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HomeMy WebLinkAboutWQ0003924_Final Permit_20110825A *` AF ER Sorg+ Carolina Department of Environment and Natural Resources Division of Water Quality Bever►,-, haves Perdue Coleen H, Sullins Governor " . Director August 25, 2011 DAVID C. GUM, III — MEMBER/MANAGER NFP HOLDINGS, LLC 701 FAIRMONT AVE WINCHESTEiZ, VIRGINIA 22601 Dear Mr. Gum: Dee Freeman Secretary Subject: Permit No, WQ0003924 National Fruit Product Co., Inc, Wastewater Irrigation System Lincoln County F In accordance with your permit change of ownership request received July 29, 2011, we are forwarding herewith Permit No. WQ0003924 dated August 25, 2011, to NFP Holdings, LLC for the continued operation of the subject wastewater treatment and wastewater irrigation facilities. Please note the Permittee has been changed from National Fruit Product Company, Inc. to NFP Holdings, LLC. This permit shall be effective from the date of issuance until February 28, 2014, shall void Permit No. WQ0003924 issued March 9, 2005, and shall be subject to the conditions and limitations as specified therein. Please familiarize yourself with the revised format of this permit and its updated requirements including a number of additional setback (buffer) requirements. Also, pay particular attention to the monitoring requirements now listed in Attachments A, B and C instead of the body of the permit with the previous permit issuance. Note that failure to establish an adequate system for collecting and maintaining the required operational information shall result in future compliance problems. If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee has the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall 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 at 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding. fir .IL'==:'Or�.'✓�_�71C 5=�`I_ hale .orh mar, 27F 1E le: ww11.nmaterauafit •C.. Q'i._=ul, ' 6F Mr. David Gum August 25, 2011 Page 2 of 2 If you need additional information concerning this matter, please contact Cory Larsen at (919) 715-6186 or cory.larsen@ncdenr.gov. Sincerely, Coleen H. Sullins cc: Lincoln County Health Department Mooresville Regional Office, Aquifer Protection Section o�r.,,,;t x;iP cx�nnnnzoza Notebook File WQ0003924 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH WASTEWATER 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 NFP Holdings, LLC Lincoln County FOR THE continued operation of a 60,000 gallon per day (GPD) wastewater treatment and wastewater irrigation facility consisting of - a 12,500 gallon capacity surge tank, a 300,000 gallon capacity storage tank, a 2,000,000 gallon storage capacity lagoon, dual 585 GPM irrigation pumps, a six zone, 21.5 acre irrigation disposal area, manual controller, and all associated piping, valves, and appurtenances, to serve National Fruit Product Company, Inc,, with no discharge of wastes to surface waters, pursuant to the application received July 29, 2011, and in conformity with the project plans, 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. WQ0003924 issued March 9, 2005 and shall be subject to the following specified conditions and limitations: WQ0003924 Version 2.1 Shell Version 101229 Pate 1 of 8 I. SCHEDULES 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 Rule 15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application. II. PERFORMANCE STANDARDS The subject non -discharge facilities shall be effectively maintained and operated at all times so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, or failure of the irrigation areas to adequately assimilate the effluent, the Permittee shall take immediate corrective actions including Division required actions, such as the construction of additional or replacement wastewater treatment or disposal facilities. 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. 3. All wells constructed for purposes of groundwater monitoring shall be constructed in accordance with 15A NCAC 02C .0 10 8 (Standards of Construction for Wells Other than Water Supply), and any other jurisdictional laws and regulations pertaining to well construction. 4. Effluent limitations shall not exceed those specified in Attachment A. 5. Application rates, whether hydraulic, nutrient or other pollutant, shall not exceed those specified in Attachment B. The compliance boundary for the disposal system shall be specified in accordance with 15A NCAC 02L .0107(b). This disposal system was individually permitted on or after December 30, 1983; therefore, the compliance boundary is established at either 250 feet from the effluent disposal area, or 50 feet within the property boundary, whichever is closest to the effluent disposal area. An exceedance of groundwater standards at or beyond the compliance boundary is subject to remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in accordance with North Carolina General Statute 143-215.6A through 143-215.6C. 7. In accordance with 15A NCAC 02L .0108, the review boundary is established midway between the compliance boundary and the effluent disposal area. Any exceedance of groundwater standards at the review boundary shall require action in accordance with 15A NCAC 02L .0106. 