WQ0003456_Final Permit_20031124

�oF W ATF9Q Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
zi
p Alan W. Klimek, P.E., Director
Division of Water Quality
November 24, 2003
Mr. Douglas E. Cregar, Vice President
National Starch and Chemical Company
10 Finderne Avenue
Bridgewater, NJ 08807
Subject: Permit No. WQ0003456
Leland Plant, Groundwater Remediation System
Wastewater Surface Irrigation
Brunswick County
Dear Mr. Cregar:
In accordance with your request for modification of your permit as a result of an adjudicary hearing filing, we are
forwarding herewith Permit No. WQ0003456, dated November 24, 2003, to the National Starch and Chemical Company for
the continued operation of the subject groundwater remediation and surface irrigation facilities. This permit is being issued
to modify the language of Condition IV 5.
This permit shall be effective from the date of issuance until May 31, 2008, shall void Permit No. WQ0003456
issued June 25, 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 Sue Homewood at [phone]
extension 502.
Sincerely,
9? rye
Alan W. Klimek, P.E.
cc: Brunswick County Health Department
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Groundwater Section, Central Office
Dan Shields, Law Engineering and Environmental Services Inc.
Technical Assistance and Certification Unit
Water Quality Central Files
NDPU Files
MNon-Discharge Permitting Unit Internet httpa/h2o.enrsiate.nc.uslndpu EI R
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE IRRIGATION 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
National Starch and Chemical Company
Brunswick County
FOR THE
continued operation of a 25,920 GPD groundwater remediation facility and surface irrigation disposal facility
consisting of five extraction wells each with a 1/2 Hp submersible pump, two 16,500 gallon aeration basins with
fine bubble diffusers, dual blower units capable of 220 scfm, dual 2 Hp transfer pumps, a flow meter, a PLC
automatic control system with manual override capability, and all associated piping, valves, controls, alarms and
appurtenances with the treated groundwater being disposed into a 1.3 million gallon, lined polishing pond and
disposed on a 20 acre spray irrigation field to serve the National Starch and Chemical Company - Leland Plant,
with no discharge of wastes to the surface waters, and in conformity with the project plan, specifications, and
other supporting data 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 May 31, 2008, shall void Permit No.
WQ0003456 issued June 25, 2003, and shall be subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The surface irrigation facilities 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 the event that the facilities fail to perform satisfactorily, including
the creation of nuisance conditions or failure of the irrigation area to adequately assimilate the
wastewater, the Permittee shall take immediate corrective actions including those actions that may be
required by the Division of Water Quality (Division), such as the construction of additional or
replacement wastewater treatment and disposal facilities.
2. 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.
3. The residuals generated from these treatment facilities must be disposed in accordance with General
Statute 143-215.1 and in a manner approved by the Division.
4. Diversion or bypassing of the untreated wastewater from the treatment facilities is prohibited.

The following buffers shall be maintained:
a) 400 feet between wetted area and any residence or places of public assembly under separate
ownership,
b) 150 feet between wetted area and property lines,
c) 100 feet between wetted area and wells,
d) 100 feet between wetted area and drainage ways or surface water bodies,
e) 50 feet between wetted area and public right of ways,
f) 100 feet between treatment/storage units and any wells, and
g) 50 feet between treatment units and property lines.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the wastewater treatment and irrigation facilities by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), the Penn-uttee 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 8G .0201. The ORC shall visit
the facilities in accordance with 15A NCAC 8G .0204 or as specified in this permit and shall comply
with all other conditions specified in these rules.
3. A suitable year round vegetative cover shall be maintained on all irrigation areas.
4. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause runoff.
5. Adequate measures shall be taken to prevent wastewater runoff from the irrigation field.
6. 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.
7. The application rate shall not exceed a cumulative loading of 52.0 inches over any twelve (12) month
period at an instantaneous application rate not to exceed 0.25 inches per hour. The application rate
shall also not exceed the annual agronomic needs of the cover crop.
8. No type of wastewater other than that from the National Starch and Chemical Company Leland Site
Groundwater Remediation System shall be irrigated onto the irrigation area.
9. No traffic or equipment shall be allowed on the disposal area except while installation occurs or while
normal maintenance is being performed.
10. Public access to the land application sites shall be controlled during active site use. Such controls
may include the posting of signs showing the activities being conducted at each site.
11. Freeboard in the polishing pond shall not be less than two feet at any time.
12. If not already installed, a waste -level gauge, to monitor waste levels in the polishing pond, shall be
installed within 60 days of issuance of this pernut. This gauge shall have readily visible permanent
markings indicating the maximum liquid level and top of the' dam elevations. Caution must be taken
not to damage the integrity of the liner when installing the gauge.
13. A protective vegetative cover shall be established and maintained on all earthen basin embankments
(outside toe of embankment to maximum pumping elevation), 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.
2

