is 12.75, which is considered
a corrosive hazardous waste under the Resource Conservation and Recovery Act (RCRA). Please
provide an updated sample of this residuals source generator material to verify that it is not a
hazardous waste.