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HomeMy WebLinkAboutWQ0021632_More Information Received_20221006Initial Review Reviewer Thornburg, Nathaniel D Is this submittal an application? (Excluding additional information.) * Yes No If not an application what is the submittal type?* Annual Report Residual Annual Report Additional Information Other Permit Number (IR) * WQ0021632 Applicant/Permittee City of Burlington Email Notifications ............................................................................... Does this need review by the hydrogeologist? * Yes No Regional Office CO Reviewer Admin Reviewer Submittal Form Project Contact Information Please provide information on the person to be contacted by NDB Staff regarding electronic submittal, confirmation of receipt, and other correspondence. ............................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................................ Name* Robert Roth Email Address* rroth@synagro.com Project Information Application/Document Type* New (Fee Required) Modification - Major (Fee Required) Renewal with Major Modification (Fee Required) Annual Report Additional Information Other Phone Number* 13364034324 Modification - Minor Renewal GW-59, NDMR, NDMLR, NDAR-1, N DAR-2 Residual Annual Report Change of Ownership We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form. hftps://edocs.deq.nc.gov/Forms/NonDischarge_Monitoring_Report Perm it Type:* Wastewater Irrigation High -Rate Infiltration Other Wastewater Reclaimed Water Closed -Loop Recycle Residuals Single -Family Residence Wastewater Other Irrigation Permit Number: * WQ0021632 Has Current Existing permit number Applicant/Permittee Address* PO Box 1358 Burlington NC 27216 Facility Name* City of Burlington Class A Residuals Program Please provide comments/notes on your current submittal below. At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg at nathaniel.thornburg@ncdenr.gov. Please attach all information required or requested for this submittal to be reviewed here. (Application Form, Engineering Plans, Specifications, Calculations, Etc.) W00021632 Add Info 10_6_22.pdf 2.78MB Upload only 1 PDF document (less than 250 MB). Multiple documents must be combined into one PDF file unless file is larger than upload limit. * By checking this box, I acknowledge that I understand the application will not be accepted for pre -review until the fee (if required) has been received by the Non - Discharge Branch. Application fees must be submitted by check or money order and made payable to the North Carolina Department of Environmental Quality (NCDEQ). I also confirm that the uploaded document is a single PDF with all parts of the application in correct order (as specified by the application). Mail payment to: NCDEQ — Division of Water Resources Attn: Non -Discharge Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Signature R RA;0 Submission Date 10/6/2022 October 5, 2022 NCDENR-DEQ Division of Water Resources Land Application Permitting and Compliance Unit Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 ATTENTION: Mr. Erick Saunders REFERENCE: Application No. WQ0021632 Additional Information Request City of Burlington DCAR Alamance County Dear Mr. Saunders: On behalf of the City of Burlington, please see a response to the additional information th request received September 15, 2022, below. Each item is listed in chronological order just as stated in the additional information request. C. Distribution of Class A Materials Form DCAR 06-16: 1. As requested, each item listed has been addressed and updated in the attached DCAR form. Additionally, a more in depth narrative specific to the composting operation is also attached. 2. As requested, this item has been addressed and updated in the attached DCAR form. This update reflects the currently permitted operations with respect to tonnages. Also a slightly amended quantitative justification is provided. D. Operations and Maintenance Plan (O&M Plan): 1. An operations and maintenance plan specific to the composting operations is now attached to this letter. E. Residuals Source CertificationRSC 06-16 RSC: 1. It is not intended that any changes will be made to the currently permitted tonnages. An updated RSC summary form is attached. 