WQ0003361_Final Permit_20090306

�ZA�
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mr. W. E. Lewis, Plant Manager
Oak -Bark Corporation
333 Neils Eddy Rd.,
Riegelwood, NC 28456
Dear Mr. Lewis:
Division of Water Quality
Coleen H, Sullins
Director
March 6, 2009
Dee Freeman
Secretary
Subject: Permit No. WQ0003361
Riegelwood, NC Manufacturing Facility
Closed -Loop Recycle System
Columbus County
In accordance with your permit modification request received January 7, 2009, and subsequent
additional information received March 2, 2009, we are forwarding herewith Permit No. WQ0003361,
dated March 6, 2009, to Oak -Bark Corporation for the operation of the subject closed -loop wastewater
recycle facilities.
This permit is being modified to reflect the change of permit type from groundwater remediation
to closed -loop recycle system. The Division understands that the two 2.3-MG lagoons will eventually be
closed out and this permit will be rescinded. Please see Condition I.1 and 1.2. for more detail regarding
the closing of the two lagoons.
This permit shall be effective from the date of issuance until February 28, 2014, shall void Permit
No. WQ0003361 issued September 9, 2003, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will
result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please contact Chonticha McDaniel at
[phone] or [e-mail].
AQUIFER PROTECTION SECTION
16Y i.'a: Service Cenw, Raleigh. North Carolina 27699-1635
Locatior; 2728 Capital Boulevard. Raleigh. North Carolina 276(Y
Phone- 919-733.3221 1 FAX 1: 919-715-0$86; FAX 2: 919-715-6048 t Custome' Service: 1-87 7-623-6W
Internet www.ncwateruuality.org
O
Nb ehCarohna
An EquG: Oppor'.:r ty, ; Af rMF,:ve AG; on Employer

Mr. Lewis
March 6, 2009
Page 2 of 2
Sincerely,
for oleen H. Sullins
cc: Colunbus County Health Department
Wilmington Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
LAU Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
CLOSED -LOOP RECYCLE SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Oak -Bark Corporation
Columbus County
FOR THE
operation and maintenance of two lined and capped 2.3-million gallon lagoons (static, no transfers in or
out) with a 36-millimiter reinforced Hypalon geomembrane liner, to serve Oak -Bark Corporation, with no
discharge of wastes to the surface waters, pursuant to the application received January 7, 2009, and
subsequent additional information received by the Division of Water Quality (Division), and in
conformity with the project plan, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until February 28, 2014, shall void Permit
No. WQ0003361 issued September 9, 2003, and shall be subject to the following specified conditions and
limitations:
I. SCHEDULES
1. The Wilmington Regional Office shall be notified in writing at least 30 days prior to the closure of
the two lagoons. The lagoon closing procedure shall be in accordance with the Division's guidelines
for the closure of treatment ponds and lagoons (attached memorandum).
2. Within 30 days after the completion of lagoon closure, the Permittee shall submit a permit rescission
request to the Division (NCDENR-DWQ, Aquifer Protection Section, 1636 Mail Service Center,
Raleigh, NC 27699-1636).
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note that Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
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II. PERFORMANCE STANDARDS
1. The closed -loop recycle system shall be effectively maintained and operated at all times so that there
is no discharge to the surface waters, nor any contravention of groundwater or surface water
standards. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate
corrective actions including those actions that may be required by the Division, such as the
construction of additional or replacement wastewater treatment, recycle, or disposal facilities.
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to ground
or surface waters resulting from the operation of this facility.
III. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities shall be properly maintained and operated at all times. The facilities shall be effectively
maintained and operated as a non -discharge system to prevent the discharge of any wastewater
resulting from the operation of this facility. The Permittee shall maintain an Operation and
Maintenance Plan pursuant to 15A NCAC 02T .1007 including operational functions, maintenance
schedules, safety measures, and a spill response plan.
2. Upon classification of the wastewater treatment and closed -loop recycle facilities by the Water
Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee shall
designate and employ a certified operator to be in responsible charge (ORC) and one or more certified
operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 08G .0200. The
ORC shall visit the facilities in accordance with 15A NCAC 08G .0200 or as specified in this permit
and shall comply with all other conditions specified in these rules.
3. Public access to the wastewater treatment equipment, wastewater storage structure(s), and closed -loop
recycle system shall be controlled.
4. The residuals generated from these treatment facilities must be disposed / utilized in accordance with
15A NCAC 02T .1100. The Permittee shall maintain a residual management plan pursuant to 15A
NCAC 02T .1008.
5. Diversion or bypassing of untreated wastewater from the treatment facilities is prohibited.
6. A protective vegetative cover shall be established and maintained on all earthen basin embankments
(outside toe of embankment to maximum allowable temporary storage elevation on the inside of the
embanlanent), berms, pipe runs, erosion control areas, and surface water diversions. Trees, shrubs,
and other woody vegetation shall not be allowed to grow on the earthen basin dikes or embankments.
Earthen basin embankment areas shall be kept mowed or otherwise controlled and accessible.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed
necessary by the Division to ensure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
2. All laboratory analyses for effluent, ground waters, or surface waters shall be made by a laboratory
certified by the Division for the required parameter(s) under 15A NCAC 02H .0800.
3. A record shall be maintained of all residuals removed from this facility. This record shall include the
name of the hauler, permit authorizing the disposal or a letter from a municipality agreeing to accept
the residuals, date the residuals were hauled, and volume of residuals removed.
WQ0003361 Version 3.0 SheE Version 090204 Page 2 of 4

