WQ0003824_Final Permit_20141027

A 4
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
October 27, 2014
Victor R. Quick — Utilities Director
City of Graham
Post Office Drawer 357
Graham, North Carolina 27253
Subject: Permit No. WQ0003824
City of Graham
Land Application of Class B Water and
Wastewater Treatment Plant Residuals
(Dedicated)
AIamance County
Dear Mr. Quick:
John E. Skvarla, III
Secretary
In accordance with your permit renewal request received May 30, 2014, and subsequent
additional information received October 6, 2014, we are forwarding herewith Permit No. WQ0003824
dated October 27, 2014, to the City of Graham for the continued operation of the subject residuals
management program- Please note that this renewed permit shall become effective on December I, 2014
(i.e. the day after the expiration date of the existing permit), which differs from the date of this letter.
Please also note that the status of this program has been changed from "Non -Dedicated" to "Dedicated".
For "Dedicated" fields, agronomic application rates may be exceeded, provided the investigation,
evaluation and documentation requirements of 15A NCAC 02T .1104(d) are met prior to application, and
a permit modification is requested to remove Permit Condition II.10. Monitoring wells will also have to
he installed, and a groundwater monitoring program will have to he established
This permit shall be effective from December 1, 2014 until November 30, 2019, shall void Permit
No. WQ0003824 issued December 27, 2005, and shall be subject to the conditions and limitations as
specified therein- Please pay particular attention to the monitoring requirements listed in Attachments A
and B for they may differ from the previous permit issuance. Failure to establish an adequate system for
collecting and maintaining the required operational information shall result in future compliance
problems.
Please note that on September 1, 2006, North Carolina Administrative Code Title 15A
Subchapter 02T — Waste not Discharged to Surface Waters was adopted. Accordingly, this permit
incorporates the requirements of these rules, therefore, please take the time to review this permit
thoroughly. The following conditions have been added, modified or deleted from those in the last permit
issuance:
➢ Condition 1.1- —describes the procedure for permit renewal
➢ Condition I.2. — an Operation and Maintenance Plan must be submitted within 90 days
Condition I.3. — signage requirements shall be met within 180 days of the effective date
1636 Mail Service Center, Raleigh, North Carofina 27699-1636
Phone: 9IM07-64641 Internet: http:flportal.ncdeni.org/web/wo
An Equal Opportunity 1 Affirmative Action Employer - Made in parr with recycled paper

Mr. Victor R. Quick
October 27,
2014
Page 2 of 3
➢
Condition II.1. —
the program shall be effectively maintained and operated
➢
Condition 11.6. —
the residuals shall meet pathogen reduction requirements
➢
Condition 11.7. —
the residuals shall meet vector attraction reduction requirements
➢
Condition 11.8. —
lists the setback distances for the land application sites
➢
Condition 11.9. ---
setback distances shall be verified prior to any application event
➢
Condition 11.10. ---
Realistic Yield Expectations shall be used to determine application rates
➢
Condition I1.11.
— the consumption of nitrogen is reduced on grazed pasture areas
➢
Condition 11.12.
— areas which are double -cropped receive special consideration
➢
Condition 11.13.
— special treatment is needed when the sodium adsorption ratio is high
➢
Condition 11.14.
— defines the Iocation of the compliance boundary
➢
Condition I11.1. —
the program shall be properly maintained and operated at all times
v
Condition III.2. —
notification shall take place at least 24 hours prior to any application
v
Condition 111.3. —
notification shall take place at least 48 hours prior to initial land application
➢
Condition 111.4. — an approved Operation and Maintenance (O&M) Plan shall be maintained
➢
Condition 111.5. —
an ORC and backup ORC must be retained for the facility operation
i'
Condition I11.6. —
a copy of the permit and O&M Plan must be present at all applications
Condition 11I.7. — spill control provisions must be in effect for all transport and application
➢
Condition 111.11.
— lists the conditions under which bulk applications cannot take place
➢
Condition 11I.12.
— lists the public access restrictions to the application sites
➢
Condition 111.13.
— states the signage requirements on the application sites
y
Condition 111.15.
— additional nutrient sources must be accounted for in the program
➢
Condition IV.2. —the
residuals must be analyzed for hazardous waste constituents
i>
Condition IV.3. —the
residuals must be analyzed for metals and other constituents
Y
Condition IV.4_ —
residuals must comply with pathogen and vector attraction reduction
➢
Condition iV.5. —
an annual Standard Soil Fertility Analysis must be performed on each site
➢
Condition IV.7. —
lists the minimal requirements for recording land application events
➢
Condition IV.8. —
an annual report is to be prepared and submitted before March I st

