WQ0006245_Final Permit_19940518

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
May 18, 1994
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
Jack King, City Manager
City of Statesville
Post Office Box 1111
Statesville, North Carolina 28687
Subject: Permit No. WQ0006245
City of Statesville
Distribution of Class A Wastewater Residuals
Iredell County
Dear Mr. King:
In accordance with your request for a permit amendment received on April 21, 1994, in the form of
a "Petition for a Contested Case Hearing", we are forwarding herewith a draft Permit No. WQ0006245 to
the City of Statesville. The objections expressed in your "petition" and the Divisions position on those
concerns are discussed below:
Objection 1: Condition 16 of Permit No. WQ0006245 places an extren7e prohibition on use of
this product.
Response 1: After doing further research concerning the use of a Class A product and additional
information presented to the Division in negotiations with other municipalities, the
Division agrees to delete this condition from the permit.
Objection 2: Condition II 3 of Permit No. WQ0006245 eliminates alternative storage area
without approval. The City of Statesville has stated in the permit application that
the defunct drying beds are to be utilized to store the finish product.
Response 2: When the permit was issued on March 21, 1994, the Division intended for the
issuance of the permit to signify that the alternative storage, the drying beds, were
approved. However, for clarity, the drying beds have now specified in the subject
condition.
Objection 3: Condition II 8 and II 9 should not be the permittee's responsibility except on the
plant site.
Response 3: Condition II 8 was intended to be the responsibility of the applier, which in this
case, is not the responsibility of the City of Statesville. Therefore, the Division
agrees to move this condition to the appropriate position, in Condition II 7.
Condition lI 9 was intended to be the responsibility of the processor and only on
the residuals treatment area, which in this case, is the responsibility of the City of
Statesville. Therefore, the Division will not move or rewrite this condition.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Page 2
Permit No. WQ0006245 DRAFT
May 18, 1994
Objection 4: Condition 1110 and II 11 should be the customer's responsibility.
Response 4: After doing further research concerning the use of a Class A product and additional
information presented to the Division in negotiations with other municipalities, the
Division agrees to delete Conditions H 10 and Conditions H 11 from the permit.
Objection 5: Condition I1I 2 requires testing of all residuals. Products derived from multiple
sources are considered one product and should be tested as such.
Response 5: The testing that the Division is requiring is to be done on the finished product. If
multiple residuals are to be blended prior to processing, then one test shall be
completed on the finished product. This was the intention of the permit condition.
The Division proposes to leave this condition unchanged.
Objection 6: All language that refers to this product as residuals should be changed to reflect it as
a single product. The term residuals should refer only to the constituent sludges
used to form the product.
Response 6: The Division considers even one product as "residuals" therefore the language in
the permit shall remain the same.
Please review this draft permit to see if the changes made with respect to your request are
satisfactory. If the terms and conditions of this draft permit are acceptable to the City of Statesville, please
inform this office by June 1, 1994 and the Division will proceed to issue the permit. Once the draft permit
is accepted, the City of Statesville should immediately file the "Notice of Withdrawal of Petition", a copy
of which is attached.
If you need additional information concerning this matter, please contact Mr. Michael D. Allen at
[phone].
Sincerely,
Preston 4oward, Jr., P.E.
cc: Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Jack Floyd, Groundwater Section Central Office
Ms. Betsy Mosely, Attorney General's Office

STATE OF NORTH CAROLINA
COUNTY OF Iredell
FILE No. 94 EHR 0493
CITY OF STATESVILLE
Petitioner,
V.
IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
DEPARTMENT OF ENVIRONMENT,
HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL
MANAGEMENT
Respondent.
NOTICE OF WITHDRAWAL
OF PETITION
Petitioner hereby withdraws its petition for a contested case hearing. No further proceedings
are needed or required to resolve the contested case captioned above.
This the day of , 19_.
Petitioner/Authority for Petitioner
CERTIFICATE OF SERVICE
I hereby certify that I have this day filed an original and one copy of this NOTICE OF
WITHDRAWAL in the Office of Administrative Hearings at the address specified below and that I
have, by first class mail, served a copy of the same on counsel for the Respondent at the address
specified below:
Office of Administrative Hearings
Post Office Drawer 27447
Raleigh, North Carolina 27611-7447 North Carolina Department of Justice
Post Office Box 629
Wm:
Raleigh, North Carolina 27602-0629
Petitioner/Attorney for Petitioner

