WQ0000701_Regional Office Historical File Pre 2018

Mooresville Regional Office
James . Hunt, Jr., Governor
Jonathan S. Howes, Secretary
DIVISION OF WATER QUALITY
March 3, 17'
Certified Mail
Return Receipt ReqR�tsted
Mr. Lawrence Sampson, Jr. , Project Engineer
Tyson Foods, Incorporated
Post Office Box S
Wilksboro, North Carolina 28697
Subject: Notice of Violation and
Recommendation for Enforcement
Permit No. WQ0000701
Tyson Land Application Programs
Rowan County
Dear ,Mr. Sampson
Chapter 143, North Carolina General Statutes, authorizes and
directs the Environmental Management Commission of the Depa
rtment
Environment,of Health and Natural Resources an
preserve the cater and air resources of the State. The Division of
Water Quality (Division) has the delegated authority to enforce
adopted pollution control rules,
site inspection of soma land application Field 'IS" was
conducted on February 24, 1997 by Mrs Michael Parker with this
Office as a result of a complaint received from an adjacent
property owner that residuals applied on the aforementioned field
had creased onto the complainant's property, entered a nearby
stream, and ultimately caused a fish kill. Tyson representatives
resent during the investigation included Mrs Mark Johnson, Harmon
Plant Manager, Mr. Danny Wyatt, Wilke oro Plant; and. Mr. Steven
Smith with Terra Renewal Services Inc
V[66res�A#e, Nofth Carollno 28116 J*IAM, )IR!
FAX [phone] Equal pport nit°y/Arfirrnafi Action Employer
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r. Lawmp rence R. Sason, Jr.
MarcLh'3, 1997
Page Two
As a result of this investigation, we have reason to believe
that Tyson is responsible for activities resulting in noncompliance
with North Carolina Law. Specifically, Part I, Condition No. 12 of
the subject Permit stipulates that adequate provisions shall be
taken to prevent wind erosion and surface runoff from conveying
pollutants from the residuals application area onto adjacent
property or into surface waters. Based on observations by Mr.
Parker, residuals were conveyed as a result of a rainfall event
(which occurred on February 21, 1997) Into an unnamed tributary to
the South Yadkin River. Impacts to the unnamed tributary as a
result of the introduction of these residuals may also have caused
a fish kill of at least three (3) species of fish, which were
observed at various points along the unnamed tributary during the
February 24th and 25th investigation by Mr. Parker and on February
23rd by Mr. Wayne Jones with the N.C. Wildlife Resources Commission
(NCWRC). Due to the small quantity of dead fish observed (-30), Mr.
Jones indicated that at the present time the NCWRC is not planning
to pursue fish replacement cost.

Pr. Lawrence R . Sampson,
March 3, 1997
Page Three
t is also requested that this office be provided with
specific information concerning residuals applic tion activities on
Field 'IS" as required in Part iil Condition No. 2 of the Permit
for the 17 calendar year (including the most recent
application). This information should accompanyyour response to
the Notice of Recommendation for Enforcement.
If you have any questions regarding this matter, please
contact Messrs. Michael ar .er Gleason, Water Quality
Regional Supervisor or me
Sincerely,
B.fagiiocnal
ith verah "..
Supervisor
cc: Compliance/Enforcement Grew
Ron Linville
Greg Green
Jesse Wells
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Wheetabrator Clean Water Systems Inc.
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Southern Reg I Lill Fax 205.664,/618
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March 8,1996
Mr. Michael Pryer RE,
North Carolina Department of Environment, Health, and Natural Resources
Division of Environmental Management
919 N Main Street
P.O. Box 950
Mooresville, 1 TY�5".'
DearMike:
wanted to express my personal appreciation for your help with the Tyson Foods
emergency. Land application was able to continue without interruption and the environment was
protected because of your response to this matter. Thank you for talking time to consider the
gravity ofthe situation and for your immediate response, Without;your help the processing
plants, which are served by this land application project, would have had to cease their operations,
Again Thanks.
Very truly Yours,
l,6ert aarnlltn
Agronomist Bio GroSystems
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Wheelabrator Clean Water Systems Inc.
January 11, 1996
North Carolina Department of Environment,
Health, and Natural Resources
Division of Environmental Management
Post Office Box 2953 5
Raleigh, North Carolina 27626-05 3 5
Attention Carolyn D. McCaskill
RE, Permit No, WQ0000701
Tyson Foods, Inc.
Emergency Land Application of Sludge
Dear Ms, McCaskill
Tyson Foods land application project has reached an emergency situation due to a wetter than
normal winter and heavy snowfall Tyson has an on site storage tank which holds approximately
520,000 gallons. This storage tank is almost at full capacity,
We have discussed a number of options which if approved by your office would allow the food
processing plants, served by this facility to continue their operations Tyson's Land Application
program could continue with no adverse effect to the environment ,
We propose to select an isolated site which is level, the sludge would be injected into the snow-
covered soil, An additional buffer will be allowed at the perimeter of the site to prevent runoff,
As a secondary option, we are requesting permission to transport sludge by truck from the
Harmony and Wilkesboro operations for storage in the Monroe, NC plant lagoon, As weather
I and soil conditions permit, we would like to land apply sludge from Harmony and Wilkesboro on
sites pernntred for the Monroe plant, The Monroe sites are permitted as WQ0000029,
41, 0,

—a;rrnyn u, ivi-aslkiil
January 1 ] R 1996
Page
If this request is approved, it wouldhelp assist in getting through this emergency We appreciate,
M's consideration of this matter. In the future, it is hoped that plans can be implemented to
help us letter manage through long periods of inclement weather,
incerely,
Robert A- ar lltun , ar n rnis
CC Nfichael Farber Engineer', PE r NCDEM
'lark Johnson plant Manager T Tyson Food
Lawrence . Sampson, Jr PE - Tyson Foods
Dee Browder - G °heelahrator Cleary Water systems
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State of North Carolina
Department f Environment,
Healthr.l Resources
_ Division ofEnvironmental are nt �
�
JamesGovernor
JonathanB.Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Lawrence R. Sampson, Jr.,
Project Engineer
Tyson Foods, Inc.
Post Office Box 88
Wilkesboro, e.sboro, o lina 28697
Dear lair. Sampson:
�.ID ,
nrl"T Or
VT
November 1, 1'.
Nov
0 1993
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Subject: Permit 1^. W1
Tyson Foods, Inc.
Harmonyd Wilkesboro Facilities
(Formerly Rally Farms Foods,Inc.)
Dated Application of Sludge
Rowan, Wilkes, & Yadkin aunties
. The permit issued specified subsurface injection as the means of disposal. The application
received on May 19, 1992, requests subsurface injection and your letter of September 29, 19quests
that surface application be allowed as well for this application. The Rowan Counter site has a history o
nuisance odors, and due to the various types of waste to be land applie , the Division felt it was necessary
to restrict the application method in order to protect the environment and the public health, 'ne request for
surface application therefore has been denied by issuance of the permit on September 1, 1992.
. Pen-nitPen-nit No. WQ0000701 issued September 1, 1992, incorrectly lists the acreage approved for
application as 1650 acres in the opening paragraph on page 1. The correct acreage permitted, excluding
buffers, is 2,634 acres. This error has been corrected ted in this modified permit,
F. : Box 29535, Raleigh, North Carolina 27626-0535 Telephone 1 -7 - FAX 1 - -9 1
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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
pertr6t, 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 Ms,, Carolyn McCaskill at
,
cc: Rowan County Health Department
Wilkes County Health Department
Winston-SalemYadkin County Health Department
Winston-Salem
Mooresville
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Groundwater Section Central Office
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Training
Facilities Assessment Unit
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DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SLUDGE LAND APPLICATION PERMIT
I
In accordahceAith the, prOvIisions of Article 21 of Chapter 143�, General Statates of North Cardlitia as
arriehd4 and other applicable Laws, Rules, and Regulations
PERMISSION IS IMRE13Y GRANTED TO
Tywh Foods, Mc.
'Rowan County
bINITIM
ii
•
1. PERMEMINCELS 1rAA_-N'_QA_RM
I The Winston-Salem Regional Office, telephone number 919/ 896-7007, 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 sludge on new sludge sites so that an inspection can be
made of the application sites and application method. Such notification to the regional
supervisors shall be made during the normal office hours from 8:00 a.m, until 5:00 pm.
on Monday through Friday, excluding State Holidays. Also the Wilkes and Yadkin
County Manager's offices 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.
1

The issuance of this permit shall not relieve the Permittee of the responsibility for dam. ages
to surface or groundwaters resulting from the operation of this facility.
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
placement wastewater treatment or disposal facilities.
. to crops for direct human consumption wall be raised on these sites for a period of 1
months following sludge application.
7. Maximum slope for sludge application sell be 10% for surface application and;18% for
subsurface applications.
8. e following buffer zones shall be maintained:
al 400 feet from sidences or places of public assemblyunder 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 l feet from residences or places of public assembly tinder 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;
100 feet from "SA and B" classified waters and public surface water supplies for
both methods,
d 0 feet from ""i " classified waters and other streams, creeps, lakes, rivers, and
surface water drainage ways for injection method,
100 feet from "WS" classified waters and other streams, creeps, lakes, rivers and
surface water drainage ways for surface application method,
10 feet from property lines for bothmethods; however, this requirement may be
reduced to 50 feet upon written concurrence from the adjoining property owner and
the appropriate DEM regional office,
g 0 feet from public right of ways for surface application meth
h feet from public right of ways for subsurface disposal methods,
i 10 feet from up'slope interceptor drains and surface water diversions for both
methods,
jl 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both meth
9, A cope of this permit shall be Dept at the land application site when sludge is being applied
during the life of this permit. Aspill prevention and control plan shall be kept in all sludge
transport and application vehicles.
19

I . The facilities and disposal sites shall be properly maintained and operated at all times.
2. A suitable vegetative cover, as listed in condition 113, shall be maintained in accordance
with the crop management plan approved by this Division.
3 The application rates shall not exceed the following for the specified crops:
Alfalfa 250
Blue Grass 220
Coastal Bermuda Grass 350
Com (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
4The annual application Tate for Cadmium shall not exceed 0.45 lbs./acre.
5. No sludges other than the following are hereby approved for land application in accordance
with this permit:
Permit Estimated
Source Counjy.. �m � Volume ( dry tons,/year)
Harmony Plant Iredell NC0005126 2,250
Wilkesboro Plant Wilkes Town of Wilkesboro, Included in Harmony
Pretreatment No. 1003-1 Planttrans
Breeden Burke Contract to render sludge at Harmony Plant
Holdings Inc. for DAF type sludges
6. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEQ:
Liff&Li m-&,—L-q-ad i �n (l�
PAM= CEC-<-5.
Lead 500
Zinc Cl
Copper 125
Nickel 125
Cadmium 4.5
0
91

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13. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the sludge application area antra the adjacent property or into the
surface waters.
14� 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.
1 Any monitoring (including groundwater, surface water, sludge, sail, or plant tissue
analyses) deemed necessary by the Division of Environmental Management to insure
protection of the environment will he established and an acceptable sampling and reporting
schedule shall he followed. If monitoring data indicates minimal or no concern to the
Division, ion, reduction of monitoring requirements may he pursued after two annual reporting
periods. s
i

2. Proper records ':;all be maintained by the Permittee tracking all disposal activities. These
records shall i a:a°°, e, but are not necessarily lirmted to the following information:
+' a) source of'sludg
b) date of sludge application
c) location of sludge application ]site, field, or zone #)
d) method of application
) weather conditions
it conditions
) type of crop or crop to be grown on field
h) volume of sludge applied in gallons/acre and dry tons/acre
) 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 and 'acre of plant available nitrogen
(PAN), and annual pounds/acre of phosphorus applied to each field.
% Base Saturation Manganese
Magnesium Cation Exchange Capacity
Phosphorus Sodium
Potassium Nickel
Leads Cadmiuml
Zinc copper
pH Calcium
Magnesiurn
t Soils analysis for these parameters shall be conducted once prior to perrnit renewal can
soils from each site which has received sludge during the pen -nit cycle.
4 A quarterly sludge analysis and annual Toxicity Characteristics Leaching Procedure
T LP) analysis shall be conducted by the Permittee and the results maintained on file by
the Pe ttee for a minimum of fire years. if land application curs at a frequency less
thanquarterly, sludge analysis will 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 c,
Copper Mickel
Cadniiurn Chromium
Sodium Calcium
Total Nitrogen Ammonia Nitrogen
Nitrate/Nitrite Nitrogen p
Plant Available Nitrogen (by calculation)
5

a
The TCLP analysis shall inclul-'� the following parameters:
Arsenic
Benzene
Carbon tetrachloride
Chlorobenzene
Chromium
m-Cresol
Cresol
14-Diehl orobenzene
1, 1 -Dichloroethylene
Endrin
ilex achlorobenzene
Hexachloroethane
Lin
Methoxychlor
Nitrobenzene
Pyridine
Silver
Toxaphene
2.4,5-Trichlorophenol
2,4,5-TP (Silvex)
Barium
Cadmium
Chlordane
Chloroform
c�-Cresol
p-Cresol
2,4-D
1,2-Dichloroethane
2,4-Dinitrotoluene
Heptachlor (and its hydroxide)
Hexachloro- 1,3-butadiene
Ix,ad
Mercury
Methyl ethyl ketone
Pentachlorophenol
Selenium
Tetrachloroethylene
Trichloroethylene
2,4,6-Trichlorophenol
Vinyl chloride
W
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
Noncompliance Notification:
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.
6

d. Any process unit failure, due to 1,,r7wn or unknown reasons, that renders the
facility incapable of adequate sludg'e !-atment.
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.
IN AB 1302" 113MI INS
1 a onitoring wells #1, #2, #3, and #5 should be abandoned due to improper location and/or
low water levels.
2. Sampling of monitoring well #4 should be discontinued until such time that field A, which
is upgradient to the well, begins receiving sludge.
3. Field H is not presently receiving sludge, but should field H begin receiving sludge in the
future, a monitoring well must be installed downgradient to the disposal area prior to
application of sludge.
4. All existing wells must be adequately marked so that a buffer between the sludge
application area and well is maintained.
5. The monitor wells on fields that are receiving sludge must be sampled every March, July,
and November for the following parameters:
NO3 Ammonia Nitrogen
TDS TOC
pH Chloride
Total Coliforms SO4
Water Level Total Suspended Solids
Volatile Organic Compounds - November Only (By method I 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 monitoring wells shall be surveyed to
provide relative elevations of the measuring point for each of the monitoring wells. The
depth of water in each well shall be measured from the surveyed point on the top of the
casing,

M !
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.
f 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 h ill be done as a modification to the
Permit.
, No land application of waste activities shall be undertaken when the seasonal high water
table is less than three feet below land surface.
4. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
13

1. This permit shall became 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.
. 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/les sees are in full, force and effect.
e following approved sites for sludge application
Site No. owner see lication Areal acre
I Dr, Richard Adams 988
WK 1-1 Diana Pardue Mathis 64.36
WK -1 Dallas Hudspeth 39.05
WK 2-2 Dallas Hudspeth 14.34
WX -3 Dallas Hudspeth 64.90
WK 3-2 Donald & Mae Duncan 51.7'
YK 1-I LenuelChamberlain� 40.68
YK 1-2 Lenuel Chamberlain 49491
YK 1-3 Lenuel Chamberlain 16.16
YK 1-4 Lenuel Chamberlain 139.92

Sites Continued-
YK 1-5
Lenuel Chamberlain
18-17
YK 1-6
Lenoel Chamberlain
44.02
YK 1-7
Lenuel Chamberlain
86.80
YK 1-8
Lenuel Chamberlain
19.46
YK 1-9
Lenuel Chamberlain
12.34
YK 1-10
Lenuel Chamberlain
9A
YK 1-11
Lenuel Chamberlain
61.65
YK 1-12
Lenuel Chamberlain
25.10
YK 1-13
Lenuel Chamberlain
4.19
YK 1-14
Lenuel Chamberlain
7.35
YK 1-15
Lentrel Chamberlain
30.62
YK 1-16
Lenuel Chamberlain
13.16
YK 147
Lenuel Chamberlain
6.48
YK 1-18
Lenuel Chamberlain
1169
YK 1-19
Lenuel Chamberlain
24.36
YK 1-20
Lenuel Chamberlain
13.64
YK 1-21
Unuel Chamberlain
12.93
YK 1-22
Lenuel Chamberlain
635
YK 1-23
Lenuel Chamberlain
47.38
YK 1-24
Lenuel Chamberlain
8.56
YK 1-25
Lenuel Chamberlain
21.95
YK 1-26
Lenuel Chamberlain
5.34
YK 2-1
Thomas Peaeh
8.09
YK 2-2
Thomas Peachey
24.23
YK 2-3
Thomas chey
26.07
YK 2-4
Thomas Peachey
32.11
YK 2-5
Thomas chey
5.66
YK 2-6
Thomas Peachey
35.04
YK 2-7
Thomas Peachey
13.73
YK 2-8
Thomas Peachey
37.03
YK 2-9
Thomas Peachey
1033
YK 2-10
Thomas Peachey
10.05
YK 2-11
Thomas Peachey
&00
YK 2-12
Thomas Peachey
11.22
YK 2-13
Thomas chey
47.10
YK 2-14
Thomas Peachey
5.70
YK 3-1
Arthur H. Winters
1037
YK 3-2
Arthur H. Winters
53
YK 3-3
Arthur H. Winters
29.58
YK 3-4
Arthur H. Winters
7.35
YK 3-5
Arthur H. Winters
3.95
YK 3-6
Arthur H. Winters
8.81
YK 3-7
Arthur H. Winters
12.02
YK 3-8
Arthur H. Winters
2.81
YK 3-9
Arthur H. Winters
6.34
YK 3-10
Arthur H. Winters
13.62
Yk 4-1
Lester & L.F. Miller
8.3
Yk 4-1
Lester & L.F. Miller
9A
Yk 4-1
Lester & L.F. Miller
22.10
Yk 4-1
Lester & L.F. Miller
33.20
Yk 4-1
Lester & L.F. Miller
37.60
Yk 4-1
Lester & L.F. Miller
6.90
Yk 4-1
Lester & L.F. Miller
71.80
10

Sites Cent` a �.
` k 4-1 Lester & L.F. Miller 25.90
Yk 4-1 Lester & L.F. Miller 12.2
YK -1 Ronald C.Ho 7.0
YK -2 Claude & Ralph Howard 26.2
Yk -3 Icahn K. Howard 36.0
Total 2,33.7
t -Application Area excludes buffer;areas.
Proposed field no. WK 3-1 (37.8 net acres) is, previously permitted to the Town of
Wilkesboro and therefore cannot be included in this permit. Proposed field no. YK 1-8 is
divided into two parts and the smaller part (3.8 acres) is too near three homes, and
therefore cannot be included in this permit.
. Failure to abide by the conditions and limitations contained in this perrmt may subject the
Permittee to an enforcement action by the Division sion of Environmental Management in
accordance c =ith North Caroling General Statute 1 3-21 , to 143-215.6C.
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 pen -nit as specified by 15A NCAC 2 .0205
(c)(4),
8. The issuance of this pennit does not preclude the Permittee from complying with any and
all statutes, vales, regulations, or ordinances which may be imposed by rather government
agencies (local, state, and federal) which have jurisdiction.
set of approved documents for the subject project must be retained by the applicant for
the life of the permit.
10. The, Pe tree, 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 deers 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 public ublic health.
g , , yp
Permit issued this the 19th day of November, ber 1993
NORTH CAROLINA ENVIRONMENTAL MANCR COMMISSION
A. Presto,n ward, Jr. P7E, acting Director �#
Division cVnIvironmental Management
By Authority of the Environmental Management Commission
Pe it No. WQ0000701

FRESHHOLLY FARMS
RETAIL A FOODS, :< W
1600 River Mosel. P,O. Box 88 * Wilkesboro, North Carolina 8 7-008 # (919) 8- 171
l January 30,
"
r. D. Rex Gleason
North Carolina Department of Environment,
Health and atural resources
Division of Environmental Management
Grater Quality Section
919 North Main Street
Mooresville, North Carolina 28115
SUBJECT: Permit No. WQ0000701
HollyFarms Foods, Inc.
Land l catio f Sludge
Rowan County, North Carolina
Dear Mr. Gleason:
� • i
As per our ,t.e '. conversation this dAtet you indicated
Holly Farms could continue to take Breeden1s, sludge and land apply
at our permitted farn in Rowan county based upon the following
parameters:
Breedenis utilizing the sale chemical program for their
dissolved air flotation units as Holly farms is utilizing i
Wilkesboro. The characteristics f their sludge is very
similar to dins_.
e;rr oK,r'r�e,ir.�h�1r..

