WQ0004258_Final Permit_19901026

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cabey, Jr., Secretary
Ms. Debby Powers, Assit. Plant Manager
West Point Pepperell
P.O. Box 697
Elizabethtown, North Carolina 28337
Dear Ms. Powers:
George T. Everett, Ph.D.
Director
October 26, 1990
Subject: Permit No. WQ0004258
West Point Pepperell
Elizabethtown Plant -
One Time -Land Application of Sludge
Bladen County
In accordance with your application received October 11, 1990 we are forwarding
herewith Permit No. WQ0004258, dated October 26, 1990, to West Point Pepperell for the
operation of a land application of sludge program. This operation will be for the one time land
application of sludge which has accumulated in the lagoon at the Elizabethtown Plant. No other
application shall be allowed under the provisions of this permit.
This permit shall be effective from the date of issuance until September 30, 1991, 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 to you,
you have the right to request an adjudicatory hearing upon written request within 30 days
following receipt of this permit. This request must be in the form of a written petition, conforming
to Chapter 150B of North Carolina General Statutes, and filed with the Office of Administrative
Hearings, P.O. Box 11666, Raleigh, NC 27604. Unless such demands are made this permit shall
be final and binding.
One set of approval documents is being foarded to you. If you need additional
information concerning this matter, please contact . CaroIyn McCaskill at 9191733-5083.
cc:
L
George T.
Bladen County Health Department
Fayetteville Regional Office
Groundwater Section -
Training and Certification.
Mr. Alexis H. Jones, Bladen County Manager
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7697 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SLUDGE LAND APPLICATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North
Carolina as amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
West Point Pepperell
Bladen County
FOR THE
construction and operation of a mechanical dewatering program consisting of a Pilgrim's Low
Profile, 1.7 meter mobile belt filter press with the use of polymers and use of existing sludge
drying beds for the temporary storage of the cake sludge with filtrate returned to the head of the
wastewater treatment plant, prior to land application and operation of a sludge land application
program consisting of the one time application of cake sludge from the polishing pond at the
Elizabethtown Plant to a site in Bladen County identified in condition no. VI, 6 of this permit with
no discharge of wastes to the surface waters, pursuant to the application received October 11,
1990 and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Environment, Health and Natural
Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until September 30, 1991, and shall be
subject to the following specified conditions and limitations:
I. PERFORMANCE TANDARD
The Fayetteville Regional Office, phone no. 919/486-1541, and the appropriate
local governmental official (county manager/city manager) shall be notified at least
twenty-four (24) hours prior to the initial application of the sludge so that an
inspection can be made of the application sites and application method. Such
notification to the regional supervisor shall be made during the normal office hours
from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays. Also the Bladen County Manager's office must be notified prior to the
initial application so that they will be aware that the operation has commenced.
2. This permit shall become voidable if the soils fail to adequately absorb the wastes
and maybe rescinded unless the sites are maintained and operated in a manner
which will protect the assigned water quality standards of the surface waters and
ground waters.

3. The land application program shall be effectively maintained and operated as a
non -discharge system to prevent the discharge of any wastes resulting from the
operation of this program.
4. 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.
5. In the event that the land application program is not operated satisfactorily,
including the creation of nuisance conditions, the Permittee shall cease applying
sludge to the sites and take any immediate corrective actions, including the
construction of additional or replacement wastewater treatment or disposal facilities.
6. No crops for direct human consumption shall be raised on these sites for a period of
18 months following sludge application.
7. Maximum slope for sludge application shall be 10% for surface application and
18% for subsurface applications.
The following buffers zones shall be maintained:
a) 400 feet from residences under separate ownership for surface application
method, however the buffer zone requirement may be reduced to a minimum of
100 feet upon written consent of the owner.
b) 200 feet from residences under separate ownership for injection method,
however the buffer zone requirement may be reduced to a minimum of 100 feet
upon written consent of the owner.
c) 100 feet from "SA and SB" classified waters and public surface water supplies
for both methods,
d) 50 feet from "WS" classified waters and other streams, creeks, lakes, rivers,
and surface water drainage ways for injection method
e) 100 feet from "WS" classified waters and other streams, creeks, lakes, rivers
and surface water drainage ways for surface application method,
f) 100 feet from property lines for both methods,
g) 50 feet from public right of ways for surface application methods,
h) 25 feet from public right of ways for subsurface disposal methods,
i) 10 feet from upslope interceptor drains and surface water diversions for both
methods,
j) 25 feet from downslope interceptor drains, surface water diversions,
groundwater drainage systems and surface drainage ditches for both methods.
9. A copy of this permit shall be kept at the land application site when sludge is being
applied during the life of this permit. A spill prevention and control plan shall be
kept in all sludge transport and application vehicles.
10. All sludges included in this permit must be stabilized by a process to significantly
reduce pathogens (as described in 40 CFR Part 257, Appendix II) prior to
application or incorporation. An evaluation of all sludges as specified in condition
II 4 must be conducted as to their ability to demonstrate compliance with this
requirement. A copy of this report must be submitted to the Assistant Chief for
Operations, Division of Environmental Management, Water Quality Section,
Operations Branch, PO Box 27687, Raleigh, NC 27611-7687, within six (6)
months of the permit issue date.
11. Specific sludge application area boundaries shall be clearly marked on each site
prior to and during sludge application.