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF CLASS A RESIDUALS
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
City of Statesville
IredeR County
FOR THE
continued operation of a wastewater residuals facility for the distribution of Class A residuals consisting
of dewatered sludge from the Fourth Creek WWTP being transported by an existing conveyor belt from
the existing Fourth Creek filter press facilities to a 53 foot long covered cleated feeder conveyor, two 25
cubic yard sludge storage hoppers (for dewatered Third Creek WWTP sludge and the Water Plant alum
sludge) with bottom screw conveyors to convey sludge from hopper to flanged connections above the 53
foot cleated feeder conveyor, a 25 foot long, 12 inch diameter twin screw sludge mixer, two (2) 12 foot
diameter by 23 foot straight wall (60 ton capacity) leg supported silos with variable speed volumetric
feeders and a common transfer screw conveyor to convey lime and/or kiln dust to the sludge mixer, a
covered cleated side wall conveyor from the end of the sludge mixer to the truck lading station, an
appropriate nonleaking transport truck(s) or approved equivalent to convey lime/ kiln dust mixed sludge,
protected pulse bins (where truck loaded sludge will be dumped and allowed to heat for pathogen
reduction), a 150 foot by 300 foot curbed sludge curing asphalt slab for treated sludge mix to be put in
windrows and allowed to continue to heat and then to dry including periodic turning with stormwater
swale and drain system draining back to the wastewater treatment facilities (walled and roofed pulse bins
along the up slope 300 foot side of sludge curing slab), all necessary measuring devices to ensure that each
truck load of mixed sludge reaches a pH of 12 for 2 hours and the temperature in the heated sludge is
maintained at a minimum of 70 degrees C for a minimum of 30 minutes and/or for measuring to ensure
that all of the subject sludges meet the requirements listed in Condition I.8, and all associated controls,
support structures, piping, and appurtenances for the distribution of approximately 3,900 dry tons per year
of residuals from the sources listed in Condition Il 2, to serve the City of Statesville, with no discharge of
wastes to the surface waters, pursuant to the application received on January 18, 1994, and in conformity
with the project plan, specifications, and other supporting data subsequently filed and approved by the
Department of Environment, Health and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until February 28, 1997, shall void Permit
No. WQ0006245 issued June 26, 1992 and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. The distribution of Class A residuals program shall be effectively maintained and operated
as a non -discharge system to prevent the discharge of any wastes resulting from the
operation of this program.
DRA
F�,f`

