WQ0004563_More Information (Received)_20060127

Where Business and Pleasure Grow Together
Public Utilities
CERTIFIED MAIL RETURN RECEIPT REQUESTED
January 23, 2006
Ms. Shannon Mohr Thornburg, Environmental Engineer II
NC DENR-DWQ, Aquifer Protection Section, Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
SUBJECT
City of Hickory
Post Office Box 398
Hickory, NC 28603-0398
Phone: [phone]
Fax: [phone]
email: [e-mail]
RECEIVED j ?; D1,010
AQUIFER r-1r5(T "r f'3n,j CFiC i IGN
JAN 9 tl 2000"
p C CU 0 W
FEB 2P )5
NC DENR MR0
DWQ -Aquifer Protection
tpr i ate air urn n n n a s�3
Hickory Regional Compost Facility & Catawba ORGRO Distribution Program
Distribution of Residuals Solids (503)
Catawba County
Dear Ms. Thornburg:
The purpose of this correspondence is to respond to your additional information request received
January- 3, 2006 regarding the above referenced application. This response letter is formatted to
match the order of the request letter for ease of reference. Responses are as follows:
General
1) The intent of this application submittal is to renew the Hickory Regional Compost Facility
and Catawba ORGRO Distribution Program (503). We do not wish to begin a Residuals
Land Application Program. We apologize for making the submittal on the wrong forms
and thank you for your willingness to consider the information submitted.
Form NDRLAP
1) Thank you for the rule clarification regarding operator in responsible charge requirements.
CC) .A FS

Lr Thornburg, Environmental Engineer II
Page Two
Form RSCA
1) The only alteration that needs to be made to Condition III. 3. a. of the existing permit is to
move the Town of Catawba WWTP NC 0025542 from the Catawba County allocation to
the City of Hickory allocation. After making this change the City of Hickory will have
the: Henry Fork WWTP, Northeast WWTP, Town of Catawba WWTP and Hickory
Water Treatment Facility. Catawba County's allocation will include Town of Claremont
WWTP (2), Town of Maiden WWTP, City of Newton WWTP, and Septage Haulers.
2) The desire of the Consortium is for the City of Conover's Southeast WWTP to remain an
approved Residuals Source —Generating Facility for the Hickory RCF since they have an
active NPDES permit.
3) Attached please find vicinity maps for each residuals source — generating facility with the
exception of the septage haulers. The vicinity maps are attached in the order of the RSCA
forms on the original submittal.
4) The total volumes listed in Condition III. 3. a. and. Condition III. 3. b. of the existing
permit are still correct. The facility is designed for 7,300 dry tons per year of residuals and
a maximum of 14,000 dry tons per year of Class A EQ residual product.
5) As suggested, we have consulted with the Division's Laboratory Certification Unit to
receive a complete explanation of the corrosivity, reactivity, and ignitability test. The
contract laboratory we use has tested by EPA SW 846 Method 1030 as required. Attached
please find amended Application Page 3 of 8 for resubmission reflecting corrections to
Item II. 3. b.
6) During completion of the application documents the wrong alternative was selected for
Item II. 7. a. on Page 8 of 8 concerning salmonella monitoring. Alternative 5, Composting
Option should have been selected as the monitoring method. Attached please find
amended Application Page 8 of 8 for resubmission reflecting corrections to Item II. 7. a.
7) As of the time this submittal was originally made, field certification for temperature
measurements had not been applied for. However, we have made contact with the
Laboratory Certification Unit, obtained the necessary forms and we have submitted the
necessary forms and $100.00 application fee to obtain this certification. All thermometers
and probes were calibrated in compliance with federal requirements.