Mr. Victor K Quick
October 27, 2014
Page 3 of 3
➢ Condition IV.9 — describes non-compliance events and the actions to be taken
➢ Condition V.I. — adequate inspection and maintenance shall be provided
➢ Condition V.3. — site inspections may be performed by any authorized individuals
➢ Condition VIA. — the permit does not exempt the permittee from other regulations
➢ Condition VI.5. — any change in ownership requires a permit modification
➢ Condition VI.6. —the permit is subject to revocation of modification in certain situations
➢ Condition VI.7. — the program may not be expanded under certain conditions
➢ Condition VI.8_ — the annual permit fee must be paid within 30 days of billing
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail
Service Center, Raleigh, NC 27699-67I4. Unless such demands are made, this permit shall be final and
binding.
If you need additional information concerning this matter, please contact David Goodrich at (919)
807-6352 or [e-mail].
Sincerely,
or Tho as A. Reeder, Director
Division of Water Resources, NCDENR
cc_ Alamance County Health Department
Winston-Salem Regional Office, Water Quality Regional Operations Section
Beth Buffington, Public Water Supply Section — Protection and Enforcement Branch
Permit File WQ0003824
Notebook File WQ0003824

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION OF CLASS B WATER AND WASTEWATER TREATMENT PLANT
RESIDUALS PERMIT (NON -DEDICATED)
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
City ®f Graham
Alamance County
FOR THE
continued operation of a residuals management program for the City of Graham and consisting of the land
application of Class B Water and Wastewater Treatment Plant residuals generated by the approved
facilities listed in Attachment A to the approved sites listed in Attachment B with no discharge of wastes
to surface waters, pursuant to the application received May 30, 2014, and subsequent additional
information received by the Division of Water Resources, and in conformity with other supporting data
subsequently filed and approved by the Department of Environment and Natural Resources and
considered a part of this permit. The use and disposal of residuals are regulated under Title 40 Code of
Federal Regulations fart 503. This permit does not exempt the Permittee from complying with the federal
regulations.
This permit shall be effective from December 1, 2014 until November 30, 2019, shall void Permit No.
WQ0003824 issued December 27, 2005, and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
2. The permittee shall submit the Operation and Maintenance (O&M) plan as required in Condition
111.4. to the Division prior to March 1, 2015_
3. The permittee shall be in full compliance with the signage requirements established in Condition
111.13. prior to June 1, 2015_
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H. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease land
applying residuals to the site, contact the Winston-Salem regional office supervisor, and take any
immediate corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3. Only residuals generated by the facilities listed in Attachment A are approved for land application in
accordance with this permit.
4. Only the sites listed in Attachment Bare approved for residuals land application.
5. Pollutant concentrations in residuals applied to land application sites listed in Attachment B shall not
exceed the following Ceiling Concentrations (i.e., dry weight basis) or Cumulative Pollutant
Loading Rates (CPLRs):
Parameter
Ceiling Concentration
(milligrams per kilogram)
CPLR
(pounds per acre)
Arsenic
75
36
Cadmium
85
34
Copper
4,300
1,338
Lead
840
267
Mercury
57
15
Molybdenum
75
n/a
Nickel
420
374
Selenium
100
89
Zinc
7,500
2,498
The Permittee shall determine compliance with the CPLRs using one of the following methods:
a. By calculating the existing cumulative level of pollutants using actual analytical data from all
historical land application events of residuals, or
b. For land where residuals application have not occurred or for which the required data is
incomplete, by determining background concentrations through representative soil sampling.
6. Residuals that are land applied shall meet Class B pathogen reduction requirements in 15A NCAC
02T .I 106 (a) and (c). Exceptions to this requirement shall be specified in Attachment A.
7. Biological residuals (i.e. residuals generated during the treatment of domestic or animal processing
wastewater, or the biological treatment of industrial wastewater, and as identified in Attachment A)
that are land applied shall meet one of the vector attraction reduction alternatives in 15A NCAC 02T
.I 107(a). Exceptions to this requirement shall be specified in Attachment A.
8. Setbacks for Class B land application sites shall be as follows:
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Setback by application type
(feet)
Setback Description
Vehicular
Irrigation
Surface
Surface
Infection /
Application
Application
corporation
Habitable residence or place of public assembly
under separate ownership or not to be maintained as
400*
400*
200*
art of the project site
Property lines
50
50
50
Public right of way
50
50
50
Private or public water supply source, waters
classified as SA or SB, and any Class I or Class II
100
100
100
impounded reservoir used as a source of drinking
water
Surface waters (streams — intermittent and perennial,
perennial waterbodies, and wetlands), any streams
classified as WS or B, any other stream, canal,
