WQ0003966_Final Permit_19910422

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27626-0535
James G. Martin, Governor
William W. Cobey, Jr., Secretary
April 22, 1991
Mr. Jim Smith, North Carolina Division Manager
Townsends, Incorporated, Poultry Products Group
P.O. Box 709
Siler City, North Carolina 27344
Dear Mr. Smith:
�.J
George T. Everett, Ph.D.
Director
Subject: Permit No. WQ0003966
Townsends, Incorporated
Land Application of Sludge
Chatham County
On January 14, 1991, the Division of Environmental Management issued Permit No.
WQ0003966 to Townsends, Incorporated for the operation of a sludge storage facility and the
operation of a sludge land application program. On February 21, 1991, the Division received a
request from. Ms. Grace Draman, acting.'as your agent, to modify the subject permit to delete the
requirements for monitoring wells. Upon review of this request, the Division agrees to delete
Conditions IV.3 and IV.4 of Permit No. WQ0003966, which was issued on January 14, 1991.
A condition is being added to the permit which states that sludge will be applied to a particular site
only once every three years.
r
This permit shall be effective from the date of issuance until December 31, 1995, shall
void Permit No. WQ0003966, which was issued on January 14, 1991, and shall be subject to the
conditions and limitations as specified therein. Please pay particular attention to the monitoring
requirements in this permit. Failure to establish an adequate system for collecting and maintaining
the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request an adjudicatory hearing upon written request within 30 days
following receipt of this permit. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447. Unless such demands
are made this permit shall be final and binding.
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

One set of approved project documents was previously forwarded to you. If you need
additional information concerning this matter, please contact Mr. Randy Jones at 919/ 733-5083.
�S'ncerely,
George T. E, Brett
cc: Chatham County Health Department
Environmental Waste Disposal (PO Box 170; Advance, NC 27006)
Raleigh Regional Office
Groundwater Section
Training and Certification (no revised rating)

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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH
SLUDGE LAND APPLICATION PERMIT
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 HERESY GRANTED TO
Townsends, Incorporated
Chatham County
FOR THE
operation of a sludge land application program consisting of the land application of approximately
1,300 cubic yards of stabilized cake sludge from the Townsends, Incorporated poultry processing
wastewater treatment plant to approximately 192 acres of disposal area and the continued
operation of a Smith Cattleguard Cake Sludge Storage Facility consisting of one 102 foot by 54
foot open sided building to shelter one 96 foot by 48 foot by S foot Smith Catdeguard Cake
Sludge Storage basin with discharge of collected leachate to the headworks of the Townsend
Farms existing Spray Irrigation waste treatment and disposal system via pump station with duplex
100 GPM pumps and high water alarms with no discharge of wastes to the surface waters,
pursuant to the application received on September 7, 1990, and the modification request received
on February 21, 1991, and in conformity with the project plan, specifications, and other
supporting data subsequently fled 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 December 31, 1995, shall void
Permit No. WQ0003966, which was issued on January 14, 1991, and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The Raleigh Regional Office, phone no. [phone], and the appropriate local
governmental official (county manager/city manager) shall be notified at least
twenty-four (24) hours prior to the initial application of the sludge so that an
inspection can be made of the application sites and application method. Such
notification to the regional supervisor shall be made during the normal office hours
from 5:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays. Also the Chatham County Manager's office must be notified prior to the
initial application so that they will be aware that the operation has commenced.
2. This permit shall become voidable if the soils fail to adequately absorb the wastes
and may be rescinded unless the sites are maintained and operated in a manner
which will protect the assigned water quality standards of the surface waters and
groundwaters.

3. The land application 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.
4. 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 facility.
5. In the event that the land application program is not operated satisfactorily,
including the creation of nuisance conditions, the Permittee shall cease applying
sludge to the sites and take any immediate corrective actions, including the
construction of additional or replacement wastewater treatment or disposal facilities.
