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HomeMy WebLinkAboutNC0025542_Permit (Issuance)_20050822NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0025542 Catawba WWTP Document Type: Permit Issuance—` Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Report Speculative Limits Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: August 22, 2005 This document is printed on reuse paper - ignore any content on the reYerse side A, ATA NCDENR Mr. Thomas N. Carr Interim City Manager City of Hickory P.O. Box 398 Hickory, North Carolina 28603 Dear Mr. Carr: Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Division of Water Quality August 22, 2005 Subject: NPDES Permit Issuance Permit No. NC0025542 City of Hickory -Catawba WWTP Catawba County Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended.) The permit authorizes the City of Hickory to discharge up to 0.225 MGD of treated wastewater to Lyle Creek, a class WS-IV CA water in the Catawba River Basin. The draft permit includes discharge requirements and/or limitations for flow, biochemical oxygen demand (BOD), total suspended solids (TSS), ammonia, fecal coliform bacteria, total residual chlorine, total nitrogen, total phosphorus, copper, zinc, and chronic toxicity. The following modifications noted in the draft permit, remain the same: • Quarterly effluent monitoring for cyanide and phenols has been deleted. A review of monitoring data indicated that there is no reasonable potential for these parameters to exceed the water quality standard and are no longer parameters of concern. • Monthly monitoring for copper and zinc has been added to permit, instead of the previous quarterly monitoring. A review of submitted monitoring data indicated that there is reasonable potential for these parameters to exceed the water quality standard. N. C. Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699.1617 Internet: h2o.enr.state.nc.us Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center: 1 800 623-7748 Letter to Thomas Carr Page 2 • A total residual chlorine limit of 28 ug/1 has been added to reflect the Division's current policy for protection against chlorine toxicity instream. The limit for total residual chlorine shall become effective upon completion of the installation of a disinfection system but no later than 18 months from permit issuance (February 1, 2007). If a method different than chlorination/dechlorination is used, the total residual chlorine limit will not be applicable. If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. Please take notice that this permit is not transferable. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits, which may be required by the Division of Water Quality, or permits required by the Division of Land Resources, Coastal Area Management Act, or any other Federal or Local governmental permits may be required. If you have any questions or need additional information, please contact Ms. Jacquelyn Nowell at telephone number (919) 733-5083, extension 512. Sincerely, ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E. Attachments cc: Mooresville Regional Office/Surface Water Protection Central Files Aquatic Toxicology Unit Permit File Permit Number NC0025542 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, the City of Hickory is hereby authorized to discharge wastewater from a facility located at the Hickory - Catawba Wastewater Treatment Plant End of 6th Avenue NW North of Catawba Catawba County to receiving waters designated as Lyle Creek in the Catawba River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective October 1, 2005. This permit and authorization to discharge shall expire at midnight on April 30, 2010. Signed this day August 22, 2005. ORIGINAL SIGNED BY SUSAN A. WILSON Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number NC0025542 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked, and as of this issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. City of Hickory, is hereby authorized to: 1. Continue to operate an existing 0.225 MGD wastewater treatment facility with the following components: • Dual bar screens • Two aeration basins • Two secondary clarifiers • Chlorine contact basin (gas disinfection) • Instrumented flow measurement (with recorder) • An aeration sludge holding tank The facility is located at Hickory -Catawba WWTP, Sixth Avenue NW, north of Catawba, Catawba County. 2. Discharge from said treatment works at the location specified on the attached map into Lyle Creek, classified WS IV CA waters in the Catawba River Basin. i Facility Information Latitude: Longitude: Quad #: Stream Class: Receiving Stream: Permitted Flow: 35°42'55" Sub -Basin: 03-08-32 81°04'25" E14NE WS-IV CA Lyle Creek 0.225 MGD t \��{ r�i� , ►/i !r l\,t\,t City of Hickory -Catawba W WTP NC0025542 Catawba County Permit Number NC0025542 A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS —FINAL Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated wastewater from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: �fiC•: YN. � : t..,'• .t �-:- N.