100
100
50
marsh or coastal waters, and any other lake or
impoundment
Upslope interceptor drains and upslope surface water
10
10
10
diversions (ephemeral streams, water —ways, ditches)
Downslope interceptor drains, downslope surface
water diversions, downslope groundwater lowering
25
25
25
ditches (where the bottom of the ditch intersects the
SHWT), and downslope surface drainage ditches
*The setback requirement may be reduced to a minimum of 100 feet upon written consent of the
owner and approval from the Water Quality Regional Operations Section of the appropriate
Division's regional office in Attachment B of this permit.
9. Land application areas shall be clearly marked on each site prior to and during any residuals
application event. The markers shall be examined prior to each application event to verify that the
application areas meet the setback distances from surface waters and other features, as listed in Permit
Condition II.8.
10. Bulk residuals and other sources of PIant Available Nitrogen (PAN) shall not be applied in
exceedance of agronomic rates. The City may apply for a permit modification to apply at greater than
agronomic rates, provided the application meets the requirements of 15A NCAC 02T .l 104(d) and
demonstrates protection of water resources. Appropriate agronomic rates shall be calculated using
expected nitrogen requirements based on the determined Realistic Yield Expectations (RYE) using
any of the following methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina
State University Department of Soil Science (http //nutrients.soil.ncsu.edulyieldslindex.php).
A copy shall be kept on file and reprinted every five years in accordance with Condition 1V.6.
c. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
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ii. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter 1
(http://www.ncagr.wWSWC/tech/documents/9th Guidance_ Doc_100109.pdf).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (MRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards Cftp:op-fe.sc.egov.usda.gov/NHQ/practice-standards/standards/590.pdfl.
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
11. When residuals are Iand applied to grazed pasture, hay crop realistic nitrogen rate shall be reduced by
25% in accordance with the USDA-NRCS 590 Nutrient Management Standards.
12. If land application sites are to be over -seeded or double -cropped (e.g., bermuda grass in the summer
and rye grass in the winter with both crops to receive residuals), then the second crop can receive an
application of PAN at a rate not to exceed 50 pounds per acre per year (lbs/ac/yr). This practice may
be allowed as long as the second crop is to be harvested or grazed. If the second crop is to be planted
for erosion control only and is to be tilled into the soil, then no additional PAN shall be applied.
13. Prior to land application of residuals containing a sodium adsorption ratio (SAR) of 10 or higher, the
Permittee shall obtain and implement recommendations from at least one of the following: the local
Cooperative Extension Office; the Department of Agriculture and Consumer Services; the Natural
Resource Conservation Service; a North Carolina Licensed Soil Scientist; or an agronomist. The
recommendations shall address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a
mechanism for maintaining site integrity and conditions conducive to crop growth. The Permittee
shall maintain written records of these recommendations and details of their implementation.
14. The compliance boundary for residual land application sites shall be specified in accordance with
I SA NCAC 02L .0107(b). These sites were individually permitted on or after December 30, 1983;
therefore, the compliance boundary is established at either 250 feet from the residual land application
area, or 50 feet within the property boundary, whichever is closest to the residual land application
area. An exceedance of groundwater standards at or beyond the compliance boundary is subject to
remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in
accordance with North Carolina General Statute 143-215.6A through 143-215.6C. Any approved
relocation of the COMPLIANCE BOUNDARY will be noted in Attachment B_
15. In accordance with 15A NCAC 02L .0108, the review boundary shall be established midway between
the compliance boundary and the residual land application area. Any exceedance of groundwater
standards at the review boundary shall require action in accordance with 15A NCAC 02L .0106.
III. OPERATION AND MAINTENANCE REQUIREMENTS
The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards_
2. The Winston-Salem Regional Office, telephone number [phone], shall be notified at least 24
hours prior to any land application event. NOTE: If the facility operates on a continual weekly land
application basis, a quarterly notification to the WSRO of planned land application activities may be
substituted.
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3. The Winston-Salem Regional Office, telephone number [phone], and the appropriate local
government official (i.e., county manager, city manager, or health director) shall be notified at least
48 hours prior to the initial residuals land application to any new land application site. Notification to
the regional supervisor shall be made from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
4. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) pursuant to