8. The Permittee shall apply for a permit modification to establish a new compliance boundary prior to any sale or transfer of property affecting a compliance boundary. 9, In accordance with 15A NCAC 02L .0107(d), wells, shall be constructed within the compliance ,0107(g). rio wells, excluding Division approved monitoring boundary except as provided for in 15A NCAC 02L WQ0003924 Version 2.1 Sheil Version 101229 Page 2 of 8 10. Except as provided for in 15A NCAC 02L .0107(g), the Permittee shall ensure any landowner who is not the Permittee and owns land within the compliance boundary shall execute and file with the Lincoln County Register of Deeds an easement running with the land containing the following items: a. A notice of the permit and number or other description as allowed in 15A NCAC 02L .0107(f)(1); b. Prohibits construction and operation of water supply wells within the compliance boundary; and c. Reserves the right of the Permittee or the State to enter the property within the compliance boundary for purposes related to the permit. The Director may terminate the easement when its purpose has been fulfilled or is no longer needed. 11. The facilities permitted herein shall be constructed according to the following setbacks: a. The setbacks for irrigation sites shall be as follows (all distances in feet): i. Any habitable residence or place of public assembly under separate ownership: 400 ii. Any habitable residence or place of public assembly owned by the Permittee: 200 iii. Any private or public water supply source: 100 iv. Surface waters: 100 v. Groundwater lowering ditches: 100 vi. Surface water diversions: ?5 vii. Any well with exception of monitoring wells: 100 viii. Any property line: 150 ix. Top of slope of embankments or cuts of two feet or more in vertical height: 15 x. Any water line from a disposal system: 10 xi. Subsurface groundwater lowering drainage systems: 100 xii. Any swimming pool: 100 xiii. Public right of way: 50 xiv. Nitrification field: ?0 xv. Any building foundation or basement: 15 xvi. Impounded public water supplies: 500 xvii. Public shallow groundwater supply: 500 b. The setbacks for storage and treatment units shall be as follows (all distances in feet): i. Any habitable residence or place of public assembly under separate ownership: 100 ii. Any private or public water supply source: 100 iii. Surface waters: S0 iv. Any well with exception of monitoring wells: 100 v. Any property line: 50 III. OPERATION AND MAINTENANCE REQUIREMENTS 1. 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 .0507, which at a minimum shall include operational functions, maintenance schedules, safety measures and a spill response plan. WQ0003924 Version 2.1 Shell Version 101229 Page 3 of 8 2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the previously cited rules. 3. A suitable year round vegetative cover shall be maintained at all times, such that crop health is optimized, allows for even distribution of effluent and allows inspection of the irrigation system. 4. Adequate measures shall be taken to prevent effluent ponding in or runoff from the irrigation sites listed in Attachment B. 5. Irrigation shall not be performed during inclement weather or when the ground is in a condition that will cause ponding or runoff. 6. All irrigation equipment shall be tested and calibrated at least once per permit cycle. Calibration records shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. 7. Only effluent from National Fruit Product Company, Inc. shall be irrigated on the sites listed in Attachment B. 8. No automobiles or machinery shall be allowed on the irrigation sites except during equipment installation or while maintenance is being performed. 9. Public access to the irrigation sites and wastewater treatment facilities shall be prohibited. 10. The residuals generated from the wastewater treatment facilities shall be disposed or utilized in accordance with 15A NCAC 02T .l 100. The Permittee shall maintain a residual management plan pursuant to 15A NCAC 02T .0508. 11. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is prohibited. 