2. A combination of analyticaldata was used to complete the RSC form for South Burlington. The initially submitted form was correct and used the attached analytics. Additionally, the initially submitted TCLP included all materials generated by the City of Burlington. It was intended that Pages 14 through 19 of 31 of the TCLP data be 284 Boger Road, Mocksville, NC 27028 Phone: (336) 790-1610 used concerning mostof therequired TCLP constituents. Thesample ID for this material is “SBWWTP Cake”. The questionaround apH of 12.75wasaresult of material being lime stabilized at the East Burlington WWTP. Lastly, another copy of the TCLP data is attached to this letter. Lastly, it is requested that each source be named just as stated on the attached RSC summary form. If you require additional information or have further questions, please contact me at (336)403-4324 or rroth@synagro.com. Thank you in advance for the timely and efficient review of this modificationapplication. Sincerely, 284 Boger Road, Mocksville, NC 27028Phone:(336) 790-1610 State of North Carolina Department of Environmental Quality Division of Water Resources 15A NCAC 02T .1100 – DISTRIBUTIONOF CLASS A RESIDUALS INSTRUCTIONS FOR FORM: DCAR 06-16 & SUPPORTING DOCUMENTATION dPleaseuse the following instructions as a checklist in order to ensure all required items are submitted. Adherence to these instructions and checking the provided boxes will help produce a quicker review time and reduce the amount of additional informationrequested. Failure to submit all of the required items will lead to additional processing and review time for the permit application. Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation For more information, visit the Water Quality Permitting Section’s Non-Discharge Permitting Unit website General – Thisapplication is for treatment, storage, transport, distribution, land application, and/or marketing of Class A (or Equivalent) . residualsunder 15A NCAC 02T .1100 Unless otherwise noted, the Applicant shall submit one original and two copies of the application and supporting documentation listed below. A.Distribution of Class A Residuals (FORM: DCAR 06-16): Submit the completed and appropriately executedDistribution of Class A Residuals(FORM: DCAR 06-16) form. Please do not make any unauthorized content changes to this form. If necessary for clarity or due to space restrictions, attachments to the application may be made, as long as the attachments are numbered to correspond to the section and item to which they refer. The project name should be consistent on the plans, specifications, etc. The Applicant’s Certification on Page 3 ofthis formshallbe signed in accordance with 15A NCAC 02T .0106(b). An alternate person may be designated as the signing official if a delegation letter is provided from a person who meets the criteria in 15A NCAC 02T .0106(b). If this project is for a modification of an existing permit, submit one copy of the existing permit. Please submit this application form at least 180 days prior to the expiration date on the existing permit, or 90 days prior to operation of proposed facility(ies) for application packages involving new or changes to treatment and storage units. B.Application Fee (New and Major Modification Application Packages) Submit a check, money order or electronic funds transfer made payable to: North Carolina Department of Environmental Quality(NCDEQ). 1 Facility ClassificationNew PermitMajor Modification Major (residuals permitted for distribution ,000 dry tons/year) $1,310$395 Minor (residuals permitted for distribution < 3,000 dry tons/year) $810$245 1 - A major modification shall be defined as any permit modification that: increases the generating facility’sresiduals dry tonnage; adds additional residuals sources; or includes the addition of new treatment or storage units/processes not previously permitted. There is no fee for minor permit modifications. C.Cover Letter (All Application Packages) List all items included in the application package, as well as a brief description of the requested permitting action. INSTRUCTIONS FOR FORM: DCAR 06-16Page 1 of 3 D. Program Information (All Application Packages) Provide a narrative explaining the following: How the materials will be handled and transported from where the residuals were produced to where it will be treated. How the residuals will be processed/treated (attach process flow diagram). How leachate collection will be handled. Where the residuals will be stored until processed. How the final product will be distributed (packaging, bulk, etc.) What nutrients or other constituents(i.e. nitrogen, phosphorous, aluminum, calcium, etc.) are usedor recommendedas the limiting parameter for determination of residuals loading rate to ensure that it does not overload the soil and cause contravention of surface water or groundwater standards, limit crop growth, or adversely impact soil quality. Attach a marketability statement detailing destinations and approximate amounts of the final product to be distributed. Provide either a label that shall be affixed to the bagged processed residual or an information sheet that shall be provided to the person who receives the processed residual. The label or information sheet shall contain, at a minimum, the following information: Name and address of the person who prepared the residual that is sold or given away. A statement that application of the residuals to the land shall be in accordance with the instructions on the label or information sheet. A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-covered. A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored residuals into any surface waters. Information on all applicable setbacks in