2. This permit shall become voidable in the event of failure of the residuals program to
adequately protect the assigned water quality standards of the surface waters and
groundwaters.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this program.
4. In the event that the residuals program is not operated satisfactorily, including the creation
of nuisance conditions, the Permittee shall take any immediate corrective actions as may be
required by the Division.
5. Diversion or bypassing of the untreated residuals or leachate from the residual treatment
facilities is prohibited.
7. All leachate must be reused as a wetting agent for the processing of residuals or routed to
the head of the treatment plant.
8. When wastewater residuals are sold or given away, one of the Class A pathogen
requirements in 40 CFR Part 503.32(a) and one of vector attraction reduction requirements
in 40 CFR Part 503.33 must be met. Additionally, an evaluation must be performed which
demonstrates the residuals ability to comply with this requirement. Upon request, a copy
of this evaluation must be submitted to the Assistant Chief, Technical Support Branch,
Division of Environmental Management, Post Office Box 29535, Raleigh, NC 27626-
0535.
In addition to the above, the Division has approved the following stabilization criteria for
the City of Statesville:
a. limekiln dust mixed sludge reaches a pH of 12 for 2 hours and the temperature in the
heated sludge is maintained at a minimum of 700 C for a minimum of 30 minutes.
b. N-Vino Soil Process
Alternative 1 Fine alkaline materials are uniformly mixed by mechanical mixing into
dewatered sludge to raise the pH to greater than 12 for seven days. The
dewatered sludge cake is then air dried (while pH remains above 12 for
at least seven days) through intermittent turning of windrows at least 30
days and until the solids levels reach and maintain a minimum of 65%
solids. A solids concentration of at least 60% is achieved before the pH
drops below 12. Mean temperature of the air surrounding the pile must
be above 50 C (41 OF) for the first seven days.
Alternative 2 Fine alkaline materials are uniformly mixed by mechanical mixing into
dewatered sludge to raise the pH to greater than 12 for at least 72 hours.
The sludge cake is then heated, while the pH exceeds 12, using
exothermic reactions or other thermal processes to achieve temperatures
of at least 520C (126F) throughout the sludge for at least 12 hours.
The stabilized sludge is then air dried (while the pH remains above 12
for at least three days) to at least 50% solids.
9. No residuals which tests, or is classified, as a hazardous or toxic waste under 40 CFR Part
261 shall be land applied or distributed and marketed.
H. OPERATION AND MAINTENANCE REQUIREMENTS
The residuals treatment facilities shall be properly maintained and operated at all times.
2 DR -AFT

2. No residuals other than the following are hereby approved for distribution in accordance
with this permit:
Permit Estimated Volume
Source County Number (Dry Tons/Year)
Fourth Creek WWTP Iredell NC0031836
Third Creek WWTP Iredell NC0020591 3,900*
Statesville Water Plant Iredell
* A maximum of 3,900 dry tons per year of combined wastewater and alum residuals
3. All residuals shall be adequately stored to prevent Ieachate runoff until treated. The
finished product may be placed on a concrete pad, placed under shelter or covered until
such time as it is distributed to the buyer. The City of Statesville may also use the defunct
drying beds to store the finished product with all leachate routed to the wastewater
treatment facility. If an alternate storage site is to be used, approval must be obtained from
the Division of Environmental Management.
4. No other residuals other than those specified under Condition II 2 above may be
distributed. The Permittee shall request and obtain a permit amendment from the Division
of Environmental Management for each additional residual source prior to acceptance of
that residual.
5. For a Class A residual to be sold or given away in bags or other container for application to
the land, the following must be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly
Average Concentrations (Dry Weight Basis) must be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters _ mgft mg&g
Arsenic
75
41
Cadmium
85
39
Chromium
3,000
1,200
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
.... -
Nickel
420
420
Selenium
100
36
Zinc
7,500
2,800
6. Upon classification of the facility by the Certification Commission, the Perrriittee shall
employ a certified residuals operator to be in responsible charge (ORC) of the residuals
program. The operator must hold a certificate of the type classification assigned to the
residuals program by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type to comply with the conditions of Title
15A NCAC 8A, .0202.

