NC0026573_Biosolids Investigation_20140131

9V
IFYCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvaria, III
Governor Director Secretary
January 31, 2014
Kent A. Lackey, P.E.
Associate Vice President,Water Division
Black & Veatch International Company
Suite 240 10715 David Taylor Drive
Charlotte, NC 28262
Subject: Disposal options for biosolids (residual)
City of Morganton
Wastewater Treatment Facility
Burke County, NC
Dear Mr. Lackey,
The Division of Water Resources (DWR) has explored the disposal options available for the
biosolids recently found at the subject facility. Our goal was to make every effort to identify
affordable disposal options that comply with applicable regulations. In examining these options,
it seems the disposal options are limited and although the emplacement date is unknown,
current regulations for residualdisposal would apply. Applicable regulations may be found in
15A NCAC 2T.1100.
For the 2000 cubic yards of biosolids to be excavated to stabilize the slope, disposal in
accordance with 15A NCAC 2T is required which would include disposal utilizing one of the
following:
1. Landfill,
2. Off -site land application via a Class B permit,
3. Process through the Class A distribution of residual solids permit WQ0002127,
4. On -site disposal at a different location via a surface disposal permit or,
5. Incineration
WATER QUALITY REGIONAL OPERATIONS SECTION
North Carolina Division of Water Resources —Asheville Regional Office
2090 U.S. Highway 70, assurance, N.C. 28778
Phone[phone]
FAX [phone]
Internat: h2o.encstate.ncus
An Equal Opportunity/AtAnnative Action Employer

Mr. Lackey
January 31, 2014
Page 2 of 2
If the City desires to dispose of the excavated residuals by either surface disposal or off -
site land application, a permit will be required prior to disposal that sets minimum
criteria pursuant to 15A NCAC 2T.
For the biosolids remaining in place following slope stability operations:
1. Conduct a limited groundwater assessment to determine if the biosolids have impacted
groundwater. The Division will be available to review a workplan for this effort to assist
if requested. If groundwater is not impacted, no further action will be required. If
groundwater is impacted, the Division will require that a compliance boundary be
established pursuant to 15A NCAC 2L .0107 through the existing NPDES permit.
Groundwater monitoring would be required to determine compliance with 15A NCAC
2L. Groundwater monitoring requirements would then be added to the existing NPDES
permit. Violations of groundwater quality at the compliance boundary would need to be
addressed pursuant to 15A NCAC 2L .0106.
2. Excavate and dispose of pursuant to 15A NCAC 2T.
The Division fully acknowledges that the City of Morganton is expending significant funds
toward upgrades to the wastewater plant infrastructure. With these costs and the related SOC
timeline, addressing the biosolids can be accomplished on a variable timeline. We are available
to discuss these issues. Please contact me when you have had a chance to reviewthese
options. I can be reached at bev.orice()ncdenr.aov or at [phone].
Sincerely, D
Beverly Price
Environmental Specialist
cc.: Jon Risgaard —DWR WQROS, Raleigh
G:\WR\WQ\Burke\Wastewater\Non-discharge\City of Morganton\Morganton Uncovered Biosolids LetterN2
2013.docx