accordance with 15A NCAC 02T .1108(b). A statement that the residuals shall be applied at agronomic or recommended rates for intended uses. E. Detailed Plans and Specifications (Application Involving New or Changes to Treatment or Storage Units) Submit detailed plans and specifications that have been signed, sealed, and dated by a NC Professional Engineer per 15A NCAC 02T .1104(a). Specifications for standard equipment may only be omitted for municipalities with approved standard specifications, but use of the standard specifications must be noted on each sheet of the plans. Plans must include the following minimum items: a general location map, a topographic map, plan and profile view of the residuals treatment and storage units as well as the proximity of the residuals treatment and storage units to other utilities and natural features within 500 feet of all treatment and storage facilities, and detail drawings of all items pertinent to the residuals treatment and storage units. Depict minimum separations required in 15A NCAC 02T .1108(a) on the plans. Specifications must include, at a minimum, the following for all items pertinent to residuals treatment and storage units: description of materials to be used, methods of construction, quality of construction testing procedures to ensure the integrity of the final product in accordance with 15A NCAC 02T .1104(a)(2)(B), including leakage and pressure testing as appropriate. Plans and specifications must not be labeled with preliminary phrases (e.g., FOR REVIEW ONLY, NOT FOR CONSTRUCTION, etc.) that indicate that they are anything other than final plans and specifications. However, the plans and specifications may be labeled with the phrase: FINAL DESIGN – NOT RELEASED FOR CONSTRUCTION. F. Engineering Calculations (Application Involving New or Changes to Treatment or Storage Units) Submit all design calculations that have been signed, sealed, and dated by a NC Professional Engineer per 15A NCAC 02T .1104(a). G. Environmental Assessments (May be Required – See 15A NCAC 1C .0300) Submit a copy of the Findings of No Significant Impact (FONSI) or Environmental Impact Statement (EIS). Also, include information on any mitigating factor(s) from the Environmental Assessment (EA) that impact the construction of the residuals treatment and storage facilities. An EA may also be required for private systems if any public funds and/or lands are used for the construction of the subject facilities. INSTRUCTIONS FOR FORM: DCAR 06-16 Page 2 of 3 H. Operation and Maintenance Plan (New and Renewal Application Packages) For Modification Application, if there are any changes to the existing plan, submit an updated O&M plan. Submit the O&M Plan in accordance with 15A NCAC 02T .1110 and include at a minimum: Operational functions; describe the operation of the program to show what operations are necessary for the program to function and by whom the functions are to be conducted. Maintenance schedules; may include equipments calibration, maintenance of signs, etc. Safety measures; may include safety training program, manuals, signs, etc. Spill response plan; including control, containment, remediation, emergency contact information, etc. Inspection plan including the following information; Names and titles of personnel responsible for conducting the inspections. Frequency and location of inspections, including those to be conducted by the ORC, and procedures to assure that the selected location(s) and inspection frequency are representative of the residuals management program. Detailed description of inspection procedures including record keeping and actions to be taken by the inspector in the event that noncompliance is observed. Sampling and monitoring plan including the following information; Names and titles of personnel responsible for conducting the sampling and monitoring. Detailed description of monitoring procedures including parameters to be monitored. Sampling frequency and procedures to assure that representative samples are being collected. Fluctuation in temperature, flow, and other operating conditions can affect the quality of the residuals gathered during a particular sampling event. The sampling plan shall account for any foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to meet pathogen and vector attraction reduction requirements (e.g. facilities that land apply multiple times per year but have an annual sampling frequency, may need to sample during winter months when pathogen reduction is most likely to be negatively affected by cold temperatures. ONE ORIGINAL AND TWO COPIES OF THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION AND MATERIALS, SHALL BE SENT TO THE FOLLOWING ADDRESS: NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES WATER QUALITY PERMITTING SECTION NON-DISCHARGE PERMITTING UNIT By U.S. Postal Service:By Courier/Special Delivery: 1617 MAIL SERVICE CENTER 512 N. SALISBURY STREET RALEIGH, NORTH CAROLINA 27699-1617 RALEIGH, NORTH CAROLINA 27604 TELEPHONE