PPFF,F'­ � �
Page
2. Holly Farms is in the process of gathering information for
submitting a permit modification to WQ0000701 to include
Breeden'Breeden's Iorcto plant a ' a source of sludge or land
aI lication. The modification package should be sent to the
state office in Raleigh with two copies to your office by
February 15, 1991.
3 Breeden is In the process of analyzing their sludge disposal
program. They estimate it will take several months to
complete this process and get the proper equipment in place
Based uponinformation received from Breeden, 1 anticipate
approval of the permit modification by your agency` before they
are prepared to resume their own sludge disposal program:
1 ;,trust the above clarifies' the present'; predicament for ,al
pasties concerned. As stated to you previously, although we
inadvertently applied Breeden"a sludge In the past without proper
approval, It is our _intention to proceed with the lard applicatlon,
of sludge in strict conformance with the permit limitations.
Please advise immediately if there remains any misunderstanding a
to Holly Farms capacity to currently proceed with accepting
Br eden' sludge for land disposal
If you have any questions or require additional information,
you may contact me at 1 - 1 1, extension 3615. Your prompt
attention to this muter is greatly appreciated.
sincerely,
tt y�
Lawrence R. Sampson Jr.1 R. E.
Project Engineer
cc: Danny Wyatt
Hen Lava

,orun.1 County office of the an
y 2,02 Nerth,, ai I n Street ! Salisbury,28144-4356
Telephone [phone]FAX [phone]
���
t August 71 11
T R4a {
MEMORANDUM
Don Canner, Director
Environmental Services Department
Herbert 'Hawley, Director
Health Department
FROM: Tim Russell, Manager
SUBJECT: Monitoring of the l `a " Land Application Permit
After our visit to the Holler Farms' Land Application Site in
western'Rowan County, it was determined that the County should
take a more active role in Monitoring the activities f Holly
Farms/Tyson Foods in its land application process. Although the
emit is a state permit, the Board felt that it would he in the
Rest interest of our citizens most affected by this permit if we
would periodically inspect and observe the activities for eneral
compliance to the permit.
The effort to he made in our participation will not he t
"red flag" or stop the project since we don't have the authority.
Also, o, will not he able to recommend advise representatives
f the Company as to proper techniques of carrying out the process
as approved by the State permit. Our role will be to periodically
observethe application process, and utilizing information
or
requirementsas outlined in the permit, determine if generally
accepted procedures are being taken in accordance with the
permit. if apparent violations are found., our e nai i'lity will
immediatelybe to infer thee State
in° seta in Mooresville f our
discoveryor concern. to should include telephone
communication as well as written fol.l u
w Since the site is under private ownershipt the owner, Dry
Richard Adams of Statesville has provided us with written
e rnieeinn to undertake themonitoringtask. Attach t this
memo is a copy of Dr. Adam's authorization for County staff to he
on his property for this purpose.
Equal Opportunity Employer
recycledpaper

I am assigning the primary task of coordinating and
conducting the monitoring task to the Environmental Services
Department, nd am asking thaton coordinate any on -site review'
of health related issues with the Health°° n . Proper
written data should be maintained in a file to identify any visits
made and the resultsvisits. I am suggesting that we
consider periodic, unannounced visits beginning with a visit
approximately every two weeks. If conditions warrant, visits more
or less frequent will be made,
will appreciate your assistance and support in undertaking
this plan. If you have any questions, please let me know.
CC, Commissioners
Mike Parker
D. Richard .dam
Q �

ak
r
Rowan'aunt ice of the Manager
202 North Min Street Salisbury, NC 28144-4356
Telephone 704- -036 FAX 7 - -
3092
July 2, 1991
Richard Adana
770 Har ness Road
Statesville, 7
Dear r Adams:
s
The Board of iaai n rs appreciates your assistance i
allowing it to visit the site which is utilized, by`Holly farm Foods,
Inc. for its sludge application 6
At the time of the visit, we requested that representatives from
Rowan County be allowed visit and inspect the,site and the actual
sludge application process as deemed necessary to ensure proper
compliance with the State of North Carolina,permit. We are pleased
that you verbally approved of our request.
As a matter of record, we wouldappreciate your written
concurrence our request. A separate letter r simply s
acknowledgement of th,i approval val y signing this letter below, will be
adequate. l believe that both you and our Board share the same concern
that any li a° i process be performedin a' safe and effective
manner.
Sincerely,
Tim Russell
Rowan County Manager
'R/d
Equal Opportunity Employer
recycled paper
A"K

i
���
���, .

Y* I- j::Rowan County Office of the Manager
t,. `,712 Nortiitylain Street * Salisbury, NC28144-4356
LN
Telephone [phone] A7i�4-638-3
092
p. x
e9 August 71991
( M
TO Dora Conner, Director
Environmental Services Department
Herbert Hawley r Director`
Health Department
FROM: Tim Russellt Manager
SUBJECT: Monitoring of the Holly Farms' land Application Permit
After our visit to the Holly Farms' Land Application Site in:
western Rowan County, it was determined that the County should
take a more active role in monitoring the activities of Holly
`arms/Tyson Foods in its Land application process. Although: the
permit is a State permit, the Board felt that it would be in the
beat interest of our citizens most affected by this permit if we
would periodically inspect and observe the activities for general
compliance to the permit.
The effort to be made in our participation will not be to
"red flag" or stop the project since we don't have the authority.
Also, we will not be able to recommend or advise representatives
of the Company as to proper techniques of carrying out the process
as approved by the State permit. our role will be to periodically
observe the application process, and by utilizing information or
requirements as outlined in the permit, determine if generally
accepted procedures are being taken in accordance with the
permit. if apparent violations are found, our responsibility will
be to immediately inform the State inspector in Mooresville of out
discovery or concern.. Notification should include telephone
communication as well as written follow-up.
Since the site is under private ownership, the owner, Dr.
Richard Adapts of Statesville has provided us with written
pe ission to undertake the monitori.ngT task. Attached, to this
memo is a copy of Dr. Adam's authorization for County staff to be
on his property for this purpose.
Equal opportunity Employer
recycled paper
4 r..
x

t
1 am assigning the primary task of coordinating and
conducting monitoring task to the Environmental Services
Department, and am asking that Ikon coordinate any on -site ravish
of health -related issues with the Health Department. Proper
_written data should be maintained in a file to identify any visits
made, and the results of ,each visits. 1 am suggesting that
consider periodic, unannounced visits beginning with a visit
approximately every two weeks. if conditions warrant, visits more
r less frequent will be mace.
1 will appreciate your assistance and support in undertaking
.his plan. if youhave any questions,please let me know.
Commissioners
Mike Parker
r. Richard Adams
g

ILOW ®:
z
L 3 1 iR f a
O - - A- - ;
Rowan punt iiF the Manager
202 North Main Street + Salisbury, NC 28144-4356
FAX 704-6 8-3t 2
Telephone [phone]
July 24, 1991
Richard Adam
o Hartness Roy
Statesville, NC 28677
Dear Br • .dams
The Board of Commissioners appreciates your assistance in
allowing it to visit the site which is utilized by Holly Farm Foods,
Inc. for its sludge application process.
At the time of the visit, we requested that representatives from
Rowan County be allowed to visit and inspect the,site and the actual
sludge application process as deemed necessary to ensure proper
compliance with the State of North Carolinapermit. We are pleased
that you verbally approved of our request.
As a matter of record, we would appreciate your written
concurrence of our request. A separate letter or simply an
acknowledgement of this approval b signing this letter below, will b
adequate. l believe that both you and our Board share the same concern
that any application process be performed in a`sfe and effective
manner.
'Sincerely,
'dim Russell
ocean Count` Manager
Rb
Equal opportunity Employer
racycled paper
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m
PERMISSION O OBSERVE SLUDGE APPLICATION
This approval is gear granted'to representative
gran
County to visit on property owned the undersigned at
the application sludge ' a
reasonable
defined in
times to observe and inspect
North Carolina"permit granted to Holly Farms
the approved State of
Foods, Inc.
g}
ate" i
n r ^,,pf Pro arty ,..
Date
t
Attest

nSN1 4,, tnt, ENT
M1N J f4
State of North Carolina fN"ES'4'lllfflfl liAL OfFICE
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury ,Street - Raleigh, North Carolina 27611
Darn s G. Martin, Governor
William w. Cobey, Jr„ Secretary
Mr„ Lawrence R. Sampson,
N. C.Division Engineer
holly Farms Foods, Incorporated
Post Office Box 88
Wilkesboro, North Carolina 28697
George `I'. Everett, Ph.1 :
Director
December 2 1, 1990
Subject: Permit No. W Qt 000701 Amendment
Dolly Fartris Foods, Inc.
Harmony and Wilkesboro Facilities
Land application of Sludge
Rowan County
Lear Mr. Sampson:
In accordance with your application received March 1, 1990, and your pernut amendment
request re ieved August 16, 1990, we are forwarding herewith permit No. W{3t700701, dated
December 21, 1990, to Holly Farms Foods, Incorporated for the; subject operation of a land
application Of sleidge pro rart .
This permit shall be effective from the date of issuance until July 31, 1995, , and shall be
subject to the conditions and limitations as specified. therein,: Tease pay particular attention to the
monitoring requirements in this permit. Failure to establish an adequate system for collecting an
maintaining the required operational inforination will result in future compliance proble,r s..
Issuance of this permit hereby voids Permit No. WQ0000701 issued July 16, 1990,
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 Mirth Carolina General Statutes, and filed with the Office of Adrninistrativ°c
Hearings, P.O, Box 11666, Raleigh, NC 27604. Unless such demands are rnade this permit shall;
be final and binding.
If you need additional information concerning this matter, please contact Mr. John
Seymour at 19' 3 - 0 ,
/ £Sincerely,
eor er. T. Ever,
Rowan County Health l epar"Unerit
Moores.ville-Regional fic
Groundwater Section
Pollution Preveenjiate Pays
P.O. Box 7687, E; ae9eiglta North Carolina 2761 1.7687 Telephone ail . ,3-7015
n Equal Opportunity AffirmaLive Action Employer

oy- NATURAL
AN'14�
NORTH CAROIANA
ENVIRONNMENTAL NIANAGENIE't\'T C0,11VIMISSION JA,"q 1�191
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAINI
RALEIGH MOORESVILLE
SLUDGE LAND APPLICATION PERMIT
Incaccordance 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
Holly Farms Foods, Incorporated
Rowan County
Ft THE
operation of a sludge land application program consisting of a 520,000 gallon capacity sludge
holding tank and the subsurface injection of sludge from the Han-riony and Wilkesboro Plants to
sites identified in condition no. VI.6 of this pernnt with no discharge of wastes to, the surface
waters, pursuant to the application received March 1, 1990 and in conforniity with the project
plan, specifications, and other supporting data subsequently filed, and apprr)ved 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 July 31, 1,995, and shall be
SLII)JeCt to the following specified conditions and limitations:
1PERI-,OR,MAN(:E STANDARDS
I 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.
The land application program shall be effectively maintained and operated as a
non -discharge system to prevent the discharge of any wastes resulting from tile
operation of this prograrn,
The issuance s-,A'th's perinit shall not relieve the Permittee of the responsibility for
darnages, to surface or groundwaters resulting from the operation of this facifiry,
I
4® In the event that the land application program is not operated satisfactorily, including
the creation of nuisance conditions, the Pennittee 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.

No crops for direct human consumption shall be raised on then e sites for a period
of 18 months follwwing sludge application,
Maximum slope for sludge application shall be 101/1, for surface application arid
18%,for subsurface applications,
'rhe 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 tinder separate ownership for injection method,
however the buffer zone requirement may be reduced to at mini tuns of 10()
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 frotri 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 triethods,
i) 10 feet front upslope interceptor drains and surface water diversions for
both methods,
J) 25 feet from downslope interceptor drains, surface water diversions,
groundwater drainage systems and SI]Tfl(,-,e drainage ditches for both
methods.
8 A copy of this permit shall be kept at the land application site when sludge is being
applied dining 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 as process to significantly
reduce pathogens (as described in 40 CFR Part 257, Appendix 11) prior to
application or incorporation, An evaluation of all sludges as specified in condition
11 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.
I
1 1. No sludge at any time shall be stored at any application site,
IL QQEPEEEAA'IIIIQ)NN AND MAINTENANCE REQUJREk�
AND —1 EN TS
The facilities and disposal sites shall, be properly maintained and open,"Ited at all
tirraes

8
suitable vegetative cover as listed in condition 11 3, shall be niaintaained in
accordance with the crop management plan approved by this Division.
.
The application rates shall not exceed the following for the specified crops:
Crta _s T AI Clb�eaar}
Small Grains 100
Soybeans 150
Corn (silage and grain) 2M
Alfalfa
Sorghum 120
Fescue grass
Timothy grasp 200
Orchard grass 200
Rye grasp 200
Blue grass 220
Coastal Bermuda brass 350
Cotton 100
Forest areas 75
Other Craps equivalent PAN';
The annual applicaanon rates shall not exceed the following -
a) Phosphate 0 lbs./acrd
b) Potassium 100Ibs,/acre
c) Cadmium 0.45 lbs./acre
dj Hydraulic loading (wet) 6788 gallons/acre
o sludges other than, the following area hereby ;approved for land application in
accordance with this permit-.
Jog r—c—e Count, Permit lea .
Harmony Treded NC"000 l f-
Plant
Wilkesboro Wilkes Town of Wilkesboro, Pretreaarnient No. 1003 T
Plant
The lifetime ;heavy metal loadings shall not exceed the following for° the
corresponding Cation lu`xcha i e Capacities (C EQ:
pararrieter C
Lead {lbs/aacre) 500
,irc. albs/acre) 20
Copper (Ibs,/acr) 125
Nickel lbs/aacrl 1.
Cadmium (lbs/aac re) 4.5
Adequate procedures shall be provided to prevent surface runoff from carrying any
d1sp used or stared slUdge material i nto any surface wafters.
Animals shall not be grazed on sludge applied land within as ":ill -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,

Surface applied sludge will he plowed or disced within twerity- our(24) Dour
after application on lands with no cover crop established,
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. 'fhe sludge must be incorporated
into the aril within twenty-four () hours of application.
IL Appropriate measures must be taken to control publics access to the land application
sites daring active site rise and for the 1-naranth period following the last sludge
application event. Such controls may include the pasting of signs indicating the
activities being conducted at each site.
12. Adequate provisions shall be tafaen 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. . hedge shall not be applied in inclement weather or until 24 hours following as
rainfall event of 1/2-inch or greater in 24 Mars. Any emergency sludge disposal
measures must first be approved by the Division of Environmental Management.
ement..
14. The site shall be adequately limed to a soil pH of at least 6.5 pricar to sludge
application. Sludge, may be, applied to sites with a pH of less than fa. ; provided a
sufficient amount of lime is also applied to archieve a final pfI of the lime, sludge and
sell mixture of at least d. w
MONITORING AND REPORTING REOUIREMENTS
I Any monitoring (including grcraindwvater, surface wwaater, sludge, soil, or plant
tissue analyses) deemed necessary by the Division of Environmental Management
to insure protection of the envirrrnr ent will be established and an acceptable
sampling and reporting schedule shall be followed. If monitoring data indicates
mininial or no concerti to the Division, reduction of monitoring requirements may, be
pursued after two annual reporting periods.
2. Proper records shall be maintained by the Perrtrittee trucking all disposal arc nvitic.s
These records shall include, but are not necessarily limited to the following
inforraaatican:'
ai source of sludge
bl date of sludge application
c l location of sludge aapplicaati rt (site, field, or zone #)
d.l metlar i of application
et weather condition
0 soil c:crnd'stians
yt type of crop or crop to be grown on field
h l volurne of sludge applied ire gaallons/arcre. and dry tons/,acre
i/ annual and cumulative totals of dry, trans/nacre of sludge, aanncaaal arid
c=trrartalaativc pounds/acre of each heavy taactaal (which shall include, but not
be, limited to lead, nickel, caadmiurn, copperand inc), annual p carwdsiatcre
of plaint available nitrogen (PAN), and annual pounds/acre of
phosphorus applied to each field,

3
`l
A representative annual sails analysis shall be conducted of each site receiving
sludge in the respective calendar year and the results maintained on file by the
Perraaittee for a; raairairaauraa of five years. The sails analysis shall include but is not
necessarily limited to the following parameters:
Standard Sail fertility "PestManganese
p Bass Saturation Cation Exchang 'aa aac.i ty
Phosphorus Sodium
Potassium nickel
Lead Cadmium
Zinc Copper
er
Magnesium Calcium
pH,
r quarterly shade analysis and annual " CLP analysis shall be t:onducted by
the Permittee and the results maintained on file by the Perrnittee for as nrinurturn, of
five years. After two years worth of analysis the leer itt e may request that the
.analysis frequency fie. changed to annually, 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
I,aac
Zinc
Copper
Mickel
Cadira um
Chr nriuraa
Sodium
Calcium
Total Nitrogen
Ammonia Nitrogen
Nitrate/Nitrite Nitrogen
P
Plant Available Nitrogen (by calculation
The l"C,'LP analysis sis shall include the following
parameters:
ers:
Arsenic
l aariurn
,Benzene
Cadmium ..
Cir on tetrachloride
Chlordane;
Chlcirobenzene,
Chloroform
C;`hrorniuraa
o-Cresol
raa-Cresol
p-Cresol
"reseal
a
r
l d-Dichlor-caben ere
l,`?-1 achlo thane
1,1-I achloroethylene
, wl initrotoluene
Endrin
Heptachlor <(and its hydroxide
Heaaachlorobenzene
Ile aachlorta-1,-butaarliene
Hex achlorc .thane
Lead
Lindane
W
is4e,tho yfchlor
l�,lethvlethyl ketone
Nitrobenzene
lent,, rc glair"f- phenot
Pyridine
Selenium
Silver
" etraachlorc ethylene
°fo aphene
Tric;hl roethyklene
,4,5-Trichlorophenol
° , ,6-Tfichl ropheri l
2., ,5-1,p Silvexl;
Vinyl chloride

5,
Three copies of all monitoring and reporting requirements as spedried in conditions
111 f, 111 2, 111:: and ill 4 shall be submitted annually can or before March 1 of
the following year to the, following address;
C Division of Environmental Management
Water Quality etction
Facility Assessment Unit
PO Begat 27687
Raleigh, h, 27611-7687
Notification -
The l e mittee shall, report by telephone to the Mooresville Regional Office
telephone no. 704/ 663-1699, as soon as possible, but in no case snore 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 lane application program which results in the
land application of significant amounts of wastes which are abnormal is
quantity or characteristic.
b.. Any failure of the land application program resulting in a release of
sludge naateriaal 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 tender
the facility incapable e of adequate sludge treatment:
C. Any spillage or discharger from to vehicle or piping, system transporting
sludge to the application site.
Persons reporting such occurrences her telephone shall also file as written repeat in
letter form within 15 days following first knowledge of the occurrence. 'l"his report;
must outline the actions taken or proposed to be taken to ensure that the problear
dares not recur.
IV, GROUNDWATER REOUIREMENTS
I Within 90 dams of permit reissuanc.e, two i additional monitor shall be
installed to nionitor fields F, Q, and L. The two additional wells should be
placed sea that, in COIF J' unction with monitor well No. 5,cane (1) well will be
upgraadie:nt, and two f l wells will be downgriadiernt of this: aforementioned fields.
The wells shall be constructed d such that the water level in the well is never above or
below the screened (open) portion of the well at any t rage during the year. However
the exact location and construction details for these wells shall be approved by than
Mooresville Regional Office, ce, front which as well construction permit must be
obtained.