x Thornburg, Environmental Engineer II
Page Three
8) The narrative included in the existing permit is generally correct. We just have the
following modifications to request. The first amendment requested is to correct the fifth
sentence to read ..., one 26,500 — cubic foot silo for storage of amendment material, ...and
correct the twelfth sentence towards the end to read..., one three — stage 72,000 cfm
parallel train chemical scrubbing system...
9) All residuals source generating facilities are responsible for their particular facility and the
individual capabilities. The City of Hickory's Northeast WWTP is the only facility
currently with concerns over storage volumes. The City of Hickory. is nearing completion
of the design phase for an upgrade to this facility, which will address those concerns with
additional tankage and RDF thickener facilities. The Sludge Consortium with the City of
Hickory as Lead Agent is responsible for the Hickory RCF. Addition of the centrifuge has
proved to be a very good addition to the facility allowing for quicker processing of
residuals from tanks and improved percent solids influent to the reactor tunnels.
Thank you for speaking with me regarding this renewal application and for your assistance and
cooperation through this permit renewal application process. We have completed the above
information and all attached forms in response to the requests for additional information. After
speaking with the sludge consortium partners, contract operator and you, I feel this response will
answer all the questions. However, should you need additional information please do not hesitate
contacting me at [phone] or via e-mail @ [e-mail].
Sincerely,
Kevin B. Greer, PE
Assistant Public Services Director
Attachments
pc: Mick Berry, City Manager, City of Hickory
Chuck Hansen, PE/Public Services Director/City of Hickory
Jimmy Clark, Public Works Director/City of Conover
Barry Edwards, PE/Director of Engineering & Utilities/Catawba County
Wayne Carroll, Veolia Water North America — South

VICINITY MAPS:
✓ CITY OF HICKORY NORTHEAST WWTP
✓ CITY OF HICKORY CATAWBA WWTP
✓ CITY OF HICKORY HENRY FORK WWTP
✓ CITY OF CONOVER SE WWTP
✓ CITY OF CONOVER NE WWTP
✓ CITY OF CLAREMONT MCLIN CREEK WWTP
✓ CITY OF CLAREMONT NORTH WWTP
✓ CITY OF MAIDEN WWTP
✓ CITY OF NEWTON CLARK CREEK WWTP

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Facility Information
ode:
35' 47' 64" Sub -Basin: 03-08-32
leitude-
81° 18, 001,
d #:
D 13 SE (Bethlehem)
Stream Class:
WS-TV & B
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NC0020401
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Facility Information
dude:
35°42'55" Sub -Basin: 03-08-32
�neitude:
81°04'25"
Quad #_
E14NE
St -earn Class:
WS-IV CA
Receiving Stream
Lyle Creek
Permitted Flow:
0.225 MGD
Facility '
Location.
City of Eckory-Cataw aWWTF
North
NCO025542
Catawba Countu

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Facility Information
nude:
35039'49" Sub -Basin: 03-08-35
-,_,oneitude:
81°19'30"
Quad #:
E13NE
St r� Class:
C
Receivinw Stream:
Henry Fork River
Permitted Flow: 9.0 MGD
Facility v
Location
Hickory -Henry Fork W W7
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35' 44' 12"
Longitude:
81' 11' 25"
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USGS Quad #:
E14NW
River Basin #:
. 03-08-32
Receiving Stream:
Lyle Creek
Stream Class:
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City of Conover
Conover NE WWTP
Catawba County
NC0024252

City of
Claremont
McLin Creek WWTP
tude: 35° 41' 44" N
State Grid: E 14 NE / E 14 SW
!itude: 81° 07' 19" W
Permitted Flow: 0.300 MGD
iving Stream: McLin Creek
Drainage Basin: Catawba River Basin
im Class: C
Sub -Basin: 03-08-32

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City of Claremont Facility �
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Grid/Ouad: E 14 NW / Newton, NC Permitted Flow: 0.100 MGD not to scale
ide: 35' 43' 21" N Longitude: 81' 09' 18" W
vine Stream: Mull Creek Sub -Basin: 03-08-32 NPDES Permit No. NC0032662
sage Basin: Catawba River Basin Stream Class: W.4-TV No rt, h. —

A.I.

AMENDED PAGE 3 OF 8
ITEM II.3. b.

