WQ0000997_Final Permit_19891127

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. Cobey, Jr., Secretary
R. Paul Wilms
Director
November 27, 1989
Mr. Jack Worsham, President
JW Manufacturing Enterprises, Inc.
US 29 North
P.O. Box 14690
Greensboro, North Carolina 27415
Subject: Permit No. NVQ0000997
JW Manufacturing Inc.
Southern Plastic
Land Application of
Contaminated Soils
Guilford Count%
Dear Mr. Worsham:
In accordance with your application received December 27, 1988, we are forwarding
,herewith Permit No. WQ0000997, dated November 27, 1989, to JW Manufacturing for the
operation of the subject land application of contaminated soils program.
This permit shall be effective from the date of issuance until October 31, 1994, and shall
be subject to the conditions and limitations as specified therein.
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 approved documents is being forwarded to you. if you need additional
information concerning this matter, please contact Ms. Carolyn McCaskill at 919/ 733-5083.
Sincerely,
k�
R. Paul Wilm
cc: Guilford County Health Department
Winston Salem Regional Office
Groundwater Section
Office of General Council
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] f
An Equal Opportunity Affirmative Action Employer

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NORTH CAROLINA
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ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
CONTAMINATED SOILS DISPOSAL 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
JW Manufacturing
Guilford County
FOR THE
operation of a land application site approximately 150 feet by 250 feet to be utilized to treat 250
cubic yards of contaminated soil from the Southern Plastics' Site with no discharge of
contaminated material to the surface waters, pursuant to the application received December 27,
1988, 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 October 31, 1994, and shall be
subject to the following specified conditions and limitations:
PERFORMANCE STANDARDS
The Winston Salem Regional Office, phone no. 9191761-2351, shall be notified
at least twenty-four (24) hours after land application of the contaminated soil so that
an 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.
2. This permit shall become voidable if the soils fail to adequately assimilate 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.
3 , 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.
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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. The following buffers shall be maintained:
a) 100 feet between disposal area and any public or private water supply including
wells
b) 100 feet between disposal area and "SA and SB" classified surface,waters
c) 50 feet between disposal area and any stream, lake, river or natural drainage"vay
d) 50 feet between disposal area and property lines
e) 10 feet between disposal area and surface water interceptor drains or diversions
(upslope)
f) 25 feet between disposal area and surface water interceptor drains or diversions
(downslope) and groundwater drainage systems.
6. No contaminated soil other than that from the Southern Plastics site as identified in
the application package shall be placed on the disposal site.
7. No contaminated soil shall be land applied within 100 feet of that portion of the
property boundary which parallels US Highway 29.
No contaminated soil shall be land applied within the 100 year flood plain of any
adjacent water bodies or drainageways.
Il. OPERATION AND MAINTENANCE REOUMEMENTS
The facilities shall be properly maintained and operated at all times.
2. Adequate measures shall be taken to prevent surface runoff from carrying any
disposed material into any surface waters.
3. The 250 cubic yards of contaminated soil shall be spread to a thickness not to
exceed three (3) inches on at least 0.6 acres of land at the disposal site.
4. 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.
5. The site shall be adequately limed to a soil pH of at least 6.5 and fertilized prior to
disposal of the contaminated soil. The contaminated soil, fertilizer and lime shall be
thoroughly incorporated into the top six to eight inches of the native soils by tilling
of disking.
7. To ensure that sufficient oxygen is provided for waste biodegradation, the site shall
be retilled at periods of one month and two months only.
8. A cover crop of fescue shall be established and maintained to aid in aeration of the
soil. The application of 20 pounds of grass seed shall be completed initially, the site
evaluated and reseeded as necessary throughout the year, and an additional 20
pounds added annually for the life of the permit. Records shall be maintained of
these activities and shall be made available at the request of the Division.
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The use of a sod aerator will be allowed on the land application site if soil aeration is
necessary once the cover crop is established.
10. The cover crop shall be harvested and removed from the ;ite periodically.
11. No food -chain crops shall be grown on the landfarriing sites for at least two years
following the completion of contaminated soil applicarior and remediation.
12. Nutrients, in the form of nitrogen and phosphorus f.rti:.-zers, must be applied over
the disposal area and fully incorporated into the mix: d contaminated and native soil
layer. To provide maximum benefits, fertilization shou'd occur no sooner than 15
days nor later than 30 days subsequent to disposal.
