OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY WATER POLLUTION CONTROL FACILIITY PERMIT EVALUATION and FACT SHEET. April 15,2010

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1 OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY WATER POLLUTION CONTROL FACILIITY PERMIT EVALUATION and FACT SHEET April 15,2010 Department of Environmental Quality Western Region - Eugene Office 165 East7th Ave., St Suite 100, Eugene, Oregon (541) Permittee: Source Contact: Source Location: County: Permit Writer: Proposed Action: Source Categoiy Lany W., Linda J., and Dan Dirksen A Fresh Way Septic Tank Service 6195 Old Stage Road Central Point OR FileNumber: Existing Permit No.: Expiration Date: 12/31/2009 Telephone Number: (541) Lany, Dan and Linda Dirksen (541) Septage Batch Alkaline Stabilization Treatment System location, 1506 Antelope Road White City, OR and land application of Class B Biosolid is on Dirksen's Farm sites at 9207 Highway 234, Gold Hill, OR Jackson Paul Kennedy Renewal Application Number: Eugene DEQ Office Minor -Domestic Septage Alkaline Stabilization Date Received: 7/1/2009 Background A Fresh Way is a septage management company that serves Jackson and Josephine Counties in southwest Oregon. This business operation includes pumping domestic septic tanks, alkaline stabilizing septage, and land applying the stabilized septage on agricultural land for beneficial use. A Fresh Way is authorized to pump domestic and commercial domestic septage under septage pumper license number Alkaline stabilization of domestic septage is considered treatment of domestic waste. Therefore, a Water Pollution Control Facilities (WPCF) permit is required under Oregon Revised Statues (ORS) 468B.050. Management of septage is also regulated under the Code of Federal Regulations (40 CRF Part 503) and the Oregon Administrative Rules (OAR ). A Fresh Way first received a WPCF permit on December 14, Their current WPCF permit (#101926) was renewed on November 3, 2000 and expired on December 31, The applicant made WPCF permit renewal application on July 1, 2009, therefore their permit is deemed in affect until the Department of Environmental Quality (DEQ) takes action and either renews, modifies or denies this permit. Domestic Septage Types Under OAR (12) the definition of "Domestic Wastewater" means the water carried human waste from residences, buildings, industrial establishments, or other places together with such groundwater infiltration and surface water as may be present that flow to wastewater treatment facilities.

2 A Fresh Way WPCF Permit Evaluation Report Page 2 of 21 FileNumber: April 15,2010 Under OAR (11) the definition of "Domestic Septage" means liquid or solid material removed from a septic tank, cesspool, portable toilet, Type III marine sanitation device, holding tanks, or similar treatment works that receive only domestic wastewater. Domestic septage does not include liquid or solid material removed from a septic tank, cesspool, or similar treatment works that receive either commercial wastewater or industrial wastewater and does not include grease removed from a grease trap at a restaurant. Alkaline stabilization of septage can be used to meet Pathogen Reduction (producing a Class B biosolid) and Vector Attraction Reduction (VAR) requirements. Note: compliance with federal regulations does not ensure compliance with state requirements. Treatment Requirements: Pathogen Reduction of Domestic Septage Tank and Domestic Commercial Septage (Class B Biosolids) Under OAR (5)(a) Domestic septage tank pumping: The ph of the domestic septic tank pumping (from one single family residence with one septic tank and one drainfield) shall be increased by introducing and actively mixing sufficient alkaline agent to elevate the ph to 12 or higher (without further addition of alkali agent) for a minimum of 30 minutes. For multiple single family dwellings on a Large On Site System, vault privies, commercial business office that have only human waste holding tanks, chemical portable toilets, the process is similar with the exception that there is a blending requirement with domestic septage (3:1) and the batch undergoes a 24- hour alkaline treatment process. This process consists of a 2 hour active mix phase at a ph of 12 or higher followed by an additional 22 hours at a ph of 11.5 or higher, active mix not required. Under OAR (5)(b) Domestic holding tank, chemical toilet, marine type III sanitation devices, vault toilet or similar treatment/holding devices that receive domestic septage (only human wastes). All of these types of Domestic Septage, which are not single family residence, would be considered then Domestic Commercial Septage and shall be mixed with domestic single family septic tank pumping at a ratio of at least three gallons domestic septic tank pumping to one gallon commercial domestic septage pumping. The ph ofthe blended domestic septage shall be increased to 12 or more by introducing and actively mixing sufficient alkaline agent to elevate the ph to 12 or higher (without further addition of alkali agent) for a minimum period of 2 hours. Immediately after the end ofthe active mixing process, the domestic septage-alkaline agent mixture shall be allowed to further react for at least 22 additional hours. At the end ofthe 22 hour reaction process, the ph ofthe domestic septage alkaline agent mixture shall be at least 11.5 (with no further addition of alkaline agent). This ph treatment process meets the Class B Biosolid process for pathogen reduction under 40 CFR Part (b)(2) Processes to Significantly Reduce Pathogen (PSRP) Condition (5) Lime Stabilization: Sufficient lime is added to the sewage sludge to raise the ph ofthe sewage sludge to 12 after two hours of contact. The ph requirement applies to eveiy container of domestic septage applied to the land, which means that the ph of each container must be monitored. Treatment Requirements: Vector Attraction Reduction (VAR) VAR: The alkaline stabilization used to produce Class B biosolids is not sufficient to meet VAR. Under 40 CFR Part 503, sewage sludge is considered to have undergone adequate VAR if sufficient alkaline has been added to: For Domestic septic tank, Raise the ph to 12 for l A hour without addition of more alkali agent For Domestic Commercial Septage, Maintain the ph of at least 12 without addition of more alkali for 2 hours