NUMBER: (919) 807-6464FAX NUMBER: (919) 807-6496 INSTRUCTIONS FOR FORM: DCAR 06-16 Page 3 of 3 State of North Carolina Department of Environmental Quality Division of Water Resources 15A NCAC 02T .1100 – DISTRIBUTIONOF CLASS A RESIDUALS FORM: DCAR 06-16 I. APPLICANT INFORMATION: 1.Applicant's name: City of Burlington Applicant type: Individual Corporation General PartnershipPrivately-Owned Public Utility Federal State Municipal County Signature authority’s name per 15A NCAC 02T .0106: Shane Fletcher Title: Residuals Management Coordinator Applicant’s mailing address: PO Box 1358 City: Burlington State: NC Zip: 27216- Telephone number: (336) 570-6138Email Address: sfletcher@burlingtonnc.gov 2.Consultant’s name: N/ALicense Number(for P.E.): Affiliation: On StaffRetained (Firm: ) Consultant’s mailing address: City: State: Zip: - Telephone number: ( ) - Email Address: 3.Fee submitted: N/A (SeeInstruction B) II.PERMIT INFORMATION: 1.Application is for (check all that apply):new, modified, renewed permit 2.If this application is being submitted to renew or modify an existing permit, provide the following: Permit number: WQ0021632 Date of most-recently issued permit: 8/18/2017 Date of most-recently certified Attachment A (if different than the permit): N/A III.FACILITY INFORMATION: 1.Name of residuals processing facility: Source Specific City: State: Zip: - Coordinates: Latitude: Longitude: Datum: Level of accuracy: Method of measurement: County where facility is located: 2.Facility contact (person familiar with residuals preparation): Name: Shane Fletcher Title: Residuals Management Coordinator Mailing address:PO Box 1358 City: Burlington State: NCZip: 27216- Telephone number: (336) 570-6138E-mail address: sfletcher@burlingtonnc.gov FORM: DCAR 06-16Page 1 of 3 3.Is the residual process facility also the generator? Yes; No If No, please specify delivery frequency and quantity of residual to be processed: Source Specific 4.Length of residuals storage at facility: Mackintosh WTP: 365 Days, SouthWWTP:60days (Note: the Division requires minimum30 days storage in units that are separate from treatment system, i.e. not in clarifiers, aeration basins, etc.)Mackintosh IV.RESIDUALS QUALITY INFORMATION: 1.Specify how these residuals will be distributed: sold or given away in bags or other containers; lawn (bulk); home garden (bulk); other(explain); WTP material is land applied by contractor, WWTPcompostmaterial sold/given awayin bulk Note: Bulk residuals shall mean residuals that are transported and not sold or giving away ina bag or other receptacles with a load capacity of one metric ton or less. 2.Complete the following if residuals are to be mixed with other materials: Amounts to be added Type of Materials per 1.0 dry ton of residuals (dry ton) Woodchips and leaves4 tons 3.Approximate amounts of the residuals received and processed at the facility: South WWTP: dry tons per year: 450 dry tons 4.Approximate amounts of the finalproduct(processed residuals) to be distributed: South WWTP:dry tons per year: 2250 dry tons 5.Provide a description of the onsite storage management plan for the treated residuals (including estimated average and maximum storage times prior to distribution): See narrative 6.Does the facility have a stormwater management plan? X Yes; No Explainwhether the treatment and storage areas are under roof or how stormwater runoff will be handled: South WWTP composting facility is under roof with approximately squarefeetof processing/storageavailable. Additionally approximately an uncovered asphalt pad is available for further processing and storage. Any stormwater from this pad is captured via storm drains and isprocessed within the South WWTP. V.RESIDUALS SOURCE INFORMATION: (Required for all new, renewed, or modified residuals source) Complete and submitthe attached Residuals Source Certification and all associated documentation. RSC 06-16.doc FORM: DCAR 06-16Page 2 of 3 Introduction In 1999, the Burlington City council agreed to allocate funds to construct a small-scale compost facility at the South Burlington WWTP capable of processing 5.5 dry tons of biosolids per day. Although the compost facility would not be large enough to compost 100% of the daily sludge production of the wastewater plant, it would be large enough to answer some important questions such as: 1. Could the City produce a quality and compliant compost at a reasonable cost? 2. Is the local demand for compost enough to warrant an expansion of the compost operations? 