ISA NCAC 02T .1110. Modifications to the O&M Plan shall be approved by the Division prior to
utilization of the new plan. The O&M Plan, at the minimum, shall include:
a) Operational functions;
b) Maintenance schedules;
c) Safety measures;
d) Spill response plan;
e) Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for
any foreseen fluctuations in residuals quality and indicate the most limiting times for
residuals to meet pathogen and vector attraction reduction requirements (e.g. facilities that
Iand apply multiple times per year but have an annual sampling frequency, may need to
sample during winter months when pathogen reduction is most likely to be negatively
affected by cold temperatures).
Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in
responsible charge (ORC) and one or more certified operators as back-up ORCs in accordance with
15A NCAC 08G ,0201. The ORC or their back-up shall visit the facilities in accordance with 15A
NCAC 08G. 0204, or as specified in the most recently approved O&M plan (i.e., see Condition
III.4.), and shall comply with all other conditions of 15A NCAC 08G. 0204. For more information
regarding classification and designation requirements, please contact the Division of Water
Resources' Technical Assistance & Certification Unit at [phone].
6. When the Permittee land applies bulk residuals, a copy of this permit and a copy of O&M Plan shall
be maintained at the land application sites during land application activities.
7. When the Permittee transports or land applies bulk residuals, the spill control provisions shall be
maintained in all residuals transport and application vehicles.
8. Residuals shall not be stored at any land application site, unless written approval has been requested
and received from the Division.
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When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind
erosion and surface runoff from conveying residuals from the land application sites onto adjacent
properties or into surface waters.
10. When the Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on
land application sites onto which residuals are applied, or application shall be in accordance with the
crop management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or an agronomist
and as approved by the Division.
11. Bulk residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species Iisted under
section 4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of
surface water or groundwater standards;
d. If the land is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of
the residuals would occur;
e. Within the 100-year flood elevation, unless the bulk residuals are injected or incorporated within
a 24-hour period following a residuals land application event;
f. During a measurable precipitation event (i.e., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. If the slope is greater than 10% for surface applied liquid residuals, or if the slope is greater than
18% for injected or incorporated bulk liquid residuals;
h. If the soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to
achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the
pH of the soil, residuals and lime mixture is suitable for the specified crop. Any approved
variations to the acceptable soil pH (6.0) will be noted in this permit;
i. If the land does not have an established vegetative cover unless the residuals are incorporated or
injected within a 24-hour period following a residuals land application event. Any field that is in
a USDA no -till program shall be exempted from meeting this vegetative cover requirement;
j. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
k. If the vertical separation of bedrock and the depth of residuals application is less than one foot;
I. Application exceeds agronomic rates.
12. The following public access restrictions apply to residual land application sites:
a. Public access to public contact sites (e.g., golf courses, parks, ball fields, etc.) shall be restricted
for 365 days after a residuals land application event;
b. Public access to non-public contact sites shall be restricted for 30 days after a residuals land
application event.
13. Public access controls shall include the posting of signs with a minimum area of 3 square feet (e.g.,
1.5' x T). Each sign shall indicate the activities conducted at each site, permit number, and name and
contact information, including the Permittee or applicator's telephone number. Signs shall be posted
in a clearly visible and conspicuous manner at the entrance to each land application site during a land
application event, and for as long as the public access restrictions required under III.12 apply.
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14. The following harvesting and grazing restrictions apply to residual land application sites after each
land application event:
Harvesting and Grazing Description
Restricted
Duration
Animals shall not be allowed to graze during land application activities and
restricted period. Sites that are to be used for grazing shall have fencing to
30 days
prevent access after each land application event.
Food crops, feed crops and fiber crops shall not be harvested for
30 days
Turf grown on land where residuals have been applied shall not be harvested for:
12 months
Food crops with harvested parts that touch the residual/soil mixture and are
totally above the land surface (e.g., tobacco, melons, cucumbers, squash, etc.)
14 months
shall not be harvested for:
When the residuals remain on the land surface for four months or longer prior to
incorporation into the soil, food crops with harvested parts below the Iand
20 months
surface (e.g., root crops such as potatoes, carrots, radishes, etc.) shall not be
harvested for:
When the residuals remain on the land surface for less than four months prior to
incorporation into the soil, food crops with harvested parts below the land
38 months
surface shall not be harvested for:
15. The Permittee shall acquire from each landowner or lessee/operator a statement detailing the volume
of other nutrient sources (i.e., manufactured fertilizers, manures, or other animal waste products) that
have been applied to the site, and a copy of the most recent Nutrient Management Plan (NMP) for
those operations where a NMP is required by the US Department of Agriculture — National Resources
Conservation Service (NRCS) or other State Agencies. The Permittee shall calculate allowable
nutrient Ioading rates based on the provided information and use appropriate reductions.
For the purpose of this permit condition, a Crop Management Plan (CMP), Waste Utilization Plan
(WUP) or Certified Nutrient Management Plan (CNMP) shall also be considered a Nutrient
Management Plan.
16. No residuals shall be land applied unless the submitted Land Owner Agreement Attachment (LOAA)
between the Permittee and landowners or lessees/operators of the land application site is in full force
and effect. These agreements shall be considered expired concurrent with the permit expiration date,
and shall be renewed during the permit renewal process.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses [eorrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
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The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
IJ-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1,0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02) .
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
0.008
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
3. An analysis shall be conducted on residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
Plant Available Nitrogen
(by calculation)
4. Residuals shall be monitored for compliance with pathogen and vector attraction reduction
requirements at the frequency specified in Attachment A, and at the time indicated in the sampling
and monitoring sections of the approved O&M plan. The required data shall be specific to the
stabilization process utilized, and sufficient to demonstrate compliance with the Class B pathogen
reduction requirements in I5A NCAC 02T .1106 (a) and (C), and one vector attraction reduction
requirement in 15A NCAC 02T .1107 (a) shall be met. Any exceptions from the requirements in this
condition shall be specified in Attachment A.
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5. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each land application site listed in Attachment B on which a residuals land application event will
occur in the respective calendar year. This analysis shall be in accordance with the "Guidance on Soil
Sampling" located in the Sampling Instructions section of the NC Department of Agriculture &
Consumer Services' website(http://www.ncagr.gov/agronomi/pubs.htm). The Permittee shall
maintain these results and a description of the sampling methodologies used to determine soil fertility
for a period of no less than five years, and shall be made available to the Division upon request. At a
minimum, the Standard Soil Fertility Analysis shall include the following parameters:
Acidity
Exchan eable Sodium. Percentage
Phosphorus
Base Saturation (by calculation)
Magnesium
Potassium
Calcium
Manganese
Sodium
Cation Exchange Capacity
Percent Humic Matter
Zinc
Copper
pH
6. Laboratory parameter analyses shall be performed on the residuals as they are land applied, and shall
be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
7. The Permittee shall maintain records tracking all residual land application events. At a minimum,
these records shall include the following:
a. Source of residuals;
b. Date of land application;
c. Location of land application (i.e., site, field, or zone number as listed in Attachment B);
d. Approximate areas applied to (acres);
e. Method of land application;
f. Weather conditions (e.g., sunny, cloudy, raining, etc.);
g. Predominant Soil Mapping Unit (e.g., CbB2);
h. Soil conditions (e.g., dry, wet, frozen, etc.);
i. Type of crop or crops to be grown on field;
j. Nitrogen Application Rate based on RYES (if using data obtained from the North Carolina State
University Department of Soil Science Website, the printout page shall be kept on file and
reprinted every five years);
k. Volume of residuals land applied in gallons per acre, cubic yard per acre, dry tons per acre, or wet
ton per acre;
1. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per acre, or
wet tons per acre;
in. Volume of soil amendments (e.g., lime, gypsum, etc_) applied in gallons per acre, dry ton per
acre, or wet tons per acre; and
n. AnnuaI and cumulative totals in dry tons per acre of residuals as well as animal waste and other
sources of nutrients (e.g., if applicable), annual and cumulative pounds per acre of each heavy
metal (e.g., shall include, but shall not be limited to, arsenic, cadmium, copper, lead, mercury,
molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN, and annual pounds per
acre of phosphorus applied to each field.
WQ0003824 Version 3.0 Shell Version 140324 Page 9 of 1 1