3 A Fresh Way WPCF Permit Evaluation Report Page 3 of 21 FileNumber: April 15,2010 Maintain a ph of at least 11.5 without addition of more alkali agent for an additional 22 hrs Lime stabilization does not reduce volatile solids. VAR, by alkaline stabilization is accomplished by reducing or stopping biological activity in the biosolids. However, this reduction does not stop biological activity permanently. If the ph drops prior to land application then surviving bacteria can become more biologically active and the sewage sludge will again putrefy and potentially attract vectors. Following land application the site is subject to 30 days of environmental irradiation and desiccation by the sun which continues the pathogen and vector attraction reduction processes. Septage Management Plan and Site Authorization Letters The current permit requires A Fresh Way to operate in accordance with a Department approved Septage Management Plan (SMP). A Fresh Way's SMP was approved on December 16, The SMP has been updated with this permit renewal to include the White City Batch Treatment Facility. Both the SMP and site authorization letters are extensions of the WPCF permit. Conditions of the site authorization letters are site specific as to time of application, agronomic loading rate for crop grown and land application setbacks. A Fresh Way Treat Facility and Land Application Program A Fresh Way collects primarily domestic septage from single family residences, but is also authorized to take commercial domestic septage. A Fresh Way is permitted to pump domestic septage tanks and transfer these liquid and solid wastes to their batch alkaline stabilization treatment facility at 1506 Antelope Road White City, Oregon. Septage tank pumping are transferred into a 6,000 gallon stainless steel batch storage/stabilization tank at this facility. The stabilized septage is then screened through 3/8"minus expanded metal screen and into a 100 gallon metal tank that is off loaded into a land application truck. The rags, plastics and other coarse materials are dewatered, put in sealed trash container, and taken to a DEQ approved landfill. Treatment of domestic septage is done by the introduction and mixing of lime slurry into the batch tank then mixing the tank contents for a required period at a ph of 12 or higher. At the start ofthe domestic septage stabilization process, the ph ofthe limed septage mix must be adjusted to 12 or higher. Once the batch tank ph achieves a ph of 12 or higher the operator then records the time and after 30 additional minutes of processing, without any addition of alkaline agent during this 30 minute process, the ph must be 12 or higher. Measurement and recording of times and phs must be done at the start and end of this treatment process. The stabilized septage is then beneficially land applied as a soil amendment meeting Class B biosolid site restriction for rural agriculture land. A Fresh Way has consistently shown adequate mixing and treatment of domestic septage (ph 12 or more for more than Vi hour) using this methodology. Site Restrictions Written Department authorization is required prior to land applying stabilized septage. All site management practices, septage land spreading practices, farming cropping practices, and irrigation practices must conform to conditions contained in the site authorization letter. All land applied septage must meet the site restrictions under 40 CFR Part (b)(l-5) and (c)(2). Land Application The Dirksen's have two land application fields that are located off Highway 234 in Sam's Valley Oregon. Site 1 is a 25 acre parcel, approved for summer land application (loading rate 100 lb. N/acre); and site 23 is a 55 acre parcel, approved for summer land application (loading rate 100 lb. N/acre. The

4 A Fresh Way WPCF Permit Evaluation Report FileNumber: April 15,2010 Page 4 of21 following map shows the locations of these land application sites: :--~-,:.-X:_ \ 7 _ i._199&d*l'onne^_^et'_au4s^jsa At these land application sites, domestic septage is either applied under pressure from a 3500-gallon pumper truck though a splash plate-spreader bar or via a trailer mounted pump and irrigation cannon. Septage is applied under pressure to promote uniform solids spreading. After land application, all exposed equipment and the end ofthe discharge pipes are washed down and disinfected as needed. All track and field septage conveyance pipes are covered with a cam lock end cap or similar device to prevent spillage. Agronomic Loadings Agronomic loading rates are also found in the site authorization letter. These rates are dependent on the crop grown, type of soils, and other site limitations. A primaiy basis of calculation is the nitrogen crop requirement. The EPA 40 CFR (c) states that the annual application rate for domestic septage applied to agricultural land, forest, or a reclamation site shall not exceed the annual application rate calculated using the following equation: AAR = N/ Where: AAR - annual application rate in gallons per acre per year (365 days); and N = amount of total plant available nitrogen in pounds per acre per year needed by the crop or vegetation grown on the site. The authorized land application sites are pasture grass and the agronomic loading for Oregon pasture grass is 100 lb. N per acre per year. Therefore, the AAR for these sites is 38,462 gallons per acre per year (100 N lb./0.0026). A Fresh Way's sites 1 and 2 are currently approved for a loading rate of 30,000 gallons per acre-year. Potential Contaminants in Septage The EPA's 1984 Septage Treatment and Disposal handbook (pg. 31) discusses septage as being much more