3. How will the cost of processing compost to a Class A residual compare to the cost of hauling Class B sludge from year-to-year? Construction on the compost facility began in 2001 and the first sludge was dewatered in 2002. The compost facility operated in a ‘test’ mode in the time between the completion of construction and the time the permit to operate a compost facility was received from the NC Department of Environment and Natural Resources in September of 2003. This annual report has been assembled as a condition of the Distribution of Residual Solids ( 2T ) Permit, #WQ0021632. I. DESIGN CRITERIA Design Flow: 5.5 dry tons feed sludge per day Equipment Description: NumberEquipmentPurpose 2 Grinder pumps Transfer residuals from existing storage tanks 1 2-meter belt press Dewater feed sludge to 16% – 20% solids nd 1Berth for 2 2-meter belt press (future) - 2 - 1 Conveyor Transfer dewatered sludge to mixing area 2 1 25,500 ftOpen area Storing amendment material 2 1 1,710 ftCovered area Blending dewatered residuals and amendment material 2 1 1,875 ftCovered areaStoring amendment material 1 Agricultural Feed Mixer Blending dewatered residuals and amendment material 2 Covered area Composting blended residuals/amendment material 1 35,700 ft 11 5-Horsepower blowers Aerating static piles (Maximum of 22 static piles) 3 1 153 yd Trammel screen Screening composted product and recovery of amendment 2 1 15,000 ftOpen area Final curing and maturation and storage of Class A product 2 1 900 ft biofilter Capture and treat odor-generating compounds in the facility 2 1 4,900 ft biofilter Capture and treat odor-generating compounds in the facility 1 Polymer Feed System Assist with the dewatering of residuals II. PROCESS DESCRIPTION The goal of the Compogro compost facility is to consistently produce a Class A EQ material that is suitable for a variety of uses on land that has no post-application restrictions. Class A residuals have the greatest degree of pathogen reduction and are considered to be very safe. All domestic residuals which are to be distributed to the public for use for landscaping must meet one of the alternatives for Class A pathogen reduction found in 40 CFR Part 503.30. Class A pathogen reduction must meet one of the following criteria: 1.A fecal coliform density must be less than 1,000 MPN (most probable number) per gram of total solids (dry weight) OR 2. A Salmonella sp. bacteria must be less than 3 MPN per 4 grams of total solids (dry weight) https://synagro-my.sharepoint.com/personal/rroth_synagro_com/Documents/Desktop/NC/Burlington/2022 Burlington Class A Renewal/Add Info Req/In depth Compost Facility Narrative.doc - 3 - The City of Burlington has selected the former criteria (fecal coliform <1,000 MPN) as the preferred method to determine compliance with the pathogen reduction requirements. This is achieved by following the time and temperature guidelines in 40 CFR 503. In addition to the pathogen reduction requirements, Compogro must also meet all of the Vector Attraction Reduction (VAR) requirements of Class A residuals. All domestic residuals which are to be distributed to the public for landscaping must meet one of the alternatives for vector attraction reduction listed in 40 CFR 503.33. The City achieves compliance by following the time and temperature guidelines provided by the USEPA. The City of Burlington Compogro Compost facility has developed a system for building aerated piles and collecting and recording data necessary to ensure that all the requirements of Class A compost are being achieved. III. RECORDKEEPING PROCEDURES A record of the aerated static pile temperatures is enclosed to demonstrate that the piles meet the required temperatures for the designated time to achieve pathogen reduction and vector attraction reduction. The document is titled Compost Pile Temperature’s. Aerated static piles are assigned an identifying number that establishes the date that the pile was built, and the blower that was used to aerate the pile. The format is year, month, day, and blower number. For example, the number 030109-07 would indicate that the pile was started on January 9, 2003 and was aerated using blower 7. Each pile is monitored for temperature with at least four thermometers. We are satisfying the 40 CFR 503 pathogen reduction requirements by keeping the compost above 131 degrees F for three (3) https://synagro-my.sharepoint.com/personal/rroth_synagro_com/Documents/Desktop/NC/Burlington/2022 Burlington Class A Renewal/Add Info Req/In depth Compost Facility Narrative.doc - 4 - consecutive days (72 hours minimum). We are satisfying the 40 CFR 503 vector attraction reduction requirements by keeping the compost above 104 degrees F and an average of greater than 113 degrees F for a minimum of fourteen (14) consecutive days. In reviewing these logs you will see that we are maintaining the aerated static piles for longer than 21 days, and keeping the temperatures elevated for longer than the regulations require. The piles on the Compost Pile Temperature log sheet were followed onto the curing piles and into the finished compost product piles. The City has included copies of residuals analyses for the finished compost product from American Testing Technologies Inc. All of the results support the EQ designation of the compost and are included in a separate section of this report. IV. “COMPOGRO” COMPOST SAMPLING PROCEDURES The Static Aerated Piles The aerated static piles are constructed under a roof to protect the