WQ0003824_Final Permit_19901026

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 2761
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Ray Fogleman, City Manager
City of Graham
Post Office Drawer 357
Graham, North Carolina 27253
Dear Mr. Fogleman:
George T. Everett, Ph.D.
Director
October 26, 1990
Subject: Permit No. WQ0003824
City of Graham
Land Application of Sludge
Alamance County
In accordance with your application received July 9, 1990, we are forwarding herewith
Permit No. WQ0003824, dated October 26, 1990, to City of Graham for the operation of a land
application of sludge program.
This permit shall be effective from the date of issuance until September 30, 1995, 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. Issuance of this permit hereby voids Permit No. 6112R issued December 30, 1985.
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 North Carolina General Statutes, and fled with the Office of
Administrative Hearings, P.O. Box 11666, Raleigh, NC 27604. Unless such demands are made
this permit shall be final and binding.
If you need additional information concerning this matter, please contact Mr. John
Seymour. at 919/ 733-5083.
Sincerely,
J
George T.
cc: Alamance County Health Department
W.M. Piatt
Winston-Salem Regional Office
Groundwater Section
Training and Certification
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

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 HEREBY GRANTED TO
City of Graham
Alamance County
FOR THE
operation of a sludge land application program consisting of the land application of sludge from
the City of Graham's Wastewater treatment Plant to Iands identified in condition VI.6 of this
permit with no discharge of wastes to the surface waters, pursuant to the application received July
9, 1990 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 September 30, 1995, and shall be
subject to the following specified conditions and limitations -
PERFORMANCE STANDARDS
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
ground waters.
2. 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.
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. 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.
5. No crops for direct human consumption shall be raised on these sites for a period of
18 months following sludge application.

6. Maximum slope for sludge application shall be 10% for surface application and
18% for subsurface applications.
7 _ The following buffers 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.
8. 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.
9. 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, PO Box 27687, Raleigh, NC 27611-7687, within six (6)
months of the permit issue date.
10. Specific sludge application area boundaries shall be clearly marked on each site
prior to and during sludge application.
11. No sludge at any time shall be stored at any application site.
IT. OPERATION AND MAINTENANCE RE UIREMENT
1. The facilities and disposal sites shall be properly maintained and operated at all
times.
2. A suitable vegetative cover as listed in condition II 3, shall be maintained in
accordance with the crop management plan approved by this Division.
2

The application rates shall not exceed the following for the specified crops:
El
5
ro s
PAN (lbs/acre/year}
Wheat (small grain)
100
Barley (small grain)
100
Milo (small grain)
100
Oats (small grain)
100
Soybeans
150
Corn (silage and grain)
200
Alfalfa
250
Sorghum
120
Sudex (silage)
200
Sudex (hay)
160
Fescue grass
250
Timothy grass
200
Orchard grass
200
Rye grass
200
Blue grass
220
Coastal Bermuda grass
350
Cotton
100
Forest areas (hard and soft woods)
75
No sludges other than the following are hereby approved for land application in
accordance with this permit:
Source
City of
Graham
WWTP
Permit Estimate
County Number Volume dU tons/year)
Alamance NC0021211 48.7
The lifetime heavy metal loadings shall not exceed the following for the
corresponding Cation Exchange Capacities (CEC):
PArameter
CEC 5-15
Lead (lbs/acre)
1000
Zinc (lbs/acre)
500
Copper (lbs/acre)
250
Nickel (Ibs/acre)
250
Cadmium (lbs/acre)
9
b. The Permittee shall employ a certified wastewater treatment plant operator to be in
responsible charge of the land application operation. The operator must hold a
certificate of the grade at least equivalent to the classification assigned to the land
application program by the Certification 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.
3

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_
1 1. 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 lime is also applied to achieve a final pH of the lime, sludge
and soil mixture of at least 6.5.
111. MONITORING AND REPORTING REOUIREMENTS
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 conditions
g) type of crop or crop to be grown on field
h) volume of sludge applied in gaIlons/acre and dry tons/acre
i) annual and cumulative totals 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 complete soils analysis shall be conducted in March and the results submitted to
the Winston-Salem Regional Office, and appropriate changes made to the sludge
land application operation and management as needed.
Fil

4. A representative annual soils 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 soils analysis shall include but is not
necessarily limited to the following parameters:
Standard Soil Fertility Test
% Base Saturation
Phosphorus
Potassium
Lead
Zinc
Magnesium
pH
Manganese
Cation Exchange Capacity
Sodium
Nickel
Cadmium
Copper
Calcium
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-Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its hydroxide)
HexachIorobenzene
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. Analysis of sludge for zinc and copper shall be conducted every March, June,
September and December. The information shall be submitted to the Division"s
Winston-Salem Regional Office every April, July, October and January, and
appropriate changes made in the sludge application rates as needed.
5

6. A complete sludge analysis shall be conducted in March and the results submitted to
the Winston-Salem Regional Office every April and appropriate changes made to
the sludge land application operation and management as needed.
7. Three copies of all monitoring and reporting requirements as specified in conditions
111 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 EnvironmentaLManagement
Water Quality Section
Facility Assessment Unit
PO Box 27687
Raleigh, NC 27611-7687
Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office
telephone no. 919/ 761-2351, 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.
IV. GRQUNDWATER RF_QUREMENTS
1, As quickly as possible two (2) new monitor wells, one (1) upgradient and one (1)
downgradient, shall be shall be installed to monitor groundwater quality, the wells
shall be constructed such that the water level in the well is never above or below the
screened (open) portion of the well at any time during the year. However, the exact
location and construction details for these wells shall be approved by the
Winston-Salem Regional Office, from which a well construction permit must be
obtained.
R