4. Monitor wells shall be sampled at the frequencies and for the parameters specified in Attachment A.
All napping, well construction forms, well abandonment forms, and monitoring data shall refer to the
permit number and the well nomenclature as provided in Attachment C and Figure 2.
Two (2) copies of the results of the sampling and analysis must be received on Form GW-59
(Groundwater Quality Monitoring: Compliance Report Form), along with attached copies of
laboratory analyses, by the Division of Water Quality, Information Processing Unit, 1617 Mail
Service Center, Raleigh, North Carolina 27699-1617 on or before the last working day of the month
following the sampling month. Form GW-59 shall include the number of this permit and the
appropriate well identification number. One Form GW-59a certification form shall be provided for
each set of sampling results submitted.
6. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (910)
796-7215, 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 at the wastewater treatment facility which results in the treatment of significant
amounts of wastes which are abnormal in quantity or characteristic, such as the dumping of the
contents of a basin or tank; the known passage of a slug of hazardous substance through the
facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate wastewater treatment such as mechanical or electrical failures of pumps, aerators,
compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass directly to
receiving waters.
d. Any time that self -monitoring information indicates that the facility has gone out of compliance
with its permit requirements.
For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300. Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the actions
taken or proposed to be taken to ensure that the problem does not recur.
V. INSPECTIONS
I. Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation
of the subject facilities.
2. The Permittee or his designee shall inspect the wastewater treatment 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 Permittec shall keep an
inspection log or summary including at least the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall
be maintained by the Permittee for a period of five years from the date of the inspection and shall be
made available upon request to the Division or other permitting authority.
WQ0003361 Version 3.0 Shell Version 090204 Page 3 of 4

3. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the disposal site or
facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be maintained under the terms and conditions of this permit,
and may obtain samples of groundwater, surface water, or leachate.
V1. GENERAL CONDITIONS
1. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statute 143-
215.6A to 143-215.6C.
2. This permit shall become voidable unless the facilities are constructed in accordance with the
conditions of this permit, the approved plans and specifications, and other supporting data.
3. This permit is effective only with respect to the mature and volume of wastes described in the
application and other supporting data. No variances to applicable rules governing the construction
and / or operation of the permitted facilities are granted unless specifically requested and granted in
this permit.
4. The issuance of this permit does not exempt 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) that have jurisdiction. Of particular concern to the Division are applicable river buffer
rules in 15A NCAC 02B .0200, erosion and sedimentation control requirements in 15A NCAC
Chapter 4 and under the Division's General Permit NCG010000, and any requirements pertaining to
wetlands under 15A NCAC 02B .0200 and 02H .0500.
5. In the event there is a desire for the facilities to change ownership, or there is a name change of the
Permittee, a formal permit request must be submitted to the Division on official Division form(s),
documentation from the parties involved, and other supporting materials as may be appropriate. The
approval of this request will be considered on its merits and may or may not be approved. The
Permittee of record shall remain fally responsible for compliance until a permit is issued to the new
owner.
The Permittee shall retain a set of approved plans and specifications for the life of the facilities
permitted herein.
7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority.
8. The Permittee must pay the annual fee within thirty (30) days after being billed by the Division.
Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit
pursuant to 15A NCAC 02T .0105(e).
Permit issued this the 6t' of March, 2009
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
i
een . Sullins, Director
Divis'& of 'Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0003361
WQ0003361 Version 3.0 Shell Version 090204 Page 4 of 4

