WQ0003824_Final Permit_19940909

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Ray Fogleman, City Manager
City of Graham
Post Office Drawer 357
Graham, North Carolina 27253
Dear Mr. Fogleman:
September 9, 1994
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Subject: Permit No. WQ0003824
City of Graham
Land Application of Wastewater Residuals
Alamance County
In accordance with the modification request received on July 22, 1994, we are forwarding
herewith Permit No. WQ0003824 as amended, dated September 9, 1994, to the City of Graham for the
continued operation of a wastewater residuals land application program. This permit is being amended as
requested to incorporate approximately 217 dry tons per year (1,000,000 gallons at 5.2 % solids) of
residuals from the City of Graham's water treatment plant into the existing land application program.
This permit shall be effective from the date of issuance until September 30, 1995, shall void Permit
No. WQ0003824 issued October 26, 1990, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring and reporting requirements contained 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 North
Carolina General Statutes, and filed with the Office of Administrative flearings, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please contact Mr. Michael D. Allen at
[phone].
Sincerely,
r
A. Preston; Howard, Jr., P.E.
cc: Alamance County Health Department
AMSCO, Incorporated
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
Training and Certification Unit (no revised rating)
Facilities Assessment Unit
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

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
RESIDUALS 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 THE
City of Graham
Alamance County
FOR THE
continued operation of a wastewater residuals land application program consisting of the application of
approximately 48.7 dry tons per year of residuals from the City of Graham wastewater treatment facility
and the application of approximately 217 dry tons per year of residuals from the City of Graham water
treatment facility to approximately 74.4 acres of land in Alamance County with no discharge of wastes to
the surface waters, pursuant to the modification request received on July 22, 1994, 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, shall void Permit
No. WQ0003824 issued October 26, 1990, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
l . This permit shall become voidable if the soils fail to adequately assimilate 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 program.
4. In the event that the land application program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease applying residuals to the sites and
take any immediate corrective actions as may be required by the Division.

5. Some of the buffers specified below may not have been included in previous permits for
this land application operation. However, any sites or fields that are included in this
permit, but were approved with different applicable buffers shall be reflagged to comply
with the below buffers. The following buffer zones shall be maintained:
a) 400 feet from residences or places of public assembly 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 and approval from the
appropriate DEM regional office,
b) 200 feet from residences or places of public assembly under separate ownership for
subsurface residual injection method; however, the buffer zone requirement may be
reduced to a minimum of 100 feet upon written consent of the owner and the
appropriate DEM regional office,
c) 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods,
d) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for surface application,
e) 50 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for subsurface application,
f) 100 feet from property lines for both surface and subsurface application methods;
g) 50 feet from public right of ways for both application methods,
h) 10 feet from upslope interceptor drains and surface water diversions for both
application methods,
i) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both application methods.
6. A copy of this permit shall be maintained at the land application site when residuals are
being applied during the life of this permit. A spill prevention and control plan shall be
maintained in all residuals transport and application vehicles.
7. Specific residual application area boundaries shall be clearly marked on each site prior to
and during application.
8. No residuals at any time shall be stored at any application site, unless approval has been
requested and obtained from the Division of Environmental Management.
9. Maximum slope for residual application shall be 10% for surface application and 18% for
subsurface applications.
10. When wastewater residuals are applied, the Class A pathogen requirements and site
restrictions in 40 CFR Part 503.32(a) or the Class B pathogen requirements and site
restrictions in 40 CFR Part 503.32(b), and one of vector attraction reduction requirements
in 40 CFR Part 503.33 must be met. Additionally, an evaluation must be performed which
demonstrates the residuals ability to comply with this requirement. Upon request, a copy
of this evaluation must be submitted including all test results and calculations. The
following water treatment plant is exempt from this condition because there is no domestic
contribution present in the residuals:
City of Graham WTP NCO045292
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities and application sites shall be properly maintained and operated at all times.
2