12. No sludge at any time shall be stored at any application site.
II. QPERAT71ON AND MAINTENANCE REQUIREMENTS
1. The facilities and disposal sites shall be properly maintained and operated at all
times.
2. A suitable vegetative cover as listed in condition 11 3, shall be maintained in
accordance with the crop management plan approved by this Division.
3. The application rates shall not exceed the following for the specified crops:
Crops PAN (lbs/acre/year)
Coastal Bermuda 350
Rye 200
Oats 100
4. No sludges other than the following are hereby approved for land application in
accordance with this permit:
Permit Estimated
Source County Num -be Volume
West Point Pepperell Bladen NC0003522 235 Dry Tons -Total
Elizabethtown Plant (2.8 MG)
5. The lifetime heavy metal loadings shall not exceed the following for the
corresponding Cation Exchange Capacities (CEC):
Parameter E
Lead (lbs/acre) 500
Zinc (lbs/acre) 250
Copper (lbs/acre) 125
Nickel (lbs/acre) 125
Cadmium (lbs/acre) 4.5
5. The Permittee shall employ a certified wastewater treatment plant operator to be in
responsible charge of the land application operation. The operator must hold a
certificate of the grade at least equivalent to the classification assigned to the land
application program by the Certification Commission.
7. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored sludge material into any surface waters.
8. Animals shall not be grazed on sludge applied land within a 30 -day period
following the sludge application. Application sites that are to be used for grazing
shall have fencing that will be used to prevent access after each application.
9. Surface applied sludge will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
2

10. For areas that are prone to flooding or within the 100 -year flood elevation, sludge
may be applied only during periods of dry weather. The sludge must be
incorporated into the soil within twenty-four (24) hours of application.
11. Appropriate measures must be taken to control public access to the land application
sites during active site use and for the 12 -month period following the last sludge
application event. Such controls may include the posting of signs indicating the
activities being conducted at each site.
12. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the sludge application area onto the adjacent property or
into the surface waters.
13. Sludge shall not be applied in inclement weather or until 24 hours following a
rainfall event of 1/2 -inch or greater in 24 hours. Any emergency sludge disposal
measures must first be approved by the Division of Environmental Management.
14. The site shall be adequately limed to a soil pH of at least 6.5 prior to sludge
application. Sludge may be applied to sites with a pH of less than 6.5 provided a
sufficient amount of lime is also applied to achieve a final pH of the lime, sludge
and soil mixture of at least 6.5.
111. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, sludge, soil, or plant tissue
analyses) deemed necessary by the Division of Environmental Management to
insure protection of the environment will be established and an acceptable sampling
and reporting schedule shall be followed. If monitoring data indicates minimal or
no concern to the Division, reduction of monitoring requirements may be pursued
after two annual reporting periods.
2. Proper records shall be maintained by the Permittee tracking all disposal activities.
This information should be submitted to the Regional Office at the close of this
operation. These records shall include, but are not necessarily limited to the
following information:
a) source of sludge
b) date of sludge application
c) location of sludge application (site, field, or zone #)
d) method of application
e) weather conditions
f) soil conditions
g) type of crop or crop to be grown on field
h) volume of sludge applied in gallons/acre and dry tons/acre
i) annual and cumulative totals of dry tons/acre of sludge, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be limited to
lead,nickel, cadmium, copper and zinc), annual pounds/acre of plant available
nitrogen (PAN), and annual pounds/acre of phosphorus and gypsum applied to
each field.
3