The monitor wells must be sampled initially after construction (and prior to waste
disposal operations) and thereafter every March, July, and November for the
following parameters:
N 0 -_I (10.0) Ammonia Nitrogen
MS (500,0) TOC
pH (6.5-8.5 standard units) Chloride (250.0) - Novernber only
Total Coliforms f I / I 00ml) SO4, (250.0)
Water Level
Volatile Or 9 anic Compounds - November Only (By method I or- 2 below)
Method 1: Method 6230D (Capillary - Column), " Standard Methods For The
Examination of Water and Wastewater", l7th ed., 1,989
Method 2: Method 502.2 "Method For The Deten-nination Of Organic Compounds
In Drinking Water", U.S. EPA - 600/4-88/039
The measurenlent of water level must be made prior to sampling for the remaining
parameters,
The measuring points (top of well casing) of all monitoring wells shall be surveyed
relative to mean sea level (M.S.L.). The depth of water in each well shall be
measured front the surveyed point on the top of the casing. The water level
Z7
elevations shall then be determined relative to M,S,L,
The numbers in parentheses represent the maxiinurn allowable co n centrat ions in
ground rater 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 TOT concentrations greater than 10 rng/l are detected in any downgradient
as oniroring well, additional sampling and analysis triust Lie, conducted to idenfii°v the
individual constituents comprising this TOC concentration, If the TOT concentration
as to in the backaround, monitor well exceeds 10 mg/l, this concentration will
be taken to represent the naturally occurring TOC concentration, Any exceedances of
this naturally occurringTOC concentration in the downgradient wells shall tsubject
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 rnay 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 GW­59 (Compliance Monitoring Report
Form) every April, AUgLISt, and December.
3 The Cbm Hance Boundar, for the disposal system is specified by regulations in 15
NC AC 2L, Classifications and Water Quality Standards applicable to tire
groundwater otNorth Carolina. An exceedance of Groundwater Quality Standards
beyond the Compliance Boundary is subject to penalty provisions applicable Under
General Statute 143-215.6(1)zi. The sale of property, by the Pernintee, which is
within or contiguous to the disposal systern site may alter location of the
Compliance BOUndary.
7

For facilities permitted on or after Decernber 30,1983, the. Compliance Boundary is
established at the lesser of 250 feet from the perimeter of the waste, disposal ,arc aa, or
50 feet within the property boundary..
f 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 Perrnit.
The ELYLEW BOUNDARY for the disposal system is specified by regulations in 15
NCAC 2L, Groundwater Classifications and Standards. A ll.lk.VIEW BOUT f I.. N ARY
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 BQUNDARY, as determined by monitoring, the per nittee 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, lii sub it 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 implerrie.nt that plan upon its
approval by the Director.
4, No land application of waste activities shall be undertaken when the seasonal high
water table is lass than three feet below land surface:
5 Any additional groundwater quality monitoring, as deemed necessary by the
Division, shall be provided.
1. °T"he. Permittee or laic 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, as
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 as period of three years
from the date of the inspection and shall be made available Capon request by the
Division of Environniental Management or other permitting authority.
2.; Any duly atathori" ed 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 an), reasonable tinge for the purpose of deternilning compliance with this
permit; may inspect or copy any records that must be kept under the terms and
conditions of this p rrnitg or may obtain samples of groundwater, surface water,
or leaachaate

OF
1. GENERAL. CONDITIONS
I, This permit shall become voidable unless the brad application activities are carried
out in accordance with the conditions of this permit and in the manner approved;
by this l ivfision,
,. This perraait is effective only with respect to the nature and volume of wastes
described in the application and rather supporting data.
3. This permit is not transferable. In, tine event there is as desire for the facilities to
change ownership or a name change of the Perrilittee, a ftinnal permit request must
be submitted to the Division of Environmental Management accompanied d 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
aara its merits and may or may not be, approved.
Prior to any transfers of this land, as 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 tile perraaittee
and the ltandownerstlessees acre in full farce and effect.
fa The following are approved sites for sludge application.-
i e v Stier liesa 'care Area e c1u inY bttf'f--r
acres
l Dr, Richard Adaunas 988
Failure to abide by the conditions and limitations contained in this permit may
subject the permittee to aria enforcement action by the Division of Environmental
Management in aacea,-ardance with North Carolina General Statine 1 - 15A
The annual administering and compliance fee must be paid by the Penruttee 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 percent as
specified by 15 NCAC 2H,0205 (t)( .
9, The issuance of this permit dares not preclude tine Ilermittee from complying with
any and all statutes, males, regulations, or ordinances which r-nay be imposed by
rather governnient agencies (local, state, and federal) which have jurisdiction,
10, A set ol' approv ;d dcacurraents for the subject project ni sst lac:: retained by the applicant:
for the life of the permit.
1.1. The Pern-ittec at least sip fa) nac Laths prior to the, expiration of this percent, shall
request its extension. Upon receipt of the request, the i'ora n-u sion will reviews
the adequacy of the facilities described therein, and it warranted, will extend the
pertaait for such period of tinge and, under such conditions ,and limitations as it may
deem appropriate,

1 . This perout may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division € f Environmental Management
deems necessary in order to adequately protect the envirc nnient and public health
1 � Issuance of this pertrut hereby voids Permit No. WQ0000701, issued JulyA 16,
1990.
Permit issued this the 2 1st days of December, 1990
ICI CAROLINAENV 0 MENTAL MANAGEMENT COMMISSION
car. e' '. Ever` t, ireet r
Division of Env meant, a ement;
By Authority cad the 0 t etttal Management ommissi rt
Permit No. WQ00007 1
1

A
Ogg
+
01. 1 wi State of North Carolina
AYI 0,10nent of Environment,, health and Natural Resource
Division of Environmental Management
512 North Salisbury Street Raleigh, North Carolina 27611
Jam . . tin, Governor George T. Everett, Fh,D.
William '', . Cobey, Jr,, Secretary Dir tzar
July 1, 1990
Mr, Lawrence R. Sampson,
C. Division engineer
Holly Farms Foods, Incorporated
Post Office Box 88
Wilkesboro, North Carolina 28697
Subject: Permit No. fll
Holly Farnis Foods, Inc.
Harmony and Wilkesboro esbort Facilities
Ladd Application of Sludge
Rowan County
Dear Mr. arrlp on:
In accordance with your application received March 1, 1990, we are forwarding herewith
permit No. WQ0000701, dated July 16, 1990, to Holly Farms Foods, Incorporated for the subject:
operation of a land application of sludge program..
This permit shall be effective from the date of issuance until July 31, 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 to system for collecting and
maintaining the required red operational information will result in future compliance problems.
Issuance of this permit hereby voids Permit No. 70 issued February 199
If any parts, requirements, or limitations contained in this pernuit are unacceptable to you,
you have the right to request an adjudicatory hearing upon written request within 30 ,days
following recent of this permit, This request artist be in the form of a written petition, conforming
to Chapter 150B of forth Carolina General Statutes, and filed with the Office of Administrative
Hearings, 1 , .1Jox 11666, Raleigh, NC 27604. Unless such demands are made this permit shall
be final and binding,
If you need additional information concerting this matter, please contact Mr. John
Seymour at 919/ 733-5081
in.erely,
r
.r came T Evert �i
co: Rowan County I-Iealh Department
tlle� . e ional Off ice
+ r6und ater section
Poldgation Prevention gays
P.0.1tox 27687, Raleigh, North Carolina 7611-75 7 "Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SLUDGE LAND APPLICATION PERMff
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
Holly Farms Foods, Incorporated
Rowan County
FORTHE
operation of as sludge land application program consisting of a 520,000 gallon capacity sludge
holding tank and the subsurface injection of sludge from the Harroony and Wilkesboro Plants to
sites identified in condition no. V1.6 of this permit with no discharge of wastes to the surface
waters, pursuant to the application received March 1, 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 July 31, 1995, and shall be
subject to the following specified conditions and limitations:
I . EiRFQRMANCF STAMARD�
I 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 Penrattee 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 Pertnittee 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.
6Maximum 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 S11" 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 11) prior to
application or incorporation, An evaluation of all sludges as specified in condition
114 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.
QPERATION AND MAINUNANCE RE-QUIREMENTa
I The facilities and disposal sites shall be properly maintained and operated at all
times.
2

2
A suitable vegetative cover as listed in condition It 3, shall be maintained in
accordance with the crop manage rnent plan approved by this Division.
3.
The application rates shall not exceed the following for the specified crops:
Coastal Berniuda grass 300
Forage Sorghum 200
Pearl Millet 200
Sorghum/ Sudan grass 200
CocaM 200
Grasses 200-300
Grains (wheat, barley, etc.) 100-150
Soybeans 150-
For st areas 50-100
4.
The annual application rates shall not exceed the following:
a) Phosphate 50 lbs./acre
b) Potassium 100 lbs./acre
c) Cadmium 0.45 lbs./acre
d) Hydraulic loading (wet) 6788 gallons/acre
5.
No sludges other than the following are hereby approved for land application in
accordance with this pennit:
=r QagnLy Pjnnk_Ng_,._
Han -pony Redell NCO005126
Plant
Wilkesboro Wilkes WQ0002386
Plant
6.
The lifetime heavy metal loadings shall not exceed the following for the
corresponding Cation Exchange Capacities (CEQ:
Parameter CBEL—<1
Lead (lbs/acre) 500
Zinc (Ibs/acre) 250
Copper (lbs/acre) 125
Nickel (lbs/acr&) 125
Cadmium albs/acre ) 4,5
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 disc within twenty-four (24) hours
alter application on lands with no cover crop established.
3

10F For areas that are prone to flooding or withinr the lilfl-yeas° flood elevation, sludge
may be applied only during periods of dry weather. The sludge must be incorporated
into the soil within twenty-four () 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 l - unth period following the last sludge
application event. Such controls ay include the posting of signs indicating the
activities being conducted at each site,
11 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.
1, . 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: d.5 provided a
sufficient amount of lime is also applied to achieve ta, final pal of the lime, sludge and
soil mixture of at least 6.5,
llf.MONITORING AND REPQRIM,REQUIREMENTa
L 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 f monitoring data indicates
minimal or no concern to the Division„ reduction of monitoring requirements may be
pursued after two annual reporting periods,
m Proper records shall be maintained by the Permittee tracking all disposal activities.
These records shall include, but are not necessarily limited to the following
info a ion:
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
) soil conditions
g type of crop or crop to be grown can field
h volume of sludge applied in gallons/acre and dry tons/acre
i annual and cumulative totals of dry torts/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.
4

3, A representative annual sails analysis; shall be conducted of each site receiving`
sludge in the respective calendar year and the results maintained can file by the:
Permittee for a minimum of five years.. The sails analysis shall include but is not
necessarily limited to the following parameters:
Standard Sail Fertility Test Manganese
Base ate titan Cation Exchange Capacity
Phosphorus i
Potassium Nickel
Lead Cadimurn
Zinc Copper
Magnesium Calcium
pH
4. A quarterly sludge analysis and annual EP Toxicity analysis shall be conducted
Y
the Permittee'qu erly and the results maintained on file by the Pertnittee for a
minirnum, of five years. If land application occurs at a frequency
r 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
Chl
orides Sulfate
Ph
osphorus hru Potassium u
Lead, Zing
Capper Mickel
Cadmium Chromium
i
Sodium Calcium
Total Nitrogen Ammonia Nitrogen
Nitrate/NitriteNitrate/Nitrite Nitrogen p `
Plant Available Nitrogen (by calculation
The EPToxicity analysis shall include the following parameters:
meters:
Arsenic "urrt
Cadmium Chromium
Lead Mercury
Selenium Silver
Endrin Lindane
l letho ychlor To aphen
2,4-D 2,4,5 -TP Silvex
Three copies of all monitoring and reporting _rd_uirements asspecified inconditions_
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 ion of Environmental Management
'water Quality Section
Facility Assessment Unit
PO Box 27687
Raleigh, NC27611-7687
5

r -
Noncompliance Notification:
The Perrnittee shall report by telephone to the Mooresville, Regional Office
telephone no. 704/ 663-1699, as soon as possible, but in no case more than 24
hours or can 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
r the parameters can which the system was designed.
d. Any processunit failure, due to brown 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..
Persians 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.
QRQUNDWAIERREQUIREMEM
l.. Within 90 days of permit reissuance, two (2) additional monitor wells, shall b
installed to monitor fields P, i , and L. The two () additional wells should be
placed so that in conjunction with monitor ' well No. 5 one (1) well will be
up radi nt, and two (2) wells will be doawn, radient of the aforementioned fields.
The wells shall' be constructed such that the water level in the well is never above or
below the screened (aspen) 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
Mooresville Regional Office, from which a well construction permit must be
obtained.
2 The monitor wells must be sampled initially after construction (and prior to waste
disposal operations) and thereafter every larch, July, and November for the
following parameters:
(10.0) Ammonia` Nitrogen
en
ply (6.5- . standard units) Chloride (250.0) - November only
Total Colifo s (1/1 l) SO4 (50.0)
Volatile Organic Compounds -'Novembe Only (By method 1 or 2 below)
Method l: Method t 2` 0D (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 w 600/4-88/039
e measurement �of water level must be rude prior tosampling for the remaining
parameters.
The measurmgpoints (tap of well casing) of all monitoring wells shall be surveyed
relative to mean sea level M.S.L. , The depth of water in each well shill be
measured from the surveyed point on the top of the casing. The water level
elevations shall then `be determined relative to I. ,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 ,liven in parts per million.
If TOC concentrations greater than 10 mg/1 are detected in any down, r :dient
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 hAQk-4LQunAmonitor well exceeds 10 mgA, this concentration will
be taken to represent the naturally occurring TOC concentration. Any exceedances of
this naturally occurring TOC concentration in the down client ells shall be subject
to the additional sampling 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 60and 611 if required, must be submitted
simultaneously.
The results of the sampling and analysis shall be sent to theN.C. Division of
Environmental ]Management on Form G -5(Compliance Monitoring deport
Form)every April, August, and December.
The Corrmhance Boundaryfor the disposal system is specified by regulations in 1
A 2L, ClassiticatlZms and Water Quality Standards applicable to the
groundwater of North Carolina.: n eatceedance of Groundwater r Quality Standards
beyond the Compliance Boundary is subject to penalty provisions applicable under
General Statute 1 3-215. a(l)a. The stale of property, by the Permittee, which i
within or contiguous to the disposal system site may alter location of the
Compliance Bound
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 bound
If the title to any property which may affect the location of the Compliance Boundary
is changed, the perrnittee shall notify the Division Director within 14 days. The
Director shall then establish a modified Compliance Boundary which will be done a
a modification to the Permit.
i

NOV
standards at the o ptr ce Boundary; or, (rr) submit a plan teary the alteration of
existingsite conditions, facility design or operational controls that will prevent
violation of standards at the Compliance Boundary, and implement that plan upon its
approval by the Director.
No land application of waste activities shall be undertaken when the seasonal high
water table is less than three feet below land surface.
Any additional groundwater quality monitoring, as deemed necessary by the
Division, shall be provided,
INSPECTIONS
I. The leer ittecor his designee shall inspect the sludge steerage, transport, and
disposal facilities to prevent malfunctions and deterioration, operator erasers 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 beep an inspection lead
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 Pertnittee 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.
. 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 arty'; records that must be feet under the teons and
conditions of this pe it; or may obtain samples of groundwater, surface water,
or leachate.
VI. GENERAL
I. This permit shall become voidable unless the land application activities are carried
out in accordance with the conditions f this permit and in the manner approved
by this Division,
This pertnit is effective only with respect to the nature' and volume of wastes
described in the application and other supporting data

FFV
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 formalit 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 rr erits and may or may not be approved.
1, Prior to any transfer of this land, a notice shall be given to the new owner that
gives frill details of the materials applied or incorporated at this site.
This permit shall become voidable unless the agreements between the Permittee
and the lando ners/lessees are in full force and effect;
6 The following are approved sites for sludge application (see attachedmap):
Qw--ntrjLgLsse AnDlication Area (excludinebuffers)
1 Dr. Richard Adanis 988
a 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 Caroling Genera] Statute 1 - 1 . .
8, The annual administering and compliance fee gust be paid by the Pertnittee within
thirty ) days after being ladled by the Division, failure to pay the fee'
accordingly may cause the Division to initiate action to revoke this permit as
specified by 15 NCAC2il .0205 c)().
" The issuance ofthis 'permit does not preclude the Permittee, from complying with
any and all statutes, rules, regulations, or ordinances which may be imposed by
rather 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 pernut.
l l . The Permittee, at least six () months prior to the expiration of this permit, shall
request its extension. Upon receipt of the request, the Commission sion 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,
2, This permit may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division (if Environmental Management
deems necessary in order to adequately protect the environment and public health.

13. Issuance of this permit hereby voids Permit No. WQ0000701 issued February 5,
1990.
Permit issued this the 16th day o. July, 1990
CAROLINA EN ONMENTAL MANAGEMENT COMMISSION
George T. Everett, D cto
Division ofEns e n agement
By, Authority of the Environmental Management Commission
Permit No,. WQ0000701
10

DIVISI
April
MEMORANDUM TO: Don Safrit
FROM: Rex Gleason
PREPARED BY: Mike Parker
SUBJECT: WQ 0000701
)F ENVIRONMENTAL MANAGEMENT
1990
This Office has conducted a review of Holly Farms' request
for renewal of the subject Permit, and offers the following
comments.
A site inspection was conducted on April 9, 1990 by the
writer who was accompanied by Mr. Ben Laws, Plant Manager, Holly
Farms - Harmony Rendering Plant. During the course of the
investigation, Mr. Parker examined past and current disposal
fields (sites) located on the farm owned by Mr. Adams. At all
sites, it appeared that buffers were well maintained and no
evidence existed that Permit conditions have been violated. Of
special concern was odors, which may have created off -site
nuisance problems. During the past 12-18 months, the MRO, had
received several calls concerning odors from this project. It
should be noted that no unusual off -site odors were detected
during the course of the investigation, even though sludge
application was taking place on the day Mr. Parker visited the
site(s).
A review of the data submitted by Holly Farms indicates that
application rates, as specified in the current Permit, were being
observed.
Holly Farms is on the verge of implementing a new process at
the Harmony facility which will significantly reduce or eliminate
the need for sludge land application. The Company, however,
wishes to retain the subject Permit in case of operational
problems that may warrant future use of the sites for sludge
disposal.
The MRO has no objection to this request, and recommends
approval pending a final technical review by the SERG and any
additional comments by the Groundwater Section.
If Foy. have any questions, please advise.
MLP:sju

HOLLY FARMS FOODS,
FRESH RETAIL DIVISION, TYSON FOODS, INC.
1600 River Road, P.O, Box 88 + Wilkesboro, North Carolina 8697-008 (919) 8 8- 171
February 29, 19
Mr. Gaon Safrit
North Carolina Dept. of Environment,
Health and Natural Resources
Permits and Engineering unit
P.O. Box 27689
Raleigh NC 27611-7687
Subject: Permit No. WQ0000701
Holly Farms Foods, Inc.
Harmony Rendering Plant
Land Application Permit
Rowan County, North Carolina
Dear Mr. afrit.
am requestingthe renewal of the above subject land
application permit. The current permit expires on June`30, 1990.
Attached you will find a check in the amount of one hundred
twenty-five dollars { 1 , to ewer the application processing
fee. Also attached is the, Non -Discharge Permit Application forms
as requested.
With regards to the present permit, Holly Farms is
continuing work on the construction of the enclosed storage tank
and making provisions for discontinuing use of the existing; open
lagoon as; detailed under item VI-14 on page 8. This work should
be completed by the current expiration date'.
Also with regard to the present 'modified permit issued on
:February 1, 1.990, there is an item that needs to be addressed:
1. Item 11-4 on page 3 of the permit; states the sludge
is from molly farms Foods, Inc. in Rowan County,
The sludge is generated at our facilities in Harmony
and Wilkesboro as detailed on the, permit application
and as previously noted in the. September 1, 19
edition of the permit under item 12 on page 2.
v
RgM 3 n1P m

I trust that the permit renewal request is in order. Please
contact me if you have any questions or require further
information,
Sincerely.
Lawrence R. Sampson, Jr., P.E.
N.C. Division Engineer
LS/ap
cc: Ben Laws
Mr. Mike Parker

a
W
•� �xara
State of North Carolina
Department of Natural Resources and Community Development
Division of Envir-a nnientaal Manaagernent
512 North Salisbury `street 0 Raleigh, North Carolina '2 611
Jtaaraes G. Martin, Governor 1 :- !on! WAS
S
March31 ' � 9iT
l`�a'illiatatr W 'calrey, jr,, Secretary Director
Mr. Frank `l'arsci.da Chief Engineer
Holly Farms Foods, fac.
PO Box 88
Wilkesboro, NC 28697-0088
SUBJECT: Permit No, WQ0000701
licrlly Farms Foods, Inc.
Harmony Rendering Plant
Land Application of Sludge
Sludge Holding Lagoon
Rowan County
Dear Mr, `f as r as e i rl o ;
In accordance with the request. received December 30, 1988, we are forwarding
herewith Permit: No. WQ0000701:, dated March 31, 1989, to Holly Farms Foods, 'Inc,
for they operation of the sralaol`ect: sludge land application facilities.
Ibis permit shall be effective from the dat.e of issuance until June 30, 1990,
shall void Permit No, WQ0000701, which was issued on December 1, "1988, and shall be
sarlar°lect to the conditions ti°on's and limitations as specified therein.
As stated in correspondence received from Holly Farms Foods . Inc,, the request
to have sludge land application sites (Bryan k Church property) permitted in Wilkes
County and to construct a sludge holding lagoon on these properties has been
withdrawn. Additionally, Holly Farms Foods, Inc. has withdrawn its request to
construct a new sludge holding lagoon on the Richard Adams' property in Rowan County.
Polly Farms Foods, Inc.; has requested that it be allowed to apply sludge during
the period fimm May 1. to October 30 to areas of certain fields on the Richard Adams'
property 'which are located within the too-yany flood plain. Since the particular
waters which may be affected are classified as ,"WS-ll:t' , this request is denied.
1f any parts, requi;rcrmR ts, or lVit;aations contained in this permit are
r.nnccce[r1.able to you, you have the right to r.o".it.re:sL an adjudicatory hearing upon
c"+uAt:en request: within 30 days fo3lowLng receipt of this permit. 'T.'tri.r request must:
be in the farm of ai written far*ta1.i:on, conrortt Lng to Chapter 150B of North Arol inn
Gener.aal if,t.gttrrle,4w, and riled with the Office nF Adrir_lnjst.r aa!7n lie,alat irr s. Post Office
Drawerl1t"66, Rnlelgb, North,-Carolinn r"1"Cat'4. Unless such demands are made thispermit shall be final and binding.
P0,, cs,x 2 €,K , klak%,,hNorth Caroimi 27611 '6 1 Tc°lepho nc 9!9-7a.3-7015,
An j c1€r18 4'ppcar¢tFna` Adtir€iative Artiafr E:rnai10'CT

If ou 'need additional information ion concerning this matter, please con a at Mr.
Randy ones, telephone No. 91 /7 3- fl 3, ext. 541. �
Paul Wilms
CC! Rowan County Health Department.
"
Regional Supervisor
Mooresville.
R<
Utz. Charles ' D, Cass.