5 A Fresh Way WPCF Permit Evaluation Report FileNumber: April 15,2010 Page 5 of21 dilute than municipal wastewater. A more current EPA document, the Domestic Septage Regulatory Guidance (40 CFR 503, 1993), discusses domestic septage as containing mostly water, sewage, inorganic and organic wastes, and small amounts of polluting substances from normal household activities. Analysis of domestic septage pollutant concentrations are significantly below the Pollutant Concentration Levels (PCL) for municipal sewage sludge (Domestic Septage Regulatory Guidance, appendix B) and do not require tracking of cumulative metals. The typical percent Total Solids of septage are less than 3 percent. Metal loading rates are accounted for and are meant to be limited indirectly by use of the Annual Application Rate (AAR) formula for septage under EPA's Domestic Septage Regulatory Guidance, Groundwater All land applied domestic septage is alkaline stabilized and land applied at agronomic loading rates. The land application sites where the stabilized septage is applied has been evaluated for groundwater impact using OAR 340 Div. 50 siting criteria and it is believed there will be no impact to groundwater from land applied alkaline stabilized septage provided the WPCF permit, SMP and site authorizations are followed. Storm water No storm water permit is needed. The permit prohibits surface runoff or subsurface drainage through drainage tiles. Compliance Histoiy In the last permit cycle, the permittee has received one Warning Letter. Warning Letter Date Class of Violation WL-WRR June 4,2007 Violation Class I Class H Modifying domestic septage alkaline stabilization facilities without DEQ approval. Improper disposal of septage screenings on the ground surface at treatment facility. PERMIT DISCUSSION Face page The term ofthe permit is not to exceed 10 years. No changes to permittee, source, facility type or River Basin information have been made. Schedule A - Waste Discharge limitations: There are no changes to Schedule A of the proposed permit. Discharge to surface water's is prohibited. Schedule A conditions are similar to other alkaline stabilization facility permits. Schedule B - Minimum Monitoring and Reporting Requirements Monitoring and reporting requirements under Schedule B of the permit ensure the minimum permit limitations of the treatment process. Recordkeeping requirements under 40 CFR 503 and OAR include tracking all treated septage that is land applied on agricultural, forest, and farm sites. The recordkeeping includes collecting information on where the septage came from, recording treatment processes, keeping a log of operations and maintenance activities, and retaining these records for 5 years. The following is required information: 1) the location, either by street address or latitude and longitude, of the site on which domestic septage is applied; 2) the number of acres in the application site; 3) the date and time domestic septage is applied to each site; 4) the nitrogen requirement ofthe crop or vegetation grown on

6 A Fresh Way WPCF Permit Evaluation Report Page 6 of 21 FileNumber: April 15, 2010 each site during the 365-day period; 5) the certification statement in (b)(6) that certifies that the pathogen (c)(2) and vector attraction reduction (b)(6) or (b)(12) requirements for domestic septage have been met; and 6) a description of how these pathogen and vector attraction reduction requirements for domestic septage have been met (Technical Support Document for Land Application for Sewage Sludge Volume 1, Chapter 14, pg.9, November 1992). Typically the review, approval and issuance of a WPCF permit satisfy line item pathogen and vector attraction reduction requirements. Schedule C - Compliance Conditions There are no compliance conditions in the proposed permit. Schedule D - Special Conditions Schedule D of the permit contains eight special conditions which are standard conditions for Water Pollution Control Facilities permits for septage alkaline stabilization systems. These conditions are listed below: 1) Requirement for submittal of plans and specification prior to any system modifications and/or expansions; 2) A contingency plan requirement; 3) A requirement to control site access to grazing animals and the public; 4) A requirement to maintain continuous performance ofthe system; 5) A certification statement requirement; 6) Operation in accordance with the approved septage management plan; 7) A reopener clause in the event that biosolids regulations change and an acknowledgement that the WPCF permit does not relieve the permittee of any responsibility under Federal regulations; and 8) A requirement to maintain a valid On Site Program sewage disposal seivice license.

