WQ0000965_Final Permit_19970717

State of North Carolina 'T
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor 3
Jonathan B. Howes, Secretary C) F
A. Preston Howard, Jr., P.E., Director
July 17, 1997
William C. Howard, Jr., P.E., Manager, Water Quality Program
R. J. Reynolds Tobacco Co.
Packaging Division, Plant 200
Post Office Box 1487
Winston-Salem, North Carolina 27102-1487
Subject: Permit No. WQ0000965
R. J. Reynolds Tobacco Co.
Plant 200, Cunningham Avenue
Groundwater Remediation Facilities
Forsyth County
Dear Mr. Howard:
In accordance with the modification request received July 8, 1997, we are forwarding herewith
Permit No. WQ0000965 as modified, dated July 17, 1997, to the R. J. Reynolds Tobacco Co. for the
continued operation of the subject groundwater remediation facility. This permit is being modified per
your request. Only the facility description (vapor carbon adsorption has been deleted), Condition IV 5
(changed to 24 hours), and Condition IV 1 (deleting PCB from the groundwater monitoring program)
have been amended. No other conditions have been modified.
Prior to any modifications to the subject facility, the R. J. Reynolds Tobacco Co. must request the
permit be amended. The permit must be amended by the Division before any construction occurs at the
groundwater remediation facility -
This permit shall be effective from the date of issuance until April 30, 2002, shall void Permit No.
WQ0000965 issued May 30, 1997, 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, you have the
right to request an adjudicatory hearing upon written request within thirty (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.
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

a

If you have any questions concerning the Groundwater Conditions or groundwater monit31ir;
requirements, please contact Mr. Ken Pohlig in the Groundwater Section at [phone]. If yo_: need
any additional information concerning this matter, please contact Mr. Michael D. Alien at [phone]
extension 547.
Sincerely
Preston Howard, Jr., P.E.
cc: Forsyth County Health Department
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Bob Check, Groundwater Section, Central Office
Training and Certification Unit
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAI, MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
GROUNDWATER REMEDIATION 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 HEREBY GRANTED TO THE
R. J. Reynolds Tobacco Co.
Forsyth County
FOR THE
continued operation of a 10,000 GPD groundwater remediation facility consisting of thirteen (13) recovery
wells (plus the continued operation of two (2) existing recovery wells) of which five (5) of the recovery
wells will be vacuum enhanced including a blower, a 1200 gallon biocide tank chamber with hydrogen
peroxide feed, a 270 gallon oil/water separator, a 550 gallon pH adjustment and aeration tank with caustic
feed, a 1400 gallon sludge settling tank, two sets of backwashing filters, one filter press, two (2)
PetroClean 4000 fixed film bioreactors with nutrient feed, a 550 gallon effluent aerated dosing tank for the
injection wells, a 2100 gallon effluent aerated dosing tank for the infiltration galleries, four (4) 1200 ft-
infiltration galleries, and four (4) 0.25 GPM injection wells to serve the R. J. Reynolds Tobacco Co.'s
Plant 200 located on Cunningham Avenue, with no discharge of wastes to the surface waters, pursuant to
the modification request received July S, 1997, 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 April 30, 2002, shall void Permit No.
WQ0000965 issued May 30, 1997, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
This permit shall become voidable if the soils fail to adequately assimilate the wastes and
may be rescinded unless the facilities are installed, maintained, and operated in a manner
which will protect the assigned water quality standards of the surface waters and ground
waters.
2. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or
replacement treatment or disposal facilities.
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 facility.