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
P E R M I T
For the discharge of Sewage, Industrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General Statutes
of North Garolina as amended, and other applicnble Laws, Rules, and Regulations
PERMISSION S. HEREBY GRANTED TO
Holly Forms Foods, Ina,
Rowan Co"nty
FOR THE
continued operation of a 425,000 g0lon capacity sludge holding lagoon (-,-o continue
operation in, accordance with the schedule specified in condition no, 41 below) And
Qe subsurface injection of sludge from the Harmony Rendering Plant to the lands
identified K condition in). 19 of this peniAt, pursuant "to the request received
)(ceaiber 11988, farad in conformity with the project plans, specifications� and
other supporting data subsequently f0ed and approved by the Department of Natural
Resources and Community Development and considered a part of this permit.
ThAs permit shall be effective, from the dote of issuance snit-i-I Juna 30, 1990,
shall void Permit NoWQ0000701, which was issued on December 1, 1.988, And shall he
subject to the following specified conditions and limitations:
1. This permit. is effective only with respect to the nature and voltune (of wastes
described in the tipplicntion and other supporting data,
L The ociliLies shall be properly maintained and operated at all times,
?. This permit is not transferable,
4. This permit shall become voidable in the evenL of failure of the soil t D
adequately absorb tha wastes and may be resAuxled unless the facilities are
installed, maintnined, and operatnd in a manner which will protect the Assigned
Wer quality standards of the surface wnLers and ground wntnrs.
5. In the nvnnt VhW tle facilil:ks fail to perform satisravorily, Winding uho
crention of nnisanco conditions, the PermLtten shall Unke suck immedj=
correctivo Mien As may be rerl"ired by this Division, including the cDnstructjou
of additionzil or repIncement wastewnter treatment or disposal facilities,
-I-

k'
6, Any monitoring deemed necessary by the Division of Environmental Management to
insure surface and ground nd water protection will be established and an acceptable
sampling reporting schedule shall be followed.
. The Per-muittee., at least six (fa) months prMior, to the expiration of this permit,
shalt r:eclrrest its eaat:ens.ioar. Upnn receipt of the request, the Commission will
review the Adequacy 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.
8, Adequate facilities shall be provided to prrevetat surface, runoff from carrying any
disposed or stored material into any surface waters,
9. The issuance of this "permit shall not relieve the permri.tt .e of the responsibility
for damages to surface or grrorunduttat:ez-s resulting from the- operat,ion of this
facility,
10, No hire of sludge other than that from the Holly ;.Farms Harmony facility or the
Wilkesboro facility shall be placed on the land application disposal site,
11, Adequate provisions shelf be taken to prevent Mitred erosion and surface runoff
from conveying pollutants from the sPw"e Application area onto the adjacent
property or into the surface e waters.
12, Sludge shall not be applied it inclement weather or until. 24 hours following ea
rr~ itrfr-a.11 avert ,o of 1/2-inch or greater i:'+`a 24 hours, Emergency 9.1ndge disposal:
measures shaat l be approved by the Division of Environmental Management.
13100-Moot buffer shall he maintained between the appropriate :tared owner's
property Line and any applied sludge.
14. 'lh- site shall be adequately 1.113Y to a soil 01 of 6.5 prior to sludge
application.
15. No crops for direct human consumption shall be raised an these sites for a period
of 18 months s following sludge application,
16. Maaxtmum slope for sludge application shall be 1811 for subsurface applications.
All Applications shall he by subsurface injection.
17. ltdel"nt e inspection, main&,atarrpan e, and cleaning shall be provided by the psrmit.tee.
to nsurre proper cremation r4f the s"bjeco facilities,
lR. Illis permit shall. become Voidable unless the agreement t)C t,S°.tr?en dolly Farms
Foods, ttrc:. naad Dr. Richard hdnms is in All t rcn and etfFec.t
eft. 'Ins permit allows the l.arml rappl is al. 47 of slabdg by s"bsr;tt'fr7cp injectLon, to
nppr'crxikrntc5 y 988 nacres of land (loss 4=u l nd that, is part of a lruufif r ;.c>tae or
ss li) mtod in Cho ltrfa--yeaur flood rl«.A in Iirwon County owned by llr. Richard
Adams,
;.?fr: n nny W.r n transfer K Oris s lancL i notice shall lute given to the new n wncur-
that gives lull details K tlaca- m aternIn applied or incusLpurasted at this site.
-2-

21,
Animals
should not be grazed on sludge applied land within a 30-day period
following the sludge applicationpplication sites that are to be used for
grazing
shall have fencing that will be used to prevent access during the 30-day,
periods
after each application.
22,
fli,ibllc
access to the land application sites shall be controlled during active
site use and for the 12-month period following the land application event.
23,
A copy
of the approved plans and specifications shall be maintained on file, by
the Permittee
for a minimum of five years Chem the date of issuance,
24.
Monitoring
wells shall be constructed and sampling schedules arranged as required
by the
Division of Environmental Management and in accordance with 15 NCAC 2C
0-10W
25,
Solids,
sludges, or other pollutants removed or resulting from the wastewater
storagefacilities
shelf be contained and disposed of in such. a manner as to
prevent
any contamination of the surface or groundwaters of the State.
26,
The following
buffers shall be maintained between any subsurface applied sludge:
n)
25 feet to drainageways;
b)
100 feet to property lines; and
c)
200 feet to residences.
27.
Holly Farms Foods, Inc. shall submit an annual summary of its sludge land
application
activities, regarding this permit, to the Mooresville Regional Office
by January
31 of each year, 'I'he summary, shall include, but not necessarily be
limited
to the followin,
a)
date sludge applied;
h)
field where sludge applied;
c)
method of application;
d)
amount of sludge applied;
e)
crop(s) grown on field; and
Q
year-Lo-daLe totals in dry tons/acre, nutrient and metat loadings in
pounds per acre.
Note:
The report period shall be for the calendar year (January I - December 31)
and shalll be submitted no later than January 31 of the following calendar
year.
28.
No sludge shall be applied within 100 feet of nary well, with the exception of a
monitoring
well, or water Supply source.
29,
No sludge shn1l be applied to any area which is located within the 100-year flood
pinin
30.
Annn&
sludge npplicnLions WE not excend the f0lowing:
a)
PAN 200 lbs. per ncre,
h)
Phasplwte 90 lbs. per acrr
C)
POLISS ium 100 lbs. per acrra
d)
CIndmium 0.45 lbs. ppr acre
e)
Dry tons 9.4 dry tons per acre
Hydrnulic loadings (wet) 6188 gallons per acre
-3-

31,
The maximum cumulative loadings for metals shall
not: exceed the following:
r°a Cadmium 4.45 l hs
. per acre
b) Copper 25 lbs ,
per acre
c) Nickel 250 As.
Tay=,r acre
rl) Tend 1000 lbs,
per acre
33.
In the ev;eat. that the cumulative loadings
of metals exceed those limits
established in, c'ondiuttimi 31, the land c)amer
shall places the following 'statement
in the property deed. "Portions of this
property have received wastewater
t:reatmesit plant; sludge at high heavy metal
application rates. tare should b
taken when food chain crops are grown Aare* to
a possible health hazard.''
33,
Sla.dgc shall be applied in as manner that
will prevent runoff:, Tacraacl.laa ,, and
erosion,
V
The Perm_tt'ee shall submits an annual current
composite sludge analysis report to
the North Carolina Department of Natural Reaswmces and CC1P€tt7lr,mity Development,
Mooresville Regional Office (91.9 North Main
Street Mooresville, NC 28115). The
sludge ea analysis report shall contain at: least
the following:
Parameters
Units
aa, Solids
ll
h. Lead
llas/dry ton
c, Cadmium
lbs/eery ton
cl. Nickel
lbs/clry tcsra
V Copper
1.hs/dry ton
F Zinc
l.hs/pry ton
. Residual Chlorine
l.hs /ri y teal
h. P01 and 11
llas/dry ton
i. T
lbs/dry Lou
J . N11as ll
ltrs,ad y tonK
NO- + NO
lbs/dry ton
t. 0 and Grease
l.las/elty ton
In . T31£
s . TT .,
n. PGB
Plrar (dry weight)
�ttbe
None: The report rind shall hfor the calendarcalendaryear"
(January l " December 31)
and sha3 p4 be .�.'11:mit.t.>ed i'ao lKE'...r than
Ailliay 31 of the following C;a31..eil{1rar
3K
The c ner: a;1 the; land application AUK) K)
shall §"re; faarni.she.d with an annual
analysis of the sludge which has been applied d
to the sites.
36.
No s lAaa>" shall 1rra: applied to land aplal a c.at:
crn sites cW-=-r ea t }„r,, alep'.�8a to t.txe
sonsona 1 h [gh wWor table Ls lass Baran three
t:asW,
-4-

37 I'lter. f.i.ve (S) existing monitor wells shall be sampled every March, Judy and
November for the following parameters:
Nitrate pll
Total Ammonia TOC
TDS Chloride
Total Coliferrms Sulfate
Water Levels ;
The measurement of water level must be made prior to sampling for the remaining
parra meter b H
The results of the "sampling and analysis shall be sent to the C .C, Division of
Environmental Management' n Form Clad-59(Compliance Monitoring Report Fehr) every
April, August. and December.
38: The use of the existing lagoon by Holly Farms Foods, Inc. must cease by
January' 1, 1990,
39. Holly Forms Foods, Crr" nwst' submit as written status report to tire. Mooresville
Regional Office each month %rhi.rla indicates the progress toward eliminating the
existing lagoon.
40. By December 19, J988, Holly Farms Foods, Inc. .e will mako a decision on the
implementation of option J or option 7 as described in condition no. 41,
41. Depending upon t:Y lire-tread;srrent, option which is chosen, hotly Farms Foods,Inc
will comply with the schedulers detailed below for either Option 1 or Option
June 30, 1989 . , . . . . . . . Completion of Installation
al.lart.ion
September. 1, 1989 . . . . . . . . 1) No Sludge Production From
Wilkesboro Complex
2) Submit Plans for On -Site Storage of
DAF Sludge at Harmony Rendering
Plant
December. 30, 1989 Open Lagoon at Richard Adams Farm To
Be Emptied and Use as Storage To 0
Discontinued
Juno 1990 . . . Open Lagoon at Richard Adams Farm To
Be Filled I n acid Landsc:�it'pe To BE
Returned To Original State'

e a•
r
Q'`I"i T�1 l
' lk k�car Plant
January y 30, 198Y
Submit Construction uc:tio Plans For Enclosed
Storage "Tank To Be Located on Richard
Adams Farm
April Y, 1989
Begin Construction Of Storage "lank
After Receiving Approval From f1CDNR&CD ;
October 31 , 1989,
. ; , Complete Construction of Enclosed
Storage Tank
December 30, 1989
Open Lagoon K Richard Adams Form To
Be Emptied and Use As Storage To Be
Discontinued
June 30, 990 ` ;
Open Lagoon at Richard Adams Farm To
Be Filled I and Landscape To Be
Returned To Original Stater
Permit Issued this the 31s.t
dray of March, 1989,
NORTH CA OLINA ENVIRONMENTAL MANAGEMENT COMMISSION
j
; I
;
yr. �
R. Paul Wilms, Director
Division of Environmental Management.
By Authority of Lhe Fnvironmental Management Commission
Permit No. WQ000070-1
"
1
m6

B
State of North Carolinato l Department f Environment, Health and Natural Resources
Division l of Environmental Management
512 North Salisbury Street - Raleigh, Now Carolina 27611
James G. Martin, Gov raatlr R. Paul Wilms
►
William W. Cobey, Jr., Secretary tar
February 16, 1990
Frank Taracido, Chief Engineer
Holly Farms Foods, Inc.
P.O. Box 88
Wilkesboro, N.C.28697-0088
Subject: Permit No.WQ0000701
Illy Farms Foods, Inc..
Harmony Rendering Plant
Land Application of Sludge
Sludge Storage Tank
Rowan County
Dear Mr. T°acidt.
In accordance with your application received January 8, 1990 we are forwarding herewith
Permit No 1, dated February 1 , 1990 to Holly Farms Foods, Inc. for the subject
operation of a land application of shade program and the construction of a sludge storage tank.
This permit has been amended by deleting 'condition no. 13 in order to eliminate the discrepancy
between conditions no. 13 and 1 in the former permit
This p,ennit shall be effective from the date of issuance until June 30, 1990, shall
supersede Permit No. WQ0000701 issued February 5,,1990 and shall be subject to the following
specified conditions and limitations:
f any parts, requirements, or limitations contained in this Permit amendment are
unacceptable to you, you have the right to request an adjudicatory hearing upon written request
within 30 days following win receipt of this permit. Thisrequest 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. Box 11666, Raleigh, NC 27604. Unless such demands
are wade this permit shall be final and bind"
Pollulion Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 1 -733-7 1
An Equal Opportunity Affirmative Action Employer

If you need additionalinfomiation concerning this matter, please contact Babette McKernie at
1 ' 33- 0 3
i cerely,
GeorgeEverett
Rowan County Health Brat
Mooresville, Regional.'
Groundwater tic s

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 HEREEYE D TO
Holly Farms Foods, Inc.
Rowan County
FOR THE
continued operation of a sludge land application program consisting of a 520,000 gallon capacity
sludge holding lagoon (to continue operation in accordance with the schedule specified in
condition no. V1 IS) and the subsurface injection of sludge from the Harmony Foods Rendering
Plant to sites identified in condition no.VI 6 of this permit with no discharge of wastes to the
surface waters, pursuant to the application received January 8, 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 June 30, 1990, shall supersede
Permit No. WQ0000701 issued February 5, 1990 and shall be subject to the following specified
conditions and limitations:
1. P—E QRMANCE STAMARDS
I . 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 gioundwaters 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 Peonittee 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.
1

1. The facilities and disposal sites shall be properly maintained and operated at all
tires.
suitable vegetative cover as listed in condition 11 3, shall be maintained in
accordance with the crop management plan approved by this Division.

3,. The annual application rates shall not exceed the following:
a) AN 200 lbs./acre
b) Phosphate 50 1 bs./acre
c) Potassium 100 1 bs./acre
d) Cadmium 0.45 lbs./acre
e) Dry Tons of Sludge 9.4 lbs./acre
f) Hydraulic loading (wet) 6788 gallons/acre
4, No sludges other than the following are hereby approved for land application in
accordance with this permit:
So= C2un_ty
Holly Farms, Foods, Inc. Rowan
5. The lifetime heavy metal loadings shall not exceed the following for the
corresponding Cation Exchange Capacities (CEO),
RUM= CEC_<_5_
Lead (lbs/acre) 500
Zinc (Ibs/acre) 250
Copper Obs/acre) 125
Nickel (lbs/acre) 125
Cadmium (lbs/acre) 4.5
6. Adequate facilities shall be provided to prevent surface runoff from carrying any
disposed or stored material into any surface waters.
7 Animals should 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.
S. Surface applied sludge will be plowed or disced within twenty-four (24) hours
after application on lands with no cover crop established.
9 For areas that are prone to flooding or within the 100-year flood elevation, sludge
may be applied during periods of dry weather. The sludge must be incorporated
into the soil within twenty-four (24) hours of application.
10. 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 sludge application.
(Such controls may include the posting of signs indicating the activities being
conducted at each site.
11. 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.
12. 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.
3

13. 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
sufficient amount of lime is also applied to achieve a final pH of the lime, sludge and
soil mixture of at least -6. >
llla MONITORING AND REPQ&
l.. Any monitoring (including groundwater, surface water„ sludge, sail, 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 Di8sion, reduction of monitoring requirements may be
pursued after two annual reporting periods.
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 elate of sludge application.
cl location of sludge application (site, field, or zone ##
dl method of application
e weather conditions
f sail conditions
e of crop growing on field
hl volume of sludge applied in gallons/acre and dry tons/acre
it annual and cumulative totals of dry tons acre of sludge, annual and
cumulative pounds/acre of each heavy metal, annual pounds/acre of plant
available nitrogen (PAN), and annual pounds/acre of phosphorus applied
to each field:
;. A representative annual soils analysis shall be conducted of each site receiving
sludge in the respective calendar year and the results maintained on dale 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 Manganese
a Base Saturation Cation Exchange Capacity
Phosphorus Sodium
Potassium Nickel
Lead Cadmium
Zinc Copper
Magnesium Calcium
p

4. A complete sludge analysis and EP Toxicity analysis shall be conducted by the
lie Ott quarterly and annually, respectively and the results maintained on file by
the Permittee fora tninimum of five years. If land application occurs at a frequency
less than, quarterly, sludge analysis will be required for each instance oftand
application. The sludge analysis shall include but is not necessarily limited to the
following parameters:
% total solids Magnesium
Total Nitrogen Sulfate
Phosphorus Potassium
Lead Zinc
Copper Nickel
Cadmium Chromium
Sodium Calcium
Chlorides
Plant Available Nitrogen (by calculation)
pH
The Eli Toxicity analysis shall include the following parameters:
Arsenic Barium
Cadmium Chromium
Lead Mercury
Selenium Silver
Endrin Lindane
Methosychlor Toxaphene
2,4-1 ,4,5 -TP Silvex
5Two copies of all monitoring and reporting requirements asspecified in conditions
1111, 1112,1113 and 1114 shall be submitted annually on or, before January 31 of
the following year to the following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 27687
Raleigh, NC,27611-7687
6. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office
telephone no.[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 discharge of
wastes to receiving waters,
5

C. Any time that self -monitoring information indicates that the facility has
gone out of compliance with the conditions and limitations of this pen -nit
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 thin 15 days following first knowledge of the occurrence. This report
test outline the actions taken or proposed to`be taken to ensure that the problem
does not recur.
GROUNDWATER l EME
1, Any groundwater quality monitoring as deemed necessary by the Division o
Environmental Managemen shall be provided.
2. No land application of waste activities shall be undertakenwhen the seasonal high
water table is less than three feet below land surface.
The five existing monitor wells must be sampled every March July, and
November for the following parameters:
Nitrate plI
Total Ammonia TOC
TDS Chloride
Total Coliforms Sulfate
Water Uvels
The measurement of water level shut be made prior to sampling for the remaining
parameters.
The results of the sampling and analysis shall be sent to the N.C. Division of
Environmental`Management on for -(Compliance Monitoring Report
E every April, August and December.
MEE-C1119M
i
1 The Eer `tree or his designee shall inspect the stud
disposal' facilities to prevent malfunctions and deterior
discharges which may cause or lead to the release of w
threat to human health, or nuisance. The Eermittee s
or summary including at lust the date and time o insp
and any; maintenance, repairs, or corrective actions tk
anv. nmental Management or ether pe i,
ge storage, transport, and
ation, operator errors and
rites to the environment, a
hall keep inspection log
ection, observations made,
en' by the Permittee. This
for a period of three years
fable upon request by the
g authority.