3. A representative annual soils analysis shall be conducted of each site receiving
sludge in the respective calendar year and the results maintained on file by the
Permittee for a minimum of five years if this operation extends beyond one year
under an amendment to this permit. The soils analysis shall include but is not
necessarily limited to the following parameters:
Standard Soil Fertility Test
% Base Saturation
Phosphorus
Potassium
Lead
Zinc
Magnesium
pH
Manganese
Cation Exchange Capacity
Sodium
Nickel
Cadmium
Copper
Calcium
4. A quarterly sludge analysis and annual Toxicity Characteristics Leaching Procedure
(TCLP) analysis (if this operation extends beyond a year under an amendment to
this permit) shall be conducted by the Permittee and the results maintained on file by
the Permittee for a minimum of five years. If land application occurs at a frequency
less than quarterly, sludge analysis will be required for each instance of land
application. The sludge analysis shall include but is not necessarily limited to the
following parameters:
% total solids
Magnesium
Chlorides
Sulfate
Phosphorus
Potassium
Lead
Zinc
Copper
Nickel
Cadmium
Chromium
Sodium
Calcium
Total Nitrogen
Ammonia Nitrogen
Nitrate/Nitrite Nitrogen
pH
PIant Available Nitrogen (by calculation)
The TCLP analysis shall include the following parameters:
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o -Cresol
m -Cresol
p -Cresol
Cresol
2,4-D
1,4 -Dichlorobenzene
1,2-Dichloroethane
1, 1 -Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its hydroxide)
HexachIorobenzene
Hexachloro-1,3-butadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5 -Trichlorophenol
2,4,6 -Trichlorophenol
2,4,5 -TP (Silvex)
Vinyl chloride
4

5 . An analysis for phenol shall also be conducted quarterly.
6. Supplemental Gypsum shall be added to the site as required to ensure the SAR is
less than 10 based on the analysis for Sodium, Calcium and Magnesium.
7. Three copies of all monitoring and reporting requirements as specified in conditions
111 1, I1I 2, 1113, III 4, and III 5 shall be submitted annually on or before March 1
of the following year to the following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 27687
Raleigh, NC 27611-7687
7. Noncompliance Notification:
The Permittee shall report by telephone to the Fayetteville Regional Office telephone
no. 9191486-1541, as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of
any of the following:
a. Any occurrence with the land application program which results in the land
application of significant amounts of wastes which are abnormal in quantity or
characteristic.
b. Any failure of the land application program resulting in a release of sludge
material to receiving waters.
c. Any time that self-monitoring information indicates that the facility has gone out
of compliance with the conditions and limitations of this permit or the
parameters on which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the
facility incapable of adequate sludge treatment.
e. Any spillage or discharge from a vehicle or piping system transporting sludge to
the application site.
Persons reporting such occurrences by telephone shall also file a written report in
letter form within 15 days following first knowledge of the occurrence. This report
must outline the actions taken or proposed to be taken to ensure that the problem
does not recur.
iti GROUNDWATER REQUIREMENTS
Any groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
No land application of waste activities shall be undertaken when the seasonal high
water table is less than three feet below land surface.

V. INSPECTIONS
1. The Permittee or his designee shall inspect the sludge storage, transport, and
disposal facilities to prevent malfunctions and deterioration, operator errors and
discharges which may cause or lead to the release of wastes to the environment, a
threat to human health, or a nuisance. The Permittee shall 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 by the Division of
Environmental Management or other permitting authority.
2. Any duly authorized officer, employee, or representative of the Division of
Environmental Management may, upon presentation of credentials, enter and
inspect any property, premises or place on or related to the disposal site and facility
at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records that must be kept under the terms and conditions
of this permit; or may obtain samples of groundwater, surface water, or leachate.
VI. ('ENERAL CONDITIONS
1. This permit shall become voidable unless the land application activities are carried
out in accordance with the conditions of this permit and in the manner approved by
this Division.
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 a name change of the Permittee, a formal permit request must
be submitted to the Division of Environmental Management accompanied by an
application fee, documentation from the parties involved, and other supporting
materials as may be appropriate. The approval of this request will be considered on
its merits and may or may not be approved.
4. Prior to any transfer of this land, a notice shall be given to the new owner that gives
full details of the materials applied or incorporated at this site,
5. This permit shall become voidable unless the agreements between the Permittee and
the landowners/lessees are in full force and effect.
6. The following are approved sites for sludge application (see attached map):
Site No. Owner/Lessee Application Area (excluding buffers)
cr s
Charles T. King 70.0 (76.2 Total acreage)
7. Failure to abide by the conditions and limitations contained in this permit may
subject the Permittee to an enforcement action by the Division of Environmental
Management in accordance with North Carolina General Statute 143-215.6.
X

8. 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 15 NCAC 2H .0205 (c)(4).
9. 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.
10. A set of approved documents for the subject project must be retained by the
applicant for the life of the permit.
11. This permit may be modified, or revoked and reissued to incorporate any
conditions, limitations and monitoring requirements the Division of Environmental
Management deems necessary in order to adequately protect the environment and
public health.
Permit issued this the 26th day of October, 1990
NORTH CAROLINAON NTAL MANAGEMENT COMMISSION
r
George T. Everetty Dire
Division of Envir6nner
By Authority of the En,
Permit No. WQ0004258
al Management Commission
IA
r
al Management Commission
IA

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