WQ0001973_Final Permit_19950210

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
February 10, 1995
Mr, John P. Turpin, Plant Manager
Arcadian Fertilizer, L.P.
P.O. Box 630
Wilmington, NC 28402
Subject: Permit No. WQ0001973 Amendment
Arcadian Fertilizer, L.P.
Surface Disposal of Raw Water Treatment Residuals
New Hanover County
Dear Mr. Turpin:
The Division received an amendment request made on your behalf by Mr. Eugene O. Evans on
July 27, 1994. In accordance with the amendment request, and after further review by Division staff on
the properties of water treatment sludges ("alum sludges"), we are forwarding herewith Permit No.
WQ0001973 as amended, dated February 10, 1995, to Arcadian Fertilizer, L.P., for the operation of a
non -discharging artificial wetlands area as an alum sludge disposal site. This amended permit is intended
to be more appropriate for the subject alum sludge disposal operation and omits those portions of the
standard sewage sludge monitoring requirements which were determined to be inappropriate in this
situation.
This permit shall be effective from the date of issuance until May 31, 1999, shall void Permit No.
WQ0001973 issued June 30, 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 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 information concerning this matter, please contact Mr. Ray Cox at (919)
733-5083.
Sincerely,
A. Prest Howard, Jr., P.E.
cc: New Hanover County Health Department
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
Training and Certification Unit
Facilities Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
ALUM SLUDGE DISPOSAL SITE 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 Regulation's
PERMISSION IS HEREBY GRANTED TO
Arcadian Fertilizer, L.P.
New Hanover County
FOR THE
operation of a non -discharging artificial wetlands as an alum sludge disposal site consisting of
approximately 1.2 acres of diked disposal area (formerly a dredge spoils area) for the disposal of
approximately 8.2 dry tons per year of alum sludge from the Arcadian Fertilizer, L.P., water treatment
facility with no discharge of wastes to the surface waters, pursuant to the amendment request received on
July 27, 1994, 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 May 31, 1999, shall void Permit No.
WQ0001973 issued June 30, 1994, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. The alum sludge disposal area 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.
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 program.
3. In the event that the alum sludge disposal area is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease disposing of the water treatment
residuals to the alum sludge disposal area and take any immediate corrective actions as may
be required by the Division.