Specify the following regarding treatment and storage volumes available at the facility:
Type and volume of residuals treatment: In -vessel composting of Municipal biosolids. Current loadings
are at 12.33 Dry Tons per Day 1,580,750 Gallons per Month, or 77,110 Gallons per day. See attachment 2c
for justification
Type and volume of residuals storage (i.e., outside of residuals treatment units): Two 100,000 storage
tanks for incoming sludge and up to 60 days of maturation and storage on the aerated concrete curing pad.
Current discharge production is 3,048 &y tons per day. See attachment 2c for justification.
H. RESIDUALS QUALITY INFORMATION (See Instruction C.):
1. Specify if residuals are regulated under (check one): ® 40 CFR Part 503 or ❑ 40 CFR Part 257.
2. Specify if residuals are intended for (check one):
® Land Application/Distribution (Class A or Equivalent).
Complete all items EXCEPT Items Il. 4b., 4c., 7b., and 7c.
❑ Land Application (Class B or Equivalent).
Complete all items EXCEPT Items II.4a., 4c., 7a., and 7c.
❑ Surface Disposal.
Complete all items EXCEPT Items II. 4a., 4b., 5., 7a., 7b., and 8.
3. Hazardous Waste Determination: Complete the following to demonstrate that the residuals are non-
hazardous under RCRA:
a. Are the residuals are listed in 40 CFR §261.31-§261.33: ❑ yes ® no.
If yes, list the number(s):
b. Specify whether or not the residuals exhibit any of the characteristics defined by 40 CFR §261.21-
§261.24: ❑ yes ® no. Fill in the following tables with the results of the latest toxicity
characteristic leaching procedure (TCLP) analysis as well as those for corrosivity, ignitability, and
reactivity: laboratory: Pace Analytical and date of analysis: 11/10/04-8/29/05
Passed corrosivity test: ® yes ❑ no. pH: 7.53 s.u. (2 <pH < 12.5).
Passed ignitability test: ® yes ❑ no. Flashpoint: _<0.8 mm/sec_ °F (> 140°F).
Passed reactivity test: ® yes ❑ no. HCN: <1.0 mg/kg (<250) & HzS: <10 mg/kg
(<500).
TCLP Parameter
Limit
(mg/L)
Result
(mg/L)
TCLP Parameter
Limit
(mg/L)
Result
(mg/L)
Arsenic
5.0
N/D
Hexachlorobenzene
0.13
N/D
Barium
100.0
.5
Hexachloro-1,3-Butadiene
0.5
N/D
Benzene
0.5
N/D
Hexachloroethane
3.0
N/D
Cadmium
1.0
N/D
Lead
5.0
.044
Carbon Tetrachloride
0.5
N/D
Lindane
0.4
N/D
Chlordane
0.03
N/D
Mercury
0.2
N/D
Chlorobenzene
100.0
N/D
Methoxychlor
10.0
N/D
FORM: RSCA 02/02
Page 3 of 8
Attachment Order 2

AMENDED PAGE 8 OF 8
ITEM II. 7. a.

