A Story of Regulatory Success

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1 A Story of Regulatory Success How the Town of Cary and Winston-Salem/Forsyth County Partnered with NC DEQ/DWR and EPA to Improve Analytical Standards for Thermally Dried Biosolids NC AW W A/ WEA Conference Presented by: Kelly Spainhour Town of Cary, South Cary WRF Chris Sham el - W inst on-salem/ Forsyth County Utilities

2 Legacy Biosolids Options Biological Treatment Fuel Digester Drying Bed Composting Landfill Land Application

3 Why Biosolids Drying? Alternatives such as land application can be challenging in urban and suburban areas. Thermal Drying reduces biosolidsvolume. Class A, Exceptional Quality Product. Applied virtually free of site and use restrictions.

4 W inst on-salem Archie Elledge WWTP (Permitted at 30 -MGD Conventional Treatment)

5 W inst on-salem Muddy Creek WWTP (Permitted at 21-MGD Conventional Treatment)

6 W inst on-salem Dewatering & Drying Facility

7 Andritz Rotary Drum Dryer

8 Dryer System Process Schematic

9 Dryer Building and Storage Facility

10 South Cary WRF 1 Dryer Serves 2 Plants

11 North Cary WRF Overview (Permitted at 12.0-MGD Advanced BNR Treatment, ADF of 7-MGD)

12 South Cary WRF Overview (Permitted at 12.8-MGD Advanced BNR Treatment, ADF of 5.5-MGD)

13 South Cary WRF Biosolids Dryer (Andritz DDS-40, Rated at 5,742 Dry Tons/ Year) South Cary WRF s Andritz Rotary Drum Dryer has been in operation since 2006 Centrifuge dewatering Centrifuge/Dryer also receives solids from North Cary WRF Processes 3,500 dry tons/year Pelletized product Class A, Exceptional Quality Nutrient content of in Enviro Gems with 1.5% iron.

14 South Cary WRF Andritz Rotary Drum Dryer

15 Western Wake Regional Water Reclam. Fac. (Permitted at 18-MGD Advanced BNR Treatment, ADF of 5-MGD)

16 Western Wake RWRF Belt Dryer Overview

17 Western Wake RWRF Kruger Belt Dryer (Pelletizing added for improved final product quality) Kruger Belt Dryers 2 Train Configuration Rated at 5,135 Dry Tons/Year End Product is Dry Strands Pelletizing improves bulk density

18 Dry Biosolids Beneficial Reuse Pelletized heat dried biosolids are marketed through Soil Plus for beneficial reuse. Potential uses are as fertilizer and organic soil conditioner for agricultural and forestry applications.

19 Compliance Challenge with Analytical Methods for Dry Biosolids

20 EPA 503 Regulations EPA s 503 Regs. National policy on biosolidsand sewer sludge disposal. Adopted in Focus on Traditional BiosolidsDisposal Heat Drying Options are Relatively New Class A, Exceptional Quality Product Virtually free of site and use restrictions Applied freely as organic soil amendment or fertilizer

21 Heat Dry Biosolids Are A Stable Product What is the Problem? Compliance Monitoring Outdated Regulations Sample Preservation and Hold Time Requirements A Federal regulatory compliance challenge

22 What is the Compliance Challenge? Four Critical Elements of Compliance Acid Preservation Total Solids Analysis ph Analysis Fecal Coliform

23 Biosolids Terminology Non-Aqueous? Not the best terminology. Liquid: ability to flow naturally Semi-solid: pliable without ability to flow naturally Solid: non-pliable

24 Biosolids Analytical Prep Methods Non- existent preparatory methods for nutrient analyses. Data qualifiers on monitoring reports. Legal defensibility of data. Outdated regulations prevent full compliance with CWA program requirements in 40 CFR Part 136.

25 Partnership Model to Solve the Compliance Challenge

26 New Approach: Forging a Partnership Cary and Winston-Salem/Forsyth County NC Dept. of Environmental Quality EPA

27 Developing our Compliance Strategy Meeting on June 22, Discuss a Common Point of View Meeting Conclusion: a Federal regulatory problem Approach EPA to find a solution

28 Kelly and Chris Go to Washington Participants: Cary, Winston-Salem/Forsyth County, NC DEQ/DWR Lab Certification, Non-Discharge Permitting, and Regional Offices. Meeting conclusion outdated regulations prevent full ability to comply with CWA requirements for biosolids analyses. EPA eager to assist in helping us to achieve our compliance goals.

29 Recommendations A Path Forward Formal Regulatory updates may take years to execute EPA ATP Process is a better option

30 How to Navigate ATP Process Approval EPA ATP for Limited Use - 40CFR Part Apply through NC DEQ/DWR Lab Certification Supervisor Submitted to EPA by NC DEQ/DWR Lab Certification Program Supervisor ATP for Limited Use is for Regional or NPDES Permit specific approval

31 Current Status Kelly Spainhour (Town of Cary) and Dana Satterwhite (NC DEQ) working together to compose new Methods for non-existent nutrient analyses New Method Development and Validation Utilizing EPA 821-B Under EPA s Alternative Test Procedure Program No acid preservation 24 hold time at ambient for coliform and ph analysis 7 day hold time at ambient for TS analysis

32 How do we Define Success? Partnership approach Working together regulated and regulatory to accomplish compliance goals Path toward National Approval

33 Questions? For more information, contact: Kelly Spainhour, South Cary WRF Lab Supervisor , Chris Shamel, W inst on-salem/ Forsyth County , chrisss@cit yofw s.com Dana Satterwhite, NC Dept. of Environmental Quality , dana.satterwhite@ncdenr.gov

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