7 ATTACHMENT 1 A Fresh Way Septic Tank Service Septage Management Plan Up Dated April 2010 A Fresh Way Septic Tank Service 6195 Old Stage Road, Central Point, Oregon (541) A Fresh Way Septic Tank Service Septage Treatment Facility 1506 Antelope Road White City OR A Fresh Way Septic Tank Service Land Application Sites Dirksen's Farm 9207 Highway 234 Gold Hill OR Background On July 8, 1994 the Department of Environmental Quality (Department) approved A Fresh Way Septic Tank Service's (A Fresh Way) initial septage management plan, which allowed only alkaline stabilization treatment of domestic septage (single family residence with one septic tank and drainfield) and land application. The Department authorized land application site conditions are pursuant to A Fresh Way's WPCF Permit Number , the Oregon biosolids rules for domestic septage processing and handling (OAR to OAR ) and all other applicable statutes, rules and federal regulations [i.e., 40 CFR Part (c)-annual solids loading rate; (b)-rninimurn site monitoring requirements and frequency; (6)(b)- minimum record keeping requirements; (b)(5) to (b)(5)(iv)-restrictions in site use and (c)(2)-pathogen reduction requirements; (a)(5) and (b)(12)-vector attraction reduction requirements]. In order to pump, haul septage and to land apply alkaline stabilized septage the A Fresh Way must have a valid Department On Site pumpers License (current license # 35219). I. Treatment Facility Introduction: The A Fresh Way owns a septage alkaline stabilization treatment business. A Fresh Way operates this facility under WPCF Permit Number # which was November 3, A Fresh Way processes primarily domestic septage generated by a single family residence pumping. "Domestic

8 Septage" pumping originate from single family dwellings; and "Domestic Commercial Septage" pumping that come from septic tanks, holding tanks, chemical toilets, marine Type III privies, and vault toilets that receive only human wastes. Domestic wastewater is defined as only water-carried human wastes; No industrial or commercial process waters or wastewaters, grease removed from grease trap and /or interceptor at a restaurant is allowed for treatment at this facility under this septage management plan. All domestic septage from the facility must be alkaline stabilized before being land applied at agronomic rates. No discharged of domestic septage or other wastes to waters of the state are allowed. Currently A Fresh Way collects only domestic septagefromsingle family residences, but is also authorized to take commercial domestic septage under their current WPCF permit. For domestic septage, the process is as follows: A) Septage Alkaline Treatment Process A Fresh Way pumps single family dwellings/domestic septage tanks and transfers these wastes to their batch alkaline stabilization treatment facility in White City, Oregon. Septage tanks are pumped into a 6,000 gallon stainless steel batch tank. The raw septage is then screened through 3/8"minus expanded metal screen and into a 100 gallon metal mix tank before offloaded into the land application truck. The rags, plastics and other coarse materials are dewatered put in sealed trash container and taken to a DEQ approved landfill. Treatment domestic septage is done by the batch tank offloading into the mix tank where lime slurry is mix with septage in the mix tank before offloading into the land application tanker truck. Truck tank contents are required to be actively mixed for a period of V2 hour at a ph of 12 or higher (See process photo documentation at end of plan). At the start ofthe domestic septage (single family dwelling) stabilization process the limed septage mix ph must be read and recorded, ph must be 12 or higher. The V% hr. liming process clock starts and the ph ofthe limed septage is read and recorded; the ph is then read again after 30 minutes of continuous agitation, where the ph must be 12 or higher without any addition of alkaline agent during this 30 minute process period. The stabilized septage is then land applied meeting Class B biosolid site restrictions. For domestic commercial septage (multiple single family dwellings on a Large On Site System, vault privies, human waste holding tanks, chemical toilets), the process is similar with the exception that it is blended with domestic septage (3 volumes of single family septic tank pumping:! volume domestic commercial septage) and under goes a 24-hour alkaline treatment process. This process consists of a 2 hour active mix phase at a ph of 12 or higher followed by an additional 22 hours at a ph of 11.5 or higher, active mix not required, but no further addition of alkali agent is allowed during the 24 hour process. B) Septage Storage Structure: Unstabilized and stabilized domestic septage and commercial domestic septage can be stored in the facility pump trucks for not more than 72 hours. Stabilized domestic septage that does not meet the alkaline stabilization time and ph requirements can not be land applied. Stabilized domestic septage held for more than 24 hours must have the ph tested, if the ph is 12 without