her Pollutants Determination: Specify whether or not there are any other pollutants of concern in the
iduals and list the results of the latest analyses : None
7. Pathogen Reduction Determination: Specify which alternative(s) will be used to meet the pathogen
reduction requirements:
a. For Class A or Equivalent:
❑ A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry
solids.
OR
® A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry
solids.
AND one of the following (except for residuals regulated under 40 CFR Part 257 that are to be distributed):
❑ Alternative 1 [40 CFR §503.32 (a)(3)] - Time/Temperature Compliance.
❑ Alternative 2 [40 CFR §503.32 (a)(4)] - Alkaline Treatment.
❑ Alternative 3 [40 CFR §503.32 (a)(5)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
❑ Alternative 4 [40 CFR §503.32 (a)(6)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
® Alternative 5 (40 CFR §503.32 (a)(7)] - Process to Further Reduce Pathogens (PFRP).
Specify one: ® composting, ❑ heat drying, ❑ heat treatment, ❑ pasteurization,
❑ thermophilic aerobic digestion, ❑ beta ray irradiation, or ❑ gamma ray irradiation.
❑ Alternative 6 140 CFR §503.32 (a)(8)] - PFRP-Equivalent Process.
Explain:
b. For Class B or Equivalent:
❑ Alternative 1 (40 CFR §503.32 (b)(2)] - Fecal Coliform Density Demonstration.
❑ Alternative 2 [40 CFR §503.32 (b)(3)] - Process to Significantly Reduce Pathogens (PFRP).
Specify one: ❑ aerobic digestion, ❑ air drying, ❑ anaerobic digestion,
❑ composting, or ❑ lime stabilization.
❑ Alternative 3 [40 CFR §503.32 (b)(4)] - PSRP-Equivalent Process.
Explain:
❑ Not Applicable - Regulated under 40 CFR Part 257 with NO Domestic Wastewater Contribution.
c. For Surface Disposal:
❑ Alternative for Surface Disposal Units Only [40 CFR §503.33 (b)(11)] - Soil/Other Material Cover.
❑ Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item IL 7a. above.
❑ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
❑ Not Applicable - Regulated under 40 CFR Part 257 with NO Domestic Wastewater Contribution.
FORM: RSCA 02/02 Page 9 of 8 Attachment Order 2

_/_�_�
QUIFER PROTECTION REGIONAL STAFF REPORT
16
Protection Central Office
Central Office Reviewer: Shannon Thornburg
County: Catawba
Permittee/Owner: City of Hickory
Application No.: W00004563
L GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal ❑ Renewal with mod.
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
❑ Land Application of Residuals ❑ Attachment B included ® 503 regulated ❑ 503 exempt
® Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (including in situ remediation)
Was a site visit conducted in order to prepare this report? ❑ Yes or ❑ No.
a. Date of site visit: 01/20/2006
b. Person contacted and contact information: Wayne Carroll, Veolia Water, 828/465-1.401
c. Site visit conducted by: Ellen Huffman MRO Shannon Thornburg_& David Goodrich, Central Office
d. Inspection Report Attached: ❑ Yes or ® No.
2. Is the following information entered into the BIMS record for this application correct?
® Yes or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location:
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater):
For Disposal and Injection Sites: N/A
a. Location(s):
b. Driving Directions:
c. USGS Quadrangle Map name and number:
d. Latitude: Longitude:

QUIFER PROTECTION REGIONAL STAFF REPORT
.L AND MODIFICA TIONAPPLICA TION
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ❑ Yes or ❑ No. N/A
Operator in Charge: Certificate #:
Backup- Operator in Charge: Certificate #:
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No.
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit (drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No. If yes, please explain:
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
® Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ❑ Yes or ❑ No. N/A
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes ❑ No ® N/A
8. Will seasonal or other restrictions be required for added sites? ❑ Yes ❑ No ® N/A
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No.
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct?
® Yes or ❑ No. If no, please explain:
11. Were monitoring wells properly constructed and located? ❑ Yes or ❑ No ® N/A.
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? ® Yes or
❑ No ❑ N/A. Please summarize any findings resulting from this review: An NOV was issued for the 2005
annual report by Central Office. This NOV will not require an enforcement action.
13. Check all that apply: ® No compliance issues, see note above; ❑ Notice(s) of violation within the last permit
cycle; ❑ Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently
under moratorium.
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? ❑ Yes
❑ No ❑ Not Determined ® N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
0 Yes or ® No ❑ N/A. If yes, please explain:

,QUIFER PROTECTION REGIONAL STAFF REPORT
TION AND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.: None.
2. Attach Well Construction Data Sheet - if needed information is available N/A.
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item: None.
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition: None.
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a reason for each special condition: None.
7. Recommendation: ® Issue ❑ Hold, pending receipt and review of additional information by regional
office; ❑ Hold, pending review of draft permit by regional office; ❑ Issue upon receipt of any needed
additional information; ❑ Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APS regional supervisor: �� \ Y. ] �� " � ,0. CC^
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.