6. No crops for direct human consumption shall be raised on these sites for a period of
18 months following sludge application.
7. Maximum slope for sludge application shall be 10% for surface application and
18% for subsurface applications.
8. The following buffer zones shall be maintained:
a) 400 feet from residences under separate ownership for surface application
method, however the buffer zone requirement may be reduced to a minimum of
100 feet upon written consent of the owner,
b) 200 feet from residences under separate ownership for injection method,
however the buffer zone requirement may be reduced to a minimum of 100 feet
upon written consent of the owner,
c) 100 feet from "SA and SB" classified waters and public surface water supplies
for both methods,
d) 50 feet from "WS" classified waters and other streams, creeks, lakes, rivers,
and surface water drainage ways for injection method,
e) 100 feet from "WS" classified waters and other streams, creeks, lakes, rivers
and surface water drainage ways for surface application method,
f) 100 feet from property lines for both methods,
g) 50 feet from public right of ways for surface application methods,
h) 25 feet from public right of ways for subsurface disposal methods,
i) 10 feet from upslope interceptor drains and surface water diversions for both
methods,
j) 25 feet from downslope interceptor drains, surface water diversions,
groundwater drainage systems and surface drainage ditches for both methods.
9. A copy of this permit shall be kept at the land application site when sludge is being
applied during the life of this permit. A spill prevention and control plan shall be
kept in all sludge transport and application vehicles.
10. All sludges included in this permit must be stabilized by a process to significantly
reduce pathogens (as described in 40 CFR Part 257, Appendix II) prior to
application or incorporation. An evaluation of all sludges as specified in condition
II 4 must be conducted as to their ability to demonstrate compliance with this
requirement. A copy of this report must be submitted to the Assistant Chief for
Operations, Division of Environmental Management, Water Quality Section,
Operations Branch, PC Box 27687, Raleigh, NC 27611-7687, within six (6)
months of the permit issue date.
11. Specific sludge application area boundaries shall be clearly marked on each site
prior to and during sludge application.
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12. No sludge at any time shall be stored at any application site.
11. OPERATION AND MAINTENANCE REQUIREMENTS
1.
2.
3.
4.
5.
The facilities and disposal sites shall be properly maintained and operated at all
times.
A suitable vegetative cover as listed in condition 11 3, shall be maintained in
accordance with the crop management plan approved by this Division.
The application rates shall not exceed the following for the specified crops:
Croon
Fescue
PAN lbs/acre/;ear)
250
No sludges other than the following are hereby approved for land application in
accordance with this permit:
Estimated
Sourcr, Counjy_Volume (dry tons/xeg)
Townsends, Inc. Pretreatment Chatham 312
The lifetime heavy metal loadings shall not exceed the following for the
corresponding Cation Exchange Capacities (CEC):
Parameter
CE.. C 5-15
Lead (lbs/acre)
1000
Zinc (lbs/acre)
500
Copper (lbs/acre)
250
Nickel (lbs/acre)
250
Cadmiumy(lbs/acre)'
9
6. Upon classification of the facility by the Certification Commission, the Permittee
shall employ a certified wastewater treatment plant operator to be in responsible
charge of the wastewater treatment facilities. The operator must hold a certificate of
the type and grade at least equivalent to the classification assigned to the wastewater
treatment facilities by the Ctification Commission.
7. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored sludge material into any surface waters.
8. Animals shall not be grazed on sludge applied land within a 30 -day period
following the sludge application. Application sites that are to be used for grazing
shall have fencing that will be used to prevent access after each application.
9. Surface applied sludge will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
10. For areas that are prone to flooding or within the 100 -year flood elevation, sludge
may be applied only during periods of dry weather. The sludge must be
incorporated into the soil within twenty-four (24) hours of application.
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11. Appropriate measures must be taken to control public access to the land application
sites during active site use and for the 12 -month period following the last sludge
application event. Such controls may include the posting of signs indicating the
activities being conducted at each site.
12. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the sludge application area onto the adjacent property or
into the surface waters.