.
Any duly authorized officer, employee, or representative of the Division of
Environmental ana ement 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 roust be kept under the terms and
condition's of this permit; or may obtain samples of groundwater, surface water,
or leachate®
VL QENERAL C
l r
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.
o
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 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. Ibe approval of this request will be considered
on its merits and may or may not be approved.
"or 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.
.
This permit shall become voidable unless the agreements .between the Permittee
and the landowners/lessees are in full force and effect.
e following are approved sates and crops for sludge application (see attached
map):
QMA"d&= ApRfip'r in 1 ing—buffLral
lDr. Richard Adams 988
7-.
Failure to abide by the conditions and limitations contained to this permit may
subject the Permittee to an enforcement action by the Division of Environmental
General Statute l
.
Management in accordance with North Carolina - .6.
The annual administering and compliance fee must be paid by the Permittee within
thirty (30) days after berm 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.0205e r
9.
The issuance of this permit does not preclude the Pennittee 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 most be retained by the applicant
for the life of the project,

11. The Permittee, at least six () 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.
12. This permit may be modified,or revoked d reissued to incorporate any conditions,
limitations d monitoring requirements the Division or Environmental Management
deems necessary in order to adequately protect the environment and public health.
13, holly Farms Foods, Inc. must submit a written stags report to the Mooresville
Regional Office each month which indicates the progress toward eliminating the
existing lagoon.
14. Holly Farms Foods, Inc. will comply with the schedule detailed. below:
D LQgll; at Will esboro lent'
January 30, lg ' .....„.A................,..Submit construction plans for enclosed,
storage tank to be located on Richard
Adams Farm
.April 30, 1989 ............ ............... -Begin construction of storage tank after
receiving approval from NCEHNR
April 15 1 .............................Complete ; construction of enclosed storage
tank
.April 15 1 ............................,...Open lagoon at Richard Adams Farm to be
emptied and use as storage discontinued.
June 30, 1 t(1...............................Open lagoon at Richard Adams Farm to be
filled in and landscape to be returned to
original state
15 Upon completion of construction ad prior to operation of this permitted facility, a
certification must be: received from a professional engineer certifying that the
permitted facility has been installed in accordance ce with this permit, the approved
plans and specifications. Mail the certification to the Permits and Engineering Unit,
P.O. Foal' 7687, Raleigh, NC 27611-27687.
Permit issued this the 1 th day of February, 1990
. A
aFaggement
MANAGE COMMISSION
George Everett, r
nrDivision of Enviroell By Authority of the Environmental ag ment Commission
Permit N. WQ0000701

Permit No. WQ0000701
February 16, 1990
I, , as a duly registered Professional Engineer in the State of North
Carolina, ha e authorized to observe (periodically,
i call weekly, full time) the construction of the
project, I for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of the approved plans d specifications.
Signature Registration No.
Date

fi
RECEIVED
.10 Ir
"Oof"WILM I State of North Carolina
"ftment of R tvirot meat Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street -' Raleigh, North Carolina 27611
James did Martin, Govemor R. Paul Wilms
William W. C.ctbcy, Jr., Secretary Director
ector
February 5 , 1990
Ir. . Frank 'l°ara ido, Chief Engineer
Hilly Farrrrs Foods, Inc.
P.C. lox S
Subject: Permit No,WQ000 701
Holly Farnis Foods, Inc.
Harmony Rendering Plant
Land Application of Sludge
Sludge Storage Tank
Roan County
Dear Mr. Taracido:
lee accordance with your application received January S, 1990 % e'are forwarding herewith
Peitnit No. 1 `{;$?Cl0007 1, dated February 5 , 1990 to Dolly F'rimis Foods, Inc. for the subject
operation of a land application of sludge prograrn and the construction of a sludge storey: tank.
This permit shall be effective from the date of issuance until June 30, 1990, shall
supersede Permit No. WQ0000701 issued September 12, 1989 and shall be subject to the
following specified conditions and limitations:
1f any parts, requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request all adjudicatory hearing upon written request within 30 days
following receipt of this permit. This request tritest be in the forra of a written petition,
conforming to Chapter l t R of North Carolina General ,Matures, and filed rill) the Office of
Administrative Hearings, P.O. Pox 11666, Raleigh, NC 27604. Unless such demands are made
this permit shall be final and binding.
Pollution Prevention Pays
P.O.Box 27' 87 � _ e 9-7 3-7o1 i Raleigh, h i��eth Carolina 27Ea11 7�7 Telephone tsrt� 1. 3
An Equal Opportunity Affimiative Action Employer

If you need additional information conceming this matter, please contact Babette McKemie at
91 733-5083,
Sinc:re,ly,,
George Everet
cc : R,o an County l l alth Department
Mooresville Regional Office
Groundwater Section

NORTH CAROLIi A
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTINIENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SLUDGE LAND APPLICATION PERMIT
In a�: rdance with the provisions of Article 21 of Chapter 143, General Statutes of € orth
Carolina a�s ',.Mended, and rather applicable Laws, Mules, and Regulations
PERMISSION IS HERFBY'GRANTED TO
Tally Farms Foods, Inc.
Rowan County
ty
FORTHE
continued o ration of a sludge land application program consisting of a 520,000 gallon capacity
sludge hol'.'Ira lagoon (to continue operation in accordance with the schedule specified in
condition no. VI 15) and the subsurface ni ction of sludge from h Harmony Foods Rendering
Plant to sits s identified in condition no.VI a of this permit with no discharge of wastes to the
1. PERFORNIANCESIANDARD$
1 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 progam 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 constructican of
additional or replacement wastewater treatment or disposal facilities.

craps for direct human; consumption n shall be raised can these sites for a period
f 18 months following sludge application,
fir:
Maximum shape for sludge application shall be 0% for surface application and
1 % for subsurface applications,
7..
The following buffers zones shall be maintain
a) 400 feet from residences under separate ownership for surface
application method,
b) 200 feet from residences under separate ownership for injection method,
c 100 feet from '° A and "° classified waters and public surface: water
supplies for both methods,
d 0 feet from " " classified waters and other streams, creels, lakes,
ravers, and surface water drainage ways for injection method.
e 100 feet from " WS" classified waters and other streams, creels, lakes,
rivers and surface water drainage ways for surface application
methc4
f 100 feet from property lines for both methods,
g) 50 feet from public right of ways for surface application method,
h 10 feet from upslope interceptor drains and surface water diversions for
both methods,
i feet from downslope interceptor drains, surface water diversions,
groundwater drainage systems and: surface drainage ditches for both
methods.
A copy of this permit shall bs:, kept in all sludge transport and application. vehicles
during the life of this project,
9.
All sludges included in this permit must be stabilized by a process to significantly
reduce pathogens (as described in 40 CFRfart 257, ;Appendix 11) prior to
application or incorporation. An evaluation of all sludges as specified in condition
11 4 must be conducted as to their ability to demonstrate compliance with this
requirement. A copy of this report mist be submitted to the Assistant Chief for
Operations, Division of Environmental Management, Water Quality Section,
Operations Branch,PO Box 27687, Raleigh, NC 27611-76871, within six (u
months of the permit issue date.
10.
Specific sludge application area boundaries shall be dearly marked on each site prior
to and during sludge, application.
11.
No sludge at any time shall be stored at any application site.
11 OPERATION AND MAINTENANCE ICE
1;
The facilities and disposal sites shall be properly maintained and operated at all
times. ;
>;
A suitable vegetative cover as listed in condition 11 3, :shall be maintained in
a
accordance with the crop management plan approved by this Division.
2

3.
Th- annual application rates shall not exceed the following:
a) PAN 200 lbs./acre
b) Phosphate 50 lbs./acre
c) Potassium 100 lbs./acre
d) Cadninarr 0.45 lbs./acre
e) Dry Tons of Sludge 9.4 lbs./acre
f) Hydraulic loading (wet) 6788 gallons/acre
4
No sludges other than the following are hereby approved for land application in
ac,:,,rdance with this perrrrit:
&,_M�l C=11-tY
Holly Pa is Foods, Inc. Rowan
5
T'- .- lifetime heavy metal loadings shall not exceed the following for the
co: -7esponding Cation Exchange Capacities (CEQ:
P,_--.-.meter CEC: <
L,e,---d Obs/acre) 500
Zi:-'- Obs/acre) 250
Co -per (lbs/acre) 125
N,,-kel (Ibs/acre) 125
C-:,_-'1mium (lbs/acre) 4.5
6
,".-qtiate facilities shall be provided to prevent surface rcnoff front carrying any
di�:.osed or stored material into any surface waters.
7
Ar,-mals should -not be grazed on sludge applied land within a 0-day period
fo'._'owing the sludge application. Application sites that are to be used for gTazing
sh,all have fencing that will be used to prevent access after each application.
8
SL:-r-ace applied sludge will be plowed or disced within twenty-four (24) hours
after application on lands with no cover crop established,
9,
Fc,- areas that are prone to flooding or within the 100-year flood elevation, sludge
May be applied during periods of dry weather. The sludge must be incorporated
into the soil within twenty-four (24) hours of application.
10,
Appropriate measures use be taken to control public access to the land application
silts during active site use and for the 12-month period following sludge application.
(SBch controls may include the posting of signs indicating the activities being
co :ducted at each site.)
11,
Aczquate provisions shall be taken to prevent wind erosion and surface runoff
fro-n conveying pollutants from the sludge application area onto the adjacent
property or into the surface waters.
12,
Sledge shall not be applied in inclement weather or until 24 hours following a
ra.'Mifall 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,
3

13, 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 lirne, sludge and
soil mixture, of at least 6.5,
NI ONELQYIN � Q ,A 2REEQE�jfNG -RF - — OUJRFM
1, Any nionitorinIg (including groundwater, surface water, sludge, soil, or plant
tissue analyses) deemed necessary by the Division of Environniental 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 coricern to the Division, reduction of monitoring requirements may be
pursued after two annual reporting periods,
roper 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
a) location of sludge application (site, field, or zone #)
d) method of application
e) weather conditions
f) soil conditions
g) type of crop growing on field
h) volume of sludge applied in gallons/acre and dry tons/acre
it ainnual and cumulative totals of dry tons/acre of sludge, annual and
cumulative pounds/acre of each heavy metal, annual pounds/acre of plant
available nitrogen (PAN), and annual pounds/acre of phosphorus applied
to each field.
3, 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
Pen-nittee for a minimum of five years. The soils analysis shall include but is not
necessarily limited to the following parameters:
Standard Soil Fertility Test Manganese
% Base Saturation Cation Exchange Capacity
Phosphorus Sodium
Potassium Nickel
Lead Cadmium
Zinc Copper
Magnesium Calcium
pH
4

4, A complete Sludge analysis and EP Toxicity analysis shall be conducted by the
lie sittee quarterly and annually, respectively and the results maintained can file by
the Peranittee 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:
% Natal solids Magnesium
Total Nitrogen Sulfate
Phosphorus Potassium
ad Zinc
Capper Nickel
Cadmium Chromium
Sodium Calcium
Chlorides
Plant ,available Nitrogen by calculation)
a
The EP Toxicity analysis shall include the followingparameters: -
Arsenic Barium
Cadmium Clara urn
Lead Mercury
Selenium Silver
Endrin Lindane
ethoxychlor Toxaphene
2,4-D 2,4,5-` P Silvex
5. Two copies of all monitoring and reporting re uiren ents'tas sp c;i ied in conditions
Ill 1, 1,112,1113 and Ill 4 shall be submitted annually on or before January 31 of
the following year to the following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Bra+ 27687
Raleigh, NC 27611-7687
Noncompliance 'Notif cation -
The Perrnittee shill report by telephone to the Mooresville resville Regional Office
telephone no.t704 663-1699, as soon as possible,taut in no case more than 24
hours or on the next working day following the occurrence or first knowledge e 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 tabn rrnal in
quantity or characteristicm
b, Any failure of the land application program resulting in a discharge of
wastes to receiving waters.
5

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.
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. Il ;14`."I"Ic l llliP
1 Any groundwater duality monitoring as deemed necessary by the Division of
nvir�nmental Management shall be provided.
. No laid application of waste activities shall be undertaken when the seasonal high
water table is less than three feet below land surface.
. The five ) existing monitorwells`- must be sampled every March, July, and
November for the following parameters:
Nitrate pal
Total.Anunonia T C
TDS Chloride
Total Colifo is Sulfate
Water Levels
The measurement of water level must be made prior to sampling for the remaining
parameters.
The results of the sampling and analysis shall be sent to the N.C.division of
Environmental Management on For W- (Compliance Monitoring Report
Form) every April, august and December.
V. l�II Tl(
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 deep 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 Pe ' ittee for a period of three years
from the date of the inspection and shall be made available upon.re nest by the
Division of Environmental Management or other permitting auth fit ,
6

,
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 thispermit; or may obtain samples of groundwater, surface water,
or leachate.
VI, GENERAL Ott 1T'lt l
l .
This permit shall becomevoidable unless the land application activities are carried
out in accordance with the conditions of this permit 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 transferable, 1n 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 ement accompanied by an
application fee, documentation from the parties involved, and other supporting
materials as may be appropriate. "l he 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.
.
This permit shall become voidable sinless the agreements between the Pe niittee
and the landowners/lessees are in full force and effect.
d,
The following are approved sites and crops for sludge; application (see attached
map):
�t o weer ,,ea5, ADolication Area trncludin buffers
Lagcresl
1 Dr. Richard Adams 988
7.
Failure to abide by the conditions and limitations contained in this permit may
subject the Perutittee to an enforcement action by the Division of Environmental
Management in accordance with North Carolina General Statute 14 - 1 .6,
,
The annual administering and compliance fee must be paid by the Pe.r nittee within
thirty (0) 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 211,0205tc)(4).
9.
The issuance of this permit dries 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 project.
7

r
I t The P rnaitte , 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 uac of the facilities described therein and if warranted will extend the
per- it for such period of time and under such conditions and limitations as it may
deem appropriate.
11 This permit may be'modified, or revoked arid reissued to inc iWrate any conditions
limitations and monitoring requirements the Division of Environmental Mara earieni
deems necessary in order to adequately protect the environment and public health.
11 The use of the existing lagoon by Holly Fariaas Foods, Inc. must cease by January
31, 1990.
14, holly Farnis Foods, Inc. must submit a written status report to the Mooresville
Regional Office each month which indicates the progress toward eliminating the
existing lagoon.
15. Holly Farms Foods, Inc. will comply with the schedule detailed below
Drip "eil bat 'ilkesloart Plant
January 30, 1 . ... —.............,—Submit construction plans for enclosed
storage tank to be located can Richard
Adams Farm
April 30, 1 ......... ............ .......... I in construction of storage tank after
receiving approval from EI- NR
April 15, 1990—..... ---....—Complete construction of enclosed storage
tank
April 15, 1,990 ............ ..........<.,.. pen lagoon at Richard Adam �arrn to be
emptied and use as storage di contiaiced.
June 30, 1990- ..........:.. ..Open lagoon at Richard AdanaAdanis Tura to be
filled in and landscape to be returned to
original state
lo. Upon completion of construction and prior to operation of this permitted facility, ai,
certification must be, received from a professional engineer certifying that the
permitted facility has been installed in accordance with this permit, the approved
Mans and specifications. Mail the certification to the Permits and Engineering Unit,
P,O. Box 27687, Raleigh, NC 27611-2768T
Permit issued this the 5th day of February, 1990
NORTH A ROLIN - eIR E ',AL MANAGEMENT COMMISSION
ION
E
George Everett, t
Division of Environ ` mea t
��,,�' y A.athorit of than EnManagement Commission
Permit No. WQ00 0701
8

permit No. WQ0000701
Ent yiaeef LCertifiicat n
as a duly registered Professional Engineer in the ,State f North
Carolina, having been authorized to observe (periodically, weekly, fall tithe) the construction of the
project, � _._ for the
Project Name Lw7cation
P rtnitt e hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was obs nets to be built within substantial
compliance and intent of the approved plans and spc fications.
Signature Registration No.
Date
I
9

pr C, / , 4,
� z
a
to
yw
X, State of North Carolina
Department of NaturalResources s lid Community Development
Division of Environmental Management
512 North Salisbury Street 0 Raleigh, North i arol na 27611
.,lames G. Martin, Governor'
William W,, tr ey, ,Jr.,, Secretary
Mr. Frank T'aaraci.do, Chief Engineer
Rielly Forms Frauds, Inc,
PO ilnx 88
September 1:2, 198
1 . Paul Wilms
Director
Wilkesboro, N" 28691-C1U8 ' ,
SUBJECT: T: Permit No0000701
Holly Farms Foods, Inc.
ai
Harmony Rendering Plant
wr,
Land Application of,, ud
Sludge Storage Tank g ° .
Rt wan County
Dear Mr. Taraci.do .
In accordance with the request received July 3, 1989, we are forwarding
h-er°ewith Permit. No. WQ000070 , dated September 1.2, 1989, to Holly Farms Foods
Inc. for the operation of the subject: sludge land application facilities and the
construction and operation - of the subject shade storage Lank..
"flats permitt shalt be effective from the date of issuance taaa& I June 30, 1990,
shall supersede ,Permit: No, WQ0000701, which was issued on March 31, 1989, and shall
be subject to the conditions and limitations as specified therein. This permit
modification includes: the construction and operation of a 520,000 gallon sludge
storage tank and the ceasing of operation of the 425,000 gallon sludge holding
lagoon at the Richard edam's Farmb
s stated in correspondence previously received. from Holly Farms Foods, Inc.,
the request to have sludge lard application sites (Bryant Church property) permitted
in Wilkes County and to construct a sludge holding lagoon can these properties has
been withdrawn. Additionally, Holly Farms Foods, Inc, has also previously withdrawn
its regaaest to construct aa; new sludge holding la cao can the Richard Adams' property
in Rowan County and has now stated That it will discontinue using the 425,000 gallon
lagoon n the Richard' Adams' property.
s stated ;in the Director's letter of March 31,' 1989, Holly Farms leads Inc.
is not allowed to apply sludge daring the period from May 1 to October 30 to areas
of certain +fields on the Richard Adams' property which are located within the
100-year flood plain since: the particular waters which may be affected are
classified as " S-111."
PO. Box 27687., Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

If any parts, requirements, or limitations contained in this permit are
naCCeptable to you, you have the right to request an adjudicatory try 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 Chanter 150B of North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 11666, Raleigh, North Carolina 21604, Unless such demands are made this
permit shall be final; and binding.
One set of approved plans for a new sludge storage tank is enclosed. If you
need additional information concerning this master, please contact Mr. Randy Jones,
telephone No, 919/788-508 ,
l , Paul. Wilms
cc: Rowan County Health Department
Mooresville Regional Supervisor
Groundwater Section

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMTSSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIG11
P E RMI T
For the discharge of Sewage, Industrial. Wast.es, or Other Wastes
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
Holly Farms Foods, Inc.
Rowan County
FOR THE
construction and operation of a 520,000 gallon sludge storage tank, with all
appurtenances, tos be located at the Harmony Rendering Plant and the subSUrfiqrp
injection of sludge from the Harmony Rendering plant to the, lands identified in
condition no, 19 of this permit, pursuant to the request received July 3, 1989, and
in conformity with. thp`�' project plans, specificat-ii.ons, and other supporting data
subsequently filed and approved by the Department of Natural Resources and Community
Development and considered a part, of this permit®
This permit shall be effective from the date of issuance until, Julie 30, 1990,
shall supersede Permit No. WQ0000701, which was issued on March 31, 1989, and shall,
be subject to the following specified conditions and limitations:
t, This permit is effective only with respect to 'the nature and volume of wastes
described in the application and other supporting data,
2. The facilities shall be properly maintained and operated at all times.
3. This permit is not transferable.
4. This permit shall become voidable in the event: of failure of the soil to
adequately absorb the wastes and may be rescinded unless the facilities are
installed, maintained, end operated in a manner which will protect the assigned
water quality standards of the surface waters and ground waters.
5, In the event that the facilities fail. to perform satisfactorily, including the
creation of nuisance conditions, the Permittee shall take such immediate
corrective action as may be required by this Division, including the construction
of additional or replacement wastewater treatment or disposal facilities,
-I-

OF
fa. Any monitoring deemed necessary by the Division of Environmental Management to
insures surface and ground water protection will be established and an acceptable
sampling reporting schedule shall be followed.
The Permi tee, at least six; (fa) months prior to the expiration caC this permit,
shall request its extension. Upon receipt of tho 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,
fi. Adequate facilities shall be provided to prevent ;surface runoff from carrying any
disposed or stored material into any surface waters.
The issuance of this permits shall not relieve the Pera i ttee of the responsibility
for damages to surface or groundwaters resulting from the operation of this
facility,
10 No type of: sludge other than that From they Holly Farms harmony facility or the
Wilkesboro fac-i_lity shall be placed on the land application disposal site:
11 Adequate provisions shad1, be taken to pre onL wind erosion and surface runoff
from conveying pollutants from the sludge application area Diets the adjacent
property or into than surface waters.
12. Sludge shall not be applied in inclement weather or sated l 24 hours following d
rainfall events of 1/2-inch or greater in 24 hours. Emergency ;Mudge disposal,
e;. measures shall be approved by the Division of Environmental Management,
13, A 1€ 0-foot buffer shall be, maintained between the appropriate land owner's
property line and any applied sludge,
10 The site shall be adequately limed to a soil p1l of 6.5 prior to sludge
application.
1.5. No craps for direct human consumption shall be raised on these sites for A period
of 18 months following sludge application.
1V Maximum slope: for shade application shall. be 1 % for subsurface applications.
All ;applications shall be by subsurface* injection.
17. Adequate inspection, maintenance, and cl,eani.ng shall be provided by the Permi.ttee
to unsure proper operation of the subject facilities.
18 : This permit shall become voidable unless the agreement between - Holly' Farms
Foods, Inc. and pr.Richard Adams is in full frame: and effect.
19. This permit allows the.land application of sludge, by subsurface injection, to
approximately ,988 acmes ,of land Tess the land that is part of a buffer zone or
is located in the 100--year flood plain) in Rowan County owned by Dr. Richard
Adams
0. In Any future transfer of this ], a.nd, a notice shall be given to the new owner
that gives full details of the materials applied or incorporated at this site.