pile from wind and rain. Before building the pile, the base or bed is made with a 4 inch perforated airline placed down the center of the bed. The airline is connected to a blower creating positive or negative pressure so that air can be forced or pulled through the compost pile. The blowers are controlled by timers that turn themon or off as needed to supply airflow to the piles. After thebiosolids and amendment (wood chips and leaves) are mixed together, the mixture is placed on the 4 inch perforated pipeto build the static aerated pile and to begin the composting process. The mixture of biosolids and amendment is then covered with a six to eight (6 – 8) inch blanket of amendment to insulate the pile. After building a pile, a minimum of four (4) thermometers with 48-inch probes are placed at various locations and depths throughout the pile to monitor the temperatures of the compost pile. The https://synagro-my.sharepoint.com/personal/rroth_synagro_com/Documents/Desktop/NC/Burlington/2022 Burlington Class A Renewal/Add Info Req/In depth Compost Facility Narrative.doc - 5 - temperaturesare recorded daily to track the composting process. Results are entered into a database to track each pile with a unique identifier to make sure it meets the regulatory requirements. The thermometers are left in place during the time required to achieve compliance with the time and temperature requirements for the process to further reduce pathogens (PFRP) and for vector attraction reduction. We have not had any trouble reaching the prescribed time and temperature requirements in our static piles. Curing and stabilization After our static compost piles have met the requirements for time and temperature, the compost is moved to the curing pile for a minimum of 21 days for further stabilization. We keep one thermometer in the curing pile (which can be a combination of several aerated static piles) and record those temperatures as well. We have found that the curing process often requires more than 21 days and may take as many as 50 days. Sampling Finished Compost for Fecal Coliform, Metals and Nutrients After the curing process is completed the material is screened to separate the reusable amendment from the compost. At this point the finished compost is ready to be sampled and analyzed for fecal coliform to demonstrate successful pathogen reduction. The finished compost pile is sampled for fecal coliform in the following manner. A core sampler is disinfected for use to collect the samples. The core sampler is used to take core samples within the compost pile at different depths and locations through out the compost pile to get a good composite sample of the product. We collect four (4) cores in a sealable plastic bag or sterile https://synagro-my.sharepoint.com/personal/rroth_synagro_com/Documents/Desktop/NC/Burlington/2022 Burlington Class A Renewal/Add Info Req/In depth Compost Facility Narrative.doc - 6 - fecal bottle to make one composite sample, and collect a minimum of three (3) composite samples for each batch of finished compost. That means that we are taking samples of twelve (12) different locations in the pile. The fecal samples are collected in sterile fecal bags and are sent directly to the lab for analysis. The samples are hand delivered to the Cityof Burlington wastewater lab (Certificate No. 188). A dry solids analysis and the fecal test require about four days turnaround from sample collection to reporting of the data. Sample results are recorded and laboratory reports are maintained in the files. Similar sampling techniques are used to collect samples for nutrient and metals analyses. Those samples are contained in the sealable plastic bags and sent to American Testing Technologies, Inc. in Akron, Ohio. A sample is also collected and sent to the NCDA&CS. This data will be used to formulate the information sheets that are given to the purchaser of the compost. These analyses will be performed within 60 days of distribution of the finished product, and the results will be maintained on file. Test for Re-growth of Fecal Coliform If the compost is not distributed within 60 days of an acceptable analysis, the pile will be resampled for fecal coliform using the same technique described above prior to distribution. https://synagro-my.sharepoint.com/personal/rroth_synagro_com/Documents/Desktop/NC/Burlington/2022 Burlington Class A Renewal/Add Info Req/In depth Compost Facility Narrative.doc City of Burlington Compost Operations and Maintenance Plan Operational Functions The operational function of this program involves belt pressing sludge from the South Burlington Wastewater Treatment Plant by Compost Facility staff and mixing the cake material with woodchips and leaves to make permit compliant Class A compost that can be sold to the public. This requires; Having reliable operational equipment in place Having trained staff Belt pressing sludge to make cake material Having amendment onsite to mix with cake Collecting all permit required