4. Any residuals generated from these treatment facilities must be disposed in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Water Quality.
5. Diversion or bypassing of the untreated groundwater from the treatment facilities i.-
prohibited.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times
2. Upon classification of the facility by the Certification Commission, the Permittec sha i `.
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) o'
the wastewater treatment facilities. The operator must hold a certificate of the type arld
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202.
3. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring deemed necessary by the Division of Water Quality to insure surface and
ground water protection will be established and an acceptable sampling reporting schedule
shall be followed.
2. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem 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 first knowledge of the occurrence of any of
the following:
a. Any occurrence at the groundwater remediation facility which results in the treatment of
significant amounts of contaminated groundwaters which are abnormal in quantity or
characteristic, such as the dumping of the contents of a basin or tank, the known
passage of a slug of hazardous substance through the facility, or any other unusual
circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the
groundwater treatment and disposal system incapable of adequate treatment and
disposal, such as mechanical or electrical failures of pumps, aerators, compressors,
etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to
such station or facility; or

d. Any time that self -monitoring information indicates that the groundwater treatment and
disposal system is not in compliance with any specified permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within five (5) 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.
IV. GROUNDWATER REQUIREMENTS
Monitor wells MW-1, MW-2, MW-6, MW-8, MW-16, MW-17, MW--19, and MW-21
shall be sampled every May and November for the following parameters:
pH Water Level
Total Phosphorus Nitrate (NO3-N)
Total Ammonia
EPA Method 624 Modifieda
EPA Method 8015b
a Analysis for acetone, MEK, isopropyl acetate, normal propyl acetate, toluene,
and heptane.
b Analysis for isopropanol and normal propanol
The measurement of water Ievels must be made prior to sampling for the remaining
parameters. The depth to water in each well shall be measured from the surveyed point on
the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide the relative elevation of the measuring point for each monitoring well.
The results of the sampling and analysis must be received on Form GW-59 (Groundwater
Quality Monitoring: Compliance Report Form) by the Groundwater Section, Permits and
Compliance Unit, P.O. Box 29578 Raleigh, N.C. 27626-0578 every June and December.
2. The influent and effluent from the treatment system shall be sampled every quarter
(February, May, August, and November) for the parameters specified below:
Total Phosphorus (effluent only)
Nitrate (NO3 -N) (effluent only)
EPA Method 624 Modifieda
EPA Method 8015b
Analysis for acetone, MEK, isopropyl acetate, normal propyl acetate, toluene,
and heptane.
b Analysis for isopropanol and normal propanol
The results of the sampling and analysis must be received on Form GW-59 (Groundwater
Quality Monitoring: Compliance Report Form) by the Groundwater Section, Permits and
Compliance Unit, P.O. Box 29578 Raleigh, N.C. 27626-0578 every March, June,
September and December.
3. Injection pressures shall not exceed 2 psi. If pressures greater than 2 psi are necessary, the
permittee must receive approval from the Winston-Salem Regional Office prior to
increasing the pressure above 2 psi.

4. All components of the groundwater recovery, treatment, and disposal system shall be
properly weather -proofed to prevent freezing and failure of the system.
5. The groundwater recovery, treatment and disposal system shall be inspected weekly. If it
is determined that the system is malfunctioning, all repairs should be made as soon as
possible and reported to the Winston-Salem Regional Office within 24 hours.
6. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
7. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983 is established at either (1) 250
feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or
beyond the Compliance Boundary is subject to immediate remediation action in addition to
the penalty provisions applicable under General Statute 143-215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.
V . INSPECTIONS
1. Adequate inspection, maintenance and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the groundwater recovery 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 three years from the date of the inspection and shall be made available to the
Division of Water Quality or other permitting authority, upon request.
3. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises or place on
or related to the disposal 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
maintained under the terms and conditions of this permit, and may obtain samples of
groundwater, surface water, or Ieachate.
VI. GENERAL CONDITIONS
Issuance of this permit does not constitute approval for reimbursement from the Leaking
Petroleum Underground Storage Tank CIeanup Funds (I 5A NCAC 2P).
2. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans and specifications, and other supporting
data.
3. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.

4. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Water Quality 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.
5. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215.6(a) to 143-215.6(c).
7. 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 15A NCAC 2H .0205
(c)(4).
8. 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.
9. The Permittee, at Ieast 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 Iimitations as it may deem appropriate.
Permit issued this the seventeenth day of July, 1997
NORTH CA
3OLINA ENVIRONMENTAL MANAGEMENT COMMISSION
-A_ Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0000965