WQ0003456_Final Permit_19980430

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
April 30, 1998
Mr. Douglas E. Cregar, Div. Vice President
National Starch and Chemical Company
10 Finderne Avenue
Bridgewater, NJ 08807
Dear Mr. Cregar:
4 •
-NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOuRCEs
Subject: Permit No. WQ0003456
National Starch and Chemical Company
Leland Plant, Groundwater Remediation
Wastewater Spray Irrigation
Brunswick County
In accordance with your application received December 1, 1997, we are forwarding herewith Permit No.
WQ0003456, dated April 30, 1998, to National Starch and Chemical Company for the continued operation of the
subject wastewater treatment and spray irrigation facilities. This permit reissuance includes a name change from
C,T, Specialties Corp. to National Starch and Chemical Co., the removal of the industrial wastewater from C.T.
Specialties Corp, by discharge into the Leland Industrial Park WWTP, and renewal of the permit for spray
irrigation of remediated groundwater only.
This permit shall be effective from the date of issuance until March 31, 2003, shall void Permit No.
WQ0003456 issued September 27, 1996, 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, P.O. Drawer 27447, Raleigh, NC 27611-7447.
Unless such demands are made this permit shall be final and binding.
If you need additional infonnation concerning this matter, please contact Mr. Randy Kepler at (919) 733-
5083 extension 544.
cc: Brunswick County Health Department
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
PO Sox 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Sincerely,
i
i
l-A. Preston Howard, Jr., P.E.
Telephone [phone] Fax [phone]
50% recycied110% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
I."40111":I
SPRAY 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 spray irrigation disposal facility
consisting of five extraction wells each with a '/z 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 polishing pond and disposed
on a 20 acre spray irrigation field to serve National Starch and Chemical Company, with no discharge of wastes to
the surface waters, pursuant to the application received December 1, 1997, 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 march 31, 2003, shall void Permit No.
WQ0003456 issued September 27, 1998, and shall be subject to the following specified conditions and limitations:
L PERFORMANCE STANDARDS
I . The spray 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 we]Is,
d) 100 feet between wetted area and drainageways or surface water bodies,
e) 50 feet between wetted area and public right of ways,
f) 100 feet between wastewater treatment units and wells, and
g) 50 feet between wastewater treatment units and property lines.
Some of the buffers specified above may not have been included in previous permits for this waste
treatment and disposal system. These buffers are not intended to prohibit or prevent modifications,
which are required by the Division, to improve performance of the existing treatment facility. These
buffers do, however, apply to modifications of the treatment and disposal facilities which are for the
purpose of increasing the flow that is tributary to the facility. These buffers do apply to any expansion
or modification of the spray irrigation areas and apply in instances in which the sale of property would
cause any of the buffers now complied with, for the treatment and disposal facilities, to be violated.
The applicant is advised that any modifications to the existing facilities will require a permit
modification.
IL OPERATION AND MAINTENANCE REQUIREMENTS
The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall employ a certified wastewater treatment plant operator
to be in responsible charge (ORC) of the wastewater treatment facilities. The operator must hold a
certificate of the type and grade at least equivalent to or greater than the classification assigned to the
wastewater treatment facilities by the WPCSOCC. The Permittee must also employ a certified back-up
operator of the appropriate type and grade to comply with the conditions of 15A NCAC 8A .0202. The
ORC of the facility must visit each Class I facility at least weekly and each Class II, III, and IV facility
at least daily, excluding weekends and holidays, and must properly manage and document daily
operation and maintenance of the facility and must comply with all other conditions of 15A NCAC 8A
.0202
A suitable year round vegetative cover shall be maintained.
4. Irrigation shall not be performed during inclement weather or when the ground is in a condition that
will cause runoff.
Adequate measures shall be taken to prevent wastewater runoff from the spray field.
b. 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 application rate shall not exceed a cumulative loading of 52.0 inches over any twelve 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.
No type of wastewater other than that from National Starch and Chemical Company's Leland site shall
be sprayed onto the irrigation area.
No traffic or equipment shall be allowed on the disposal area except while installation occurs or while
normal maintenance is being performed.
2