2. A suitable vegetative cover, as listed in condition 114, shall be maintained in accordance
with the crop management plan outlined by the local Extension Office of the Department of
Agriculture, or the Soil Conservation Service, or other agronomist, and approved by this
Division.
3. An acceptable pH must be maintained in the soil, residual and lime mixture, greater than
6.0, on all land application sites to insure optimum yield for the crop(s) specified below.
The agronomist shall provide information on the pH best suited for the specified crop and
the soil type.
4. The application rates shall not exceed the following for the specified crops:
Crop PAN 1 ./acr r
Alfalfa
200
Bermuda Grass (Hay, Pasture)
220
Blue Grass
120
Corn (Grain.)
160
Corn (Silage)
200
Cotton
70
Fescue
250
Forest (Hardwood & Softwood)
75
Milo
100
Small Grain (Wheat, barley, oats)
100
Sorghum, Sudex (Pasture)
180
Sorghum, Sudex (Silage)
220
Soybeans
200
Timothy, Orchard, & Rye Grass
200
5. No residuals other than the following are hereby approved for land application in
accordance with this permit:
Permit Estimated
Source County Number Volume (dry tons/yearl
City of Graham WWTP Alamance NCO021211 48.7
City of Graham WTP Alamance NCO045292 217.0
6. The metal loading rates shall not exceed the following Cumulative Pollutant loading. rates:
Kilograms Pounds
Parameters Wr Hectare er Acre
Arsenic
41
36
Cadmium
39
34
Chromium
3,000
2,677
Copper
1,500
1,338
Lead
300
267
Mercury
17
15
Molybdenum
----
----
Nickel
420
374
Selenium
100
89
Zinc
2,800
2,498

7. The pollutant concentrations in the residuals which will be applied to the land shall not
exceed the following Ceiling Concentrations (Dry Weight Basis):
Parameter
m
Arsenic
75
Cadmium
85
Chromium
3,000
Copper
4,300
Lead
840
Mercury
57
Molybdenum
75
Nickel
420
Selenium
100
Zinc
7,500
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified land application/residuals operator to be in responsible charge (ORC) of
the land application program. The operator must hold a certificate of the type classification
assigned to the land application program by the Certification Commission. The Permittee
must also employ a certified back-up operator of the appropriate type to comply with the
conditions of Title 15A NCAC 8A, .0202.
9. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
10. Surface applied residuals will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
11. For areas that are prone to flooding or within the 100-year flood elevation, residuals may
be applied only during periods of dry weather. The residuals must be incorporated into the
soil within twenty-four (24) hours after application.
12. 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 residual application
event. Such controls may include the posting of signs indicating the activities being
conducted at each site.
13. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals application area onto the adjacent property or into
any surface waters.
14. Residuals 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 residuals disposal measures must
first be approved by the Division of Environmental Management.
15. Residuals shall not be applied to any land application site that is flooded, frozen or snow-
covered.
16. Residuals shall not be applied at rates greater than agronomic rates, unless authorized by
the Division.
17. Animals shall not be grazed on an application site for 30 days after residuals application.
Application sites that are to be used for grazing shall have fencing that will be used to
prevent access after each application.
4

18. Food crops, feed crops and fiber crops that do nQj come in contaq —with-the residuals shall
not be harvested for 30 days after residuals application.
19. Food crops with harvested parts that touch the residual/soil mixture and are totally above
the land surface (ex. tobacco, melons, cucumbers, squash, etc.) shall not be harvested for
14 months after residuals application.
20. Food crops with harvested parts below the surface of the land (root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20.months after application of residuals
when the residuals remain on the land surface for four (4) months or longer prior to
incorporation into the soil.
21. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after application of residuals when the residuals remain on the land surface for less
than four (4) months prior to incorporation into the soil.
22. Turf shall not be harvested for 1 year after residuals application if the turf is to be placed on
land with a high potential for public exposure.
MO ITORI G AND REPORTING -REQUIREMENTS
1. Any monitoring (including groundwater, surface water, residuals, 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.
2. Proper records shall be maintained by the Permittee tracking all application activities.
These records shall include, but are not necessarily limited to the following information:
a) source of residuals
b) date of residual application
c) location of residual application (site, field, or zone #)
d) method of application
e weather conditions (sunny, cloudy, raining, etc.)
soil conditions
g) type of crop or crops to be grown on field
h) volume of residuals applied in gallons/acre, dry tons/acre or kilograms/hectare
i) annual and cumulative totals of dry tons/acre of residuals, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be limited to arsenic,
cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium 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 residuals 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:
Acidity
Calcium
Copper
Magnesium
Base Saturation (by calculation)
Cation Exchange Capacity
Manganese Potassium
Percent Humic Matter Sodium
pH Zinc
Phosphorus
5