21, Animals should not be grazed on sludge applied ied 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 during the 30-clay
periods after each application. ,
, Public access to the land application sites shall. be controlled during active
site use and for the l -month period following they land application event.
3. A copy of the approved plans and specifications c:at.ions shall be maintained oil, file by
the Permi:ttee:for the life e of the :l
rro ect
_i
20 Monitoring wells shall_ be constructed and sampling schedules arranged as required
by the Division of Environmental Management and in accordance with 15 MCC 2C
W100.
25. Solids, sludges, or other pollutants removed or resulting from the wastewater
storage facilities shall be contained and disposed of in such a manner as 'to
prevent: any contamination of the surface or groundwaters of ;the State.
2 x; The, following buffers shall be maintained between any subsurface applied sludge:
€l) 25 feet to draina ewaya;
b) 100 feet to property lines} and
c) 200 feet to residences.
27. Holly Farms Foods, Inc. shall submit an annual summary of its sludge land
application activities, 'regarding this permit:, to the Mooresville Regional Office
by January 31 of each ytear. "I"Ire summary shall. include, but not negessarily be
limited to the following:
aa) date sludge applied;
b) field where sludge applied;'
c) method of application;
d) amount of sludge aappl.ied,
e) craps), grower on field; and
Q year-to-date totals in dry tons/acre, nutrient and metal loadings in
pounds per acre.
Note: The report period shall be for the calendar yeaa.r. January 1 - December 1)
and shall be submitted no later than January 31 of the following calendar
year.
28. No sludge shall be applied within 100 feet of any well, with the exception of a
monitoring well, or water supply source.
2 . No sludge shall be applied to any area which is located within the 100-year flood
plain.
30.: Annual sludge applications shall not exceed the following:
aa) PAN 200 lbs, per acre
b, Phosphate 50 lbs. per acre
c) Potassium 100 lbs, per acre
d) Cadmium 0.45 lbs. per acre
e) Dry toffs 9,4 dry tons per acre
f') Hydraulic loadings (wet) 6788 gallons per acre

FFPPF'
51.
The maximum cumulative loadings for metals shall not exceed the following:
::
a) Cadmium 4.45 lbs.
per nacre
b Copper 250 lbs;
per acre
c) Nickel 250 As.
per acre
d..) Lse`ad. 1000 lbs.
per acre
W
7n the event that the cumulative loadings
of metals exceed those limits
established In condition 311 the land owner
shall place the following statement
in the property deed: "Portions of this
property have received wastewater
treatment plant sludge at high heavy metal
application rates, Care should be
taken when food chain crops are grown dace to a
possible health hazard.',
:3:3.
Sludge shall be applied in a manner that
will prevent runoff, pondin , and
erasion
W
The Perm ttee shall submit an annual current:
composite sludge analysis report to
the North Carolina Department of Natural, resources and Community Development,
Mooresville Regional Office (919 North Main Street, Mooresville, NC 28115), "flee:
sludge analyses report shall contain at least
the following:
Ara e ters
Units
a. Solids
%
K Veal
lb/dry tore
C. Cadmium
lb/dry ton
d Nickel
lb;s/dry ;ton
e. Copper
lb/dry tear
f Zinc
lbs/dry ton
a Residual: Chlorine
lbs/dry ton
K phi and P
Alas/dry 't on
i 10
lbs/dry ton
. N11 as N
bs/dry ton
k* NO + NO
lbs/dry gran
1. i and l reaase
lbs/dry tern
m. pl{
S. U.
n, PCB
ppm (dry eight)
Nate. The report period shall be for the calendar
year (,January_ l _ December 1
and shall be submitted no later t}rasa.. January
51 of the following calendar
year.
5.,
The owner of the bandapplication site(s)
shall be furnished with are: annual
analysis of the sludge which has been applied
to the sites.
.
No sludge~ sba,rll be applied to land application sites where the depth to the
seasonal high water table is less than three feet,
-4-

37.- The five (5) existing monitor wells shall be snmp:d(,,d every March, July an
November for the following parameters:
Nitrate pIl
Total Ammonia TO
TDS Chloride
Total Coliforms Saltate
Water Levels *
The measurement of water level must be made prior to sampling; for the remaining
parameters.
The results of the sampling and analysis dull be sent to the N.C. Division o
Environmental Management on Form -5 (Compliance Monitoring Report Form) every'
April, August and December.
38.. `I'her use of the existing lagoon by }lolly Farms Foods, Inc must cease by
January 1, 1990.
3Y Holly farms Foods, Inc. must submit a written status report to the Mooresville
Regional Office each month thigh indicates the progress toward eliminating, the
existing lagoon;
4li„ By December 19, 1988, Holly Farms Foods, Inc. will mad<e a decision on the
implementation of option I or option 2 as described in condition no. 41.
ro
4Y Depending upon they pre-treatment option which is chosen, Holly Farms Foods, Inc.
will comply with the schedules detailed below for either Option .1 or Option 2
OPTION I: ngtal1 tion of- PI Technology
June 30, 1989 . ,Completion of Installation
September I, 1989 1) No Sludge Production n from
Wilkesboro Complex
2 Submit flans for On -Site Storage of
DAF Sludge at Harmony Rendering
Plant
December 30, 1989 Open Lagoon at Richard dams Farm To
Be Emptied and Use as Storage To Be
Discontinued
June 30, 1990 s a ,a . Open Lagoon at Richard Adams .warm To
e Filled In, and Landscape To Be
Returned To Original State

OPTION 2; DAF Fell. at Wilkesboro Plant
January 30, 1989 . . . . . . . u Submit Construction Plans For
Enclosed Storage Tank To Be Located
on. Richard Adams -Farm
April 30 1989, Begin Construction Of Storage Tank
After. Receiving Approval From
October 31, 1 8 . . . Complete Construction of Enclosed
Storage dank
December 30, 1989 Open Lagoon at Richard Adams fare
To Bemp' ied and Use As Storage
To Be Discontinued
June 30, 1.990 . . . , . Open Lagoon .;at Richard Adams Farm
To Be filled In and Landscape To Be
Returned "T'o'Original State
2. Upon completion of construction and prior to operation of this permitted
facility, a certification must be received from a professional engineer
certifying that the permitted facility has been installed its accordance with the
approved plans and specifications.
Permit Issued this the 12th day of September, 1989.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
/X
R�au3. Wilms, Director
Division of Environmental Mana n
By Authority of the En.vi.ronmen al Management Commission
Permit No, WQ0000701
-

ENGINEER'S CERTIFICATION
I,
_ ) as a duly registered
Professional
Engineer in the State
of North
Carolina, having been authorized
to observe
(periodically/weekly/full
time) the construction of the project,
for the
(Project)
(Names or location)
hereby state; that, to the best of
ray
(Project Owner)
abilities, slue care and
diligence
was used in the observation of
the project
construction such that the
construction
was observed to be built within
substantial
compliance and intent of the
approved
plans and specifications,
Signature _
�
,dn Registration No.
Date
Permit No. WC Clt 00701;
September 12, 198
,nM

DIVISION N OF ENVIRONMENTAL A EMEN
October 27, 188
MEMORANDUM TO ArthurM ruberr _ :..
f
FROM E. Rex leason.-.�-
PREPARED BY: J . Thurman Horne
SUBJECT: Holly Farms, Inc. Harmony Rendering Plant
Sludge Land Application Permit Renewal
APN 011350
Rowan .'County, North Carolina
This memo is a supplement to our Staff Report and
Recommendations sent to you dated September 28, 1988. This
office has reviewed the letter from Mr. David Taylor to you
dated October 20, 1988 and letter from Mr. Taylor to Thu.rman.
Horne dated October 21, 1988 with a map delineating the flood
plain boundary (copy attached)
The schedule which Holly Farms proposes to eliminate the
use of the existing storage lagoon is acceptable. Considering'
the past history of our dealings with this matter, it is o
utmost importancethatwe tame every precaution: to insure that
the Permit includes all the commitments which Holly Farms has
made to eliminate the lagoon. Toward this end, we suggest that
the Permit contain the following:
a. A condition which includes the schedule provided by
Holly Farms to pursue alternatives and to ultimately
eliminate e the existing lagoon.
. A condition which specical.y states that the use o
the existing lagoon must cease by no later than
January 1, 1990.
c . A condition that Holly Farms must submit a monthly
status report to the Mooresville ' Regional office
indicating their progress towards eliminating the
lagoon.

■
pppp-
Arthur Mouberry
Page Two
October 27, 198
d. The Permit should expire on June 1, 1999 (car there
about)
The map delineating the "estimated" location of the
19-year fled plain appears reasonable and acceptable. Holly
Farms has requested that .they be allowed to apply sludge on
those areas within the flood plain, during the period of May I to
October 30. Although this has ;been allowed in other permits
where the ;sludge is applied by subsurface injection, e
recommend that this; request be denied since the affected waters
are Class` S-III watery
It should be noted that Holly Farms has revised the
boundaries of the application fields since our Staff, Report and
Recommendationswas sent on September 28, 1988. 'these revised
boundaries are indicated on the attached map submitted October
21, 1988. Due, to these revisions,� the total land area available
for sludge application is 988 acre (existing fields plus
proposed new fields
n conclusion, the information submitted appears to be
acceptable, but there is one remaining issue which should be
resolved., Holly Farms ` should indicate in writing that they are
withdrawing their request to construct ra new lagoon on Dr.
Adams' property In Rowan County. This was indicated during our
October 19 meeting, but it needs to be put in writing before we,
can feel it is „safe' to renew' the Permit. Again, we believe
these precautions are necessary due to the past history of
permit negotiations.
When this matter has been resolved, we recommend that the
Permit be drafted, sent to the Mooresville Regional office for
review, and issued after our review
f you have any questions or need any additional
information, please advise.
"H: ae

r
peg IN
H
State of North C r lina
F.Division of Envirtaart°riental Managyrnent
517. North �aliiSbLIr-�' Street # Raleigh, North Carolina 27641
K �' . Psu Blears
JamesG. Martin,.�r�vr4r-rear March�i ;
William �� Cobey, Jr. ec`ret ry � � �' ` Director
t�cr�~
Mr. Frank Tarracido, Chief Engineer
Holly Farms foods, Inc.
PO Box 88
Wilkesboro, lkesboro, tl dfa 7-0088
SUBJECT: Permit No. WQ00Y01
Holly Farms >Foods,1111 . ,a, ary eta :wum
Harmony RenderingPlant
Land Application of Sludge
Sludge Holding Lagoon
Rowan County
Dear Mr. `1`rar°racidcr.
In s. c oxdance with the rddrrest received December :30, 1988, we are forwarding
herewith Permit, 'a No. WQ0000701, dated March 31, 1989, to Holly Farms Foods, Inc.
for the operation of the subject shade lazed application facilities.
This permit shall be effective from the date of issuance until june 30, 1990,
hall void 'Permit No. WQ0000701, which was issued on December 1, 1988, and shall be
subject to the condition, and limitations as specified therein.
s stated in correspondence received ed from Holly Farms Foods, Inc,, the request
to Kea sludge Land application sites (Bryant Church property) permitted in Wilkes
County and to construct a sludge holding lagoon on these'properties has "1-aeerr
withdrawn. Additionally, Holly Farms Foods, Inc. has withdrawn its request to
construct a new sludge holding lagoon on the Richard Adams' property in :Moran County.
Holly Farms Foods, Inc. has requested that it be allowed to apply sludge during
the period from May 1 to October 30 to areas of certain fields on the Richard Adams'
property which are located within the 100-year flood plain. Since the particular
waters which may be affected are classified as s WS-III a this request is decried,
if any parts, requirements, or limitations contained in this permit are
unacceptable to you, you have the right to request an adjudac t:or-y 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 150D of Yorth Carolina
General Stntutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 11666, Raleigh, North Carolina 27604. Unless such demands are made this
permit: shall be final and binding,
N) Pox 276,97, Raleigh, Nearer Cxtartif na 611 7687 Telephone [phone]car 7
An Equal Opp�snunity ; fiirmataaac 7wrtoon Employer

If you geed additional information r-oncerning this matter, please contact Mr
RaDdy Jones, telephone No. l /733-50 3, ext. 54 .
Sincerely,
r
.M.. W r Paul Wilms �
cc: Rowan County Ifealth Department
Mooresville Regional Supervisor
Groundwater Section
Mr. Charles D. Case
R�:

NORTH CAROLINA
PF" ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NAIURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
P E R M I T
For the dischnrge of Sewage, Industrial Wastes, or Other Wastes
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
Holly Farms Foods, Inc.
Rowan County
Cl THE
continued operation of a 425,000 gallon capacity sludge holding lagoon (,to continue
ope4ation in accordance with, the schedule specified in condition no. 41 below) and
the sukurface injection of sludge from the Harmony Rendering Plant to th(-,s lands
identified in condition -no. 19 of this permit, pursuant to the request receivod
December 1, 1988, and & conformity with the project; plans, specifications, and
other supporting data subsequently filed and approved by the i�)epartment of Natural
Resources and Community Development and considered a part of this permit,
This p(.,-rmi,,t shall be effective from the, date of issuance until June 30, 1,990,
shall void Permit No. WQ0000701, which was issued on December 1, 1988, and shall be
subject to the following specified conditions and limitations:
1. This permit is effective only with respecL to the nature And volume of,` - qstes
described in the application and other supporting data.
2. The facilities shall be properly maintained and operated at all times.
3. This permit is not transferable.
4. This permit shall become voidable in the event of failure of the soil to
adequately absorb the wastes and may be rescinded unless the facilities are
installed, maintained, and operated bi as manner which will protect the, assigatad
water quality standards of the surface waters and ground waters,
5. In the event that the facilities fail to perform safisfactorily, including the,
creation of nuisance conditions, the Permittee shall take such immediate
corrective action as may be required by this Division, 0cluding the construction
of additional or replacement wastewater treatment or disposal facilities,

fa Any inonirating deemed necessary by the Division of Environmental Management to
insure surface and ground water protection will be established and an acceptable
sampling reporting schedule shall he followed.
. The Peirmittee, at least six () months priorto 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 deer` appropriate,
, Adequate facilities shall be provided to prevent surface runoff from carrying any
disposed or stored material into any surface; seaters,
. The issuance of this permit shall, net relieve the Pe.rmittee of the responsibility
for damages to surface or groundwdters resulting from the operation of this
facility.
iii. No type of sludge other- than that from the Holly Farms Harmony facility or the
Wilkesboro facility shall be placed on the land application disposal site,
1 ] . 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.
1.2, Sludge shall not be applied in inclement weather or until 24 -lions following ai
rainfall event of 1/2-inch or greater in 24 hours. Emergency sludge disposal
measures shall be approved' by the Division of Environmental Management,
33. A 100-foot buffer shall be maintained between the appropriate land owner's
property line and any applied sludge.
14. The site sball be adequately lined to as scai.l pH of 6.5 prior to sludge
application.
15, No crop Yor direct human consumption shall be raised on these sites for Ka period
of 1.8 merratli following sludge application.
16. Maximum slope for sludge application shall. be 18° for subsurface applications.
All applications shall be by subsurface injection.
17. Adequate inspection, maint-e.n.aance, and cleaning shall be provided by the Per ittee'
to insure proper operation of the subject facilities.
1.8. This permit" shall became, voidable unless the agreement between Holly Darns
Foods,, TnC.. and ]bra Richard Adams is in full force and effect.
1Y This permit allows the hand application of sludge, by subsurface injection, t
approximately 88 acres of 1 nand (Less the la3ry ; that is part: of as buffer zone or
10 located in the l(lii-year flood plain) in Kara}an County owned dry Dr, Richard
Adams.
20. In any future' transfer of this hand, aa;notice shall be given to the new owner"
that gives full details of the materials applied or incorporated at this siLe:.
�2_

21,
op
ppl-
Animals
should not be grazed on sludge applied land within a 30-day period
.
fol;owiug the sludge, application. Application sites that are to be'used for
grnzing
shall have fencing that will be used to prevent access during the 0-day
periods
after each application,
2L
Public
access to the land application sites shall be controlled during active
site use and for the 12-month period following the and application event.
2Y
A copy
(if the approved plans and specifications shall be maintained Oil file by
the Parmittee
for a minimum of five years from the date of issuance.
24.
Monitoring
wells shall be constructed and sampling schedules arranged as required
by the
Division of Environmental Management and ifn accordance with 15 NCAC 2C
0,100,
2K
Solids,
sludges, or other pollutants removed or resulting from the wastewater
storage
facilities shall be contained and disposed of in such a manner as to
prevent
any contamination of the surface or groundwaters of the State.
26,
The following
buffers shall be maintained between any subsurface applied sludge:
a)
25 feet to drainageways;
b)
100 feet to property lines; and
Q
200 feet to residences,
Holly joarms Foods, Inc, shall submit an annual summary of its sludge. land
"27,
app3ication
activities, regarding this permit, to :hex Mooresville Regional Office
by January 31 of each year. The summary shall ainclude, but not necessarily be
limited
to the following:
a)
data sludge applied;
b)
field where sludyp applied;
c)
method of application;
d)
amount of sludge applied;
e)
crop(s) grown on field; and
f)
year-to-date totals in dry tons/acre, nutrient and metal loarslin i.n
pounds per acre.
Note:
The report period shall be for the calendar year (January I - December al
and shall be submitted no later than January 31 of the following calendar
year.
2K
No sludge shall be applied within 100 feet of any well, with the exception of a
monitoring well, or water supply source.
29,
No sludge shall be applied to any area which is lesated within the 100-year flood
plain.
30.
Annual
sludge applications shall not exceed the Wowing.
a)
PAN 200 1W per anre
0)
Phosphate 50 lbs, per acre
C)
Potassium 100 1W per a:re
d)
Cadmium V45 lbs, per acre
e)
Dry tons 9.4 dry tons per acre
f)
Hydraulic loadings (wet) 6788 gallons per acre
-3-

31. The maximum imum cumulative loadings for metals shall not exceed the following:
a Cadmium 4.45 its. per acme
b topper 250 lbs .
per acre
c Nickel 250 l bs
per acre
d Lead 1000 l.bs
W per acre
32;
7n the event that the cumulative loadings of meals exceed those limits
established in condition 31, the lazed owner
shall l _ace the following statement;
in the property deed. "Portions of this
property have received: wastewater
treatment plant sludge at high heaver metal
appl ca. on rates. Caine should be
taken when food chain craps alp grown dare to a possible health hazard.''
3 a
Sludge shall be applied in a wanner that
will, prevent r_ulloff, pon in , and
erosion.
W
The permit:tee shall submit an annual current
composKe sludge analysis report to
the North Carolina Department of Natural Resources
and Community llevet pmentw,
Mooresville Regional Office (919 North Main
Street, Mooresville, NC 28115).e
sludge analysis sis report shall contain at, least
the -following:
Parameters
Units
a. Solids
l
b. ' Lead
lbs/dr° ';terra
'
c. Cadmium
lbs'/dry tore
& Nickel
lbs /dry to-
e, Copier
lbs/dr,. tcrzt
f. Zuni
lbs dry tern
, ; Residual Chlorine
lbs;/dr'y torn
hw PO and P
Q
lbs/dry ton
ii
leas,/dry ton ,
.l ; NH as N
lb/dry 'ton
K NO t NO
{
l bs/dray tiara
1. Zli.�; air reaase
lbs/dry tan
M. PH
s , tz .
n. Pit
ppm dry weight
Note: The report period dull be for the calendar year(January l a December 31
and shall be submitted no salter than January 1 of the following calendar�`;
year.
35.
`Fhe owner of the land' application site(s)
shall be furnished with an annual
analysis of the sludge which has been applied
to the sites..
36.,.
No sludge slant be applied to hand ripplic;ation Vies where the depth to the
seasonal high water table is Less thah three
feet.