III. MONITORING AND REPORTING RE UIREMENTS
Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed
necessary by the Division to insure surface and ground water protection will be established and an
acceptable sampling reporting schedule shall be followed.
2. Flow of pumped groundwater into the aeration basins shall be monitored and daily flow values shall
be reported on Form NDMR.
3. The influent to the aeration basin and the effluent the point just prior to mixing with any other
wastewater (or just prior to direct irrigation if only remediated groundwater is irrigated) shall be
monitored by the Permittee every March, July, and November for the following parameters:
Volatile Organic Compounds - use only one of the following methods:
1) Standard Method 6230D, Practical Quantitation Limit (PQL) at 0.5 ug/L or less
2) Standard Method 6210, PQL at 0.5 ug/L or less
3) EPA Method 8021, Low Concentration, PQL at 0.5 uglL or less
4) EPA Method 8260, Low Concentration, PQL at 0.5 ug/L or less
5) Another method with prior approval by the Groundwater Section Chief.
Any of the referenced methods used for VOCs must at a minimum, include all the
constituents listed in Table VIII of Standard Method 6230D. Any method used must provide
a PQL of 0.5 ug/L or less, which must be supported by laboratory proficiency studies as
required by the DWQ Laboratory Certification Unit. Any constituents detected above the
Method Detection Limit (MDL) but below the PQL of 0.5 ug/L must be qualified (estimated)
and reported.
4. Adequate records shall be maintained by the Permittee tracking the amount of wastewater disposed.
These records shall include, but are not necessarily limited to, the following information:
a. date of irrigation,
b. volume of wastewater irrigated,
c. field irrigated,
d. length of time field is irrigated,
e. continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for each field,
f. weather conditions, and
g. maintenance of cover crops.
5. Freeboard in the polishing pond shall be recorded weekly.
Three (3) copies of all monitoring data (as specified in condition III 2 and I113) on Form NDMR-1
and three (3) copies of all operation and disposal records (as specified in condition III 4, and 1115) on
Form NDAR-1 shall be submitted monthly on or before the last day of the following month. All
information shall be submitted to the following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted on each
irrigation field and the results maintained on file by the Permittee for a minimum of five years. The
Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the following
parameters:

Acidity Manganese Potassium
Calcium Percent Humic Matter Sodium
Copper pH Zinc
Magnesium Exchangeable Sodium Percentage Phosphorus
Cation Exchange Capacity Base Saturation (by calculation)
8. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (910)
395-3900, 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 sludge digester; 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 without treatment of all or any portion of the influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility has gone out of compliance
with its permit limitations.
Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].
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.
IV. GROUNDWATER REQUIREMENTS
Monitor wells MW-9, MW-l7 and MWA 8 shall be sampled every March, July and November for the
parameters listed below. Prior to sampling the parameters, the measurement of water levels must be
taken. The depth to water in each well shall be measured from the surveyed point on the top of the
casing. The measuring points (top of well casing) of all monitoring wells shall be surveyed relative to
a common datum.
Water level pH Total Dissolved Solids
Chloride Lead Total Ammonia Nitrogen
Nitrate Volatile Organic Compounds — in November only
For Volatile Organic Compounds (VOCs), use only one of the following methods:
1) Standard Method 6230D, Practical Quantitation Limit (PQL) at 0.5 ug/L or less
2) Standard Method 6210, PQL at 0.5 ug/L or less
3) EPA Method 8021, Low Concentration, PQL at 0.5 ug(L or less
4) EPA Method 8260, Low Concentration, PQL at 0.5 ug/L or less
5) Another method with prior approval by the Groundwater Section Chief.
4