sampling Record keeping Safety Measures The City of Burlington has an established safety program in place that employees are refreshed yearly on. This facility is inspected yearly by the City of Burlington’s Safety Director and all findings are addressed and corrected to his satisfaction. Signage is employed to warn the public or any visitors of dangers, exits and restricted areas. The entrance to our Compost loading area is closed off with a cable that is controlled by facility staff The loading area is marked and while loading is taking place the public remain inside their vehicles. When loading is complete, the buyer must cover the load with a tarp or other type of cover to prevent loss of compost during transport. There are no keys left in equipment after hours of operation. The breaker for the Kuhn mixer is off in the control building at all times unless we are making compost. Our compost area is protected from fire by a dry sprinkler system that is inspected yearly by an outside contractor. All issues are corrected as soon as possible by this contractor. Before the sale of compost is complete, all buyersare provided with a Utilization Agreement which includes agronomic analysis. This agreement lists all the permit requirements and conditions that the end user must follow. Equipment Maintenance Schedule General MaintenanceofCompost equipment is handled by Compost Facility employees on an as needed basis. Complex maintenance or repair is handled by the Water Resources Dept. Plants Maintenance Division. All maintenance on our John Deere loader and Freightliner tandem dump truck is scheduled by the City of Burlington’s Equipment Services Division while maintenance on the Erin Screener is handledby an outside contractor once per year. Sampling The City of Burlington’s Residuals Management Coordinator or his designee will schedule and collect all permit required samples and follow all Chain of Custody.All sample data and records are kept onsite at the Compost Facility. Nutrient and Metal samples will be collected as required for permit compliancefrom each finished compost pile and sent to contract laboratories for analysis. TCLP will be collected once per yearand sent to a contract laboratory for analysis. 3 composite samples with each composite sample consisting of 4 core samples will be collected on each finished compost pile to run fecal coliform analysis to determine if the pile is Class A compliant. This analysis will be conducted by The City of Burlington Laboratory. Every 60 days we reanalyze for fecal coliform if the finished compost pile has not been distributed to ensure Class A compliance. Each finished pile has 1 grab sample taken and sent to the North Carolina Department of Agriculture for Agronomic nutrient analysis. A record is kept of all woodchip and leaf deliveries. Each static pile is uniquely numbered and will have 4 thermometers that will be used to track daily temperature. Inspection The Facility is inspected Mon – Fri bythe Residuals Management Coordinator or Compost Facility staff. Shift operators from the South Burlington Wastewater Plant record pile temperatures and keep watch on the facility on weekends and holidays. Daily temperature checks of compost static, curing, and finished piles. Weekly inspections of the sprinkler system. Weekly inspections of storm water drains and retention pond. DOT required inspections of transportation vehicles. City of Burlington required safety policy inspections. All inspection records are kept onsite. Any inconsistenciesor causes for concern found during any inspection are addressed in a timely manner by Compost Facility staff, City of Burlington Plants Maintenance staff,and Cityof Burlington Fleet Maintenancestaff or outside contractors. Last Reviewed 4/28/2022 SOUTH BURLINGTON WASTEWATER TREATMENT PLANT QUANTITATIVE JUSTIFICATION FOR RESIDUALS The following is a record of the last 3 years in which class A material was distributed from the above referenced plant: Year Dry Tons Removed 20210 2020 244.93 2019 575.84 As shown above the last year material was generated and distributed under this Class A permit was 2020. This was done because ofincreasing cost and currently available alternate disposal options. However, it is requested that the currently permitted tonnages be kept in place. City or Burlington, NC Attn: Sharon Wagoner 1302 Belmont Street Burlington, NC 27215 Date Received: 01/06/2022 Date Reported: 02/24/2022 Date Collected: 01/04/2022 Time Collected: 0915 Client ID #: Mackintosh Lagoon 9 2 ,.aboratory ID #: 010622-26 41000 American Testing Technologies, Inc. Certificate of Anal sis Parameter Results Units Method Date of Number Analysis Reactive Cyanides c0.5 mg/kg 7.3.3.2 01/17/2022 Reactive Sulfides <25 mg/kg 7.3.4.1 01/17/2022 pH (Lab) 8.22 S.U. 9045D 01/07/2022 Flash point >140 OF 1010A 01/14/2022 reviewed by: 1350 Home Avenue Akron, Ohio 44310 Page 31 of 31 Tot! Free. 877.634.9906 Phone. 330.634.9906 Fax. 330.634.9907 www.AmericanTestingTeChnolOgies.com