13. Sludge shall not be applied in inclement weather or until 24 hours following a
rainfall event of 1/2 -inch or greater in 24 hours. Any emergency sludge disposal
measures must first be approved by the Division of Environmental Management.
14. The site shall be adequately limed to a soil pH of at least 6.5 prior to sludge
application. Sludge may be applied to sites with a pH of less than 6.5 provided a
sufficient amount of lune is also applied to achieve a final pH of the lime, sludge
and soil mixture of at least 6.5.
M. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, sludge, 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. If monitoring data indicates minimal or
no concern to the Division, reduction of monitoring requirements may be pursued
after two annual reporting periods.
2. Proper records shall be maintained by the Permittee tracking all disposal activities.
These records shall include, but are not necessarily limited to the following
information:
a) source of sludge
b) date of sludge application
c) location of sludge application (site, field, or zone #)
d) method of application
e) weather conditions
f) soil condition's
g) type of crop or crop to be grown on field
h) volume of sludge applied in gallons/acre and dry tons/acre
i) annual and cumulative tbtals of dry tons/acre of sludge, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be limited to
lead,nickel, cadmium, copper and zinc), annual pounds/acre of plant available
nitrogen (PAN), and annual pounds/acre of phosphorus applied to each field.
3. A representative annual soils analysis (Standard Soil Fertility Analysis) shall be
conducted of each site receiving sludge in the respective calendar year and the
results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the
following parameters:
% Base Saturation Manganese
Magnesium Cation Exchange Capacity
Phosphorus Sodium
Potassium Nickel
Lead Cadmium
Zinc Copper
pH Calcium
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4. A quarterly sludge analysis and annual Toxicity Characteristics Leaching Procedure
(TCLP) analysis shall be conducted by the Permittee and the results maintained on
file by the Permittee for a minimum of five years. If land application occurs at a
frequency less than quarterly, sludge analysis will be required for each instance of
land application.
The sludge analysis shall include but is not necessarily limited to the following
parameters:
% total solids
Magnesium
Chlorides
Sulfate
Phosphorus
Potassium
Lead
Zinc
Copper
Nickel
Cadmium
Chromium
Sodium
Calcium
Total Nitrogen
Ammonia Nitrogen
Nitrate/Nitrite, Nitrogen
pH
Plant Available Nitrogen (by calculation)
The TCLP analysis shall include the following parameters:
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o -Cresol
m -Cresol
p -Cresol
Cresol
2,4-D
1,4 -Dichlorobenzene
1,2-Dichloroethane
1,1-Dichloroerhylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its hydroxide)
Hexachlorobenzene
Hexachloro-1,3-butadiene
Hexachloroethane '
Lead
Lindane
Mercury
Methoxychlor '
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5 -Trichlorophenol
2,4,6 -Trichlorophenol
2,4,5 -TP (Silvex)
Vinyl chloride
5. Three copies of all monitoring and reporting requirements as specified in conditions
III 1, 1112,1113 and 1114 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
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6, Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office-, telephone
no. [phone], as soon as possible, but in no case more than 24 hours or on
the next working day following the occurrence or first knowledge of the occurrence
of any of the following:
a. Any occurrence with the land application program which results in the land
application of significant amounts of wastes which are abnormal in quantity or
characteristic.
b, Any failure of the land application program resulting in a release of sludge
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 sludge treatment.
e. Any spillage or discharge from a vehicle or piping system transporting sludge to
the application site.
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.
1. Any additional groundwdter quality monitoring, as deemed necessary by the
Division of Environmental' Management, shall be provided.
2. No land application of waste activities shall be undertaken when the seasonal high
water table is less than three feet below land surface.
3. The Compliance Boundary delineated on the attached site map for the disposal
system is specified by regulations in 15A NCAC 2L, Groundwater Classifications
and Standards. An exceedance of Groundwater Quality Standards beyond the
Compliance Boundary is subject to the penalty provisions applicable under General
Statute 143-215.6(1)a, The sale of ptoperty, by the Permittee, which is within or
contiguous to the disposal site, may alter the location of the Compliance Boundary.