<u:: • ._-xd'.> .:tT _ ", .....v . .-K t �' rt'F`z;' f � _� t:� }•"..:: .t - x Ff< WQ'..t. ..1�«.-... ., _;Te i : <7.. ....s 5:.t i �,... r t : x .:.V '� EFFLUENT r... f ':::... z. 5 i i.a>n:^ S �.j. ... � � a4 .57 't R' � '-} t�,. <e.. y , e i * r�t ��N� •° �� F •�" �' :_ i�.:-,u �. S ..::. �.. kf R 9_ :1 f :zsl .;4. 4 Ft- f ix_.,, ��J f� � �h t4a 4$tY:�{itr Y �iC...��i d{ _! �"t� Y'_..F [ % ;Y��, �0���<. z,�Q?_MF11T1t�S �� w• ...s .c.; v ._r":-;a:,a-'vi .:ai cTdu .,:.tii ai--,-?zi.ii-3i,-ea a= ri,- a .-`:3'R LIMITATIONS c, `• „«.«:.. t,.,.Y•«, ;.nej ;. .i .,N."+t...., ',.7.-4.1. .f. wr ".a,—, ' E.. tro,,,,..��.F%1:E f 2 .'_*�� .::. �� � .a � � .y � ,>~ _ r Y tE 2 2 t $ t i .: , .. .;4..t::.. <K... .`�t'."... .....miw- _........ ..:... ._. .. ...::, :...::� ',.....c.: :: ,a x�rMonthty � "7sv. :.,r .R.: y�. f�Weekl � � r .Aver a _,....: � �=DaiX9 � t *ttza.nws±su.an...a.:w:�xx�, �liECesurement t sk...� waa >ef C �5�p � ...� � �`amlleN Average �F asimum Freauencp r .y At, r t _ .ocationL ,� .. t. .. _.. �:...... .r..vl...a }.51 •.t -, t, •s,. ^Y r - :::�: ..1.. .. .. ... ... :tf'-., ; . i�T.' �� f' Y .. ..fix..: s...,. ;-F..... n ye'r..�" `-^�'.z ,;41077 ... - � ..:. .«- �..,a' �Y ri }!.a.-._... .. �F "s�'ar LS >, � s.r,C ..,�;..... _...$ }r S: - s .^�}?. �... .,...�i-.o» Flow 0.225 MGD Continuous Recording I or E BOD5 2 30.0 mg/1 45.0 mg/1 Weekly Composite E,I Total Suspended Solids2 30.0 mg/1 45.0 mg/1 Weekly Composite E,I NH3-N ( 2/Month Composite E Fecal Coliform 200/100 ml 400/100 ml Weekly Grab E pH3 Weekly Grab E Total Residual Chlorine4 28 ug/1 . 2/Week Grab E Temperature Daily Grab E Conductivity Weekly Grab E Copper Monthly Composite E Zinc Monthly Composite E Total Nitrogen (NO2 + NO3 + T Quarterly Composite E Total Phosphorus Quarterly Composite E Chronic Toxicity5 Quarterly Composite E Notes: 1. Sample Locations: E - Effluent, I - Influent, 2. The monthly average effluent BOD5 and Total Suspended Solids concentrations shall not exceed 15% of the respective influent value (85% removal). 3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units. 4- Monitoring requirement applies only if chlorine is added for disinfection.- See A (3.) Special Conditions of the Supplement to Effluent Limitations. 5. Chronic Toxicity (Ceriodaphnia) P/F ® 2.1%; February, May, August, November. See A (2.) Special Conditions of the Supplement to Effluent Limitations. There shall be no discharge of floating solids or visible foam in other than trace amounts. Permit Number NC0025542 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QRTRLY) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 2.1%. The permit holder shall perform at a minimum, quarteriu monitoring using test procedures outlined in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity T t-ProcPriure" (Revised=ebruary 1998) or subsequent versions. The tests will be performed during the months erand Decembffluent sampling for this testing shall be performed at the NPDE permitted final effluent disc har Blow all treatment processes. earEd- r c-$ y 4Q :- Na / If the test procedure performed as the first test of any single quarter re ults in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring, Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address: Attention: Environmental Sciences Branch North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences Branch at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. I" Permit Number NC0025542 SUPPLEMENT TO EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (3.) TOTAL RESIDUAL CHLORINE The limit for total residual chlorine shall become effective upon completion of the installation of a disinfection system but no later than 18 months from the issuance of the permit (February 1, 2007). If a method different than chlorination/dechlorination is used, the total residual chlorine limit will not be applicable. DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0025542 Facility Information Applicant/Facility Name: City of Hickory -Catawba WWTP Applicant Address: P.O. Box 398 Hickory, N.C. 28603 Facility Address: End of 6th Avenue NW Permitted Flow 0.225 MGD Type of Waste: Domestic Facility/Permit Status: Renewal Facility Classification II County: Catawba Miscellaneous Receiving Stream: Lyle Creek Regional Office: Mooresville Stream Classification: WS-IV CA(11-74-al USGS Topo Quad: E14NE/Catawba, N.C. 303(d) Listed?: No Permit Writer: Jackie Nowell Subbasin: 03-08-32 Date: June 20, 2005 Drainage Area (mi2): 72.8 . �^ -' Summer 7Q10 (cfs) 16 Winter 7Q10 (cfs): 29 Average Flow (cfs): 84j1`d IWC (%): 2.1 Primary SIC Code: 4952 SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION The City of Hickory is requesting renewal of the former Catawba WWTP. Hickory purchased the Town of Catawba WWTP in July 2003. The WWTP discharges into Lyle Creek, a class WS-IV CA stream, in CTB32 subbasin. The facility does not have a pretreatment program. Its wastewater is primarily domestic. Lyle Creek is not listed on North Carolina's 2002 303(d) list. There is a management strategy for the