WQ0007062_Final Permit_19930622

State of North Carolina
Dr,partment 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
June 22, 1993
Mr. John C. Murdock, ffi, Executive Director
Water & Sewer Authority of Cabarrus County
Post Office Box 428
Concord, North Carolina 28025
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DEHNR
Subject. Pem-iiit No. WQ0007062
Informal Adjudication
Water & Sewer Authority of Cabarrus
County
Rocky River Wastewater Treatment Plant
Land Application of Ash
Dear Mr. Murdock: Cabarrus County
On April 28, 1993, the Division of Environmental Management issued Permit No. WQ0007062 to
the Water & Sewer Authority of Cabarrus County for the operation of the subject ash land application
program. On June 8, 1993, the Division received your letter, which objected to some of the wording in
the permit; therefore, the Division has reviewed your objections and they are discussed below along with
the Division's response to those objections:
Objection 1: You state that condition I.10, requiring stabilization, should be deleted since the ash
is incinerated at a temperature of approximately 12000 F to 15000 F.
Response 1: The subject permit is being issued for the land application of ash that results from the
incineration of wastewater residuals. The Division acknowledges that stabilization
requirements apply to the wastewater residuals and not to incinerated residuals or ash
(the ash could be considered a result of the stabilization of the wastewater residuals);
therefore, condition 1.10 has been deleted from the permit.
Objection 2: Request that the word sludge in condition II.13 be changed to ash.
Response 2: The requested modification has been incorporated into condition 11.13.
Objection 3: Same as objection 1.
Response 3: Same as response 1.
Objection 4: You state that the appropriate map, referenced by condition IV.2, was not included.
Response 4: Condition 1V.2 has been modified by deleting the reference to a map.
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

Mr. Murdock
June 22, 1993
Page 2
This permit shall be effective from the date of issuance until March 31, 1997, shall void Permit
No. WQ0007062, which was issued on April 28, 1993, and shall be subject to the conditions and
limitations as specified therein. Please pay particular attention to the monitoring requirements in this
permit. Failure to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within 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; Randy Jones at 919/
733-5083.
Sincerely,
L
A. Prest4 Howard, Jr., P.E.
cc: Cabarrus County Health Department
Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Jack Floyd, Groundwater Section Central Office
Training and Certification (no revised rating)
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
ASH 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 1S HEREBY GRANTED TO
Water & Sewer Authority of Cabarrus County
Cabarrus County
FOR THE
operation of an ash land application program consisting of the application of approximately 359 dry tons
of ash from the Rocky River Wastewater Treatment Plant to approximately 42 acres of land in Cabarrus
County over a period of 3.8 years with no discharge of wastes to the surface waters, pursuant to the
informal adjudication received on June 8, 1993, 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 March 31, 1997, shall void Permit
No. WQ0007062, which was issued on April 28, 1993, and shall be subject to the following specified
conditions and limitations:
I. PERFORMANCE STANDARDS
The Mooresville Regional Office, telephone number 704/ 663-1699 and the appropriate
local governmental official (county manager/city manager) shall be notified at least twenty-
four (24) hours prior to the initial application of the ash so that an inspection can be made
of the application sites and application method. Such notification to the regional supervisor
shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday
through Friday, excluding State Holidays. Also the Cabarrus County Manager's office
must be notified prior to the initial application so that they will be aware that the operation
has commenced.
2. 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.
3. 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.

4. The issuance of this permit shall not relieve the Perrnittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
5. In the event that the land application program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease applying to the sites and take any
immediate corrective actions, including the construction of additional or replacement
wastewater treatment or disposal facilities.
6. No crops for direct human consumption shall be raised on these sites for a period of 18
months following application.
7. Maximum slope for application shall be 10% for surface application and 18% for
subsurface applications.
8. 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 the appropriate
DEM regional office,
b) 200 feet from residences or places of public assembly 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 and the appropriate DEM
regional office,
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) 50 feet from property lines for both methods; however, this requirement may be
reduced upon written concurrence from the adjoining property owner and the
appropriate DEM regional office,
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.
9. A copy of this permit shall be kept at the land application site when ash is being applied
during the life of this permit. A spill prevention and control plan shall be kept in all
transport and application vehicles.
10. Specific application area boundaries shall be clearly marked on each site prior to and during
application.
11. No ash at any time shall be stored at any application site.
II. OPERATION AND MAINTENANCE REUITREMENTS
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