9 further addition of alkali agent then it can be land applied else the batch must be restabilized. Stabilized commercial domestic septage held for more than 24 hours must have the ph tested, if the ph is 11.5 for stabilized commercial septage without further addition of alkali agent then it can be land applied else the batch must be restabilized. C) Sampling: 1) Alkaline Stabilization Domestic Septage Batch Tank Sample locations: During the stabilization batch of domestic septage process all man-ways and/or observation ports on the batch tank and land application truck tank should be close to reduce odors. A Fresh Way can pull random compliance samples from the conveyance pipe between the batch tank and land application truck, while loading truck, to ensure ph requirements is met; or, A Fresh Way can use a tank out let pipe (valve) tied to land application pumper truck to collect random initial and final compliance ph samples after thorough mixing in the application truck. 2) Alkaline Stabilization Commercial Domestic Septage Batch Tank Sample locations: During the batch stabilization of domestic commercial septage process all man-ways and/or observation ports on the batch tank and land application truck tank should be close to reduce odors. A Fresh Way can pull random initial compliance samples from the conveyance pipe between the batch tank and land application truck, while loading truck, to ensure ph requirements is met; or, A Fresh Way can use a tank out let pipe (valve) tied to land application pumper truck to collect initial, 2 hour and 24 hour compliance ph samples from the batch tank on the land application truck. Number and type of sample taken per batch: Seven (7) random samplesfrombatch tank 100 ml (approx.) put in a 5 gallon bucket, should be are mixed together to form a composite sample for each ph analysis. II Septage Alkaline Stabilization Processes The EPA's 40 CFR Parts 503 allow A Fresh Way to use EPA approved alternatives to satisfy domestic septage treatment requirements for pathogen or vector attraction reduction criteria. OAR (5) requires all septage be stabilized with alkali agent. The A Fresh Way must notify the Department in writing and get written approval prior to any process change that would utilize pathogen reduction and/or vector attraction reduction alternatives other than their primary reduction alternatives contained in this management plan. The A Fresh Way must also certify that the alternatives used are EPA approved and that sampling and monitoring conforms to the 40 CFR Part 503 and OAR Biosolid regulations. A) Pathogen Reduction To meet the Part 503 regulatory requirements pathogen reduction must be met before vector attraction reduction or at the same time vector attraction reduction is achieved.

10 Alkaline Stabilized Domestic Septage Under EPA 40 CFR part (c) for domestic septage and commercial domestic septage pumping that are beneficially applied on rural property, pathogen reduction is met by the following: For domestic septage, all the Class B site restrictions under (b)(5) are met. (The State of Oregon is more restrictive than the EPA in that all septage must be screened and alkaline stabilized prior to land application. The ph of all domestic septage and commercial domestic septage must be raised to 12 or higher by alkali addition and maintained at ph of 12 or higher for 30 minutes without adding more alkali. The site restrictions on crop harvesting in 40 CFR Part (b)(5)(i-iv) and (c)(2) must be met. Eveiy batch of domestic septage and commercial domestic septage stabilized must be monitored for the time, mixing, and elevated ph requirements. B) Vector Attraction Reduction For alkaline stabilization of domestic septage and commercial domestic septage, this facility can use the following two (2) vector attraction reduction options: 1) Alkaline Stabilization QA hour process), (b) (Option 12) this option applies to Domestic Septic Tank pumping only, sufficient alkali agent is added to the Domestic Septic Tank pumping to raise the ph to 12 or higher, then hold the ph at 12 or more for a minimum of 30 minutes or more, active mix. 2) Alkaline Stabilization (24 hour process), (b) (Option 6) this option applies to Domestic Septic Tank pumping mixed with Domestic Septage. These are blended at a ratio of 3:1 Domestic Septic Tank pumping to Domestic Septage. Sufficient alkali agent is added to the domestic septage batch to raise the ph to 12 or higher, the batch must be held at a ph 12 or higher for a minimum of 2 hours active mix, then for an additional 22 hours at ph of 11.5 or higher. Stabilized domestic septage must remain at a ph 11.5 or higher to be land applied. Ill Biosolid Nutrient Analysis: If A Fresh Way were to stabilize about 1,000,000 gallons (gal.) of domestic septage, then the annual application rate would be calculated as follows: Annual # lb. N required by crop/ = gallons of alkaline stabilized septage. (Pasture grass 100 lb. N/acre) / = gallons of alkaline stabilized septage per acre. 1,000,000 gallon treated annually/ 38,462 gallons per acre = 26 acres required to beneficially reuse alkaline septage annually. A Fresh Way has 65 plus acres to land apply on to handle their annual biosolid nitrogen production.

