WQ0004563_Additional Information Request_20190708

ROY COOPER
Governor
MICHAEL S. REGAN
5ecretary
LINDA CULPEPPER
Director
WARREN WOOD — CITY MANAGER
CITY OF HICKORY
POST OFFICE BOX 398
HICKORY NORTH CAROLINA 28603
Dear Mr. Wood:
NORTH CAROLINA
Environmental Quality
July 8, 2019
Subject: Application No. WQ0004563
Additional Information Request
Hickory Regional Compost Facility
and Catawba ORGRO
Distribution
Distribution of Class A Residuals
Catawba County
Division of Water Resources' Central and Regional staff has reviewed the application package
received May 30, 2019. However, additional information is required before the review may be completed.
Please address the items on the attached pages no later than the close of business on August 7, 2019.
Please 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 the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A and B, or failure to provide the additional information on or before the above requested date
may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Paul Spencer — Veolia Water North America Operating Services, LLC (Electronic Copy)
Permit Application File WQ0004563
�� North Carolina Department of Environmental Duality I Division of Water Resources
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512 North Salisbury Street i 1617 Mail Service Center 1 Raleigh, North Carolina 27099-1617
919.707.9000

Mr. Warren Wood
July 8, 2019
Page 2 of 2
A. Residuals Source Certification Application FORM: RSC 06-16 :
1. The submitted summary table for the residuals sources lists the City of Conover Southwest WWTP
as a residuals source, but it was not listed as a source in the previous permit issued October 10,
2014. If this treatment plant were to be added as a residuals source, it would need to be submitted
as a major modification to our office. Please clarify whether this treatment plant is a residuals
source or not.
2. The submitted summary table for the residuals sources does not list the Hickory WTP as a residuals
source, but it is listed as a source in the previous permit. Please clarify whether this treatment plant
is a residuals source or not.
3. The submitted summary table for the residuals sources lists the current and proposed maximum
annual weight of residuals permitted for distribution and land application/disposal as 5,200 dry
tons/year. However, you were permitted for 14,000 dry tons for distribution in the previous permit.
Please clarify if you would like to reduce the permitted distribution dry tonnage.
4. The toxicity characteristic leaching procedure (TCLP) analysis submitted for the regional compost
facility is missing two parameters needed to demonstrate that the residuals are non -hazardous under
RCRA. The missing parameters are 2,4-D and 2,4,5-TP (Silvex), both chlorine acid herbicides.
Submit documentation from a verified lab that demonstrates that these two parameters are below
their TCLP limits.
B. Product Information Sheet:
1. The "Regional Compost Facility Use Agreement" and "Regional Compost Facility Use Agreement
for Land Application" documents submitted did not include the 100' setback to non -monitoring
wells listed in 15A NCAC 02T .1108(b). Add this setback to these documents and resubmit.
2. The "Regional Compost Facility Use Agreement for Land Application" document states that the
compost should not be applied or stored "within ten (100) feet of any public or private water
supply". The setback should be 100', not 10' as listed. Amend this document and resubmit.