12. Freeboard in the lagoon shall not be less than two feet at any time. 13. A gauge to monitor waste levels in the lagoon shall be provided. This gauge shall have readily visible permanent markings indicating the following elevations: maximum liquid level at the top of the temporary liquid storage volume; minimum liquid level at the bottom of the temporary liquid storage volume; and the lowest point on top of the dam. 14. A protective vegetative cover shall be established and maintained on all earthen embankments (i.e., outside toe of embankment to maximum allowable temporary storage elevation on the inside of the embankment), 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 dikes or embankments. Earthen embankment areas shall be kept mowed or otherwise controlled and accessible. MONITORING AND REPORTING RE UIREMENTS 1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses) necessary to ensure groundwater and surface water protection shall be established, and an acceptable sampling reporting schedule shall be followed. 2. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for the required effluent, groundwater or surface water parameters. WQ0003924 Version 2.1 Shell Version 101?29 Page 4 of 8 Flow through the treatment facility shall be continuously monitored, and daily flow values shall be reported on Form NDMR. The Permittee shall install and maintain an appropriate flow measurement device to ensure the accuracy and reliability of flow measurement consistent with accepted engineering and scientific practices. Selected flow measurement devices shall be capable of measuring flows with a maximum deviation of less than ten percent from true flow; accurately calibrated at a minimum of once per year; and maintained to ensure the accuracy of measurements is consistent with the selected device's accepted capability. The Permittee shall maintain records of flow measurement device calibration on file for a period of at least five years. At a minimum, documentation shall include: a. Date of flow measurement device calibration, b. Name of person performing calibration, and c. Percent from true flow. 4. The Permittee shall monitor the effluent from the subject facilities at the frequencies and locations for the parameters specified in Attachment A. The Permittee shall maintain adequate records tracking the amount of effluent irrigated. At a minimum, these records shall include the following information for each irrigation site listed in Attachment B: a. Date of irrigation; b. Volume of effluent irrigated; c. Site irrigated; d. Length of time site is irrigated; e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings; f. Loading rates to each infiltration site listed in Attachment B; g. Continuous monthly and year-to-date loadings for any non -hydraulic parameter specifically limited in Attachment B; h. Weather conditions; and i. Maintenance of cover crops. 6. Freeboard (i.e., waste level to the lowest embankment elevation) in the lagoon shall be recorded weekly. Weekly freeboard records shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. Three copies of all monitoring data (as specified in Conditions IV.3. and IVA.) on Form NDMR for each PPI and three copies of all operation and disposal records (as specified in Conditions IV.5. and IV.6.) on Form NDAR-2 for every site in Attachment B shall be submitted on or before the last day of the following month. If no activities occurred during the monitoring month, monitoring reports are still required documenting the absence of the activity. All information shall be submitted to the following address; Division of Water Quality Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 WQ0003924 Version 2.1 Shell Version 101229 Pa(ye > of 8 9. A record shall be maintained of all residuals removed from this facility. This record shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, this record shall include: a. Name of the residuals hauler; b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality agreeing to accept the residuals; c. Date the residuals were hauled; and d. Volume of residuals removed. 10. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, this log shall include: a. Date of calibration of flow measurement device; b. Visual observations of the plant and plant site; and c. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.). 11. Monitoring wells shall be sampled after construction and within 3 months prior to initiating non - discharge disposal operations. Monitoring wells shall be sampled thereafter at the frequencies and for the parameters specified in Attachment C. All mapping, well construction forms, well abandonment forms and monitoring data shall refer to the Dermit number and the well nomenclature as provided in Attachment C and the Monitoririv Well Location Ma(previously provided in the last permit issuance as Attachment A). 