7. A label shall be affixed to the bag or other container in which residuals that are sold or
given away for application to the land, or an information sheet shall be provided to the
person who receives the residuals sold or given away in an other container for application
to the land. The label or information sheet shall contain the following information:
a. The name and address of the person who prepared the residuals that is sold or given
away in a bag or other container for application to the land.
b. A statement that application of the residuals to the land is prohibited except in
accordance with the instructions on the label or information sheet
c. Information on all applicable buffers including a 10 foot buffer between application site
and any public or private water supply source (including wells) and any stream, lake,
or river.
d. Residuals shall not be applied to any site that is flooded, frozen or snow-covered.
e. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
8. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals treatment area onto the adjacent property or into
any surface waters.
1. Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division of Environmental Management to insure
protection of the environment will be established and an acceptable sampling and reporting
schedule shall be followed.
2. Proper records shall be maintained by the Permittee tracking all residual activities. These
records shall include, but are not necessarily limited to the following information:
a. source, volume and analysis of each residuals
b. name of residuals' recipient, volume received, and intended use
3. A residuals analysis will be conducted every 60 days from the date of permit issuance by
the Permittee and the results maintained on file by the Permittee for a minimum of five
years.
The residuals analysis shall include but is not necessarily limited to the following
parameters:
Arsenic
Aluminum
Cadmium
Ammonia -Nitrogen
Chromium
Calcium
Copper
Nitrate -Nitrite Nitrogen
Lead
% Total Solids
Mercury
pH
Molybdenum
Phosphorus
Nickel
Plant Available Nitrogen (by calculation)
Selenium
Potassium
Zinc
Sodium
Magnesium
TKN
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4.
After the residuals have been monitored for two years at the above frequency, the Permittee
may submit a request to the Division for a permit modification for the reduction of the
frequency of monitoring for pollutant concentrations and for the pathogen density
requirements, but in no case shall the frequency of monitoring be less than once per year
when residuals sold or given away.
A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Permittee annually. The TCLP analysis shall include the following parameters (please note
the regulatory level in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
1, 1 -Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. All residuals included in this permit must be monitored every 60 days, from the date of
permit issuance, for compliance with condition I.8 of this permit. Data to verify
stabilization of the residuals must be maintained by the Permittee. The required data is
specific to the stabilization process utilized, but should be sufficient to clearly demonstrate
compliance with the Class A pathogen requirements in 40 CFR Part 503.32(a) and the
vector attraction reduction requirements in 40 CFR Part 503.33. In addition, the EPA
certification statements concerning compliance with pathogen requirements, vector
attraction reduction requirements and management practices must be completed every 60
days by the proper authority or authorities if more than one is involved, either the person
who generates the residuals or the person who prepares the residuals to be sold or given
away.
After the residuals have been monitored for two years at the above frequency, the Permittee
may request a permit modification for the reduction of the frequency of monitoring for
pollutant concentrations and for the pathogen density requirements, but in no case shall the
frequency of monitoring be less than once per year when residuals are sold or given away.
6. Three copies of all required monitoring and reporting requirements as specified in
conditions III 1, III 2, III 3, 1114, and III 5 shall be submitted annually on or before March
1 of the following year to the following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535

7. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or fast knowledge of the occurrence of any of
the following:
a. Any occurrence with the distribution program which results in the land application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving
waters.
c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit or the parameters on
which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V . INSPECTIONS
1. The Permittee or his designee shall inspect the residuals storage, transport, and treatment
facilities to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health, or a
nuisance. The Permittee shall maintain an inspection log or summary including at least the
date and time of inspection, observations made, and any maintenance, repairs, or corrective
actions taken by the Permittee. This log of inspections shall be maintained by the Permittee
for a period of five years from the date of the inspection and shall be made available to the
Division of Environmental Management or other permitting authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the treatment site or facility at any reasonable time for the
purpose of determining compliance with this permit; may inspect or copy any records that
must be kept under the terms and conditions of this permit; and may obtain samples of
groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. This permit shall become voidable unless the distribution activities are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by this Division.
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2. This permit is effective only with respect to the nature and volume of residuals described in
the application and other supporting data.
3. This permit is not automatically transferable. In the event that there is a desire for the
facilities to change ownership or a name change of the Permittee, a formal permit request
must be submitted to the Division of Environmental Management accompanied by an
application fee, documentation from the parties involved, and other supporting materials as
may be appropriate. The approval of this request will be considered on its merits and may
or may not be approved.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6(a) to 143-215.6(c).
5. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15 NCAC 2H .0205
(c)(4)•
6. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
7. The Pernuttee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
8. This permit may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division of Environmental Management deems
necessary in order to adequately protect the environment and public health.
Permit issued this the DAY day of MONTH, 1994
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0006245 DRAFT
DRAFT