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The following buffer zones shall be maintained:
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a) 400 feet from residences or places of public assembly under separate ownership;
however, the buffer zone requirement may be reduced to a minimum of 100 feet upon
written consent of the owner and approval from the appropriate DEM regional office,
b) 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class Il impounded reservoir used as a source of drinking water,
c) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment,
d) 100 feet from property lines;
e) 50 feet from public right of ways,
f) 10 feet from upslope interceptor drains and surface water diversions,
g) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches.
A copy of this permit shall be maintained at the alum sludge disposal site when residuals
are being disposed during the life of this permit. A spill prevention and control plan shall
also be maintained on site.
II. OPERATION AND MAINTENANCE REOi1IREMENTS
1. The facilities and application sites shall be properly maintained and operated at all times.
2. The naturally occurring vegetative growth (reeds and other wetland vegetation) shall be
maintained in accordance with the management plan approved by this Division.
3. The dikes shall be regularly inspected and maintained so as to prevent surface water runoff
from the alum sludge disposal site.
4. No residuals other than the following are hereby approved for disposal in the alum sludge
disposal area in accordance with this permit:
Estimated
Source County Volume (dry tons/year)
Arcadian Fertilizer, L.P. New Hanover 8.2
Water Treatment Facility
5. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings Obstacre)
Paramete
CEC < 5
CEC 5 - 15
EEC > 1
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125
250
500
Nickel
125
250
500
Cadmium
4.5
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6. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified operator to be in responsible charge (ORC) of the active sewage sludge
unit. The operator must hold a certificate of the type classification assigned to the sewage
sludge unit by the Certification Commission. The Permittee must also employ a certified
back-up operator of the appropriate type to comply with the conditions of Title 15A NCAC
8A, .0202.
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7. Appropriate measures must be taken to control public access to the alum sludge disposal
site during active site use and for the 12 months following closure of the alum sludge
disposal area. Such controls may include the posting of signs indicating the activities being
conducted at the site.
Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the alum sludge disposal site onto the adjacent property or into
any surface waters.
9. Food crops, feed crops and fiber crops shall not be grown on the alum sludge disposal site,
unless approval has been requested and received from the Division of Environmental
Management.
10. Animals shall not be grazed on the alum sludge disposal site unless approval has been
requested and received from the Division of Environmental Management.
III. MONITORINGAND REPORTING REQUIREMENTS
1•. Any monitoring (including groundwater, surface water, residuals, 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.
2. Proper records shall be maintained by the Permittee tracking all application activities.
These records shall include, but are not necessarily limited to the following information_
a) quantity of alum product used on a monthly basis
b) date of alum sludge disposal
c) volume of alum sludge disposed in gallonslyear, dry tons/year or kilograms/year
d) annual and cumulative totals of dry tons/acre of residuals applied and pounds/acre of
each heavy metal listed in condition 111.3 of this permit.
3. Within 90 days of permit issuance, and thereafter annually, a soils analysis will be
conducted by the Permittee and the results maintained on file by the Permittee for a
minimum of five years.
The annual soils analysis shall include, but is not necessarily limited to, the following
parameters:
Aluminum pH acidity CEC
Cadmium Copper Lead Nickel
Zinc
4. Within 90 days of permit issuance, and thereafter annually, a residuals (alum sludge)
analysis will be conducted by the Permittee and the results maintained on file by the
Permittee for a minimum of five years.
The residuals (alum sludge) analysis shall include but is not necessarily limited to the
following parameters:
Aluminum
Lead
% Total Solids
Zinc
Copper
Cadmium
Nickel
Calcium
Magnesium
Sodium
pH
Phosphorus
Potassium

5. If, after two consecutive monitoring periods, the permittee determines that the continued
monitoring of certain parameters above may be inappropriate for the subject facility, the
permittee may petition the Division to formally amend the permit with a reduction in
monitoring parameters. Upon receipt of the monitoring reduction request, the Permits and
Engineering Unit will review the request on its merit to determine whether a reduction is
feasible.
6. Three copies of all required monitoring and reporting requirements as specified in
conditions III 1,1112,1113 and 1114 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 29535
Raleigh, NC 27626-0535
In addition to the annual report submitted to the Facility Assessment Unit, the results of the
initial analyses (both soils and residuals) shall be forwarded to the Permits and Engineering
Unit for review, to identify the current levels of each of the -subject parameters in the soil
and residuals, respectively. The results should be submitted to the following address:
NC Division of Environmental Management
Water Quality Section
Permits and Engineering Unit
PO Box 29535
Raleigh, NC 27626-0535
8. 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 fast knowledge of the occurrence of any of
the following:
a. Any occurrence with the surface disposal program which results in the disposal of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the surface disposal program resulting in a release of material to
receiving waters.
e. 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 residual treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to the
disposal 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.
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I V . GROUNDWATER REQUIREMENTS
1. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
2. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983, and is established at either
(1) 250 feet from the waste disposal area, or (2) 50 feet within the property boundary,
whichever is closest to the waste disposal area. An exceedance 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
The Permittee or his designee shall inspect the residuals 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 maintain 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 five years from the date of the inspection and shall be made available to the
Division of Environmental Management or other permitting authority, upon request.
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 surface 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 kept under the terms and conditions of this permit; and may obtain
samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. This permit shall become voidable unless the alum sludge disposal activities are carried out
in accordance with the conditions of this permit, the supporting materials, 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 automatically transferable. In the event that 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. 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(a) to 143-215.6(c).
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5. 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).
6. 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.
7. 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.
8. 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 tenth day of February, 1995
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
oo.Y C L'� - X
A. Preston ward, Jr., P.E.1 Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0001973
E
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