ATTACHMENT A — GROUNDWATER MONITORING AND LIMITATIONS
Monitoring wells: MW-22, MW-23, MW-25, and MW-26.
Permit Number: WQ0003361. Version: ,..►
GROUNDWATER CHARACTERISTICS
GROUNDWATER STANDARDS
MONITORING REQUIREMENTS
Parameter Description - Parameter Code
Daily Maximum
Frequency Measurement
Sample Type
Footnotes
Water level, distance from measuring point - 82546
Annually
Calculated
a, b
pli - 00400
6.5 - 8.5
su
Annually
Grab
a
Solids, Total Dissolved- 180 Deg.0 - 70300
500
mg/1
Annually
Grab
Sulfate, Total (as SO4) - 00945
250
mg/1
Annually
Grab
Nitrogen, Ammonia Total (as N) - 00610
10
Annually
Grab
Nitrogen, Nitrate Total (as N) - 00620
mg/I
Annually
Grab
Volatile Compounds. (GCIMS) - 78732
Annually
Grab
c, d
Carbon. Tot Organic (TOC) - 00680
Annually
Grab
e
Methanal (formaldehyde) Whole Water.ug/L - 76995
Annually
Grab
f
a. The measurement of water levels shall he made prior to purging the wells. The depth to water in each well shall he measured from the surveyed point on the top of the casing. The measurement
of pil shall be made after purging and prior to sampling for the remaining parameters.
b. The measuring points (top of well casing) of all monitoring wells shall be surveyed to provide the relative elevation of the measuring point for each monitoring well. The measuring points (top
of casing) of all monitoring wells shall be surveyed relative to a common datum.
c. Volatile Organic Compounds (VOC) - In November only, analyze by one of the following methods:
I. Standard Method 6230D. PQL at 0.5 pg/ . or less
2. Standard Method 62I01), PQL at 0.5 µg/L or less
3. EPA Method 8021. Low Concentration. PQL at 0.5 rag/L or less
4. EPA Method 8260, Low Concentration. PQL at 0.5 µg/L or less
5. Another method with prior approval by the Aquifer Protection Section Chief
Any method used must meet the following qualifications:
a. A laboratory must be DWQ certified to run any method used.
b. The method used must, at a minimum. include all the constituents listed in Table Vill of Standard Method 6230D.
c. The method used must provide a PQL of 0.5 pgll, or less that must be supported by laboratory proficiency studies as required by the DWQ Laboratory Certification Unit. Any constituents
detected above the MDL but below the PQL of 0.5 lag/L must be qualified (estimated) and reported.
d. If any volatile organic compounds (VOC) are detected as a result of monitoring as provided in Attachment C. then the Wilmington Regional Office Aquifer Protection Supervisor, telephone
number [phone], must be contacted immediately for further instructions regarding any additional follow-up analyses required.
e. If TOC concentrations greater than 10 mg/l are detected in any downgradient monitoring well, additional sampling and analysis must be conducted to identify the individual constituents
comprising this Too concentration. If the TOC concentration as measured in the background monitor well exceeds 10 mg/l, this concentration will be taken to represent the naturally occurring
TOC concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient wells shall be subject to the additional sampling and analysis as described above.
f. Sampled in monitoring wells MW-23 and M W-26 only,
Note: Monitoring wells shall be reported consistent with the nomenclature and location information provided in Figure 2 and this attachment.
WQ0003361 Version 3.0 Attachment A Page I of 1