12. Two copies of the monitoring well sampling and analysis results shall be submitted on a Compliance Monitoring Form (GW-59), along with attached copies of laboratory analyses, on or before the last working day of the month following the sampling month. The Compliance Monitoring Form (GW- 59) shall include this permit number, the appropriate well identification number, and one GW-59a certification form shall be submitted with each set of sampling results. All information shall be submitted to the following address: Division of Water Quality Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 13. An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on each irrigation site listed in Attachment B. These results shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, the Standard Soil Fertility Analysis shall include the following parameters: Acidity Exchangeable Sodium Percentage Phosphorus Base Saturation (by calculation) Magnesium Potassium Calcium Manganese Sodium Cation Exchange Capacity Percent Humic Matter Zinc Copper PH WQ0003924 Version 2.1 Shell Version 101229 Page 6 of 8 14. Noncompliance Notification: The Permittee shall report by telephone to the Mooresville Regional Office, telephone number (704) 663-1699, as soon as possible, but in no case more than 24 hours, or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence at the facility resulting in the treatment of significant amounts of wastes that is abnormal in quantity or characteristic, including the known passage of a hazardous substance, b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons, rendering the facility incapable of adequate wastewater treatment. c. Any facility failure resulting in a by-pass directly to receiving surface waters. d. Any time self -monitoring indicates the facility has gone out of compliance with its permit limitations. e. Ponding in or runoff' from the irrigation sites. Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300, Persons reporting such occurrences by telephone shall also file a written report in letter form within five days following first knowledge of the occurrence. This report shall outline the actions taken or proposed to be taken to ensure the problem does not recur. V. INSPECTIONS 1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the wastewater treatment and disposal facilities. The Pennittee or their designee shall inspect the wastewater treatment and disposal facilities to prevent malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the release of wastes to the environment, a threat to human health or a public nuisance. The Permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the for upon request. 3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect any property, premises or place on or related to the wastewater treatment and disposal facilities permitted herein at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy any records required to be maintained under the terms and conditions of this permit, and may collect groundwater, surface water or leachate samples. VI. GENERAL CONDITIONS 1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statutes 143- 215.6A to 143-215.6C. 2. This permit shall become voidable if the permitted facilities are not constructed in accordance with the conditions of this permit, the Division approved plans and specifications, and other supporting documentation. WQ0003924 Version 2.1 She]] Version 101229 Pane , of 8 3. This permit is effective only with respect to the nature and volume of wastes described in the permit application, Division approved plans and specifications, and other supporting documentation. No variances to applicable rules governing the construction or operation of the permitted facilities are granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105 (n). 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 jurisdictional government agencies (e.g., local, state, and federal). 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; any requirements pertaining to wetlands under 15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of Chapter 143 of the General Statutes. 5. In the event the permitted facilities change ownership or the Permittee changes their name, a formal permit modification request shall be submitted to the Division. This request shall be made on official Division forms, and shall include appropriate property ownership documentation and other supporting documentation as necessary. The Permittee of record shall remain fully responsible for maintaining and operating the facilities permitted herein until a permit is issued to the new owner. 