WQ0006245_Additional Information Request_20200416

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 16, 2020
ANDY SMITH — OPERATIONS MANAGER
CITY OF STATESVILLE
POST OFFICE BOX I I I I
STATESVILLE, NORTH CAROLINA 28687-1111
Subject: Application No. WQ0006245
Additional Information Request
City of Statesville DCAR
Distribution of Class A Residuals
Iredell County
Dear Mr. Smith:
Division of Water Resources' Central and Regional staff has reviewed the application package
received February 14, 2020. 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 May 18,
2020.
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 and B, or failure to provide the additional information on or before the above requested date
may result in your application being returned as incomplete.
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 two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely,
�2GC�i �Q�tNr ,G�v/t,G.
Erick Saunders, Engineer
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Permit Application File WQ0006245
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
mo
m )ry rN c. itiA
o.,aro�em or Ew�����a�:r� �./� 919.707.9000

Mr. Andy Smith
April 16, 2020
Page 2 of 3
A. Residuals Source Certification:
Only one Residuals Source Certification (FORM: RSC 06-16) was received for this program, which
includes three residuals sources. This sample can only be considered representative if the program
involves blending each of these residuals sources to create a homogenous mixture. The submitted
program information and operation and maintenance plan are not clear whether or not each of these
residuals sources are blended to create a homogenous product, or if each of these sources is treated
and distributed separately. Please clarify whether or not each residuals source is mixed to create a
homogenous final product. If residuals of different sources are not mixed, then three separate RSC
06-16 forms shall be submitted to verify that each residuals source meets residuals quality
standards.
2. According to Section C in the Instructions for FORM RSC 06-16, laboratory analytical reports and
operational data shall be submitted for all laboratory analyses used to complete this certification.
Both the Metals Determination in II.4.a and the Nutrient/Micronutrient Determination in II.S.b
reference a November 25, 2019 sampling event from Prism as the source of the information in the
tables. Please submit the reports of the laboratory analyses used to complete this certification.
According to Section C in the Instructions for FORM RSC 06-16, documentation that the facility
complies with any applicable pathogen reduction and vector attraction reduction requirements shall
be submitted along with the RSC 06-16 form. In order to prove pathogen reduction requirements,
data shall be submitted demonstrating that fecal coliform density is less than 1,000 MPN per gram
of dry solids, along with data to support that the alternatives chosen in the application to further
reduce pathogens are met. In this case, pH or temperature data shall verify that either Alkaline
Treatment or pasteurization has occurred properly in accordance with the requirements for each of
these treatment processes listed in 15A NCAC 02T .1106(a)(3).
Likewise, data shall be submitted demonstrating that vector attraction reduction requirements have
been met for the choices that were chosen in the application. This shall include either results from
a Specific Oxygen Uptake Rate (SOUR) test, or pH data for Alkaline Stabilization. These results
shall meet the requirements for these alternatives listed in 15A NCAC 02T .I 107(a).
4. The parameters of 2,4-D, Lindane, and 2,4,5-TP (Silvex) were not reported in the Hazardous Waste
Determination. In order to determine that the product is non -hazardous, all parameters in the
toxicity characteristic leaching procedure (TCLP) shall be proven to be under the limits in this
table. Please submit data from a verified lab that proves that all of these parameters are under their
TCLP limit.
5. The parameter of Molybdenum was not reported in the Metals Determination. In order to determine
that the product is below the ceiling concentration limit for Class A residuals, this parameter shall
be proven to be under the limit in this table. Please submit data from a verified lab that proves this
parameter is under 75 mg/kg on a dry weight basis.
6. The parameter of Aluminum was not reported in the Nutrient/Micronutrient Determination. In order
to determine the nutrient loading of Aluminum for this residual, this concentration of this parameter
shall be reported. Please submit data from a verified lab for this parameter.

Mr. Andy Smith
April 16, 2020
Page 3 of 3
B. Operation and Maintenance Plan f15A NCAC 02T .11101:
The submitted operational functions in the "Operation and Maintenance Plan" (hereby referred to
as O&M Plan) document and the "Sta-Lime Processing and Distribution Program Narrative"
(hereby referred to as Program Narrative) document do not detail how residuals from the City of
Statesville WTP and Third Creek WWTP will be transported to the liming facilities at the Fourth
Creek WWTP. Please amend these documents to describe how residuals will be transported from
each of these residuals sources, including all associated facilities and equipment.
2. See A.1. If the residuals are mixed, please amend the Program Narrative and O&M Plan to describe
how and where the mixing occurs.