8. Three copies of an annual report shall be submitted on or before March 1'. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual ReRortin
Forms. Instructions for reporting and annual report forms are available at
hgp://portal.nedenr.orp-/web/wq/ass/lau/reporting, or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
9. 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 with the land application program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the land application program resulting in a release of material to surface waters.
Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
be taken to ensure that the problem does not recur.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan.
Prior to each bulk residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. The Permittee shall maintain an
inspection log that includes, at a minimum, the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log
for a period of five years from the date of inspection, and this log shall be made available to the
Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
WQ0003824 Version 3.0 Shell Version 140324 Page 10 of I 1

VT. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
This permit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit.
3. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCGO I0000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the residuals program changes ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division_ This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T 0110.
7. UnIess the Division Director grants a variance, expansion of the permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
8. The Penmittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T _0105(e)(3).
Permit issued this the 27'h day of October 2014, effective December 1, 2014
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
e-
6r-homas . Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0003824
WQ0003824 Version 3.0 Shelf Version 140324 Pave 1 1 of 1 1

ATTACHE NT A - Approved Residual Sources
Cite of Graham
Certification Date: December 1, 2014
Permit Number: WQ0003824 Version: 3.0
Approved
Monitoring
Monitoring
Monitoring
Mineralization
Permit
BiologicaE
Maximum
Frequency For
Frequency for
Frequency for
Mate
Olrner
Facility Name
Count
Number
Residuals
Dr Tons
y 1
Non -hazardous
Metals and
Pathogen &
g
Raw=0..
Per Year
y
Characteristics
5, s
Nutrients
Vector Attraction
Aerobic = 03;
Reductions 4,s,6Anaerobic
= 0.2;
Com ost = 0.1
City of Graham
Graham / Mebane WTP
Alamance
NCO045292
No
295
Annually
Quarterly
Quarterly
0.40
City ol'Graham
Graham WWTP
Alamance
NCO021211
Yes
560
Annually
Quarterly
Quarterly
0.30
Total
855
I. Maximum Dry Tons per Year is the amount of residuals approved for land application from each permitted facility.
2. Anah•ses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen and vector attraction reductions as stipulated under permit Condition IVA,
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per real
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1/year
=>3 19 - <1,650
11 Quarter 4 times per ear
='11.650 - <16.500
1/60Days (6 times per 'ear
16.500
1/month (12 times per yem
6. Water Treatment Plant residuals are exempt from meeting the vector attraction reduction requirements in Condition IVA, provided they are not mixed with residuals that have been generated
during the treatment of domestic wastewater. the treatment of animal processing wastewater, or the biological treatment of industrial wastewater. The Water Treatment Plant residuals must be
treated and processed in a manner as to not meet the definition of "Biological Residuals" as defined in 15A NCAC 02T .1102(6).
If no land application events occur- during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is required), then no
sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual
report to EPA may be required to make up the missed sampling, contact the EPA for additional information and clarification.
Page I of 1