Rate of fertilizer application should be the lesser of the fo'.?owing:
a) For nitrogen, the tolerance level of the vegetative crop, as determined by a
knowledgeable party, or 75-100 pounds per acre plant available nitrogen
(PAN).
b) For phosphorus, the tolerance level of the vege=ativt crop, as determined by a
knowledgeable party, or 50.75 pounds per acre P705 (or equivalent).
c) For potassium, the tolerance level of the vegetative crop, as specified in the
application package, of 60 pounds per acre.
Records of these activities shall be maintained and made available at the request of
the Division.
13. Soil samples will be collected, from a minimum of t vo ! 2) areas at the disposal site,
six months and twelve months thereafter following dispc;al.
Each sample will be composed of the vertical column o: soil, extending from land
surfaces to the maximum depth of waste incorporation, E -id collected by using a soil
auger, Shelby tube or split -spoon sampler.
Samples at each location will be thoroughly mixed and a representative portion
analyzed to determine the concentration of (1) Petroleum Fuel Hydrocarbons
(Method 3550) and any (2) Volatile Organic Aromatic (VOA) compounds present.
A copy of the laboratory results of the soil analysis will be submitted to the Winston
Salem Regional Office, to the attention of the Regional Hydrogeologicai Supervisor,
within thirty days of sample collection.
14. The soil shall be sampled and analyzed once per year for pH and the eight (8) E.P.
Toxicity metals. The results of this sampling will be submitted to the Winston Salem
Regional Office, Water Quality Section on or before January 31st of the following
year.
MONITORING AND REPORTING REQUIREMENTS
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.
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2. Noncompliance Notification:
The Permittee shall report by telephone to the Winston Salem Regional Office,
telephone no. 919/761-2013, 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 failure noncompliance of the disposal ac.:vities resulting in a
by-pass directly to receiving waters.
b. Any time that self-monitoring information indicates that the facility has gone out
of compliance with its permit limitations and/or requirements.
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
Any groundwater quality monitoring as deemed necess`ry by the Division of
Environmental Management shall be provided.
2. Prior to beginning waste disposal operations, two (2) nionitor wells, one (1)
upgradient and one (1) downgradient, shall be installed to monitor groundwater
quality. The location and construction details for these wells shall be approved by
the Winston Salem Regional Office, from which a well construction permit must be
obtained.
The monitor wells shall be sampled initially after construction (and prior to waste
disposal operations) and thereafter every March, July, and November for the
following parameters:
Benzene
Toluene
Total Xylenes
Ethylbenzene
Polynuclear Aromatic
Hydrocarbons (PAH)
Hydraulic Oil
Water Level
EPA Method 602
EPA Method 602
EPA Method 602
EPA Method 602
EPA Method 610 or 625
EPA Method 9070
The measurement of water level must be made prior to sampling for the remaining
parameters.
The -Compliance Boundary delineated on the attached site plan for the disposal
system is specified by regulations in 15 NCAC 2L, Classifications and Water
Quality Standards applicable to the groundwater of North Carolina. An exceedance
of Groundwater Quality Standards beyond the Compliance Boundary is subject to
penalty provisions applicable under General Statute 143-215.6(1)a. The sale of
property, by the Permittee, which is within or contiguous to the disposal system site
may alter location of the Compliance Boundary.
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For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the land application site, or 50 feet within
the property boundary.
If the title to any property which may affect the location of the Compliance Boundary
is changed, the permittee shall notify the Division Director within 14 days. The
Director shall then establish a modified Compliance Boundary which will be done as
a modification to the Permit.
The results of the sampling and analysis shall be sent to the NC Division of
Environmental Management, Groundwater Section, Winston Salem Regional Office,
every April, August, and December.
INSPECTIONS
1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
2. The Permittee or designee shall inspect the contaminated soil area to prevent any
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 ;fears 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.
GENERAL CONDITIONS
1. This permit shall become voidable unless the contaminated soil is disposed in
accordance with the conditions of this permit and the approved documents.
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 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.
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4. In any future 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. A set of approved documents for the subject project must be retained by the applicant
for the life of the project.
6. 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.
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 I
NCAC 2H.0205 (c)(4).
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.
9. The Permittee, at least six 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.
10. Testing will be completed and continued until there is an indication that
contamination of the soil no longer exists. Only at that time will the Division
consider the remediation/t eatment program complete and void the subject permit.
Permit issued this the 27th day of November, 1989
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EARTH CAROLINA E2 -NV MANAGEME\TT COMM[SSION
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! R. Paul Wilms, D o
Division of Environmen . Management
,f By Authority of the Environmental Management Commission
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