WQ0004563_Additional Information Request_20051229

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
December 29, 2005
MR. MICK W. BERRY, CITY MANAGER
CITY OF HICKORY
POST OFFICE BOX 398
HICKORY, NORTH CAROLINA 28603
JAN - 4 2006
Protection
Subject: Application No. WQ0004563
Additional Information Request
City of Hickory
Hickory Regional Compost Facility and
Catawba ORGRO Distribution Program
Distribution of Residual Solids (503)
Catawba County
Dear Mr. Berry:
The Division of Water Quality's (Division) Land Application Unit has completed a thorough technical
review of the subject permit renewal application package. At this time, additional information is required
before we may continue our review. Note that detailed technical reviews of the package has not yet been
completed by this office, the Aquifer Protection Section of the Division's Mooresville Regional Office, or the
Division's Groundwater Section. Therefore, additional requests for information may be necessary to address
any comments generated by those reviews. In the meantime, however, please address the following items no
later than January 28, 2006:
General:
1. The incorrect application forms were used to prepare this permit renewal application package.
Form NDRLAP (i.e., "Non -Dedicated Residuals Land Application Programs") and the related
attachment forms are to be used to apply for permits associated with residuals land application
programs and not for permits associated with residuals distribution programs. The correct form is
Form DRS (i.e., "Distribution of Residuals Solids"). Since all of the information requested by
Form DRS has been included in the very thorough preparation of the package that was submitted,
the Division will not require that the correct application form be completed. However, please
confirm that it is desired to renew this permit as a residuals distribution program and not as a
residuals land application program.
Form NDRLAP:
1. Item II. 2. on Page 3 of 5 lists the operator license type of the operator in responsible charge
(ORC) and the back-up ORC as the affiliation. Note that the Division is interested in the
affiliation of the ORC and back-up ORC themselves (i.e., by whom are they employed). Note
further that, at this time, the Division does not classify residuals distribution programs as there is
no operator license associated with this type of program; therefore, it is not necessary for the
Permittee to classify an ORC and back-up ORC for this permit. No response is. required to
respond to this comment other than to make note of this explanation so that fiiture packages may
be prepared correctly.
NorthCarolina
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Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: www.ncwaterquality.org 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
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Mr. Mick W. Berry
December 29, 2005
Page 2
Form RSCA:
1. Please confirm that the information listed in Condition IIl. 3. a. of the existing permit regarding
the residuals source -generating facilities that contribute to the Hickory RCF is still correct and
accurate. If not, please provide details as how the listed information should be changed.
Information presented in the permit renewal application package indicates that the City of
Conover's Southeast WWTP has been closed. The Division's database shows that the NPDES
permit for this facility is still active and was renewed as late as July 14, 2005. Please clarify
whether or not this facility should be listed among the residuals source -generating facilities that
are approved to haul residuals to the Hickory RCF for treatment in the renewed permit, when
issued.
3. Please provide a vicinity map that depicts the location of each of the residuals source -generating
facilities that contribute to the Hickory RCF. The Division will attach these as well as the vicinity
map for the Hickory RCF that was provided in the submitted permit renewal application package
to the renewed permit, when issued.
4. Item I. 7. on Page 2 of 8 states that 7,300 dry tons per year of residuals are requested to be
certified to the Hickory RCF. Please confirm that this value represents the maximum volume of
residuals that is able to be accepted for treatment at the Hickory RCF and that the resultant
maximum volume of Class A EQ residuals product would be 14,000 dry tons per year. Basically,
the Division is asking for confirmation that the total volumes listed in Condition III. 3. a. and
Condition I11. 3. b. of the existing permit are still correct and accurate. If not, please provide
details as how these values should be changed.
Item 11. 3. b. on Page 3 of 8 left the checkbox that indicates whether or not the Class A EQ
residuals product passed the ignitability test blank. The cover letter submitted along with the
permit renewal application package also expressed some confusion over this analytical test. The
Division's Land Application Unit has consulted with the Division's Laboratory Certification Unit
regarding this issue. The guidance provided indicates that your contract laboratory should be
using EPA's SW 846 Method 1030 to determine ignitability of a solid material. The contract
laboratory is correct in stating that a closed -cup flashpoint method (i.e., SW 846 Method 1010) is
to be used for liquid material. From the guidance provided thus far, Method 1030 consists of two
tests: an ignitability test, during which it is determined whether or not the material is flammable,
and a burning rate test, during which it is detenmined whether how quickly the material burns.
The steps and the limits associated with these two steps are different depending on whether the
material is metallic or non-metallic. The stated result of <0.8 millimeters per second indicates
that the Class A EQ residuals product passed the burning rate test (i.e., Step 2 of Method 1030 for
non-metallic substances). It is suggested that the contract laboratory contact the Division's
Laboratory Certification Unit regarding the proper method to use, what steps/replicates are
required with the proper method, obtaining a certification for this method (i.e., if it does not
already have one), how to report the results to satisfy the Division's reporting requirements, etc.
No response is required to respond to this comment other than to make note of this explanation.
The Division will also include this guidance in the cover letter of the renewed permit, when
issued.
Item II. 7. a. on Page 8 of 8 states that the Permittee meets the Class A requirements through
monitoring of salmonella sp. density and compliance with 40 CFR §503.32(a)(3) (i.e., Alternative
1). From review of the Hickory RCF's historical information and annual reports, it appears as if
the composting option of Alternative 5 (i.e., 40 CFR §503.32(a)(7)) is used. Please clarify this
apparent discrepancy.

Mr. Mick W. Berry
December 29, 2005
Page 3
Form RSCA (continued):
7. Please clarify whether or not a field certification for the temperature parameter has been applied
for and received from the Division's Laboratory Certification Unit. The person/company
performing field measurements of temperature may be subject to the certification requirements
under 15A NCAC 2H .0800. If this field certification has not been obtained, it is suggested that
the Divisions' Laboratory Certification Unit be contacted as soon as possible for further guidance.
8. Please confirm that the narrative of the permitted unit processes at the Hickory RCF as detailed in
the description of the existing permit is still correct and accurate. If not, please provide details as
how this description should be changed.
The cover letter of the existing permit for this facility/program corresponds the Division's
concerns regarding the minimal volume of storage available for residuals coming in for treatment.
It was suggested that the Permittee evaluate the quantity of storage volume available at the
Hickory RCF as well as that available at all of the residuals source -generating facilities that
deliver residuals to it for treatment. It was states that the Division would investigate the
Permittee's progress on this evaluation during this permit renewal application package review.
Please comment on the status/result of this evaluation accordingly.
Please reference the subject permit application number when providing the requested information.
Two copies of all revised information should be submitted to my attention at the address on the first page of
this correspondence.
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 this request are still the responsibility of the
applicant. In addition, any omissions made in responding to the requested additional information items may
result in future additional information requests and delays in the issuance of a final permit. Therefore, read
each additional information item carefully, and provide the information that is requested as well as any
information that results from changes made as a result of this additional information request. If there is any
question about what information is being requested or is desired, please do not hesitate to contact me at any
time at [phone], or at [e-mail], and I will be happy to provide additional
explanation as required.
Thank you in advance for your cooperation and assistance.
Since ely,
Yannon Mohr Thornburg
Environmental Engineer II
Land Application Unit
cc: Mr. Wayne Carroll, Veolia Water North America Operating Services, L.L.C.
Mr. Kevin B. Greer, P.E., City of Hickory
Mr. James W. Meyer, Laboratory Section - Laboratory Certification Unit
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Permit File WQ0004563