Lyle Creek watershed. Results of a 1988 modeling analysis indicated that BOD5 and NH3 had been over allocated in Lyle Creek under prior wasteload allocation procedures. The model was done to establish NPDES permit limits for the Town of Conover WWTP (discharging upstream of Catawba) to protect the DO standard and was used to guide recommendation for future expansions and new facilities in the Lyle Creek watershed. Expanding facilities in the Lyle Creek watershed will receive BOD and NH3 limits that will hold their load of oxygen consuming wastes constant. All new facilities discharging to the Lyle Creek watershed will receive limits for oxygen consuming waste of ultimate summer BOD not greater than 21 mg/1 (equivalent to 8 mg/1 BOD5 and 2 mg/1 NH3 for domestic discharges.) In the 2004 Catawba River Basinwide Management Plan --The Aquatic Life use support rating for 6.3 miles of Lyle Creek from Bakers Creek to US Highways 64 and 70 is supporting based on monitoring. No problem parameters are listed in this report. Previously sediment was listed as a problem parameter in this segment of Lyle Creek. The 1997 benthos rating at US Highways 64 and 70 was Good -Fair. The results of 1997 fish sampling at US 79 was Good. City of Hickory -Catawba W\VTP Fact. Sheet NPDES Renewal Pale 1 Existing Effluent Limits for Catawba WWTP (per 2001 permit) Qw = 0.225 MGD BOD5 = 30 mg/1 NH3 = monitoring) TSS = 30 mg/1 Fecal Coliform = 200/ 100m1 TRC = monitoring pH = 6-9 SU Quarterly monitoring for cyanide, copper, phenols, zinc, TP and TN Chronic Toxicity P/F CO 2.1%; February May August November TOXICITY TESTING: Current Requirement: Chronic Toxicity P/F @ 2.1%; February May August November Facility has passed all tests from 2001 through May 2005 Although facility is primarily domestic, future plans may include industrial ww. City has request inhouse for spec limits which would make the facility a major discharger. Recommend renewal of Chronic Toxicity P/F @ 2.1%; February May August November COMPLIANCE SUMMARY: Facility appears to be well operated. Only one violation report in Compliance System, pH violation in March 2005. All other limits have been met. INSTREAM MONITORING REQUIREMENTS: Instream monitoring is not required for this WWTP. REASONABLE POTENTIAL ANALYSIS The following metal/toxicity parameters are monitored in the NPDES permit: Copper, cyanide, phenols, and zinc. Data for these parameters was reported in the discharge monitoring reports (DMR) and a RPA was done: Reasonable potential analysis was conducted based on data from 2002 through April 2005. Results and data analysis are attached. • Monthly monitoring should be started for copper based on RPA. Copper results had fifteen (15) reported values. There was reasonable potential to exceed the allowable acute concentration but not the allowable chronic concentration for the NC action level. Monthly monitoring is required based on the class of the facility. • Monthly monitoring should be started for zinc based on RPA. Zinc results had fifteen (15) reported values. There was reasonable potential to exceed the allowable acute and chronic concentrations for the . NC action level. Monthly monitoring is required based on the class of the facility. • Quarterly monitoring for cyanide and phenols should be deleted. Based on analysis, neither parameter showed reasonable potential to exceed allowable concentrations. PROPOSED CHANGES: The following modifications have been made to the permit: • The addition of a Total Residual Chlorine limit of 28 ug/1 based on DWQ procedure that requires limit for all municipal discharges. Eighteen month compliance schedule will be given_ • Quarterly monitoring for copper and zinc will be changed to monthly monitoring based on the results of RP analysis. • Quarterly monitoring for cyanide and phenols will be deleted based on the results of the RP analysis. City of Hickory -Catawba WkrW T'P Fact Sheet NPDES Renewal Page 2 • PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: 06/22/2005 Permit Scheduled to Issue: 08/15/2005 STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact ,d ckie Nowell at (919) 733-5083 ext. 512. DATE: c 1 EGIONAL OFFICE COMMENT: Titc,c% O f 7 %7fI-G,G / 4s / -i92 s 0,L7 r6.xmr / 5 /�/C/�O/L 1�- . %7 N"9 � 7 / %�-es O /Vv/ 77 - 6' 2 G/i-r/,1t/g ww%7' �L s� ,7o/ /9-/7 g— /Ai/ivc. -V/e6 —/ l�lvir%� 73 lboro%Ly to ! r'' M/,9't I�/�.yi�`� oit/ j �rL 4 2oa . its, 724( NAME: NPDES SUPERVISOR COMMENT: NAME: 7/21/.),-- 31`11DATE:�� DATE: City of Hickory -Catawba WWII' Fact Sheet NPDES Renewal Page 3 Catawba Permits Subject: Catawba Permits From: Dave Toms <dave.toms@ncmail.net> Date: Thu, 21 Jul 2005 13:49:14 -0400 To: Jackie Nowell <Jackie.Nowell@ncmail.net>, Susan Wilson <susan.a.wilson@ncmail.net>, Dave Goodrich <Dave.Goodrich@ncmail.net> CC: Bob Sledge <Bob.Sledge@ncmail.net>, Bob Guerra <Bob.Guerra@ncmail.net>, Darlene Kucken <darlene.kucken@ncmail.net>, Michelle Woolfolk <Michelle.Woolfolk@ncmail.net> Howdy Permitters, I want to give you all an update on information coming out of the Duke/FERC