11 IV Biosolid Beneficial Reuse Program Transportation and Land Application: A Fresh Way can land apply stabilized septage on Department authorized farm fields owned by the Dirksens. The farmland is located at 9207 Highway 234 Gold Hill, OR (area is known as Sams Valley). All DEQ site authorizations are part of A Fresh Way Septage Management Plan. Domestic septage is offloaded into a (3,500gal.) tanker truck at the A Fresh Way's White City treatment facility. During the summer months A Fresh Way land applies treated septage on two Department authorized sites. The land application sites are capable of assimilating A Fresh Way's annual total nitrogen production. The perennial agronomic biosolid land application rate for pastures and grass is 100 lb. available N per acre-yr. Land application: Annually, A Fresh Way may treat as much as 1,000,000 gallons of domestic septage. A Fresh Way can land applies on their own farmlands in the Sams Valley area. All DEQ site authorizations are part of A Fresh Way Septage Management Plan. A Fresh Way has approximately 65 plus acres of farmlands to beneficially reuse alkaline stabilized septage. Biosolids Site management Information: Site ID 1 2 Name Sitel Site 2 Net Acres Crop Grass Grass App. Process Surface Spread Irrigation Surface Spread Irrigation or or Crop Removal lb./acre Grazing Grazing Approved Start Date May 1 st May 1 st Approved End Date Oct 31 st Oct 31 st Approved Lb./acre 100 lb. N, 38,000/ac 100 lb. N, 38,000/ac Agronomic loading for domestic septage and site restrictions are contained in the septage site authorization letter. References to the OAR 34-50, EPA 40 CFR Part 503, site setbacks, site agronomic loading rates, land application restrictions and site restrictions are also detailed out in the site authorization letters. A Fresh Way's Septage Stabilization and Transportation Trucks A Fresh Way two pumper trucks: 2002 International White truck with a 3,000-galIon tank International White truck with a 2,300-gallon tank Volvo White land application truck with a 3,500-gallon tank Freightliner White tanker truck with a 5,000-gallon tanker used to transport septage to other facilities during winter no land application periods. V Spill Contingency In event domestic septage is spilled between the treatment facility and the land application

12 site A Fresh Way 's sewage treatment works shall contain the spill, lime, absorb (via sand) and remove spilled sludge solids spills with a front end loader or shovels and dispose ofthe spillage at a DEQ authorized application or disposal site. All spills into waters ofthe state or spills on the ground surface that are likely to enter waters of the state shall be reported immediately to Oregon Emergency Response System (OERS) at and your regional biosolids coordinator at (541) All spills (25 gallons or more) to just the ground surface shall be reported to the regional biosolids coordinator at (541) At least 100 pounds of hydrated lime (calcium hydroxide) or quick lime (calcium oxide) shall remain available at A Fresh Way treatment facility at all times for use as a disinfectant/deodorant in the event an accidental domestic septage spills. VI Reporting Dailv Reporting and Recordkeeping: Each year prior to land application of biosolid the source operators shall check to see if contiguous property owners have changed. The operators shall keep a record of contact (date, and/or written log of phone call w/ name and number, and/or xerox of postcard w/ name and address, etc.,) with contiguous property owners, which notify them ofthe biosolid land application practice. Operator shall provide this documentation in the annual biosolid report. Annual Reporting The Annual Biosolid and Next Year Forecast Reports are due February 19, of each year for the previous years land applied domestic septage. Part of this report is the submittal of the daily site logs, which has a table with the date, time, operator name, and quantity gal/acre land applied for each day-tank-batch land applied. Site logs shall have a scaled map showing the site and the land application location that coincides with the daily site loading methods (truck spreader bar, irrigation cannon). Daily records should clearly show the location of daily loading on a site map. The Annual Report shall have a signed copy of the certification statement for pathogen and vector attraction reduction, and that the domestic septage has been land applied at approved agronomic loading. Person signing statements should be the operator of record at the treatment plant. The operator shall shown how the vector attraction reduction was met i.e. was achieved by addition of alkali agent, ph and time requirement. Certification of pathogen reduction is required and is satisfied by submittal of test results in the Annual Biosolid Report. All the previous year's biosolid sampling and analysis that is required by the permit shall be included in A Fresh Way's Annual Biosolid Report (in each year's annual report appendix). VII Certification Statement A Fresh Way's facility is capable of achieving alkaline stabilization of domestic septage pathogen and vector attraction reduction criteria. Signed domestic septage pathogen and vector attraction certification statement shall accompany all alkaline stabilized domestic septage to be land applied. Certification statement must also show conformance with nutrient and land application loading rates where applicable.

13 "I certify, under penalty of law, that the pathogen requirements in (c)(2), the management practices in (b) (5), and the vector attraction reduction requirements in (b)(12) have been met. This determination has been made under my direction and supervision in accordance with the system designed to ensure that qualified personnel properly gather and evaluate the information used to determine that the pathogen requirements and vector attraction reduction requirements have been met. I also certify that all-alkaline stabilized septage were land applied at the approved agronomic loading rate noted in the respective Department site authorization letter. I am aware that there are significant penalties for false certification including the possibility of fine and imprisonment." Signature Date.