2. The monitor wells must be sampled every March, July, and November for the
following parameters:
NO3 (10.0) Ammonia Nitrogen
TDS (500.0) TOC
pH (6.5-8.5 standard units) Chloride (250.0)
Total Coliforms (1/100m1) SO4 (250.0)
Water Level
Volatile Organic Compounds - In November Only (By method 1 or 2 below)
Method 1: Method 6230D (Capillary - Column), "Standard Methods For The
Examination of Water and Wastewater", 17th ed., 1989
Method 2: Method 502.2 "Method For The Determination Of Organic
Compounds In Drinking Water", U.S. EPA - 600/4-88/039
The measurement of water level must be made prior to sampling for the remaining
parameters.
The measuring points (top of well casing) of all new monitoring wells shall be
surveyed relative to mean sea level (M.S.L.). The depth of water in each well shall
be measured from the surveyed point on the top of the casing. The water level
elevations shall then be determined relative to M.S.L..
The numbers in parentheses represent the maximum allowable concentrations in
groundwater for the various analytical parameters, as specified in 15 NCAC 2L
[Groundwater Classifications and Standards]. Unless otherwise noted, the
concentrations are given in parts per million.
If TOC concentrations greater than 10 mg/1 are detected in any downgradient
monitoring well, additional sampling and analysis must be conducted to identify the
individual constituents comprising this TOC concentration. If the TOC concentration
as measured in the background monitor well exceeds 10 mg/l, this concentration will
be taken to represent the naturally occurring TOC concentration. Any exceedances
of this naturally occurring TOC concentration in the downgradient wells shall be
subject to the additional sampling and analysis as described above.
If any volatile organic compounds are detected by method 6230D, or the equivalent
method 502.2, then EPA methods 604 and 611 must also be run to detect other
organic compounds which may be present. The results of all analyses specified in
the monitoring requirements, including 604 and 611 if required, must be submitted
simultaneously.
The results of the sampling and analysis shall be sent to the N.C. Division of
Environmental Management on Form GW-59 (Compliance Monitoring Report
Form) every April, August, and December.
3. The Compliance Boundary for the disposal system is specified by regulations in 15
NCAC 2L, Classifications and Water Quality Standards applicable to the
groundwater of North Carolina. An exceedance of Groundwater Quality Standards
beyond the Compliance Boundary is subject to penalty provisions applicable under
General Statute 143-215.6(1)a. The sale of property, by the Permittee, which is
within or contiguous to the disposal system site may alter location of the Compliance
Boundary.
7

For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the perimeter of 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 Division Director within 14 days. The
Director shall then establish a modified Compliance Boundary which will be done as
a modification to the Permit_
The REVIEW BOUNDARY 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.
4. Any additional groundwater quality monitoring, as deemed necessary by the
Division, shall be provided.
V. INSPE TION
1. 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. GENFERAL CONDMONS
This permit shall become voidable unless the land application activities are carried
out in accordance with the conditions 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.
5. This permit shall become voidable unless the agreements between the Permittee and
the landowners/lessees are in full force and effect.
_ 6. The following are approved sites for sludge application (see attached map):
Site No.
4wner/Lessee
Application Area (excluding buffers)
acres
I
City of Graham
15.2
2
City of Graham
12 A
-'• 3
City of Graham
6.8
4
City of Graham
8.8
5
City of Graham
10.4
6
City of Graham
12.0
7
City of Graham
U
Total
74.4
Fields 1, 4, 5, 6, and 7 were reported as being overtaken by weeds. A consistent
and acceptable cover crop shall be maintained in order to properly control and
monitor nutrients, metals and PAN levels.
7. Failure to abide by the conditions and limitations contained in this permit may
subject the Permittee to an enforcement action by the Division of Environmental
Management in accordance 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 being billed by the Division. Failure to pay the fee
accordingly may cause the Division to initiate action to revolve this permit as
specified by 15 NCAC 21-1.0205 (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.
9

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. Issuance of this permit hereby voids Permit No. 6112R issued December 30, 1985.
Permit issued this the 26th day of October, 1990
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
I
George T. Event, Dire or
Division of Environmey vial Management
By Authority of the EnkoXnental Management Commission
Permit No, WQ0003824
10

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SCALE I -1000
CONTOUR INTERVAL 10 FEET
DATUM IS MEAN SEA LEVEL
THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY
FOR SALE BY U.S. GEOLCIGfCAL SURVEY, WASHING'
A 1701-DER DESCRIBING TOPOGRAPHiC MAPS AND SYMBOLS IS A
SCALE I -1000
CONTOUR INTERVAL 10 FEET
DATUM IS MEAN SEA LEVEL
THIS MAP COMPLIES WITH NATIONAL MAP ACCURACY
FOR SALE BY U.S. GEOLCIGfCAL SURVEY, WASHING'
A 1701-DER DESCRIBING TOPOGRAPHiC MAPS AND SYMBOLS IS A