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OAK -BARK LINEDICAPPED LAGOONS (KELLY PONDS)
PERMIT NO. WQ0003361
COLUMBUS COUNTY
PROPERTY BOUNDARY.}
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MW22-,
MW25
COMPLIANCE BOUNDARY- \
L-MW26
POTABLE WATER SUPPLY WELLS
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WATER POLLUTION CONTROL SYSTEM OK--ATORS
CERTIFICATION COMMISSION
CLASSIFICATION
RATING SHEET FOR WATER POLLUTION CONTROL SYSTEMS
FACILITY INFORMATION:
NAME OF FACILITY:
— 1341v-lz�- 61'c"-
MAILING ADDRESS: Hr� CIS l c / f l e il'0// _
COUNTY: 0 L Leal, 5
CONTACT PERSON: Cv(j TELEPHONE: (% l
PERMIT NO: L 73�/ Check One: NC WQ -------HEALTH DP,_
c
ORC; l ~ I TELEPHONE: Vic)JIC'��
RATING INFORMATION: (Before completing this section, please refer to pages 2-4)
PERMITTED FLOW: (1 MGD BNR? YES NO
CHECK CLASSIFICATION: WASTEWATER: 1 2 3 4
COLLECTION: 1 2 3 4
SPRAY IRRIGATION SUBSURFACE
PHYSICAUCHEMICAL GRADE I
LAND APPLICATION
GRADE II
RATED BY: a S r-4 REGION: DATE:
REGIONAL OFFICE TELEPHONE NUMBER: Zf EXT:
P0 a C'b V
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Classification of Biological Water Pollution Control Treatment Systems:
Grade I Biological WPCS
- Septic tank/sand filter systems
- Biological lagoon systems
- Constructed wetlands and associated appurtenances
Grade II Biological WPCS
- Systems that utilize an activated sludge or fixed growth process with a permitted flow
less than or equal to 0.5 million gallons per day (mgd)
Grade III Biological WPCS
- Systems that utilize an activated sludge or fixed growth process with a permitted flow
of greater than 0.5 through 2.5 million gallons per day (mgd)
- Grade Il systems that are required to achieve biological nutrient reduction
Grade IV Biological WPCS
- Systems that utilizing an activated sludge or fixed growth process with a permitted flow
of greater than 2.5 million gallons per day (mgd)
- Grade III systems that are required to achieve biological nutrient reduction
* Biological Nutrient Reduction -
The reduction of total nitrogen or total phosphorous by an activated sludge or fixed growth
process as required by the facilities permit.
Classification of Collection Water Pollution Control Systems:
(whichever provides lowest grade)
Same grade as biological water pollution control system. Grade of systern:
Based on population served:
1,500 or Less = Grade I
1,501 to 15,000 = Grade H
15,001 to 50,000 = Grade III
50,001 or more = Grade 1V

Classification of Spray Irrigation Water Pollution Control Systems: -
Systems which utilize spray irrigation for the reuse or disposal of waster -water.
These systems include: septic tanks, sand filter, oil/water separators, lagoons,
storage basins, screening, sedimentation. Systems other than those listed above .=.,
shall be subject to additional classification.
-----------------------------------------------------------------------------------------------------------------------
Classification of Land Application of Residuals Systems:
.1=
Systems permitted and dedicated for land application of residuals that are produced by a
water pollution control system or contaminated soils.
Classification of Physical/Chemical Water Pollution Control Treatment Systems:
k.E
Grade I Physical/Chemical: Any water pollution control'system that utilizes a primarily
physical process to treat wastewater. This classification includes groundwater
remediation systems. **
Grade II Physical/Chemical: Any water pollution control system that utilizes a primarily
chemical process to treat wastewater. This classification includes reverse osmosis,
electrodialysis, and ultrafiltration systems. **
** Any water pollution control system that utilizes a phyical/chemical process to enhance an
activated sludge or fixed growth process, shall not be subject to additional classification.
Classification of Subsurface Water Pollution Control Systems:
Systems which utilize the'soil for subsurface treatment and disposal of wastewater
and/or are required to have a certified operator under 15A NCAC 18A.1961. ***
*** Any subsurface system that has as part of its treatment process a water pollution control
systems that may be classified under Rules .0302 through .0307 of this section shall be
subject to addional classification.