3 . The application rates shall not exceed the following for the specified crops:
Q1M
PAN 1 . acr
Alfalfa
250
Blue Grass
220
Coastal Bermuda Grass
350
Corn (Silage & Grain)
200
Cotton
100
Fescue
250
Forest (Hardwood & Softwood)
75
Small Grain (Wheat, barley, milo, oats)
100
Sorghum
120
Soybeans
150
Sudex (Hay)
160
Sudex (Silage)
200
Timothy, Orchard, & Rye Grass
200
4. No materials other than the following are hereby approved for land application in
accordance with this permit:
Permit
Estimated
Source County Number
Volume tons
RWWTPRiver Cabarrus NCO036269
359 (over 3.8 years)
Incinerator Ash
5. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings flbs/acre
Paramet
CEC < 5
CEC 5 - 15
_CEC > 1
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125
250
500
Nickel
125
250
500
Cadmium
4.5
9
18
6. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202.
7. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored material into any surface waters.
8. Animals shall not be grazed on applied land within a 30-day period following the
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 ash 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, ash may be
applied only during periods of dry weather. The ash must be incorporated into the soil
within twenty-four (24) hours of application.
11. 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 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 application area onto the adjacent property or into the surface
waters.
13. Ash 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 ash 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 application. Ash 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.
Any monitoring (including groundwater, surface water, ash, 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 ash
b) date of application
c) location of 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 ash applied in gallons/acre and dry tons/acre
i) annual and cumulative totals of dry tons/acre of ash, 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 representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted
of each site receiving ash 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:
0

% Base Saturation
Magnesium
Phosphorus
Potassium
Leadl
Zinc
pH
Manganese
Cation Exchange Capacity
Sodium
Nickell
Cadmiuml
Copper
Calcium
I Soils analysis for these parameters shall be conducted once prior to permit renewal on
soils from each site which has received ash during the permit cycle.
4. A quarterly ash 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, ash analysis will be required for each instance of land application.
The ash 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)
Hexachlorobenzene
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. Three copies of all monitoring and reporting requirements as specified in conditions III 1,
IH 2, III 3, III 4, and III 5 shall be submitted annually on or before March 1 of the
following year to the following address:
5

NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number 704/ 663-1699, 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 treatment,
e. Any spillage or discharge from a vehicle or piping system transporting ash 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.
1. Ash shall be applied to the sites as a one time only application, with the existing ash being
spread over a 3.8 year period.
2. The Compliance Boundary for the disposal system is specified by regulations in 15A
NCAC 2L, Classifications and Water Quality Standards. An exceedance of Groundwater
Quality Standards beyond the Compliance Boundary is subject to penalty provisions
applicable under General Statute 143-215.6(1)a.
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 land application site, or 50 feet
within the property boundary.
Any sale or transfer of property which affects the location of the compliance boundary shall
be reported immediately to the Director. The permittee shall not transfer land within an
established compliance boundary unless the permittee has satisfied all the requirements of
15A NCAC 2L .107 (e and f).
0

The REVIEW BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. A REVIE3Y BQUNDARY 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.
3. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
1. The Permittee or his designee shall inspect the 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. GENERAL CONDITIONS
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. This permit shall become voidable unless the agreements between the Permittee and the
landowners/lessees are in full force and effect.
7

5. The following are approved sites for sludge application (see attached. map(s)):
Site No. _ Owner
jLessee Application Areal acres
Rocky River Water & Sewer 42
WWTP Authority
Cabarrus County
1 - Application Area excludes buffer areas.
6. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 143-215.6C.
7. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205
(c)(4).
8. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
9. A set of approved documents for the subject project must be retained by the applicant for
the life of the permit.
10. 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.
11. 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 22nd day of June, 1993
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Ca��
A. Presto Howard, Jr., P.E., Director
Division &f Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0007062
0

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