Any of the referenced methods used for VOCs must at a minimum, include all the constituents listed
in Table VIII of Standard Method 6230D. Any method used must provide a PQL of 0.5 ug/L or less,
which must be supported by laboratory proficiency studies as required by the DWQ Laboratory
Certification Unit. Any constituents detected above the Method Detection Limit (MDL) but below
the PQL of 0.5 ug/L must be qualified (estimated) and reported.
2. Any laboratory selected to analyze parameters must be Division of Water Quality (DWQ) certified
for those parameters required.
All reports and documentation shall be mailed to the following address:
Groundwater Section.
Permits and Compliance Unit
1636 Mail Service Center
Raleigh, NC 27699.1636
Updated blank forms (GW-1, GW-30, GW-59) may be downloaded from the Groundwater Section's
website at htt :// w.ehnr.state.ne.us/ or requested from the address mentioned above.
4. The results of the sampling and analysis must be received on Form GW-59 (Groundwater Quality
Monitoring: Compliance Report Form) by the Groundwater Section (address listed in the "Reporting
/ Documentation" section of the Groundwater Requirements), on or before the last working day of the
month following the sampling month. The data of all groundwater sampling analyses required by the
permit conditions must be reported using the most recent GW-59 form along with attached copies of
the laboratory analyses.
5. Surface irrigation activities should not occur when the vertical separation between the land surface
and the actual water table is at less than three (3) feet. If this vertical separation cannot be met as
demonstrated by measurements taken at in -field piezometers, then a demonstration must be made
using predictive calculations from recent (raid-2001) monitoring data that show the use of this
irrigation field will not result in the contravention of assigned standards at its Compliance Boundary.
Continued favorable groundwater samplings that meets or exceeds all groundwater standards are
considered acceptable predictive calculations for this specific permit. In addition, elimination of
rainwater and non -treated well water from the waste disposal system should be considered for
reduction of the hydraulic loading to this field.
6. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary for the disposal system
individually permitted prior to December 30, 1983 is established at either 500 feet from the waste
disposal area, or at the property boundary, whichever is closest to the waste disposal area. An
exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is subject to
remediation action according to 15A NCAC 2L .0106(d)(2).
7. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards at
the Review Boundary shall require action in accordance with 15A NCAC 2L .0106(d)(1).
Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to insure 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 Permittee shall keep an
inspection log or summary including at least the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall
be maintained by the Permittee for a period of three years from the date of the inspection and shall be
made available upon request to the Division or other permitting authority.
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.
VI. GENERAL CONDITIONS
1. 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.
2. This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data.
3. This permit is not transferable. In the event there is a desire for the facilities to change ownership, or
there is a name change of the Permittee, a formal permit request must be submitted to the Division
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. 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.
5. 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) which have jurisdiction, including but not limited to applicable river buffer rules in 15A
NCAC 2B .0200, erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under
the Division's General Permit NCGOl00OO, and any requirements pertaining to wetlands under 15A
NCAC 2B .0200 and 2H .0500.
6. A set of approved plans and specifications for the subject project must be retained by the Permittee
for the life of the project.
7. The annual administering and compliance fee must be paid by the Permittee within thirty (30) days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division to
initiate action to revoke this permit as specified by 15A NCAC 2H .0205 (c)(4).

The Permittee, at least six (6) months prior to the expiration of this permit, shall request its extension.
Upon receipt of the request, the Commission will review the adequacy of the facilities described
therein, and if warranted, will extend the permit for such period of time and under such conditions
and limitations as it may deem appropriate.
Permit issued this the 24 h day of November, 2003
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0003456