Reliscensing process on the Catawba and find out where we are on permit renewals in the Rhodhiss area. We are starting to get preliminary data from the water quality models Duke is developing for the Catawba mainstem. Some of that data is included in the draft study report - link below. Not currently included in the report is evidence demonstrating the impact the Valdese WWTP is having on Lake Hickory. This is particularly interesting because the Valdese discharge is into Lake Rhodhiss, about 6 miles upstream of the dam. Our working assumption has been Valdese is a major contributor to the eutrophic conditions that led to Rhodhiss' impairment. The model, however, is indicating the Valdese discharge has a larger impact on Lake Hickory. (Please recall that Lake Hickory is on the borderline of nutrient impairment.) The majority of Rhodhiss' point source problems appear to be coming from Morganton and Lenoir's WWTPs. The model will be able to isolate Morganton's impact on Rhodhiss, but unfortunately, the Lenoir discharge is hidden in the total load entering from Lower creek. • Have these WWTP permits been renewed yet? If so, what were their terms? If not, can we set aside some time to discuss optimization options and the like? http://www.dukepower.com/community/lakes/cw/library/plans/W Q%2ORC%20Report%20ver%205.pdf Thanks, Dave Toms Basin Planner Planning Branch : Basinwide Planning Program unit DENR : Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699 Phone# (919) 733-5083, ext. 577 Fax# (919) 733-5637 o t- a r-i to ri TA c_y\f‘rsi. Lanair \/\/WTP Valdese WV\/TP 1 of 2 7/21/2005 2:26 PM Catawba Permits 7 organton VVTP David Toms <dave.toms@ncmail.neb Basin Planner Division of Water Quality NC Department of Environment and Natural Resources Lenoir VVVVTP p- odhiss Valdese VVVVTP 2 of 2 7/21/2005 2:26 PM PUBLIC NOTICE STATE OF NORTH CAROLINA-- 'ENVIRONMENTAL • MANAGEMENT CONMISSIONMPDES UNIT 1617MAIL:. - SERVICE CENTER RALEIGH, NC 27699.1617 •NOTIFICATION - OF .INTENT TO ISSUE A NPDES WASTEWATER PERMIT • On the basis of thorough staff review and application of NC General Statue. 14321, ,Public law 92-500 and other lawful 'standards and reg ulations; the North Carolina • Environmental Management Commission pre - poses to issue a National Pol- lutant Discharge Eiminattonstem NPD S wastewater discharge permit to the per- sons) listed below effective 45 days from the publish date of this notice.. :- . Written comments regarding the proposed permit will be ac- cepted until 30 days after the publish date of this notice. An comments received prior to that date are considered in the final ,determinations . regarding the proposed penniL The -.Di- rector ,of the NC Division of Water . Quafdy may decide to fold a meeting for the proposed Wri should the Di- vision receive a - signifoant. de- gree of public interest. Copies of the drsupportingafpemmit and infrmation other fe used determine con- ditons present in the draft per-• mit are available upon request and paymentof the costs of reproduction. , -Mali comments :and/or for information to the NC Division of Water Quality at :the above address or. call the;,•Point Source Branch at (9191733.5083, ex 'tension 520.-Please include the NPDES permit number (a Tttached) in any communica- tion. Interested persons may also visit the Division of Water Quality , at 512 N. Salisbury Street, Raleigh, . NC 27604- 1148 between the hours of 8:00 am.- and 5:00 p.m. to re- view information on file.. .. NPDES Permit Number NC0025542, City of Hickory - Catawba " WWTP; Catawba County, has applied for renew- . al of its permitter a facility cis: :charging treated wastewater tq the Lyle Creek in the Catawba River Basin.` Currently fecal cordon and total residual chlorine are water quality Limitet this discharge may af- fect future allocations in this. portion of the receiving stream. LIC: duneA, 2005 as 23083 NORTH CAROLINA CATA A COUNTY Otr\DAO being first duly swor ays: That he or she is . �. �? /— of the Hickory aily ,. Record, a newspaper pub- lished at Hickory, North Carolina; that in the issues of the said newspaper for the following days, to wit: ure_ 2bp/065- there appeared spaced lines of advertising as per attached named advertiser The Hickory Daily Record is a qualified news- paper within the meaning of sec ' 1-597 of the General tatutes of N. C. Affiant Sworn to and subscribed before me, this ..........