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the waste disposal area, or 50 feet within
the property boundary.
If the title to any property which may affect the location of the Compliance
Boundary is changed, the Permittee shall notify the DEM Director within 14 days.
The Director shall then establish a modified Compliance Boundary which will be
done as a modification to the Permit.
6

The REVIEW BOUNDARY delineated on the attached site reap for the disposal
system is specified by regulations in 15 NCAC 2L, Groundwater Classifications
and Standards. A REVIEW BOUNDARY is established around disposal systems
midway between the Compliance Boundary and the perimeter of the waste disposal
area. When the concentration of any substance equals or exceeds the maximum
allowable concentration of that substance at the REVIEW BOUNDARY, as
determined by monitoring, the permittee shall either (i) demonstrate, through
predictive calculations or modeling, that natural site conditions, facility design and
operational controls will prevent a violation of standards at the Compliance
Boundary; or, (ii) submit a plan for the alteration of existing site conditions, facility
design or operational controls that will prevent a violation of standards at the
Compliance Boundary, and implement that plan upon its approval by the Director.
V. INSPECTIONS
The Permittee or his designee shall inspect the sludge storage, transport, and
disposal 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 keep 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 three years from the
date of the inspection and shall be made available upon request by the Division of
Environmental Management or other permitting authority.
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 disposal site and 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; or may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become vc' dable unless the land application activities are carried
out in accordance with the c6nditions of this permit and in the manner approved by
this Division.
2. This permit is effective only with respect to the nature and volume of wastes
described in the application and other supporting data.
3. This permit is not transferable. In the event 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. Prior to any transfer of this land, a notice shall be given to the new owner that gives
full details of the materials applied or incorporated at this site.
7
4

5.
11
This permit shall become voidable unless the agreements between the Pem-iittee and
the Ian downers/lessees are in full force and effect.
The following are approved sites for sludge application (see attached map):
Site No. Owner/Lessee Application Area(excluding buffers
acres
Barker - 1
Hazel Barker
23.4
Barker - 2
Hazel Barker
3.0
Barker - 3
Hazel Barker
7.5
Barker - 4
Hazel Barker
11.7
Watson - 1
Treva Watson/Benny Watson
15.6
Watson - 2
Treva Watson/Benny Watson
19.1
Watson - 3
Treva Watson/Benny Watson
22.6
Watson - 4
Treva Watson/Benny Watson
22.3
Watson - 5
Treva Watson/Benny Watson
13.8
Swain #1-1
John C. Swain
19.3
Swain #2-2
John C. Swain
4.0
Swain #2-3
John C. Swain
30.0
Total 192.3
The land application sites designated below are covered in part by soils having a
seasonal high water table at depths ranging from 1.5 to 2.5 feet below land surface.
Therefore, these fields shall be subject to seasonal application as follows:
Treva Watson December through May
John C. Swain - Site #1 December through May
7. Failure to abide by the conditions and limitations contained in this permit may
subject the Permittee to aA enforcement action by the Division of Environmental
Management in accordancb with North Carolina General Statute 143-215.6.
8. The annual administering and compliance fee must be paid by the Permittee within
thirty (30) days after bei4g billed by the Division_ Failure to pay the fee
accordingly may cause thDivision to initiate action to revoke this permit as
specified by 15 NCAC 2H.0205 (c)(4).
9. 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.
10. A set of approved documents for the subject project must be retained by the
applicant for the life of the permit.
11. The Permittee, 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.
S
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12. 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.
13. Sludge may be applied to a particular site only once every three years, utilizing the
three year rotation schedule.
Permit issued this the 22nd day of April, 1991.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
1
eorge T. Everett, irecto
Division of Envieental gement
By Authority of the . onmemal Management Commission
Permit No. WQ0003966
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