WQ0004956_Final Permit_19970402

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Jerry B. Wood, III, General Manager
Brookwood Farms, Inc.
Post Office Drawer F
Siler City, North Carolina 27344
Dear Mr. Wood:
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April 2, 1997
Subject: Permit No. WQ0004956
Brookwood Farms, Inc.
Land Application of Wastewater Residuals
Chatham County
In accordance with the name change request received March 24, 1997, we are forwarding herewith
Permit No. WQ0004956 as amended, dated April 2, 1997, to Brookwood Farms, Inc. for the operation of
a wastewater residuals land application program. This permit is being amended as requested to account for
a change of ownership of the subject facilities from Hickory Mountain Farms, Incorporated to Brookwood
Farms, Inc.
This permit shall be effective from the date of issuance until August 31, 2001, shall void Permit
No. WQ0004956 issued September 26, 1996, 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 Hearings, 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] extension 547.
S' erely,
(aX -4
�i A. Preston oward, Jr., P.E.
cc: Chatham County Health Department
Raleigh Regional Office, Water Quality Section
Raleigh Regional Office, Groundwater Section
Bob Check, 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
Itvl801[e1.1
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
Brookwood Farms, Inc.
Chatham County
operation of a wastewater residuals land application program consisting of the application of 35.0 dry tons
per year of residuals from the sources listed in Condition 115, to approximately 31.3 acres of land in
Chatham County with no discharge of wastes to the surface waters, pursuant to the renewal request
received on April 30, 1996, 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 August 31., 2001, shall void Permit
No. WQ0004956 issued September 26, 1996, and shall be subject to the following specified conditions
and limitations:
I. PERFORMANCE STANDARDS
1. 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 DWQ 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 DWQ 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 Water Quality.
9. Maximum slope for residual application shall be 10% for surface application and 18% for
subsurface applications.
10. When residuals from an animal processing facility are being land applied, one of the
following stabilization methods shall be completed to control possible nuisance conditions:
a, The residuals are subsurfacely injected, or
b. The residuals are incorporated into the soil within 24 hours, or
c. Sufficient time is added to the residuals to create a uniform mixture and achieve a pH
of 10 for thirty minutes prior to being surface land applied.
II. OPERATION AND MAINTENANCE REQUIREMENTS
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 (lb..acre/ rr
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 Volume
Source County _Number _ dry tons) ear
Brookwood Farms, Inc. Chatham n/a 35.0
6. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings (lbs/acre
Parameter
CEC < 5
CEC 5 - 15
CEC > 15
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125
250
500
Nickel
125
250
500
Cadmium
4.5
9
18
7. 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.
8. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.

9. Surface applied residuals will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
10. For areas that are prone to flooding or within the 100 -year flood elevation, 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.
I I . 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.
12. 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.
13. Residuals shall not be applied in inclement weather or until 24 hours following a rainfall
event of 112 -inch or greater in 24 hours. Any emergency residuals disposal measures must
first be approved by the Division of Water Quality.
14. Residuals shall not be applied to any land application site that is flooded, frozen or snow-
covered.
15. Residuals shall not be applied at rates greater than agronomic rates, unless authorized by
the Division.
16. 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.
17. The Division is concerned about the high Sodium Adsorption Ratio (SAR) found in the
residuals being land applied. Appropriate measures, including the application of gypsum to
balance the ratio if necessary, shall be undertaken to ensure that the land application sites
are not damaged. An agronomist or soil scientist should be consulted before problems
arise.
1II. MONITORING AND REPORTING_ REQUIREMENTS
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division of Water Quality 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.)
f. 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 cadmium,
copper, lead, nickel, and zinc), annual pounds/acre of plant available nitrogen (PAN),
and annual pounds/acre of phosphorus applied to each field.
4

3 . A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted
on 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
The Standard Soil Fertility Analysis (see above) and an analysis for the following
pollutants shall be conducted once prior to permit renewal on soils from each site which has
received residuals during the permit cycle.
Cadmium Lead Nickel
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:
Cadmium
Nitrate -Nitrite Nitrogen
Copper
% Total Solids
Lead
pH
Nickel
Phosphorus
Zinc
Plant Available Nitrogen (by calculation)
Aluminum
Potassium
Ammonia -Nitrogen
Sodium
Calcium
TKN
Magnesium
5. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Permittee annually. 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)
Silver (5.0)
Toxaphene (0.5)
2,4,5 -Trichlorophenol (400.0)
2,4,5 -TP (Silvex) (1.0)
5
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)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6 -Trichlorophenol (2.0)
Vinyl chloride (0.2)

6. All residuals included in this permit must be monitored annually from the date of permit
issuance, for compliance with condition 110 of this permit. Data to verify stabilization 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 B pathogen requirements as defined in 40 CFR Part 503 or the Process to
Significantly Reduced Pathogens (PSRP) as defined in 40 CFR Part 257 Appendix 11.
7. Three copies of all required monitoring and reporting requirements as specified in
conditions 111 1,1112, 111 3, II14, 1115, and II16 shall be submitted annually on or before
March 1 of the following year to the following address:
NC Division of Water Quality
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
8. Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh 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 five (5) days following first knowledge of the occurrence. This report must
outline the actions taken or proposed to be taken to ensure that the problem does not recur.
I V . GROUNDWATER REQUIREMENTS
1, The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983 is established at either (1) 250
feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or
beyond the Compliance Boundary is subject to immediate remediation action in addition to
the penalty provisions applicable under General Statute 143-215.6A(a)(1).
6

In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
3. No land application of waste activities shall be undertaken when the seasonal high water
table is less than three feet below land surface.
V. INSPECTIONS
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 rive years from the date of the inspection and shall be made available to the
Division of Water Quality or other permitting authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises or place on
or related to the 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.
VI. GENERAL CONDITIONS
1. 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.
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 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 Water Quality accompanied by an application fee,
documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.

4. The following are approved sites for residuals application (see attached map[s]):
Application Area [acres]
Site No: Owner/Lessee (excluding buffers)
1
Raymond C Fields
4.4
2
Raymond C Fields
2.1
3
Raymond C Fields
3.3
4
Raymond C Fields
1.1
5
Raymond C Fields
3.4
6
Raymond C Fields
0.8
7
Raymond C Fields
2.6
8*
Raymond C Fields
----
9
Raymond C Fields
2.9
10
Raymond C Fields
1.6
11
Raymond C Fields
2.2
12*
Raymond C Fields
2.0
13
Raymond C Fields
L8
Power Line*
Raymond C Fields
3.1
TOTAL AVAILABLE ACRES
31.3
* The Power Line field is composed of the portions of Fields 8 and 12. Currently, none
of the remaining area in Field 8 is cleared.
5. Failure to abide by the conditions and Iimitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215,6(a) to 143-215.6(c).
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 Water Quality deems necessary in
order to adequately protect the environment and public health.
10. This permit shall become voidable unless the agreements between the Permittee and the
landowners/lessees are in full force and effect. The land owner agreements are considered
expired concurrent with the expiration date of the permit and must be renewed at the same
time the permit is renewed.

Permit issued this the second day of April, 1997
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
a
A. Preston lftoward, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0004956