6. The Permittee shall retain a set of Division 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 pursuant to 15A NCAC 02T .01056). 8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. 9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). 10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A NCAC 02T .0105(e)(3). Permit issued this the 25th day of August 2011 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION VWater'Quality �r eenirector ivision of By Authority of the Environmental Management Commission Permit Number WQ0003924 WQ0003924 Version 2.1 Shell Version 101229 Page 8 of 8 ATTACHMENT A - LIMITATIONS AND MONITORING REQUIREMENTS PPI 001--- WWTF Influent Permit Number: WQ0003924 Version: 2.1 INFLUENT CHARACTERISTICS INFLUENT LIMITS MONITORING REQUIREMENTS PCS Parameter Description Montlaly Monthly Geometric Daily Daily Measurement Sample Cade Average Mean Minimum Maximum Frequency Type 50050 Flow. in conduit or through treatment plant 60,000 1 GI'L) Monthly Recorder PPI 002 — WWTF Effluent EFFLUENT CHARACTERISTICS EFFLUENT LIMITS MONITORING REQUIREMENTS PCS Code Parameter Description Monthly Average Monthly Geometric Mean Daily Minimum Daily Maximum Measurement Frequency Sample Type 00310 BOD, 5-day (20 deg. C) mg/1 Semi-annually Grab 00916 Calcium. `Dotal (as Ca) mgll Send -annually Grab 31616 Coliform, Fecal W, M-FC Broth, 44,5 C #/m00 Semi-annually Grab U0927 Magnesium, Total (as Mg) mg/1 Semi-annually Grab 00400 p1l S.O. Serni-annually Grab 00931 Sodium Adsorption Ratio ratio Semi-annually Grab 00929 Sodium, Total (as Na) mg/l Selni-anunally` Grab 00530 Solids. 'Total Suspended mg/[ Semi-annually) Grab Notes: I. Send -,annual sampling shall occur in the months of April and October. WQ0003924 Version 2.1 Attachment A rage 1 of 2 THIS PAGE BLANK lerseon 2.1 At( mit A ,e 2 of 2 ATTACHMENT B - APPROVED LAND APPLICATION SITES AND LIMITATIONS Permit Number: WQ0003924 Version: 2.1 NFP Holdings, LLC — National Fruit Product Company, Inc. IRRIGATION AREA INFORMATION APPLICATION LIMITATIONS Field Owner County Latitude Longitude Net Acreage Dominant Soil Series Parameter Hourly Rate Yearly Max Units 111 National Fruit Product Company, Inc. Lincoln 35°30'52" 81 °l4'48" 4,6 01284 - Application Surface Irrigation 0.5 45.5 inches 02 National Fruit Product Company. Inc. Lincoln 3590'54" 81"14'48" 2.7 01284 - Application Surface Irrigation 0.5 45.5 inches 03 National Fruit Product Company, Inc. Lincoln 35°30'56" 81'14'49" 4.0 01284 - Application Surface Irrigation 0.5 45.5 inches 04 National Fruit Product Company, Inc. Lincoln 35°30'59" 81° 14'50" 3.8 01284 - Application Surface Irrigation 0.5 45.5 incites 05 National Fruit Product Company, Inc. Lincoln 35031'01" 81°14'52" 3.1 01284 -Application Surface Irriga€ion 0.5 45.5 incites 06 National I'mit Product Company. Inc. Lincoln 35°31'03" 81'14'47" 3.3 01284 - Application Surface Irrigation 0.5 45.5 inches Totals 21.5 45.5 This permit allows a total maximum hydraulic loading of 45.5 inches per year at a rate not to exceed 0.5 inches per Hour. WQ0003924 Version 2,J Attachmciit B Page I of 2 THIS PAGE BLANK WQ00035 Icrsion 2.1 Att iettt B 'age 2 of 2 ATTACHMENT C --" GROUNDWATER MONITORING AND LIMITATIONS Monitoring wells: YlW-I, MW-2, MW-3, MW-4 Permit Number: WQ0003924 Version: 2.1 GROUNDWATER CHARACTERISTICS GROUNDWATER STANDARDS MONITORING REQUIREMENTS PCs Code Parameter Description Daily Maximum Frequency Measurement Sample Type Footnotes 00680 Carbon. Total Organic (TOC) mg/1 Semi-annually Grab See below 00941) Chloride (as CI) 250 mg/l Semi-annually Grab See below 00111() PH s.u. Setrti-annually Grab See below 70300 Solids, "total Dissolved. 180 Deg_ C 500 rng/I Semi-annually Grab See below 82546 Water level, distance from measuring point feet Senti-annually Calculated See below 1. Scmi-annual sampling shall occur in the months of April and October 2. "l lie measurement of water levels shal I 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 or )I I shaft he made after purging and prior to sampling for the remaining parameters. 3, 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) ofall monitoring wells shall be surveyed relative to a common datum. 4. It' TOC concentrations greater than 10 ntg/I 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 occurrine TOC concentration in the downgradient wells shall he suhiect to the additional RninnIinv and analysis as described nhnve. 5. Monitoring wells shall he reported consistent with the nomenclature and location information provided in this attachment and the Monitoring Well Location Map (previously provided in the last permit issuance as Attachment A)" WQ0003924 Version 2.1 Attachment C Page 1 of I