•0?' .......... day of ,20' My Commission Expires �� , 20 er DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0025542 Facility Information Applicant/Facility Name: City of Hickory -Catawba WWTP Applicant Address: P.O. Box 398 Hickory, N.C. 28603 Facility Address: End of 6th Avenue NW Permitted Flow 0.225 MGD Type of Waste: Domestic Facility/Permit Status: Renewal Facility Classification II County: Catawba _ Miscellaneous Receiving Stream: Lyle Creek Regional Office: Mooresville Stream Classification: WS-IV CA(1f-74-(V.) USGS Topo Quad: E14NE/Catawba, N.C. 303(d) Listed?: No Permit Writer: Jackie Nowell Subbasin: 03-08-32 Date: June 20, 2005 Drainage Area (mi2): 72.8 . t Summer 7Q10 (cfs) 16, �' a� Winter 7Q10 (cfs): 29 Average Flow (cfs): 84 IWC (%): 2.1 Primary SIC Code: 4952 SUMMARY OF FACILITY INFORMATION AND WASTELOAD ALLOCATION The City of Hickory is requesting renewal of the former Catawba WWTP. Hickory purchased the Town of Catawba WWTP in July 2003. The WWTP discharges into Lyle Creek, a class WS-IV CA stream, in CTB32 subbasin. The facility does not have a pretreatment program. Its wastewater is primarily domestic. Lyle Creek is not listed on North Carolina's 2002 303(d) list. There is a management strategy for the Lyle Creek watershed. Results of a 1988 modeling analysis indicated that BOD5 and NH3 had been over allocated in Lyle Creek under prior wasteload allocation procedures. The model was done to establish NPDES permit limits for the Town of Conover WWTP (discharging upstream of Catawba) to protect the DO standard and was used to guide recommendation for future expansions and new facilities in the Lyle Creek watershed. Expanding facilities in the Lyle Creek watershed will receive BOD and NH3 limits that will hold their load of oxygen consuming wastes constant. All new facilities discharging to the Lyle Creek watershed will receive limits for oxygen consuming waste of ultimate summer BOD not greater than 21 mg/1 (equivalent to 8 mg/1 BOD5 and 2 mg/1 NH3 for domestic discharges.) In the 2004 Catawba River Basinwide Management Plan --The Aquatic Life use support rating for 6.3 miles of Lyle Creek from Bakers Creek to US Highways 64 and 70 is supporting based on monitoring. No problem parameters are listed in this report. Previously sediment was listed as a problem parameter in this segment of Lyle Creek. The 1997 benthos rating at US Highways 64 and 70 was Good -Fair. The results of 1997 fish sampling at US 79 was Good. City of Hickory -Catawba WWTP Fact Sheet NPDES Itenewa! Page: 1 Existing Effluent Limits for Catawba WWTP (per 2001 permit) Qw = 0.225 MGD BODS = 30 mg/1 NH3 = monitoring) TSS = 30 mg/1 Fecal Coliform = 200/ 100m1 TRC = monitoring pH = 6-9 SU Quarterly monitoring for cyanide, copper, phenols, zinc, TP and TN Chronic Toxicity P/F @ 2.1%; February May August November TOXICITY TESTING: Current Requirement: Chronic Toxicity P/F @ 2.1%; February May August November Facility has passed all tests from 2001 through May 2005 Although facility is primarily domestic, future plans may include industrial ww. City has request inhouse for spec limits which would make the facility a major discharger. Recommend renewal of Chronic Toxicity P/F @ 2.1%; February May August November COMPLIANCE SUMMARY: Facility appears to be well operated. Only one violation report in Compliance System, pH violation in March 2005. All other limits have been met. INSTREAM MONITORING REQUIREMENTS: Instream monitoring is not required for this WWTP. REASONABLE POTENTIAL ANALYSIS The following metal/toxicity parameters are monitored in the NPDES permit: Copper, cyanide, phenols, and zinc. Data for these parameters was reported in the discharge monitoring reports (DMR) and a RPA was done: Reasonable potential analysis was conducted based on data from 2002 through April 2005. Results and data analysis are attached. • Monthly monitoring should be started for copper based on RPA. Copper results had fifteen (15) reported values. There was reasonable potential to exceed the allowable acute concentration but not the allowable chronic concentration for the NC action level. Monthly monitoring is required based on the class of the facility. • Monthly monitoring should be started for zinc based on RPA. Zinc results had fifteen (15) reported values. There was reasonable potential to exceed the allowable acute and chronic concentrations for the . NC action level. Monthly monitoring is required based on the class of the facility. • Quarterly monitoring for cyanide and phenols should be deleted. Based on analysis, neither parameter showed reasonable potential to exceed allowable concentrations. PROPOSED CHANGES: The following modifications have been made to the permit: • The addition of a Total Residual Chlorine limit of 28 ug/1 based on DWQ procedure that requires limit for all municipal discharges. Eighteen month compliance schedule will be given_ • Quarterly monitoring for copper and zinc will be changed to monthly monitoring based on the results of RP analysis. • Quarterly monitoring for cyanide and phenols will be deleted based on the results of the RP analysis. City of Hickory .Cai.;:o.vba llj\VTP {'i1('t Sheet ZJNI}.ES it('.I1C'.wa} f' a g c 2 PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: 06/22/2005 Permit Scheduled to Issue: 08/15/2005 STATE CONTACT: If you have any questions on any of the above information or on the attached permit, please contact Mackie Nowell at (919) 733-5083 ext. 512. NAMI : L L- t1 ° im,(.. DATE: VZis RgGIONAL OFFICE COMMENT: NAME: DATE: NPDES SUPERVISOR COMMENT: NAME: DATE: City of i..hc.I(()..:-Catawba \\T\l''I'I.' Fact S}hi-c't NI"DES Page 3 REASONABLE POTENTIAL ANALYSIS Hiickory - Catawba WWTP NC0025542 Time Period 01/2002-02/2005 Qw (MGD) 0.225 7010S (cis) 16 7010W (cis) 29 3002 (cis) 34 Avg. Stream Flow, QA (cis) 84 Rec'ving Stream Lyle Creek WWTP Class 11 !WC (%) 0 7010S 2.1332 ® 7010W 1.1883 ® 3002 1.0153 ® QA 0.4135 Stream Class C Outfall 001 Qw = 0.225 MGD PARAMETER TYPE 111 STANDARDS& CRITERIA (2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION NC IYQS/ Chronic K FAY/ Acute n it'd Mzx Fred Cw Altowabftt Cw Arsenic NC 50 ug/L 0 0 NIA Acute: WA __�--.