14 Stabilization Process Photo Documentation A Fresh Way has consistently shown adequate mixing and treatment (ph 12 or more) using their stabilization, mixing and transportation methodology. A Fresh Way screens and lime stabilizes domestic septage (septic tank pumping) in a six thousand gallon stainless steel tanker in their septage treatment facility in 1506 Antelope White City, OR A Fresh Way then transports (1/2 hour drive) and land applies their alkaline Stabiliz p d Qpntnop nn DpnnWtnp.nt nnnrnvprl land smrdinatirm eitns I *.t i_k w >**-»«* esss9 L'-I 3/8" bar screen and Lime mix tank.

15 6,000 gallon stainless steel batch tank with secondary containment. Sufficient hydrate calcium hydroxide is mixed with the screened septage and elevate to a ph of 12 of 7 random samples from the land application tank truck. The ph is checked prior to leaving the facility to ensure the ph is 12 or higher.

16 *r. I-' f X^,<*V v< V - - -*-. * <-> ^ ' ' j, S ( /,**' >. ^ 4 '" S r- ' ff ' *> '-_. The batch septage then under goes mixing for thirty minutes of agitation before and during transportation to the field where the ph is tested again to ensure the ph is 12 or higher prior to land application. «_* t '-Jfr.-JUM '-^i' '} L >_-._»L"_t i v.-i '-JL * % # * -. - < : ' : - ; : < > ^ i. " V - ";".' ' ".' ; :- " '., ' 1, ^. ;'WJ---- '..... :*. <.-... *&vwv>. '...«; " '.-..' >.A ph 12, sampling at land application site 30 minutes later, prior to land application.

17 ATTACHMENT 2 1TQ P^OTl i^i John A. Kitzhaber, M.D., Governor Department of Environmental Quality Western Region Roseburg Office 725 SE Main Roseburg, OR (541) T7AV f*a 1\ AA(\_1ia< October 11,2000 Larry and Linda Dirksen A Fresh Way 6195 Old Stage Road Central Point OR Re: FileNumber Authorization to Land Apply Alkaline Stabilized Septage to Dirksen property Twp. 36S, R. 2W. Sec. 5 Summer Site Dear Mr. and Mrs. Dirksen: The Department has reviewed A Fresh Way's alkaline stabilization of domestic septage and land application activities for your property site. The approval site is approximately a 40 acres of Carney Clay soils on the South Side of Highway 234 (property map enclosed). This site is use for non-irrigated pasture. Based upon the evaluation of this property the Department is pleased to grant you authorization to land apply alkaline stabilized domestic/commercial septage subject to the conditions under your WPCF Permitfileand the following stipulations: 1. Septage processing and handling will comply with Oregon biosolid rules and guidelines (OAR to OAR ) and all other applicable statutes, rules and the following federal regulations: 1) 40 CFR Part (c)-annuat solids loading rate; (3)(b) and (d) monitoring frequency for pathogens and vector attraction reduction; 2) (b)-site monitoring requirements; (6)(b)-recordkeeping requirements; 3) (c)(1) and (b)(5) or (c)(2) which include (b)(5)(i) through (b)(5)(iv)-pathogen reduction requirements and site use restrictions; 4) and (b)(9), (10), and (12)-vector attraction reduction requirements. 2. Domestic septage will be stabilized via the addition of lime, hydrated lime, or an alkaline

18 Dirksen Site Authorization File Number: October 11,2000 Page 10 of 5 agent that will elevate the ph to 12 (minimum) and maintain the ph at that level for 30 minutes (minimum) prior to land application. 3. Commercial septage (chemical toilets, holding tanks, and vault privy pumping) shall be coblended three parts domestic septage to one part commercial septage, then stabilized via the addition of lime, hydrated lime, or an alkaline agent that shall be actively mixed while the ph is 12 or more for at least 2 hours (minimum), followed by 22 hours of a ph 11.5 or higher prior to land application. 4. Other types of septage (i.e., grease trap, septage containing other commercial and industrial wastes etc.) must be disposed at a domestic wastewater treatment facility or other DEQ approved facility. 5. Based on septage characteristics, existing crop, topographic and soil conditions of the subject properly, 100 pounds of available nitrogen 38,000 per acre per year can be applied to areas ofthe property the Department determines suitable for receiving solids. ((maximum 100# N/0.0026) = 38,462 liquid gallons of septage) Land application of treated septage should dry and not pond or pool as a liquid in the field after 24hrs. 5. If other sources of nitrogen will be applied to the pasture sites, the septage application rate must be reduced so that commercial, animal manure or green chop nitrogen plus septage nitrogen does not exceed the agronomic loading rate of any field within site. 6. Changes in crop or crop management practices will necessitate appropriate adjustments in the application rate to maintain nitrogen loading consistent with crop demands. Adjustments must receive written concurrence from the Roseburg Branch Office before initiation. 7. This site is approved for summer application (June 1 to October 31). During septage land application, care should be taken to avoid wet soil conditions, which may have occurred as a result of precipitation, especially in low and concave areas of sites. Driving over wet soils can result in compacted soil conditions and reduced crop yields. 8. Septage can be applied using an irrigation cannon or spreader gate on the back of pumper truck during fall, winter and spring months. Permittee shall insure that septage is applied evenly and in a manner, that will prevent ponding and runoff. 9. All septage shall be screened to remove grit, solids and rags (solid waste). All solid waste shall be placed in a container on a daily basis to reduce vector attraction. These solid wastes must be dewatered and taken to a DEQ approved landfill on a regular* basis. DEQ-DCl