37.
Ile five (5) existing monitor wells shall be sampled every March, July and
November for the following parameters:
Nitrate pll
Total Ammonia TOC
TDS Chloride
Total Coliforms Sulfate
Water Levels
The measur-ment of water level must be made prior to sampling for the remaining
parameters,
The results of the smspling and aialysis shall be sent to the X. Division of
Environmenzal Management on Form GW-59 (Compliance Monitoring Report Form) every
April, August and December.
38.
The use of the existing lagoon by Holly Farms Foods, Inc.;must cease by
January 1, 199Y
3Y
Holly Farms Foods, Inc. must submit a written status report to the Mooresville
Regional Office each month which indicates the. progress toward eliminating the
existing lagoon.
40.
By December 19, 1988, Holly Farms Foods, Inc. will nake a decision on the
implementation of option I or option 2 as described in condition no, 41,
41,
Depending upon the pro- treatment, option which is chosen, Holly Farms Foods, Inc.
will comply with the schedules detailed below for either Option 1 or Option 2:
0PTI0N_l: Installytionsuf EPI_Technolgg
gY
June 30, 1989 - . . . Completion of Installation
September !, 1989 . . . 1) No Sludge Productio.6''jf,pm � _
Wilkesboro Complex
2) Submit.Plans for On -Site Storage of
DAF Sludge at Harmony Rendering
Plant
December 30, 1989 Open Lagoon at Richard Adams Farm To
Be Emptied and Use as Storage To Be
Discontinued
June 30, 1990 Open Lagoon at Richard Adams Farm To
'Be Filled In and Landscape To Be
Returned To Original State
-5-

FF70P'1Fj-,i,(0)N : DAF Cell
at Wilkesboro Plant
January 30, 1989,
Submit Construction Plans For Enclosed
Storage Tank To Be Located on Richard
Adams Ear
April 30, 1989.
Begin Construction Of Storage Tank
After Receiving Approval. From NCDNR&(.',D
October 31, t98 ,
. Complete Construction cr Enclosed
Storage Tank
December 30, 1989 s
v
. . . Open Lagoon at. Richard Adams Farm To
BeEmptied and Use As Storage To Be
Discontinued
June 30, 1990 q
. . , . . . . Open Lagoon at Richard Adams Farm To
Be Filled In and Landscape To Be
Returned To Original State
Permit issued this the,
31st day of Marcie, 1,989.
NOT CAR L NA ENVIRONMENTAL MANAGEMENT COMMISSION
r '
R, Paul lays, Director
Division of Environa entnI Management
By Authority of the Environmental Management Commission
Kermit No. t C3CJC 0701

DIVISION OF ENVIRONMENTAL MANAGEMENT
March 1989
MEMORANDUM TO: Arthur Mouberry
FROM: J. Thurman SUBJECT:Horne �
Holly "arms Fo a s , Inc.
Permit No. WQ 0000701
Sludge Land, Application Permit
Rowan County, North Carolina
The staff of the Mooresville Regional office -Water Quality
Section has reviewed the letter dated December 30, 1988
requesting modifications of the subject ermi' . Our
and/or recommendations are keyed below to the number of the.
comments in the letter:
1. This concerns a standard "boiler plate" condition that
is usually contained in all permits involving soil
absorption. The intent is to insure that, applications
do not occur or continue can sails that do not properly
assimilate the waste'. Examples of inadequate
absorption could include surface- ponding runoff,
persistent odors, increased disease vectors (flies,
rats, etc.) etc'. These examples should be offered a
clarification, but not as definition. The condition
in question requires professional judgement and cannot
and should not be constrained: by a specific,
definition. It should not be necessary to
specifically define each phrase, term; or condition of
this or any other permit If the permittee clues not
have the professional competence to understand such an
elementary principle ' as this, then the permi.tte
should recognize that they should enlist the services
of someone having competence such as a professional
sludge management ement .firm. This logic should beapplied
to requests No. 2, 3 and: 4 of the letter.

prppr,
Arthur Mouberry
Page Two
March 23, 1989
2. Again, it should not be necessary to specifically
define "nuisance condition". However, for
clarification, the permittee should be advised that we
would consider such things as excessive odors,
spillage on highways, unusual incidence of flies, etc.
as a nuisance which common sense would dictate warrant
corrective action.
3. These facilities and provisions may or may not be
necessary due to any number of site specific
variables. These conditions require a minimum of
professional competence to understand. A simple
example would be to refrain from applying sludge on or
near the edge of a slope which a rain could carry into
a stream or onto adjacent property. Conditions such
as this provide a benefit to the permittee in that we
assume he will exercise sound judgement and has at
least a minimal understanding of good management
practices. This would seem a better approach than to
presume everything will go wrong and, therefore, we
should require construction of berms, wind breaks,
etc. before a remotely possible problem can occur.
4. The condition should be rather simple to understand.
Inclement weather should be considered to include
rainfall, snowfall or icefall. It should be obvious
to anyone with a minimal understanding of proper
sludge management that applications should not occur
when the ground is covered with ice or snow or
saturated from rain so as to prevent ready absorption
into the soil. The requirement that applications not
occur within 24 hours of a rainfall event of 1/2 inch
or greater provides an additional measure of safety
that should be easy to understand and to <follow. It
is not at all contradictory to the rest of this
condition and should be a useful tool to the permittee
in making management decisions.
5. It is recommended that this request be denied. DEM
should retain a capability to immediately intervene if
circumstances warrant such intervention. For
instance, we must be able to terminate this permit if
the permittee loses permission to use the application
fields. otherwise, we may be considered as condoning
an illegal trespass.
6. We fail to see that the inclusion of this condition
waives any rights the permittee may have to appeal.
Legal Affairs should review this and render an
opinion. our intent is to maintain an ability to
direct prompt corrective actions if such are
necessary. The permittee may refuse or dispute such
directives through existing regulatory process.

Arthur Mouberry
Page Three
March 23, 1989
7. We believe that the permittee has a valid concern, but
it may actually be to their benefit to leave these
requirements as is. As now written, we May require
additional monitoring if we feel it is needed. If we
do not maintain this capability then we would have no
recourse but to go ahead and establish an extensive
monitoring requirement that would be an extreme
financial burden. For instance, the Groundwater
Section may find it necessary to require the
installation of monitoring wells around the perimeter
of all the application fields now instead of p2§,p�ibl
needing a few later. Without the latitude to make
these judgements later, we would be forced to make
conservative judgements now that would be a
significant financial burden.
We suggest that the permittee: decide if they would
prefer to be given an extensive monitoring requirement
now which would cover every concern we can
legitimately conceive. We cannot imagine that this
would be to anyones best interest.
8. No co -went- (Groundwat-er concern',
9. 988 acres is the total area of the fields as indicated
on the permit application documents submitted. This
is the sum of the areas listed for each application
field. This total does not reflect the actual area
available for application. It merely indicates the
total area of the permitted fields. The actual area
available for application will be reduced by the
various buffer requirements including, but not limited
to, the flood plain. The area of each field that is
available to application will be reduced by buffers to
streams, drainage ways, property lines, wells, etc.
It should be the responsibility of the permittee to
properly track the actual area onto which sludge is
applied. For instance, if a field has ten (10) acres
that are suitable for receiving sludge, but due to
management decisions, only five (5) acres receive
sludge, the application rate should be determined
based on the area which actually receives sludge and
not the entire field area. Again, with a minimal
knowledge of proper sludge management procedures, the
permittee should understand that application rates
(i.e. lbs or gallons per acre) are controlled by
calibrating the application rates in the field.
The matter of the total area listed in Condition No.
19 is irrelevant except that it aids in identifying
the total field area that is permitted, less the
required buffers.

Arthur Mouberry
''age Four
March 23, 1989
s for prohibiting applications in the flood plain of
a WS watershed, the Mooresville Regional Office
believes this is reasonable and prudent. However,
there should be consistency in this and other DE
procedural Matters. If the pormi.ttee is correct in
citing the circumstances with the Town of Wilkesboro,
then we should reconsider and revise this condition to
be no more or less stringent than theirs.
The matter of the established limitation for hydraulic
loading was not numbered, but was raised as a concern. The
Mooresville Regional office believes this is a limitation that
is needed and is justified based on our past experience and
professional judgement. This is supported by the fact that this
limitation n is applied in other permits for sludge of a similar
nature .g. Breeden Poultry in Burke County). It has been our
experience with sludges of this nature that this limitation is
needed to prevent nuisance conditions and poor assimilation of
the sludge due to the relatively high grease content. We have
investigated sites where this type of sludge was applied and:
these investigations support the necessity for maintaining this
limitations.
In conclusion, we must question the appropriateness of the
manner in which Holly Farms has raised these issues. Most o
these conditions were in the previously expired permit and and
nothing new.
It is our opinion that the manner in which these concerns
were raised duos not oblige any action on the part of DEM other
than the dourtos of a response. The hatter transmitting the
permit to Holy Farms (dated December 1, 1 ) clearly states
the proper procedure for contesting any of the permit
requirements. This procedure was not followed and, therefore,
the conditions of the permit as written should be binding.
If you have any questions please advise.
JTH : se

PPFPPF'
DIVISION OF ENVIRONMENTAL MANAGENIFNIT
GROUNDWATER SECTION
s
l
24 nag
w
P o tag ?,
FROM: Bill Reid
SUBJECT: Application for V Renewal.; 1�r����:dnm:e]in: Perri No 1
NewPer�ai
Facility Naas
Count
l x p
Type of ProjectApplicable Permit Numbers 00 InV117
9
EPA A
We have received a copy of the above referenced application,
which was saint to your regional office for comment on or about
1
ou should review the application package for completeness and
adequacyadeqpacy of relevant information and submit your request for
additional information to me (via telephone or memo) by
_ _ _ , 1989 o that all required information can be
requestel-40&a� the applicant at one time. A copy of our formal
request to the applicant for additional information will be
provided to you.
If you do not require additional information from the
applicant to complete your evaluation of the project, you should
review than application package and submit your comments to me by
1989.
If :a copy of the application package has not been mach
available to your office;, PLEASE LET ME KNOW TMME IA"RELY so that a
copy can be forwarded to you as loran as possible.

1, r'
h.. :'yam" Ff, }4N N Gk'b"CEi :°*4i 11 "A F»,'F
P PALE.iGi-i,
* TEt_En-'x OEki '.� 'a FrS .Ar#srtti'J.,AtfG,,E pmpA, NC.
g,.' ,✓ a. w TCLCFAX
December 30, 1988
Via Hand el iv
r. Arthur M uberryt Head
Permits and Engineering .'
Division of Environmental
512 Management . N. Salisbury Street �;ol�
Raleigh, North Carolina 27611
ate<w golly Farms Foods, Inc., Harmony Rendering Plant
Lead Application Permit No. WQ0000701
Dear Mr. Mouber yb
This letter is submitted on behalf of` 1. y Farms Foods, inck
("Holly Farms" to request certain modifications f North
Carolina Non -discharge Permit No. WQ0000701 (the "Permit"), which
was issued to the Company for the subsurface injection of sludge
from Rally Farms' Harmony rendering plant. We understand that
this request is in lieu of are appeal, as discussed in the cover
letter of the Permit, and that, according :to the Division's
.on'
normal practice, an appealable final action on the Permit will be
taken after review of this request for modifications.
Holly Farms believes that several conditions included in the
Permit are vague. Therefore, as discussed further below, we are
seeking clarification of certain terms to ensure that the Company
is provided adequate guidance for compliance with the Permit.
Several conditions included in the Permit may also inadvertently
alter legal rights granted to Molly Farms by North Carolina law
and rules, and we also request clarification or modification of
those conditions.
Finally, based upon information provided by doily Farms, w
believe that Holly Farms apparently has been inappropriately
denied permission to ;apply sludge to areas located within the
100-year flood plain of the South Yadkin River. It also appears
that the Permit limitation can hydraulic loading of 6788 galleons
per acre is also inappropriately low.

pr
Mr. Arthur Mouberry
December 30, 1988
Page
Holly Farms requests that the following Conditions
in the
be clarified.
Condition Of the Permit makes the Permit
voidable
"in the event of failure of the soil to adequately
absorb the wastes," but does not describe what
constitutes adequate a scrbttan of the wastes. We
request that some attempt be made to describe what th,e
€ ivision considers adequate abs arbtion of the was2. tes.
etas g
cat the errrr�
p _ ,
shall take �, t provides that the erm�.tee
ediate corrective
action as
the Division to address" ,amonother th n required b
Conditions.,, Holly Farms is end,"nuisance
ure whattheDivision feels would constitute a ""n�ras rice condition"
for this facility. Therefore, the Company a tl.�anr"
the Division or the Permit further specify, �" asks that
Possible, what situations co itte�
conditions," could co ""nuisanc
3.
Conditions 8 and 11 require that ""ads adequate (and) provision "" b taken to prevent surface runoff
and wind erosion from conveying nett
�a�.1u't pollutants
-`
adjacentt
property car near on t
fur
Dy surface e waters.
eels "facilities"
It
that such. .t "� the
a s c r "
I' are t3.
e 11 Of the c11.� Farms requests sthat onditionss
and 11 �a.t the Permit be and altered c specify "facilities""facilities""" ,, whit
adequate.
"Provisionswould b considered
4.
Condition 12 requires that, sludge not be a
inclement weather r until hours followingli d ""gin
rainfall event of I incur or
Condition greater in 24 hours."
does not adequately describe "inclement �h
weather." The meaning
further Complicated b c ""inclement weather"" is
Pthe rainfall event after which sludgescma nn of a specific
applied. � not be
pp Tease further define the relationship
between "inclement t weather" and.. "a rainfall event of r
inch within 24 hours ""
"inclement weather.,"" car define further the terra
Holly Farms is also concerned that several c
the Permit may alterconditionsregulations adopted b included in
Procedural North
protections provided to by �
cmmi sign,. y the ch Carolina Environ cent l Management
legal rights: �'eci ically, the cell in Conditions may alter those

Cr. Arthur Mouberry
FPVDecember 30, 1988
Page
4 Conditions 4 and 18 provide that the Permit will
become "voidable"" if certain requirements are not
met. The word "voidable"requires some further act by
the Division to "void" the Permit but does not
necessarily require that the Division follow the
procedure established at 15 N A .0213 for the
revocation of a permit. We request that Conditions
and 18 be modified to specify that the Permit shallt
only become void through the permit revocation process
established at 15 NCAC 2 .0213
$. Condition 5 of the Permit provides that the Pera ittde
must take corrective action "as may be required b
this Division." This Condition could be read to waive
the Permi tte "s right, as established at
N. . . . 15 _2 and at 15 NCAC 2 .t13 1 to contest any
order to institute corrective action, should the
Permittee believe that such action is unnecessary".. We
thus request that Condition 5 be clarified to provide
that the Per aittee shall have ; in opportunity to
contest the carder under the North Carolina
Administrative Procedure act. _
7. Conditions fa and 24 provide that any "monitoring
deemed necessary" by the Division of Environmental
Management , . . will: be established," but ;does not,
provide how such monitoring will be required. We
believe that the -Division; must undertake the permit
modification process in the permitting regulations at
15 . .A. a 2H.0213 to add monitoring requirements to,
the Permit, and thus request the modification. of the
Permit to specify that, this procedure must be used to
impose monitoring requirements not already included in
the Permit.
Holly Farms has also identified ghat it believes may be
factual errors in the Permit. In .instances where these
suspected errors are not errors in fact, but are in fact
intended to be conditions of the Permit, Holly" Farms
contests the inclusion of those conditions in the Permit.
8. Condition ti.on 28 requires that "Cn]o sludge shall be
applied within 100 feet of any wel"'
or water supply,
source.'"However, 15 i A 2H. 2.1 ( P allows the
application of sludge within 100 feet of an approved
groundwater monitoring well. We suspect that the
Division intended to adopt the requirements of this
Section 2il.219(j)(5)(P), and inadvertently left; out

7MFr. Arthur Mouberry
December 30, 1988
Page 4
the exception for application of sludge near
groundwater monitoring wells. If not, we would reqest
that the Permit be so written or that we be advised if
the deletion was intentional.
9. Condition 29 of the Permit prohibits sludge
application within the 100-year flood plain. This
provision may be of great concern to the Company,
depending on the location of the flood plain. This
provision may simply require clarification.
Condition 19 states that the Permit allows land
application of sludge to approximately 988 acres of
land owned by Dr. Richard Adams. However, depending
on the location of the 100-year flood plain, as little
as 861 acres may actually be available to Holly Farms
for land application of sludge. We believe that the
988 acres is the correct figure and request that
Condition 19 be clarified accordingly.
If our understanding is incorrect, we believe that
Condition 19 goes beyond the requirements of the
Division's rules concerning disposal of wastes which
are not discharged to surface waters. '.hose rules
establish Minimum buffer zones around particular areas
sensitive to contamination from wastewater
discharges. The buffer zone required between disposal
systems and private or public drinking water supply
sources is 100 feet, and the buffer zone required
between a subsurface disposal system and a stream
classified WS-Iii, like the South Yadkin, is 5o
feet. 15 NCAC 2B.0219(j)(5)(D) and (C)(i). Larger
buffer zones may be established when necessary to
address particular site or waste characteristics.
15 NCAC 2H.0219(j)(5). These buffer zones adequately
protect water supplies and streams classified as
WS-III.
The rules require that facilities be "protected from
100-year flood[ s)," but do not prohibit subsurface
injection within the 100-year flood plain. Given the
purpose of the buffer zones, and the clear
co,nsideration of the relationship of subsurface
injection of wastes to water Supply sources in those
buffer zones, the prohibition of subsurface injection
within the 100-year flood plain is unwarranted The
prohibition also appears to be arbitrary, given our
understanding that the Division has permitted the Town
of Wilkesboro to apply sludges to land within the

Mr. Arthur Mouberry
December 30, 1988
Page
0 -year flood plain of the Yadkin Raver, which serves
as a drinking water supply for Tinton -Salem. if the
acreage established in Condition 19 is incorrect,
Holly Farms requests that this prohibition be removed
from the Permit, or that it be provided additional
reasons for the inclusion of this prohibition
Holly Farms also questions the inclusion of a l ial tation on the
hydraulic loading. Polly Farms believes that the limitations
upon discharge of nutrients and metals adequately protects the
environment, and that this hydraulic loading limitation severely
restricts discharges otherwise permitted to dolly Farms, and will
require the use of more land for dispersal,. Rally Farms requests
the removal of this limitation, or requests that the Division
provide some explanation for the ` inclusion the limitation.
Please consider the above requests and advise us of the
Division's response. As stated previously, Rally Farms would
prefer to resolve informally issues related to the Permit.. if
you have any questions regarding holly Farms' position, please do
not hesitate to call us. Thank you for your attention to this
matter. With best wishes, we remain,
Very Truly Yours,
MOORMOORE & VAN ALLEY
Charles D. Case
J. evin Milliken
enclosures
cc: Randall S. Janes
Garin J . €lotto l y
"'rank J.M. Taracidc
David M. Taylor
William C. Warden, Jr

DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
February 10, 1989
MEMORANDUM
T: Arthur Mubefr
nrfl
THROUGH: Bob Cheek (Z
E Bill Reid r
SUBJECT: olly Farms, Harmony Plant
Amendment to Permit No. WQ00001'01-
Rowan Countyn'
GW 1
(Arthur ouberr : DEN BERG Review Engineer)
The Groundwater Section has reviewed red the subject permit
application and offers the following comments and
recommendations. Holly Farms wishes to amend several
conditions of their recent permit No. WQ0000701. Conditions
No. 4, 5, 8, 11 and 12 concern issues which are primarily
,
related to surface water concerns. However, Condition No. 4
is a groundwater concern in that it implies that the soil
resat adequately absorb the waste so as to prevent the ,
contravention f established groundwater quality standards.
It is not recommended that Conditions No. 6 and 24 be
modified as requested. No additional monitoring would be
required unless a contravention of groundwater quality
standards occurred and/or a change in operation deemed
additional monitoring necessary.
We have no objection to the modification of Condition
No.. 28 so as to allow the application of sludge within 100
feet of the monitoring wells. When initially located, the
monitor ells were placed within the buffer zones to detect
any contamination of groundwater.Since application i
permitted up to the buffer zone boundary and the wells were
intentionally placed within the buffer zone, it was
considered obvious that the 0-fact separation distance was
not applicable to these wells.
The questions raised by the applicant concerning
conditions which relate to land application within the 100
year floodpla .n i.eConditions No. 19 and ) are
primarily surface water issues. However,; the applicant
should, be made aware that in accordance with 15 NCAC

il l ( ) , industrial waste shall not be applied or
discharged onto or below the land surface when the vertical
separation between the waste and the seasonal high water'
table is leas than one foot,. If the area to be utilized has
a_ separation of less than three () ;feed, and in other areas >
as designated by the director, a demonstration yq u
r_
.. must M� a:Y be
using predictive calculations or modeling methods,,
acceptable to the director, that such placement will not
result in contravention of classified groundwater standards.
The applicant's concern refers to some of the land owned b
Dr. Richard Adams which lies within the 100 year flood lain
of the South Yadkin River. As these fields were permitted
several years ago, the information concerning the soils and
depth to seasonal high water table in this area are; n
longer available. The death to seasonal.high water table in
these areas needs to be established. Depending upon the
death to seasonal high water table, > these fields may my b
suitable for land application on a seasonal basis.
If you have any questions concerning these Matters
please advise
JWR/M /te
cc: Erie Klingel
Central File
Permit Issuance Files

