WQ0037135_Staff Report_20230123

RE ,
January 23, 2023
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00037135
Attn: Ehsan Ba. eri Facility name: US Biosolids RLAP
From: Caitlin Caudle
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 1/23/2023
b. Site visit conducted by: C. Caudle
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Zach Kev and their contact information: [e-mail]
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Dennis Key Certificate #: 15704 Backup ORC: Zach Kev Certificate #: 27660
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ❑ Yes or ❑ No
If no, please explain:
Description of existing facilities:
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
4. Is the residuals management plan adequate? ® Yes or ❑ No
5. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
6. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ❑ No
7. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
8. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ® No
Please summarize any findings resulting from this review: The WWTP is based in MRO. A brief review of BIMS
records shows the facility to be compliant with some past issues with land application notifications.
9. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
FORM: WQROSSR 04-14 Pagel of 3

10. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain: See comments. Based on past land application activity and comments from Mr. Key there
should be enough land, in practice, to accommodate permitted facilities.
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
Designation of David Key
David Key is listed as a BUORC but is not designated in BIMS.
as BUORC
3. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
4. Signature of report preparer:
Signature of regional supervisor:
Date: 1/23/2023
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FORM: WQROSSR 04-14 Page 2 of 3

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The most recent US Biosolids permit was issued 7/23/2020 and the most recent Att. A was issued 8/9/2022.
The application form and O&M Plans listed 38% reduction, 30-day bench scale test, and lime stabilization as PVR
methods. Only 38% reduction was selected. Mr. Kev stated that Dallas WWTP normally uses 30-day bench, and
will use lime stabilization as a back up method for PVR.
The Spill Plan has both WSRO and MRO listed for reporting purposes. Should the Spill Plan be updated to report
to WSRO as US Biosolids is based in WSRO? Should the plan be updated to include both WSRO and MRO for
24hr notification?
The new total for US Biosolids will be 1,600 dry tons, with 100 dry tons being added for Dallas WWTP. Dallas
WWTP has an individual permit and currently permitted for 100 dry tons. MRO has reported in BIMS entries that
Dallas WWTP was transporting solids to Rocky River WWTF for incineration as well as land applyingsolids.
olids.
Will there be enough land available to add this facility?
Based on the current permitted acreage, the majority of fields will need to be applied at rates between 150 and
200 lbs PAN/ac to sustain the permitted dry tons. The majority of the land is permitted for pasture which
requires a 25% reduction in application rates. Based on the soil series in Att. B, the application rates for the
308 ac in pasture would range from 118 to 156 lbs PAN/ac, and the hay land would range from 158 to 209 lbs
PAN/ac. In 2020 578 tons were applied, and in 2021521 tons were applied. In 2021, all four facilities applied
from had PAN values less than 50 lbs/ton. If they continue with these application rates there will be enough
land to accommodate all facilities.
Mr. Key stated that the US Biosolids permit will be a back up, and maybe used once a year and Dallas
WWTP's own permit will be used as well. The majority of the permitted sources also have individual permits,
which will take some of the pressure off of the land permitted for US Biosolids.
FORM: WQROSSR 04-14 Page 3 of 3

Compliance Inspection Report
Permit: WQ0037135 Effective: 08/09/22 Expiration: 09/30/24 Owner: U S Biosolids Inc
SOC: Effective: Expiration: Facility: U.S. Biosolids Class B Residuals Program
County: Wilkes 397 Riverside Dr
Region: Winston-Salem
Forest City NC 28043
Contact Person: Zachery Key Title: President Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0006564 Baxter Healthcare Corporation - Baxter Healthcare Corporation
NC0025861 City of Lowell - Lowell WWTP
NC0025909 Town of Rutherfordton - Rutherfordton WWTP
NC0020761 Town of North Wilkesboro - Thurman Street WWTP
NC0025984 Town of Forest City - Forest City WWTP
NC0021181 City of Belmont - Belmont WWTP
NC0020567 Yadkin Valley Sewer Authority - Yadkin Valley Sewer Authority WWTP
NC0020664 Town of Spindale - Spindale WWTP
Inspection Date: 01/23/2023 Entry Time 10:OOAM Exit Time: 10:30AM
Primary Inspector: Caitlin Cau/d''lellll� /f �,�. Phone: [phone]
Secondary Inspector(s): V'"'�ruv' l�D&
1/23/2023
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0037135 Owner - Facility: U S Biosolids Inc
Inspection Date: 01/23/2023 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On January 23, 2023, Division of Water Resources staff Caitlin Caudle conducted a site visit for permitting purposes. Zach
Key of US Biosolids and Michael Stafford, ORC of Dallas WWTP, were present during the enitre site visit.
Aeration Basin --> Clarifier --> Digestor --> Dallas Creek
There are two identical treatment trains that have an AB and digestor surrounding the clarifier (see map in file). In December
some flow was diverted to Two Rivers WWTP in Gastonia, cutting the influent flow in half. But new development will replace
that flow soon.
Mr. Key stated that typcially 30-day bench scale will be used to meet PVR, but lime stabilization will be used as a back up.
Approximately 130,000 gallons are hauled during each event from both digestors. The digestors have approximately 3
months of storage. When land applicaiton is not possible solids from the drying beds are taken to Rocky River WWTP for
incineration as a last resort. One digestor can be emptied into the drying beds.
Mr. Key stated that the permit mod applicaiton to add new land in Wilkes County will likely be submitted next month.
Page 2 of 3

Permit: WO0037135 Owner - Facility: U S Biosolids Inc
Inspection Date: 01/23/2023 Inspection Type : Reconnaissance Reason for Visit: Other
Page 3 of 3

WQ0037135 Dallas WWTP 20230123
1 /23/2023 1:1, 600
0 0.01 0.02 0.04 mi
0 0.02 0.04 0.07 km
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