---.-------_---.-----•—.—•— ' Chronic:- ronic: 2,344 Beryllium C 6.5 ug/L 0 0 WA Acute: WA _ _ _ _ _ Chronic: 1,572 ------------_—.—.---.—.---.—.— Cadmium NC 2 15 ugh. 0 0 WA—,--•----------------------------- Acute: 15 ChroniC: •94 Chromium NC 50 1,022 ug/L 0 0 WA Acute: 1,022 _ 2,3 _�.----------- Chronic: 44 --- —•—•_ —---- ------ Copper NC 7 AL 7.3 ug/L 16 7 251.9 Acute: 7 _ _ _•_ _ ------------ Chronic: .— exceeds the acute action level Recommend monthly monitoring •—_—.—.•—.— ---—.— Cyanide NC 5 N 22 10 ug/L 16 2 5.0 Acute: 22 _ _ _ _, ._.---_ Chronic: 234 No RP shown Recommend monitoring be dropped _—.—•—_—_—.— — — —_ Fluoride NC 1,800 ug/L 0 0 NIA Acute: N/A _ _ _ 84,381 Chronic: -- ---.—_—_— _—_—_—_—_—_—.—_—_— Lead NC 25 N 33.8 ug/L 0 0 WA Acute: 34 _ ._ _ _—_—.—.—.—.— Ch►onic: 1,172 _--•---------.—.—.—.— Mercury NC 0.012 0.0002 uglt. 0 0 N/A Acute: N/A Chronic: 1 Molybdenum A 3,500 ug/L 0 0 N/A Acute: WA _ ro_ _ Chnic: 344,719 + --- — -------------------------- .— Nickel NC 88 261 ug/L 0 0 N/A Acute: 261 _ _ _ Chronic: 4.125_ -.------- ------- ---.------ ----- — Phenols A 1 N ugh_ 13 1 32.0 Acute: N/A _ _ ---•--•—•----------------------------- Chronic: No RP shown Recommend that monitoring be dropped Selenium NC 5.0 56 ug/L 0 0 N/A Acute: 56 _ _ ._ _ _----------- Chronic: 234 _--- ----------------- Silver NC 0.06 AL 1.23 ug/L 0 0 N/A Acute: 1 Chronic: '-- 3 •--------•---•--------------------- Zinc NC 50 AL 67 ug/L 15 15 715.9 Acute: 67 _ _ _ Chronic: - 2,344 exceeds the acute action Level Recommend monthly monitoring ---•---•---------•-------------•— • Legend: C = Carcinogenic NC = Non -carcinogenic A = Aesthetic '• Freshwater Discharge 25542rpa05, rpa 6/21/2005 REASONABLE POTENTIAL ANALYSIS Copper Cyanide 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 199 200 Date Data BDL=1/2DL Results Feb•2005 < 38 19.0 Std Dev. 17.2305 Oct-2004 <:. 38 19.0 Mean 22.2250 <38 19.0 C.V. 0.7753 7.5 7.5 n 16 4.1 4.1 0ct-2003 < 38 19.0 Mull Factor = 3.1100 38 19.0 Max. Value 81.0 ug/L <, 25 12.5 Max. Pred Cw 251.9 ug/L <' 50 25.0 Dec-2002 < 25 12.5 31 31.0 16 16.0 21 21.0 31 31.0 81 81.0 Apr-2005 <. 38 19.0 Date 1 Feb-2005 2 Oct-2004 3 4 5 6 Oct-2003 7 8 9 10 Dec-2002 11 12 13 14 15 16 Apr-2005 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 199 200 Data BDL=1/2DL Results 9 5.0 Std Dev. 0.0000 5 5.0 Mean 5.0000 5 5.0 C.V. 0.0000 2 5.0 n 16 2 5.0 2 5.0 Mull Factor = 1.0000 2 5.0 Max. Value 5.0 ug/L 5 5.0 Max. Pred Cw 5.0 ug/L 5 5.000 5 5.000 5 5.000 5 5.000 5 5.000 5 5.0 5 5.0 5 5.0 -2- 25542rpa05, data 6/21/2005 REASONABLE POTENTIAL ANALYSIS Phenols Zinc 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 199 200 Date Data BDL=1/2DL Results Oct-2004 < 20 10.0 Std Dev. 3.8297 < 20 10.0 Mean 6.5000 < 20 10.0 C.V. 0.5892 < 20 10.0 n 13 Oct-2003 < 20 10.0 12 12.0 Mult Factor = 2.6700 < 5 2.5 Max. Value 12.0 ug/L < 5 2.5 Max. Pred Cw 32.0 ug/L Dec-2002 < 10 5.0 < 5 2.5 < 5 2.5 < 5 2.5 Apr-2005 < • 10 5.0 Date Data BDL=1/2DL Results 1 Feb-2005 173 173.0 Std Dev. 62.9365 2 Oct-2004 59 59.0 Mean 83.0000 3 28 28.0 C.V. 0.7583 4 36 36.0 n 15 5 44 44.0 6 30 30.0 Mull Factor = 3.1400 7 88 88.0 Max. Value 228.0 ug/L 8 28 28.0 Max. Pred Cw 715.9 ug/L 9 59 59.0 10 12/202 30 30.0 11 59 59.0 12 83 83.0 13 228 228.0 14 160 160.0 15 Apr-2005 140 140.0 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 199 200 - 3 - 25542rpa05, data 6/21/2005 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Alan W. Klimek, P.E., Director MEMORANDUM To: From: Subject: Britt Setzer NCDENR / D Mooresville Regional Office Jackie Nowell NPDES Unit June 22, 2005 / Regional Engineer Review of Draft NPDES Permit NC0025542 Hickory -Catawba WWTP Catawba County AVA NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Please indicate below your agency's position or viewpoint on the draft permit and return this form by July 29, 2005. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address listed at the bottom of this page. RESPONSE: (Check one) Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of the above permit, provided the following conditions are met: Opposes the issuance of the above permit, based on reasons stated below, or attached: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 512 (fax) 919 733-0719 VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES Jackie.Nowell@ ncmail.net Draft Permit Reviews (2) Subject: Draft Permit Reviews (2) From: John Giorgino <john.giorgino@ncmail.net> Date: Fri, 29 Jul 2005 15:11:56 -0400 To: Jackie Nowell <Jackie.Nowell@ncmail.net> Jackie, I have reviewed the following: NC0025542 Catawba WWTP NC0085359 Twelve Mile Creek WWTP I have no comments. Thanks for forwarding them. John John Giorgino Environmental Biologist North Carolina Division of Water Quality Environmental Sciences Section Aquatic Toxicology Unit Mailing Address: 1621 MSC Raleigh, NC 27699-1621 Office: 919 733-2136 Fax: 919 733-9959 Email: John.Giorgino@ncmail.net Web Page: http://www.esb.enr.state.nc.us 1 of I 7/29/2005 3:08 PM The Observer News Enterprise 309 North College Ave. P O Drawer 48 Newton, NC 28658 NCDENR DWQ/Point Source Branch Attn: Carolyn Bryant 1617 Mail Service Center Raleigh, NC 27699-1617 Date(s) Run Description 06/24/05 Notice-NPDES/L North Carolina Catawba County Charge Balance 58.28 58.28 STEVE GARLAND... BEING DULY SWORN SAYS; That he is the publisher of the OBSERVER NEWS ENTERPRISE, a newspaper published at Newton, N.C. And that it is a newspaper of general circulation in Catawba County and surrounding counties. The Annexed Notice of Notice-NPDES/L was published in said newspaper and not a supplement thereof and is a true copy of the notice as it was published in the regular and entire edition of THE OBSERVER NEWS ENTERPRISE. Appearing each week, beginning on the 24th day of June 2005 and ending on the 24th day ofJune 2005 and that said OBSERVER NEWS ENTERPRISE was regularly distributed to the subscribers during said period. Sworn to and subscribed before me, this 204 day ofJune 2005 NOTARY PUBLIC My commission expires April 24, 2009 rutsuu NOTICE STATE OF NORTH CAROLINA ENVIRONMENTAL MAI\ AGEMENT COMMISSION/NPDES ' UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-161 NOTIFICATION OF IN- TENT TO ISSUE A NPDE. WASTEWATER PERMIT On the basis of thoroug staff review and applicatio of NC General Statut 143.21, Public law 92-50 and other lawful standard and regulations, the Norti Carolina Environments Management Commissioi proposes to issue a Nation al Pollutant Environmenta Elimination Systerr (NPDES) wastewater dis charge permit to the person(s) listed below effec tive 45 days from the pub lish date of this notice. Written comments re garding the proposed permi will be accepted until 3( days after the publish date of this notice. AU comment: received prior to that date are considered in the fina determinations regardinc the proposed permit. The Director of the NC Divisior of Water Quality may decide to hold a public meeting foi the proposed permit shoulc the Division receive a signif- icant degree of public inter- est. Copies of the draft per- mit and other supporting in- formation on file used to de- termine conditions present in the draft permit are avail- able upon ren.-;s: and pay- ment of the costs of repro- duction. Mail comments and/or requests for informa- tion to the NC Division of Water Quality at the above address or call the Point Source Branch at (919) 733-5083, extension 520. Please include the NPDES permit number (attached) in any communication. Inter- ested persons may also visit the Division of Water Quali- ty at 512 N. Salisbury Street, Raleigh, NC 27604- i148 between the hours of 8:00 a.m. and 5:00 p.m. to review information on file. NPDES Permit Number NC0025542, City of hickory - Catawba County, has ap- plied for renewal of its per- mit for a facility discharging treated wastewater to the Lyle Creek in the Catawba river Basin. Currently fecal coliform and total residual chlorine are water quality limited. This discharge may affect allocations in this por- tion of the receiving stream. Pub: Friday, June 24, 2005. SOC PRIORITY PROJECT: Yes_ No X To: Permits and Engineering Unit Water Quality Section Attention: Carolyn Bryant Date: August 18, 2004 NPDES STAFF REPORT AND RECOMMENDATION County: Catawba MRO# 04-63 Permit No. NC0025542 PART I - GENERAL INFORMATION 1. Facility and address: City Of Hickory, Catawba WWTP P.O. Box 398 Hickory, North Carolina 28603 2. Date of investigation: August 12, 2004 3. Report prepared by: Samar Bou-Ghazale, Env. Engineer.' 4. Persons contacted and telephone number: Mr. Watkins Bradberry, ORC, (828) 323-7500. 5. Directions to site: From the intersection ofNC Hwy 10 and 6th Avenue, NE, in the Town of Catawba, travel east on 6th Ave., NE. The WWTP is located at the end of 6t Ave., NE. 6. Discharge point(s). List for all discharge points: Latitude: 35 ° 42' 55" Longitude: 81 ° 04' 25" Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map. USGS Quad No.: E 15 NE USGS Name: Catawba, NC 7. Site size and expansion area are consistent with application? Yes X NoIf No, explain: 8. Topography (relationship to flood plain included): Facilities are not located in the 100-year flood plain. Slopes range from 3- 5%. 9. Location of nearest dwelling: Approximately 400 feet from WWTP site. 10. Receiving stream or affected surface waters: Lyle Creek_ a. Classification: WS-IV CA b. River Basin and Subbasin No.: Catawba 030832 c. Describe receiving stream features and pertinent downstream uses: The receiving stream is a large creek that discharges to lake Norman. Lake Norman is used as a source of water supply and for primary recreation. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: 0.225 MGD (Ultimate Design Capacity) b. What is the current permitted capacity of the wastewater treatment facility? 0.225 MGD c. Actual went capacity of the current facility (current design capacity)? 0.225 MGD d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: N/A. e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The existing facilities consists of dual bar screens, two aeration basins, two secondary clarifiers, chlorine contact basin (gas disinfection), instrumented flow measurement, and an aerated sludge holding tank. £ Please provide a description of proposed wastewater treatment facilities: N/A. g. Possille toxic impacts to surface waters: N/A. h. Pretreatment Program (POTWs only): In compliance. 2. Residuals handling and utiii7ation/disposal scheme: Sludge is removed as necessary and transported to the Ifickory Regional Compost Facility (WQ0004563). The Hickory Regional Compost Facility converts all biosolids to a class "A" compost marketed as "Catawba ORGRO". 3. Treatment plant classification (attach completed rating sheet): Class II (no change ofraimg, no rating sheet attached). 4. SIC Code(s): 4952 Primary: 01 Secondary: Page 2 Main Treatment Unit Code: 05003 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? NIA. 2. Special monitoring or limitations (including toxicity) requests: None. 3. Important SOC, JOC or Compliance Schedule dates: N/A 4. Alternative Analysis Evaluation: (Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated): N/A 5. Air quality and/or groundwater concerns or hazardous materials utilized at this facility that may impact water quality, air quality or groundwater? No known air quality, groundwater or hazardous materials concerns. 6. Other Special Items: In July 2003, the City of Hickory purchased the Catawba WWTP from the Town of Catawba. PART IV - EVALUATION AND RECOMMENDATIONS The Permittee, the City of Hickory, is applying for renewal of the facility's NPDES permit to discharge treated wastewater. The City of Hickory has upgraded the influent and effluent flow measuring devices and is in the process of budding a new chlorine room. No major modifications have taken place at the facility. Pending review and approval by the P&E, it is recommended that the permit be renewed as requested. ass Signature of Report ' arer Water Quality ; egional Supervisor Date Page 3 4111ek0ryre Business and Pleasure Grow Together t' June 8, 2004 Mrs. Valery Stephens NCDENR/DWQ/Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 /UMxs Public Utilities Administration J U L 1 2004 DEHR - WA fFR no1.°:t.TY POINT SG :;.:: :.;..,lCH City of Hickory Post office Box 398 Hickory, NC 28603-0398 Telephone 828.323-7427 Fax 828.323.7403 kgreer@ci.hickory.nc.us Subject: Hickory -Catawba WWTP (NPDES # NC 0025542) Permit Renewal Application Dear Mrs. Stephens: Attached please find the completed renewal application package including Sections A, B, C, E, Sludge Management Plan Narrative, Site Topographic Map and Process Flow Diagram for the above referenced site. This application is requesting renewal of the existing permit with no capacity modifications having taken place at the facility with the exception of ownership and sludge disposal methods. The City of Hickory has upgraded various components of this operation since purchasing in July 2003. The influent and effluent flow measuring devices have been replaced, updated lab equipment has been purchased and instituted and a new chlorine room has been constructed. Thank you in advance for your cooperation and assistance in completing this renewal application. Should you have any questions or desire additional information, please do not hesitate to contact me at (828) 323-7427 or at kgreer@ci.hickory.nc.us. Sincerely, Kevin B. Greer, PE Public Services Manager PC: Gene Haynes, Utilities Resource Director Watkins Bradberry, ORC — HCWWTP Shawn Pennell, Collection System Superintendent Bob Shaver, Back-up ORC HCWWTP GREATER HICKORY METRO c orb Where Business and Pleasure Grow Together June 8, 2004 Subject: Biosolids Management Plan for Hickory -Catawba Wastewater Treatment Plant NPDES # NC 0025542 To Whom It May Concern: The City of Hickory owns and operates three wastewater treatment facilities: Hickory -Catawba WWTP (NPDES # NC 0025542), Northeast WWTP (NPDES # NC 0020401) and Henry Fork WWTP (NPDES # NC 0040797). All city owned wastewater facilities transport biosolids generated via road tractor and tanker to the Hickory Regional Compost Facility (WQ 0004563). The Hickory Regional Compost Facility then commingles and processes to convert all biosolids to a Class "A" compost marketed as "Catawba ORGRO". The Hickory Regional Compost Facility has operated for over eight (8) years without a significant shut down. In the unlikely event of a shut down at this facility, the City of Hickory has an agreement with the Catawba County Landfill which allows Hickory to thicken biosolids to 9.0% then dispose of directly in land fill cells. This alternative is to meet the emergency backup operation requirement. GREATER HICKORY METRO