The Standard Soil Fertility Analysis (see above) and an analysis for the following metals
shall be conducted once prior to permit renewal on soils from each site which has received
sludge during the permit cycle.
Arsenic
Cadmium
Chromium
Lead Nickel
Mercury Selenium
Molybdenum
4. A residuals analysis will be conducted annually from the date of permit issuance 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 annually, a residuals analysis will be
required for each instance of land application. The residuals analysis shall include but is
not necessarily limited to the following parameters:
Arsenic
Aluminum
Cadmium
Ammonia -Nitrogen
Chromium
Calcium
Copper,
Nitrate -Nitrite Nitrogen
Lead
% Total Solids
Mercury
pH
Molybdenum
Phosphorus
Nickel
Plant Available Nitrogen (by calculation)
Selenium
Potassium
Zinc,
Sodium
Magnesium
TKN
Analysis of Zinc and Copper shall be conducted in the wastewater treatment plant
residual 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 application rates as
necessary.
5. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Permittee annually the following facilities:
City of Graham WWTP NC0021211
The TCLP analysis shall include the following parameters (please note the regulatory level
in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Co

Silver (5.0) Tetrachloroethylene (0.7)
Toxaphene (0.5) Trichloroethylene (0.5)
2,4,5-Trichlorophenol (400.0) 2,4,6-Trichlorophenol (2.0)
2,4,5-TP (Siivex) (1.0) Vinyl chloride (0.2)
6. The following facility will be monitored annually from the date of permit issuance for
compliance with condition 110 of this permit:
City of Graham WWTP NCO021211
Data to verify stabilization and vector attraction reduction of the residuals must be
maintained by the Permittee. The required data is specific to the stabilization process
utilized, but should be sufficient to clearly demonstrate compliance the Class A pathogen
requirements in 40 CFR Part 503.32(a) or with the Class B pathogen requirements and site
restrictions in 40 CFR Part 503.32(b), and one of vector attraction reduction requirements
in 40 CFR Part 503.33. In addition, the EPA certification statements concerning
compliance with pathogen requirements, vector attraction reduction requirements and
management practices must be completed annually by the proper authority or authorities if
more than one is involved, either the person who prepares the residuals, the person who
derives the material, or the person who applies the residuals.
7. Three copies of all required monitoring and reporting requirements as specified in
conditions III 1, III 2, III 3, III 4, 1115 and 1116 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
8. 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 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 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 residual treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals 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.
7

IV. GROUNDWATER REQUIREMENTS
The two (2) existing monitoring wells shall be sampled every March, July, and November
for the following parameters:
Nitrate (NO3) Total Ammonia
TDS TOC
pH Chloride
Total Coliforms SO4
Water Level
Volatile Organic Compounds - In November only (by Method 1 or Method 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 "Methods 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 depth of 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 relative elevations of the measuring point for each monitoring well.
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.
2. The CQMPLIANCE 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 perminee.
3. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
Fla

V.
INSPECTIONS
VI.
1. The Permittee or his designee shall 'inspect the residuals storage, transport, and application
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 five years from the date of the inspection and shall be made available to the
Division of Environmental Management or other permitting authority, upon request.
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 application 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 kept under the terms and conditions of this permit; and may obtain samples of
groundwater, surface water, or leachate.
GENERAL- CONDITIONS
2
9
This permit shall become voidable unless the land application activities are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by this Division.
This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
This permit is not automatically transferable. In the event that 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.
The following are approved sites for residuals application (see attached map(s)):
Application Area [acres]
$it�No. Owner/Lessee (excluding buffers).
1 City of Graham
15.2
2 City of Graham
12.4
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
8.8
TOTAL AVAILABLE ACRES
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.
9

5. 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(a) to 143-215.6(c).
6. 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 15 NCAC 2H .0205
(c)(4).
7. 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.
8. 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. 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.
Permit issued this the ninth day of September, 1994
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
1 f
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A. Preston, oward, Jr., P ., Director
Division of -Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0003824
10

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