ATTACHMENT B - Approved Land Application Sites
City of Graham
Certification Date: December 1, 2014
Permit Number: WQ0003824 Version: 3.0
Field/ Site
Owner
Lessee
County
Latitude
Longitude
A Net a
Dominant Soil Series
Footnotes
NC-AM-01-01
City of Graham
Alamance
36000'25"
7902I'00"
7.0
TaB — Tirzah silt loam (Tarrus)
NC-AM-01-02
City of Graham
Alamance
36P00' 18"
79020'53"
5.9
TaB—'Firzah silt loam (Tarrus)
NC-AM-01-03
City of Graham
Alamance
36000' 18"
79021'04"
4.6
DbB — Davidson clay loam
NC-AM-0I-04
City of Graham
Alamance
36°00'07"
79021'07"
5.9
TaB — Tirzah silt loam (Tarrus)
NC-AM-01-05
City of Graham
Alamance
36000' 18"
7902I'07"
14.4
DbB — Davidson clay loam
NC-AM-01-06
City of Graham
Alamance
W00'25"
79021'04"
9.8
TaB — Tirzah silt loam (Tarrus)
NC-AM-01-07
City of Graham
Alamance
36000'36"
79*21'07"
9.9
GaB2—Georgeville silt loam
NC-AM-01-08*
City of Graham
Alamance
36000'I 1"
79021'22"
3.5
Cg- Congaree fine sandy loam
NC-AM-01-10*
City of Graham
Alamance
35059'56"
79020'56"
10.3
Congaree-Chewacla soil complex
Total
71.3
"These fields are within the 100-ye2r floodplain and, in accordance with 15A NCAC 02T .1109(b)(1)(E), land application is restricted to injection or incorporation
within 24 hours of land application.
Page 1 of 1

TOPOGRAPHIC MAP
S�1111 SYNAGRO
A J?tridvdlt Mariagemeat Company
kM
OWNERS City of Graham SCALE: v ALAMANCE COUNTY
t � WQ0003824
PHOTOQUAD/YEAR Mebane/l 991 CON LOCATION MAP FOR SITES
01 THROUGH 08 AND 10

�1tf`. ♦ f
f ♦rf+as..
♦ V df
�13 ram::;-'•;=g•. Cl)
..;...
� m
f' h
1 � 1
I F
� / r i� 1t
FIELD 6 4` € 1
9.8 Acs. +/ 1
k ` FIELD 1
7.0 Acs. YI
l
•a te; 'C JELD 2 ,,_::

FIGURE 3
The Compliance Boundary is established either 250 feet
CITY OF GRAHAM
from the perimeter of the residuals application area or 50
503 LAND APPLICATION PROGRAM
feet within the property boundary, whichever is closer. The
ALAMANCE COUNTY
Review Boundary is established midway between the
WQ0003824
Compliance Boundary and the perimeter of the
DETAIL MAP FOR SITES
residuals application area.
NC-AM-01-02 & 04

The Compliance Boundary is established either 250 feet
from the perimeter of the residuals application area or 50
feet within the property boundary, whichever is closer. The
Review Boundary is established midway between the
Compliance Boundary and the perimeter of the
residuals application area.
FIGURE 4
CITY OF GRAHAM
503 LAND APPLICATION PROGRAM
ALAMANCE COUNTY
WQ0003824
DETAIL MAP FOR SITES
NC-AM-01-03, 05 & 08

The Compliance Boundary is established either 250 feet
from the perimeter of the residuals application area or 50
feet within the property boundary, whichever is closer. The
Review Boundary is established midway between the
Compliance Boundary and the perimeter of the
residuals application area.
FIGURE 5
CITY OF GRAHAM
503 LAND APPLICATION PROGRAM
ALAMANCE COUNTY
WQ0003824
DETAIL MAP FOR SITE
NC-AM-01-10