WQ0000965_Final Permit_19940616

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P,E., Director
June 16, 1994
Mr. W. C. Howard, Jr., P.E., Manager
R. J. Reynolds Tobacco Company
Water Quality Program
Winston-Salem, North Carolina 27102-2959
Dear Mr. Howard:
Affl�.�VA
ED E
Subject: Permit No. WQ0000965
R. J. Reynolds Tobacco Company
Package Operations Plant 200
Subsurface Disposal System
Forsyth County
In accordance with your request for a permit amendment received on April 5, 1994 by the
Groundwater Section, we are forwarding herewith a Permit No. WQ0000965 as amended dated June 16,
1994, to the R. J. Reynolds Tobacco Company for the construction and operation of the subject
groundwater remediation and disposal facility. The objections expressed in your letter to the Office of
Administrative Hearings and the Divisions position on those concerns are discussed below:
Objection 1: Substitute EPA Method 624 with a modified version of Method 624 and add EPA
Method 8015. The EPA Method 624 (modified) will be utilized to analyze for the
targeted compounds of acetone, MEK, isopropyl acetate, normal propyl acetate,
toluene, and heptane. Isopropanol and normal propanol should be analyzed by
Method 8015.
Response 1: The Division does not object to this because the modified version of Method 624
will only analyze for the target constituents associated with the subject groundwater
remediation effort.
Objection 2: Delete EPA Method 602 (including MTBE and Xylenes). There has been no
MTBE or xylenes detected at this site. The EPA Method 602 is a superficial.
requirement since all targeted compounds can be detected by Method 624.
Response 2: The Division does not object to this request since the modified version of Method
624 will suffice for the target constituents.
Objection 3: Analysis should be added for PCB's by Method 8080 in order to ensure that no
residual PCB's remain from the PCB remediation project.
Response 3: The Division inadvertently omitted this from the permit and it will be included.
Objection 4: The test for benzene, toluene, ethylbenzene, and xylene by EPA Method 602
should be deleted. Instead EPA Method 624 (modified) inciuding benzene and
Method 8015 should be. utilized.
P.O, Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% past -consumer paper

Page 2
June 16, 1994
R. J. Reynolds Tobacco Company
Response 4: The Division does not object to this because the modified version of Method 624
will only analyze for the target constituents associated with the subject groundwater
remediation effort.
Objection 5: The data used to prepare the isoconcentation contour maps should be taken from the
November data and not from the December data as stated_
Response 5: The Division does not object to this request.
This permit shall be effective from the date of issuance until July 31, 1997, shall void Permit No.
WQ0000965 issued February 14, 1994, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring and reporting requirements contained 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.
Please be advised, in the future if the R. J. Reynolds Tobacco Company wants to pursue an
adjudicatory hearing, an official petition must be filed with the Office of Administrative Hearings. It has
come to the Division's attention that the letter dated March 28, 1994, requesting an adjudicatory hearing
was returned to the R. J. Reynolds Tobacco Company with instructions to file an official petition. Since
that petition was not filed, the Division is not obligated to amend the subject permit. However, since the
Division's Groundwater Section agreed with objections raised, the permit was amended. Also in the
future, please notify the Division once a petition has been filed so that we may begin to review your
objections. For your information, a copy of an official petition has been attached to the permit.
If you need additional information concerning this matter, please contact�M�r11itD: A1lnYt
[phone].
Sine ely,
Preston o d, Jr., P.E.
cc: Forsyth County Health Department
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
ESE Biosciences, Inc.
Facilities Assessment Unit
Training and Certification Unit (no revised rating)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
INFILTRATION GALLERY 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 THE
R. J. Reynolds Tobacco Company
Forsyth County
FOR THE
construction and operation of a 7,750 GPD groundwater remediation facility consisting of thirteen (13)
recovery wells (plus the continued operation of two (2) existing recovery wells) of which five (5) of the
recovery wells will be vacuum enhanced including a blower and vapor carbon adsorption cells, a 550
gallon influent tank with submersible pump, a PetroClean 4000 fixed film bioreactor with nutrient feed, a
550 gallon effluent aerated dosing tank for the injection wells, a 2,100 gallon effluent aerated dosing tank
for the infiltration galleries, four (4) 1,200 £t2 infiltration galleries, and four (4) 0.25 GPM injection wells
to serve the R. J. Reynolds Tobacco Company's Package Operations Plant 200 with no discharge to the
surface waters, pursuant to the permit amendment received on April 5, 1994 by the Groundwater Section,
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 July 31, 1997, shall void Permit No.
WQ0000965 issued February 14, 1994, and shall be subject to the following specified conditions and
limitations:
I. PERF RMANCE STANDARDS
1. Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit and the approved plans and
specifications. Mail the Certification to the Permits and Engineering Unit, P.O. Box
29535, Raleigh, NC 27626-0535.
2. The Winston-Salem Regional Office, telephone number [phone], shall be notified
at least forty-eight (48) hours in advance of operation of the installed facilities so that an in -
place inspection can be made. 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.
3. This permit shall become voidable if the soils fail to adequately absorb the wastes and may
be rescinded unless the facilities are installed, maintained, and operated in a manner which
will protect the assigned water quality standards of the surface waters and ground waters.

4. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as
may be required by this Division, such as the construction of additional or replacement
treatment or disposal facilities.
5. 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,
6. Any sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management,
7. Diversion or bypassing of the untreated groundwater from the treatment facilities is
prohibited.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Certification Commission, 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 Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 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 Title 15A, Chapter 8A, .0202.
3. 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.
III. MONITORING AND REPORTING REQUIREMENTS .
I . Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
2. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone
number [phone], 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 without treatment of all or any portion of the
influent to such station or facility.
2

TV.
d. Any time that self -monitoring information indicates that the facility is not in
compliance with its permit limitations.
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.
GROUNDWATER REQUIREMENTS
1. Monitoring wells, 1, 2, 6, 8, 16, 17, 19, and 21, shall be sampled every May and
November for the following parameters:
Total Phosphorus
Water Levels
pH
EPA Method 624 Modified"
EPA Method 8015 b
NH3
NO3
PCBs (by EPA Method 8080)
a Analysis for acetone, MEK, isopropyl acetate, normal. propyl acetate, toluene, and
heptane.
b Analysis for isopropanol and normal propanol
The measurement of water level must be made prior to sampling for the remaining
parameters. The depth of 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 relative elevations of the measuring point for each of the monitoring wells.
2. The influent and effluent of the groundwater treatment system shall be sampled once every
two (2) weeks for the first three (3) months and monthly thereafter for the parameters
specified below:
EPA Method 624 Modifieda
EPA Method 8015 b
NO3 (effluent only)
Total phosphorus (effluent only)
a Analysis for acetone, MEK, isopropyl acetate, normal propyl acetate, toluene, and
heptane.
b Analysis for isopropanol and normal propanol
3. All groundwater monitoring data shall be sent to the Groundwater Section on Form GW-59
every June and December.
4. All influent and effluent monitoring data shall be submitted along with the groundwater
monitoring data in accordance with the above biannual schedule.
5. The permittee shall use water levels, toluene, MEK, and NO3 concentrations in the
monitoring wells to develop isoconcentration contour maps for these constituents. These
maps should be developed using the data collected in November and submitted along with
the monitoring data for that month.
6. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management, shall be provided.
9

V.
7. All components of the groundwater recovery, treatment and disposal system shall be
properly weather -proofed to prevent freezing and failure of the system.
8. The groundwater recovery, treatment and disposal system shall be=inspected weekly. If it
is determined that the system is malfunctioning, all repairs should be made as soon as
possible and reported to the Winston-Salem Regional Office.
9. All wells that are constructed for purposes of groundwater monitoring shall be constructed
in accordance with 15A NCAC 2C .0108 (Standards of Construction for Wells Other than
Water Supply) and any other state and local laws and regulations pertaining to well
construction.
10. The Permittee shall obtain a well construction permit from the Winston-Salem Regional
Office prior to construction of the recovery wells.
11. The injection wells shall be constructed of six inch schedule 40 PVC and grouted from the
top of the bentonite seal to the ground surface. Each wellhead shall have a gauge to allow
measurement of injection pressure at the screened interval.
12. Injection pressures shall not exceed 2 psi.
permittee must receive approval from
increasing the pressure above 2 psi.
INSPECTIONS
If pressures greater than 2 psi are necessary, the
the Winston-Salem Regional Office prior to
l . 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 groundwater recovery and treatment
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 of Environmental Management or other permitting authority.
3. 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.
V I. GENERAL CONDITIONS
1. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans, 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.
L'

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 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. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
5. 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 143-215.6A to 143-215.6C.
6. 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).
7. 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.
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 16th day of June, 1994
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
fk Preston d, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0000965
5

Permit No. WQ0000965
June 16, 1994
Engineer's Certification
I, , as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project,
Project Name
Location
for the
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of the approved plans and specifications.
Signature
Date
Registration No.

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FIGURE f.
GROUNDWATER SAMPLING FREOUENCY PLAN
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WINSTON-SALEM. NC
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SOURCE: ESE. INC.. 1993.