19 Dirksen Site Authorization FileNumber: October 11, 2000 Page 11 of Land application of septage shall have at least one-day time period between applications on the same area should ponding occur. Septage land application shall cease when the ground surface is frozen where potential exists for runoff. 11. An additional application of stabilized septage above the approved site agronomic loading rate maybe be applied in the same year, if there is a harvest and removal of green plant cuttings from site between applications periods. Any application of stabilized septage above agronomic loading rates requires written approval from the DEQ before application. 12. A 50 feet (minimum) setback shall be maintained from roadways, irrigation and storm water control ditches, drainage ways, ponds, wetlands, streams and any other surface water bodies and points of septage application. 13. A 100 feet (minimum) setback shall be maintained between points of septage land application and residential structures. 14. A minimum setback of 200 feet shall be maintained between the nearest area of septage land spreading and all irrigation wells and a 200 feet setback shall be maintained between any drinking water wells and other water sources and the nearest location of septage land application. 15. Areas where septage has been applied shall be clearly marked by flag pins or stakes which note the date when septage was last applied. 16. On areas amended with septage, unless otherwise authorized in writing by the Department, an interval of at least 38 months shall occur between the time septage is applied to the subject property and direct food chain crops are harvested. 17. A 30-day (minimum) period shall follow the application of septage before grazing livestock on any septage-amended field or harvested alfalfa from septage areas. 18. Public access to the site shall be restricted for at least 12 months after septage land spreading has ceased. 19. Immediately following land spreading, the septage tanker operator shall remove extraneous septage (at the application site) from areas ofthe equipment coated with septage to prevent septage from leaking onto public highways. 20. The land application truck operator shall clean up any spillage of septage. Spillage, which cannot be completely cleaned up, must be covered with diy lime and posted where appropriate. DEQ-DCl

20 Dirksen Site Authorization FileNumber: October 11, 2000 Page 12 of Permittee shall notify all contiguous property owners that alkaline stabilized septage is being beneficially applied to this DEQ approved site at agronomic loading rates. 22. The Roseburg Branch Office ( ) shall be notified within one hour of any spills of more than 50 gallons or other threats to the environment that may occur. Failure to provide notification within one hour may be considered cause for taking enforcement action against A Fresh Way. Spills that occur after normal working hours shall be reported to the Emergency Management Division (EMD) within one hour. The telephone number of EMD is In the event an odor problem is reported to the Department after septage has been land spread at the subject properties, immediate steps, such as, but not limited to, the addition of liming materials or tilling the septage into the soil, must be taken to counteract that condition. 24. The septage applicator shall maintain daily records for the septage land application site which indicate (on a field map grid system) where, when, and how much (gallons) septage was land applied to a particular area. 25. Site records shall indicate the date, location and amount of septage applied, segments of each field that received septage, pounds of nutrients applied to each area receiving septage, and the type of crop grown. These data shall be maintained by A Fresh Way and be made available to the Department for review upon request. 26. The Department shall have the right to, (at reasonable times); enter the A Fresh Way's place of record keeping to review septage management operations and records; obtain copies of any records required under the terms of this authorization and A Fresh Way's solids management plan; inspect any monitoring equipment required under this authorization; inspect any collection, transport, or land spreading vehicles and obtain any photographic documentation or evidence deemed appropriate. 27. A Fresh Way shall provide DEQ a monthly summary of septage processing and land application activities required under the business' septage management plan. 28. The Department may impose any additional restrictions or conditions deemed necessaiy to assure adequate septage management. Any variations from A Fresh Way's DEQ approved septage management plan and this authorization letter must receive prior written approval from the Roseburg Branch Office 29. This authorization is subject to revocation should health hazards, environmental degradation, or nuisance conditions develop as a result of inadequate septage treatment or site management. This authorization is considered part of the business' WPCF permit. Therefore, if operations are not conducted in accordance with terms specified under this DEQ-DCl

21 Dirksen Site Authorization FileNumber: October 11,2000 Page 13 of 5 authorization, the Department will initiate an enforcement action, which may lead to the assessment of a civil penalty. 30. Copies of A Fresh Way's site authorization letter and certification letters as required under the 40 CRF part 503's must accompany all septage land applied at this site. If you have any questions regarding this authorization, please contact me at Sincerely, Paul Kennedy Natural Resource Specialist 3 Roseburg Branch Office cc: Biosolids: Portland DEQ-DCl

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