,ks a
fil
: t
State of NorthCarolina
Department of Natural1r and Community Development
Division of Environmental l Management
517 North Salisbury Street Raleigh, North Carolina 27611
James . Martin, Governor Ra Paul Wilms
S. Thomas Rhodes, Secretary Drector
June 3, 1.986
Mr. Frank Taracfdo
Holly Farms Poultry Industries, Inc.
Pest Office Box
Wilkesboro, N. C. 28697
:xk
SUBJECT: Permit No. 7911R2
Holly Farms Poultry Industries, Inc.
Sludge Holding Lagoon & Subsurface
Application of Sludge from Harmony
.endearing Plant
Rowan aunty/lredell County
Dear Mr. Taraci.do:
In accordance with your application received September 12, 1985, we are
forwarding herewith Permit No. 7911P., dated June 3 1986, to Holly Farms
Poultry Industries, Inc. for the continued ope atat on of the subject sludge
holding lagoon and subsurface application of sludge.
This Permit shall be effective from the date of issuance until May 1,
1988, shall be subject to the conditions and limitations as specified therein
and shall supercede Permit 7911. 1 issued on March 10, 1983.
If any, parts, requirements, or limitations contained in this permit are
unacceptable to you, you have the right to an adjudicatoradjudicatory hearing before a
hearing officer upon written demand to the Director within thirty (3 days
following receipt of this permit, identifying the specific issues to be Con-
tended. Unless such demand is lade, this permit shall be final and binding.
One (1) sat of approved plans and specifications is being, forwarded to
you. if you have any questions or need additional information concerning this
matter, please contact 'Mr. Cecil G. Madden, Jr., telephone No. 919/733-5083,
et, 122.
Sincerely yours,
cc: I edell County Health Dept .i.
Dennis Ramsey Wilms
Mooresville Regional 1 ffice I-Ibtlut€ n Stir fr trc�
.0 Box 27687, RaIeO, North Camlina 27611-7687 Id pshone 19-733-701
n Eqwl t ni r Affirmative Action F n

NORTH CAROLINA
ENVIRONMENTAL SIT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
LI11
I T
For the Discharge of Sewage, Industrial Wastes, or tither Wastes
In accordance with the provisions of Article 21 of Chapter 143, General Statute:
of North Carolina as amended, and other applicable Laws, pules and Regulations
PERMISSION IS HEREBY THIS TO
Holly'Farms Poultry Industries, Inc.
Rowan Count*
FOR THE
continued operation of a sludge holding lagoons with approximately
425,000 gallons of capacity and the subsurface injection of sludge from
the Harmony Rendering Plant to the land identified in Condition Number
28 of this Permit,'
pursuant to the application received September 12,1985, and in conformity
with the project plans, specifications, and other supporting data subsequently
filed and; approved by the Department of Natural Resouces and: Community
Development and considered a part of this permit.
This 'Permit shall be effective from the date of issuance until May 1,
Iq d, and shalt be subject to the following specified conditions and limitations;
1. This permit is effective only with respect to the nature and volume
of wastes described in the application and other supporting data:
2. The facilities shall be properly maintained and operated at all tires.
. This permit is not transferable,
. This permit shall become voidable in the event of failure of the soil
to adequately absorb the wastes, and may be rescinded unless the
facilities are, installed, maintained and operated in a manner which
will protect the assigned water quality standards or the surface waters
and. ,ground: waters

Page 2
5. Monitoring wells shall be constructed and sampling schedules arranged
as required by the Division of Environmental Management and constructed
in accordance with 10 NCAC 2C 0.100.
6. Any monitoring deemed necessary by the Division of Environmental
Management to insure°surface and ground water protection will be
established and an 'acceptable sampling reporting schedule shall be
followed.
7. The land application sites shall be effectively maintained and operated
at all times so that there is no discharge to the surface waters, nor
any contamination of ground waters which will render them unsatisfactory
for normal use. In event the facilities fail to perform satisfactorily,
including the creation of nuisance conditions, or failure of the irrigation
area to adequately absorb the wastewater, the Permittee, shall take
such immediate corrective action as may be required by the Division
of Environmental Management.
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 indicated, will extend the Permit for such period of time and
under such conditions and limitations as it may deem appropriate.
9. Adequate facilities shall be provided to prevent surface runoff from
carrying any disposed or stored material into the receiving stream.
10. The issuance of this permit shall not relieve Holly Farms of the
responsibility for damages to surface or ground waters resulting from
the operation of this facility.
11. The facilities shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastewater into the
surface waters of the State.
12. No type of sludge other than that from the Holly Farms Industries, Inc. -
Harmony Rendering Plant shall be placed on the land application disposal
site.
13. Adequate provisions shall be taken to prevent wind erosion and surface
runoff from conveying pollutants from the sludge application area onto
the adjacent property and/or surface waters.
14. Sludge shall not be applied in inclement weather or until 24 hours
following a rainfall event of k-inch; or greater in 24 hours. Emergency
sludge disposal measures shall be approved by the Division of Environmental
Management.

Vpag,e
1.. A 100-foot buffer shall be maintainedbetween the appropriate land
owner's property line and any applied sludge.
16. The site shall be adequately limed to a wail pH of 6.5 prior to sludge
application.
17. A 5-foo fe shall be cai aired between drainageways, a 0-foot
buffer shall be maintained between, each landowner'landowner's property lines,
and d 10 foot buffer shall be maintained between any residence and
any applied shade. ;
18. A recorded log of applications including amounts applied, dates, whether
infected or incorporated, coordinates of application, etc., shall. be
maintained at the wastewater treatment pant as a permanent record.
19. Public access to land application sites shall be controlled during
active site use and for the 12-mranth period following the land
application event
20. No liquid _ sludge will be applied by surface or subsurface application
within 100 .feet of any surface grater or well, or within hin 200 feet of
" any tributary of public water supply.
21. No sludge shall be disposed in area subject to the 100--year flood.
22. This permit shall become voidable unless the facilities are operated
in accordance with the .approved plans, specifications and other supporting
data.
23 Diversion or bypassing of the sludge from the, sludge land application
site is prohibited.
24. No roost or leaf crops for public consumption shall be raised on these
sites for a period of eighteen, (18 months following fng sludge applications.
25 Sludge applications shall not exceed.
A. Annual Loadings.
1. PAN 200 lbs/acre/year
2. PO4 50 lbs/acre/yea
3. K 100 lbs/acre/year
. Cd 0.45 lbs/acre/year
5. Dry "erns . /acre/year
6. Hydraulic Loading (wet) 6,288 gal/acre/year
B. Cumulative Loadings:
1# Cd 8.9 lbs/acre
2. Pb 1000 lITb s /ac e
3. 2xa 500 lbs/acre
4. Cu 250 l.bs/ac're
. Ni 250 lbs/acre

Page
fs: Sludge small be uniformly applied so to avoid runoff, pending o
erosion-
27. The additions should not exceed the needs of the crop being grown based
Capon current soil and sludge analysis.
28. This Permit shall become voidable unless the agreements between Holly
Farms and the; land owners listed below are in full force and effect::
Site No. Owner cress f( l icati.on fields, inlnadinn
buffers)
r.. Richard Adams 606
29. The Permittee shall submit a current composite slndgeanal si:s report,
and --a summary of all applications, annually, to the North Carolina
Department of Natural and Community Development, Mooresville regional
Office (919 North Main Street-, Mooresville, NC 28115). The sludge
analysis report shall contain at least the following:
Parameters Units
a¢ Solids
bd `bead lbs/dry tens
c. Cadmium lbs/dry ton
d. Nickel lbs dry ton
e. Copper lbs/dry ton
f, Zinc lbs/dry torn
a Residual Chlorine lbs/dry tan
b. PO and p lbs/dry torn
I. TKN lbs/dry ton
J. XH3 as N lbs /dry ton
k. NO2+ NO3 lbs/dry tan
1. Oil and Grease lbs/dry ton
.. pH a. U.
nn PCB ppm (dry eight
Note: The report period shall be for the,calendar year (Januar
Dec be l} and shall be submitted by no later :than February
1 of the following calendar year.
30. The ,summary f shade applications shall specify the date of application,
location of application and loading rates for nutrients, metals and
hydrual.ie
1.. Should cumulative applications of metals exceed those limitations indicated
in Means No. 25, the Permittee shall take whatever remedial actions may
be required b the Division of Environmental Management' including, but
not limited to, inclusion of the following statement as a part of the
property deed.
Continued a

Permit No. 112
Page
"Portions of this Property have received solid
waste at high metals application rates and care
should be taken if food chain crops are grown due
to a possible health hazard."
2. The owner of the disposal site shall be furnished an analysis of
sludge delivered, to the site annually.
. No land application of sludge shall be conducted where the depth to
the seasonal hill water table is less than three feet.
34. The southeramostexisting well is dry and thus useless for monitoring
groundwater quality. This Drell shall be abandoned ed in accordance with
the requirements of the "Well Construction Standards", 15 NCAC 2C.0113(2).
35. Two additional wells shall be installed to monitor changes in groundwater
quality at the land application sites. The locations and construction
details, of the wells shall be by approval of the Mooresville Regional
Office.
:lh. All three monitor wells shall be sampled within 24 hours of completion
of the 3 new monitor wells. Thereafter, all wells shall be sampled
every March, duly, and November for the following parameters:
Total_Coliforms
Chloride "Dotal Ammonia
PH SO4
TDS TOE
Water revels
The measurement of water level, shall be made prior to sampling for the
remaining parameters.
7 The Permittee shall contact the Mooresville Regional Office to obtain
proper forms and assistance in maintaining proper records and submitting
reports.
ld. Groundwater monitoring reports shall be forwarded to the Mooresville
Regional Supervisor within sixty 60 clays of each sampling.
g.. The sludge storage lagoon shall be used only for short term storage
(not to emceed two weeks) of sludge during periods of inclement weather,
and shall be operated so as to prevent the creation of nuisance odors.

Perm
P r111
lt
it No. 791IR-2
Pa s (a
6
40.
Within thirty (30) days of receipt of this Permit, the Permittee shall
submit a written report of a thorough investigation of the present
operating procedures with respect to the existing storage lagoon including
recommendations for improving operation precedgar es, etc., to eliminate
the creation of nuisance odors. The report will pay particular emphasis
to use of the lagoon for short to (less than two weeks) storage during
inclement weather only. Upon receipt of the report and review of the
proposed improvements in operating procedures, the Division of Environ-
mental Management will determine whether the proposal affords reasonable
assurance that odors will be effectively controlled. Failure to adequately
demonstrate that the lagoon can and will be operated without the creation
of nuisance odors and/or failure to submit a report as specified will
prompt the Division of Environmental Management to terminate the
permitted use of the lagoon and/or rescind this Permit.
41.
Once use of the lagoon is discontinued, the Permittee shall properly
land apply all sludge remaining in the lagoon. Once empty the lagoon
shall be backfilled by the Permittee.
P.
If any nuisance condition arises concerning this land application system
including the transportation,storage, application or creation of an odor
problem, Holly Farms Poultry Industries, Inc., shall terminate sludge
disposal immediately after notification by the Division of Environmental
Management.
43.
Lactating dairy animals shall not be grazed on sludge applied areas
for a period of one year following sludge application. All other
animals should not be grazed on sludge applied land within 30-day
period following the sludge application. Application sites that
are to be also used for grazing shall have fencing that will be used
to prevent access after each application.
44.
Maximum slope for sludge application shall be 18% for subsurface applications.
All applications shall be subsurface.
Permit issued this the 3rd day of June, 1986.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
R. Paul Wilms,Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. 791IR-2

Y16
Nlarch lair 1983
DIVISION OF ENVIRONXSNTAI, MANAGEWINT
Mr. Frank Taracid(-,), Chief Engineer
Holly Farms Poultry Industries, Lnca
P.O. Box 88
Wilkesboro, $69
Permit No. 7911RI.
Holly Farms Poulti-V lnd�ustries, It
Sludge I-Iolding Lag oon, and Subsurface
Application of Sludge fron., the 11,armon-,','
Rendering Plant
Rowan CounLY/try dell Count,;
Dear Mr. Taracido:
In accordance with your application received October 18, 1982, we are
farding herewith Permit No. 7911RI dated March, 1983, to Holly Farms
orw
Poultry industries, Inc. for the construction and operation of the subject
non —discharge type sludge storage lagoon for the temporary storage of sludge
prior to its land application by subsurface injection and for the land
application by subsurface injection on a site of approximately 1200 acres.
This permit shall be effective from the date of issuance until. April 30,
1983, and shall be subject to the conditions and iimitations as specified
therein.
If any parts, requirements, or IiT,Ilitations contained in th-is permit, are
unaccepLable to you, you have the right, to an adjudicatory hearing be' - ore a
hearing officer upon written demand to the Director within thirty (30) days
followin.- receipt of this permit, identifyinla,' the specific 1 s` Lrt s tO he
contended, U1:11Less sucIn demand is made, this permit shall be Iinal and biridina,.
One (1) set Of approved plans and sptcif ca;Lx.ons= is being forwarded to
you. If Nou have any quesLionS or need additional information concer'ning
this matter, please contact y1r. A. R- Hagstrom, tel-epbone No. 919/733-5083
Ent. 102.
Sincerely your
Original Signed By
FORREST R. WESTALL
FOR
Robert F e H e 1. TnS
"j Director
CC' Iredell County Health Departinent,
Mr. Forrest R, Westall
Mr. Richard Peace
Mooresville Regional Manager
N

NORTH QkROLINA
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT'
TAR dd
F F Tt M i T
For the Discharge of Sewage, Industrials Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General
Statutes at North Carolina as amended, ,and anger applicable Laws, Rules, and
Regulations
PEMIISSION IS HEREBY GRANTED TO
Holly Farms Poultry Industries, Inc.
Rowanoun ty and l y d l 1, County
FOR THE
construction and operation of an approximately 425,000 gallon sludge holding
lagoon used for the temporary steerage of sludge during periods when land
application of sludge cannot be accomplished in accordance with this Permit,
and For the a sur ac and application by injection of a maximum of 50,00
gallons/week of waste sludge from the Hare any Rendering Plant to a site
having ai total area.a, of approximately 1200 acres owned by Tyr. Richard W. Adams, "
and with no discharge to the surface waiters of the State,
pursuant to the application received October 18, 1982, and in co aiornity with
the project plans, specifications, and' other supporting data., Subsequently
filed and approved by the Department of NaturalResources anid Conmiunity
Development and considered a par,t of this Peraaaltu
'M- -, -Dn —. 4 r- �,I,�'T i k- ra. far f-i vlia� n'f d -,cz,a,qnrp im H I An r.t : 0LL
3
ds Permit No. 7911 dated February 9, 1983.
Foraat t slaal.i become,, voidable unless the facilities are ca, nsttaaCtE-2d an
d in accordance with the approved plans, specifications and other
porting data
Permit is effective only witla respect to thenature and volume of
i s described in the application used other supporting data.
facilities shall be properly maintained and operated at all ti,-,ks

it No. 7911RI
h 10, 1983
4
The slud3e handling and application operations shall be effectively maintained
and operated at all times so that there is no discharge to the surface waters,
nor any contamination of ground of ground water which will render them
unsatisfaztory for normal use. In event the operations fail to perform
satisfactorily, including the creaLion of nuisance conditions, or failure of
the applioation areas to adequately absorb the wastewater, the PermitLee, shall
take such immediate corrective action as may be required by the Division of
Environmental Management.
5. Diversion of the digested sludge from the sludge land application areas is
prohibited.
6. The over-all application program shall be effectively managed as as non -
discharge and non -spill operation to prevent the discharge of any sludge
during its collection, transportation, or application.
7. This peruit is not transferable.
8. The issuance of this permit shall not relieve Holly Farms Poultry Wdustries,
Incorporated of the responsibility of damages due to groundwater pollution.
9. Adequate provisions shall be taken to prevent wind erosion and surface
runoff from conveying pollutants from the sludge application area onto
the adjacent property and/or surface waters.
10, Sludge shall not be applied in inclement weather or until 24 hours following
as rainfall event of 0-inch or greater in 24 hours. Emergency sludge disposal
measures shall be approved by the Division of Environmental Management
11. No type of sludge other than that from the Harmony Rendering Plant shall be
placed on the disposal sites or stored in the lagoon.
12. only subsurface injection is to be used; therefore, a 50-foot buffer shall.
be maintained between each land owner's property line and any applied sludge,
and a 100-foot buffer ashall. be maintained between any residence and any
applied sludge.
IL The sites shall be adequately limed to a soil Q above 6.5 prior to sludge
application, and maintained at a Q above 6.5 during the duration of the
land's use for sludge applications.
14. No root or leaf crops for public consumption shall be raised on these sites.
15. Any monitoring deemed necessary by the Division of Environmental Management
to insure surface and groundwater protection will be established and an
acceptable sampling reporting schedule shall be followed.
16. Maximum slope for sludge application shall be 15% for subsurface applications.
1V Only subsurface injection is to be used; therefore, sludge will not be
applied within a 50-foot buffer ,one of any surface water, 25-feet of
surface drainage areas or erosion prone areas, 200-feet of any tributary'
of public water supply, 100-feet from any potable water supply, but may,
be applied up to the 100 year flood clevation contour

7 t No.
p 7911RI
IP 3 of 4
18. he boundaries of sludge application areas shall be delineated by markers.i
19 Animals should not be grazed on sludge applied laid with a. 60 day period
following the sludge application.
20. No sludge application shall. be made below the 100 -year flood level or to
flood prone areas.
1.., The sludge applications 'shall be uniform.
23. Me sludge application rates shall not exceed the following:
For sludge applied to Dr. Richard W.
Adam Property
(approximately 1200acres)
1. 240 lb . /ac c/year of plant available nitrogen
p
. ,000gallons/acre/year
3. o more time 1.78 lba . Cadmium/acre/year anr
4.45 lba. cad Waite l.if lacre.
(B.) he needs of the vegetative crops being grown based
upon current soil and sludge analyses.
. Where no vegetative covet' of crops are currently grown, a suitable vegetative
cover shall. be established and maintained.
24. All residents near the sludge application sites are to be advised of the
sludge application projects and then prior to any actual sludge application.
o public access shall be allowed on the site until. 12 months after'
applications have ceased
33 The perm .ttee at least six 6 months prior to the e piratiou of thI.s> permit,
shall request its d ton iou< Upon receipt of the request, the Commission will
ever the adequacy of the facilities described therein, and if indicated, will
extend the permit for such, period of time and under such conditions and
limitations as it may deem appropriate.
36;.. The land application sites shall be mooted with signs indicating that it
is bei.ng used for the "Land disposal_ of sludge from the Holly Farms Poultry
Rendering plant. in,Harmony, North Carolina".
27. The storage lagoon shall be secured with fencing and the area posted to
prevent unauthorized public access.
ado The freeboard in the holding, lagoon shall not be leas than 3 feet.
29., When time lagoon operation ceases, all stored sludge and residues in and
aro=d the site shall be removed from the site for subsurface land application
or incorporated on site into available soils. The lagoon and site shall_ be
Loft safe and clean d planted with a suitable vegetative cover.

er 1-0i t No. 7911RI
� March 10, 1983
-It
I'
f Z�
4 of 4
4 0 n
IPP30. nie amount of sludge that is placed in this storage o laC,con shallo nest exceed
10,000 GPD and 50,000 gallons/week. A permanent record shall be maintained
at the harmony Rendering Plant of the dates, amounts, source of each input
of sludge, and the level of the sludge holding lagoon,
31. A Permanent records log of sludge applications that includes amounts
applied, dates, coordinates of application, etc., shall be maintained at
the Harmony Rendering Plant as a permanent record.
32. In any future transfer of this 1&nd, a notice shal.1 be given to the new
owner that gives full details as to the materials applied or incorporated
at these sites.
33, If any nuisance condition arises concerning this land application system
including the transportation, storage, or application including creation
of ian odor problem, the Holly Farms Poultry Industries, Inc. shall
terniiiiate sludge disposal immediately after notification by the Division
of Environmental Management,
34. This permit shall become void unless the agreement between Holly Poultry
Industries, Inc. and Dr. Richard W. Adams for the use of approximately
1200 acres of his land for a storage lagoon and for the subsurface
application of sludge is in full force and effect.
Permit issued this the 10th day of March, 1983.
NORTH CAROLJNA J-V�IRONMENTAL KUNIAGEMFNT C01,01ISSION
C­'--, igm Y
FORREST R, WESTALL
FOR
'io�e s -,Di re c -to r---
Division of Environmental Management,
By Authority of the Environmental Management Commission
PerTidt No. 7911RI