August 18, 2003
MEMORANDUM
TO: Groundwater Regional Supervisors
Permits & Compliance Unit
Operations Branch
FROM: Arthur Mouberry, F.E.
Chief, Groundwater Section
SUBJECT: Guidelines for the Closure of Treatmeni Ponds and Lagoons
Purpose: The purpose of these. guidelines is to protect the quality of the groundwater resources
of the state while accomplishing the closure of treatment pond or lagoon.
Background: Man-made treatment ponds and lagoon type structures are used to contain fluids
and semi -solids for a variety of reasons. As these ponds and lagoons become no longer
necessary, the structure needs to be abandoned in an environmentally friendly manner. The
Groundwater Section's major concern with the elimination of these structures is that
groundwater remains protected both during and after abandonment. Each structure must be
considered for its unique circumstances on a case -by -case basis.
Regulations relevant to the abandonment of ponds and lagoons for ;round waters of the state
include the Classifications and Water Quality Standards found in Title 1 SA NCAC 2L. Other
pertinent standards and regulations maybe found in the DENR Land Resources regulations
pertaining to Sedimentation and Erosion Control and Dane Safety, the DENR Waste
Management regulations pertaining to the disposal of wastes and sludge, and the NCDOT
regulations pertaining to transportation of materials on public highways. Lagoons for animal
waste are regulated under the federal MRCS Standards.
Recommended Procedure-,
The major elements of pond and lagoon structures include the contents, the walls, the floor and
the liner, if one exists. Each element must be characterized for its quantity and material
properties in order to prepare a closure plan. Guidelines for the preparation of this plan are
described in the following steps:
1} Collect and assemble field information by characterizing the structural elements and liquid
contents, including bottom sludge in the impoundment. Sampling will be required in most
situations, and the types of sampling and analyses will depend on factors such as what the
lagoon was used for, its construction materials (earthen, concrete, natural or synthetic Iiner),
and size. The samples must be representative of the medium sampled, and the rationale for
the depths, locations and number of samples should be justified and documented in
preparation of being legally defensible. The sampling must be performed under the direction
Lagoon Closure final.doc Page } oF3

of a qualified individual and analyzed by a DWQ Certified Laboratory,
?) Prepare and submit a Closure Plan to the DWQ regional office at least 30 dads prior to
commencin, deconstruction activities. This should include as a minimum:
a. the quantity and characteristics (TCLP, nutrients, metals) of the materials for disposal
(contents, walls, floor and liner), including the calculations used to determine
volumes,
b. an assessment of alternatives (actions, costs and timing) in sufficient detail to select
an optimum approach consistent with minimal groundwater impact,
c. a proposed method for removal/disposal, including the abandonment and salvage of
any physical equipment, and a timetable for the project,
d. site reclamation plan and section view of the treatment, storage and disposal area(s),
e. vicinity map, and
f. location map to scale showing items such as the location of sampling points, existing
monitoring and supply wells (within 500 feet), depth to groundwater, direction of
groundwater flow, roads, structures, and rock outcrops.
3) If the structure is to be retained for an orriamental pond, storage or any other function other
than for treatment, then the Closure Plan will need to demonstrate that the residuals of
treatment (e.g. physical connections, bottom sludge, coliforms, nutrients and metals) conform
to all appropriate surface water standards.
4) If the structure is to be abandoned in place (totally or partially), sampling of the underlying
native soil, whether it has a natural or synthetic liner, is required. If the sampling determines
that the soil is contaminated, then the Closure Plan will need to demonstrate, by modeling or
numerical calculations, that leaving the contents and or structure materials in place will not
cause a contravention of the groundwater quality standards in the groundwater beneath the
structure. If the modeling does not demonstrate this, than removal or treatment of the soils
must be included as part of the Closure Plan.. If it were an earthen structure, the preferable
approach would be to completely eliminate the walls and incorporate the material in the
existing site.
5) Any land disturbing activity associated with the closure activities that affect more than one
(1) acre of land must have an erosion and sediment control plan approved by the Land
Quality Section of the Division of Land Resources. NC General Statute 113A-57(4) requires
this plan to be submitted at least thirty (30) days prior to beginning the land -disturbing
activity.
Closure Documentation:
Upon completion of the closure, the owner should submit documentation to the DWQ regional
office with the following:
1) A description of all actions taken and dates relative to the abandonment.
Lagoon Closure final.doc Page 2 or3

2) Copies of all pertinent correspondence with private, local, state and/or federal agencies,
IP
3) Ultimate disposal sites with weigh tickets or processing verifications, as appropriate,
4) Certification by a Professional Engineer (PE) or Professional Geologist (i'G) if the pond or
lagoon:
a. is greater than five (5) acres in total area,
b. contains hazardous substances as defined by TCLP tests, or
c. involves a breaching of a dam, which could impose a safety hazard to persons or
property below it,
Lagoon Closure final.doc rage 3 ni3