WQ0004563_Staff Report_20240223

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0004563 Minor(?) Modification
Attn: Zachry Mega Non -Discharge CO permitting group
Facility name: Hickory DCAR Permit
From: Edward Watson
Mooresville Regional Office
Note: This form has been adapted from the non -discharge fg acili , staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 0212312024
b. Site visit conducted by: Edward Watson & Hannah Slep
Inspection report attached? ❑ Yes or ® No
c. Person contacted: Andrew Foy, Assistant Public Utilities Director, and their contact information: (YL8) 323 -
742 7 ext.
e. Driving directions: 4014 River Rd., Hickory, NC 28602
2. Discharge Point(s): The new treatment system is located at
Latitude: N 35' 46' 29"
Latitude:
Longitude: W 80' 48 " 50 "
Longitude:
3. Receiving stream or affected surface waters: Henry Fork
Classification: C (stream subclassification 11-129-1)
River Basin and Subbasin No. Catawba
Describe receiving stream features and pertinent downstream uses: no information on downstream intakes,
Henry Fork drains to South Fork Catawba a few miles below facility.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ® N/A
WWTP has appropriately certified ORC, this new process hasn't gone through WPCSOCC for classification yet.
ORC: Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Henry Fork WWTP, NPDES #NC0040797, facility under construction, treatment
units described in application.
Proposed flow: 14,000 GPD influent flow
FORM: WQROSSR 04-14 Page 1 of 4

Current permitted flow: 14,000 GPD. The total maximum cake production for the system is 12.3 DT/Day of
DCAR material.
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No
If no, please explain: N/A
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ® Yes or ❑ No
If yes, please explain: Location change, treatment method is being changed and storage is being added to the
facility.
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No
If no, please explain: N/A
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: New treatment method proposed in this modification.
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
11. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ❑ No
If yes, please explain: N/A
13. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: Only if facility does not operate as a non -discharge system. Material
might enter Henry Fork during an extreme weather event.
16. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 4

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the Non -Discharge Unit Central Office to obtain through an additional
information request:
Item
Reason
I
Please submit a diagram of the treatment incinerator that displays the sample
ports and temperature check locations through the treatment process.
2
Present the Operation and Maintenance plan for the facility. Among the items,
this should include belt feed maintenance.
3
Please correct the emergency response name to NCDEQ, MRO.
The contributors (Consortium) members to the new facility are still to be
determined by the permittee. Please provide the names of the consortium
4
members once they have been determined so they are listed in the permit. MRO
would also like to know members who are not participating so that NPDES
inspectors can appropriately follow up with how residuals are being handled at
each of the other generatingjacilities.
5
Please submit the information that is to be provided to the receiver of the DCAR
product.
3. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office.
® Issue upon receipt of needed additional information.
❑ Issue
❑ Deny (Please state reasons: )
4. Signature of report preparer: Edward Watson, Hydrogeologist-DWR WQROS-MRO 2/23/2024 .
oocusi9ned by: 2/2 3/2024
5. Signature of regional supervisor: FA4,4w H Nu" Date:
F161 FB69AMUA3...
FORM: WQROSSR 04-14 Page 3 of 4

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The new treatmentfacility is being constructed under A. to Cpermit 040797A01. Facility modifications were reviewed
during the site visit.
DCAR 06-16 FORM, INDICATES: A major modification shall be defined as any permit modification that increases
the generating facilities residual drying tonnage: add additional sources, or includes the addition of new treatment or
storage unit/processes not previously permitted.
This modification will change the process of how the DCAR treatment is performed. Since the process method is
different than the previous method, should this be a major modification rather than a minor modification?
1. The MRO has viewed the new facility. The location of the treatment system meets the required setbacks for the
permit.
2. MRO staff has reviewed the storage location during the site visit.
3. The spill plan was reviewed during the site visit.
4. The new treatment system will allow for increased production under the DCAR permit. The current flow is set at
14, 000 DTY. Is this volume expected to increase production with the new treatment system? The application is
calling for the same volume to be produced. However, the permittee may wish to consider increasing the total
volume.
S. The sliding scale in Attachment B of the permit will dictate the number of sampling events required based on
production amount.
6. Please provide information for the decommissioning of the Hickory Regional Composting facility (RCF) to
complete the removal of this process from the permit.
7. Does the RO need to observe closure activities or is there a requirement for the RO to receive any documentation
for the RCF closure?
8. Please incorporate belt feed maintenance to the O&Mprocess for the facility.
9. ORC and Backup Orc information needs to be presented to the RO prior to system startup if so required by
WPCSOCC.
10. Please notes the RO prior to cake production, so the RO can be present to see startup.
FORM: WQROSSR 04-14 Page 4 of 4