I0. 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.
l l _ Freeboard in the polishing pond shall not be Iess than two feet at any time.
III. MONITORING AND REPORTING REQUIREMENTS
1. 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. 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.
3. The effluent from the subject groundwater remediation facilities shall be monitored at the point just
prior mixing with any other wastewaters (or just prior to direct spray irrigation if only remediated
groundwater is sprayed) every March, July, and November for the following parameters:
Volatile Organic Compounds - by Method 6230D (Capillary -Column), "Standard
methods for The Examination of Water and Wastewater", 17th ed., 1989
4. Three (3) copies of all operation and disposal records (as specified in condition II1 2) on Form NDAR-
I shall be submitted on or before the last day of the following month. Three (3) copies of all effluent
monitoring data (as specified in condition III 3) on Form NDMR-1 shall be submitted 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
Post Office Box 29535
Raleigh, North Carolina 27626-0535
5. A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted on each
spray 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 Phosphorus
Cation Exchange Capacity Base Saturation (by calculation)
3

6. 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.
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.
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
1. Monitor wells MW-9, MW-l7, and MW-18 shall be sampled every March, July, and November for the
following parameters:
Water Level pH
Chloride Total Dissolved Solids (TDS)
Fecal Coliform Lead
Nitrate (NO3) Total Ammonia (as N)
Volatile Organic Compounds - In November only using one of the following:
A) Standard Method 6230D, PQL at 0.5 ug/L or less
B) Standard Method 621 OD, PQL at 0.5 ug/L or less
C) EPA Method 8021, Low Concentration, PQL at 0.5 ug/L or less
D) EPA Method 8260, Low Concentration, PQL at 0.5 ug/L or less
E) Another method with prior approval by the Groundwater Section Chief
Any method used must meet the following qualifications:
1) A laboratory must be DWQ certified to run any method used.
2) The method used must, at a minimum, include all the constituents listed in Table VIII of
Standard Method 6230D.
3) The method used must provided a PQL at 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 MDL but below the PQL at 0.5 ug/L must be qualified
(estimated) and reported.
If any volatile organic compounds are detected by the methods listed, then the Wilmington Regional
Office Groundwater Supervisor, telephone number 910-395-3900, must be contacted immediately for
further instructions regarding any additional follow-up analyses required. The results of all initial and
follow-up analyses must be submitted simultaneously.
The measurement of water levels must be made prior to sampling for the remaining parameters. Th-e
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 to provide the
relative elevation of the measuring point for each monitoring well.
If TOC concentrations greater than 10 mg/1 are detected in any downgradient 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 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.
The results of the sampling and analysis must be received on Form GW-59 (Groundwater Quality
Monitoring: Compliance Report Form) by the Groundwater Section, Permits and Compliance Unit,
P.O. Box 29578 Raleigh, N.C. 27626-0578 on or before the last working day of the month following
the sampling month.
2. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
3. 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
constructed prior to December 31, 1983 is established at either (1) 500 feet from the waste disposal
area, or (2) at the property boundary, whichever is closest to the waste disposal area. An exceedanee of
Groundwater Quality Standards at or beyond the Compliance Boundary is subject to immediate
remediation action in addition to the penalty provisions applicable under General Statute 143-
215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the disposal
systems midway between the Compliance Boundary and the perimeter of the waste disposal area. Any
exceedance of standards at the Review Boundary shall require remediation action on the part of the
permittee.
V. INSPECTIONS
Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to insure proper
operation of the subject facilities.
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.
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
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.
The issuance of this permit does not preclude the Permittee from complying with any and all statutes,
rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and
federal) which have jurisdiction.
A set of approved plans and specifications for the subject project must be retained by the Permittee for
the life of the project.
The annual administering and compliance fee must be paid by the Permittee within thirty (30) days
after being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate
action to revoke this permit as specified by 15A NCAC 2H .0205 (c)(4).
8. The 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 Thirtieth day of April, 1998
NORT7COLINA ENVIRONMENTAL MANAGEMENT COMMISSION
r
�-- A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0003456

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