WQ0005458_Final Permit_19920124

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 George T. Everett, Ph.D
William W. Cobey, Jr., Secretary Director
January 24, 1992
Mr. John A. Henriksen, President
Takeda Chemical Products USA, Inc.
Highway 421 North
Wilmington, NC 28402
Subject: Permit No. WQ0005458
Takeda Chemical Products USA, Inc.
Land Application of Sludge
New Hanover County
Dear Mr. Henriksen:
In accordance with your application for modification received August 14, 1991, we are forwarding
herewith Permit No. WQ0005458, dated January 24, 1992, to Takeda Chemical Products USA, Inc. for
the operation of a land application of sludge program. This modification consists of adding 2.25 acres and
ive (5) additional sprinkler heads to the sludge application site.
This permit shall be effective from the date of issuance until May 31, 1993, shall hereby void
Permit No. 16176 issued May 11, 1988, 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. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. Henriksen
January 24, 1992
Page Two
One set of approved plans and specifications is being forwarded to you. If you need additional
nformation concerning this matter, please contact Mr. Lindsay L. Mize at 919/ 733-5083.
cc:
New Hanover County Health Department
Davy McKee Corporation
Wilmington Regional Office, Water Quality
Wilmington Regional Office, Groundwater
Groundwater Section, Jack Floyd
Training and Certification
Facilities Assessment Unit
Sincerely,
eorge T. E erect

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
Takeda Chemical Products USA, Inc.
New Hanover County
FOR THE
operation of a sludge land application program consisting of the continued operation of the land application
of residual solids onto 4.5 acres through spray irrigation using ten (10) solid set sprinklers and the
construction and operation of an additional 2.25 acres land application of residual solids (total existing and
additional shall be 6.75 acres) through spray irrigation using five additional solid set sprinklers and
associated appurtenances with no discharge of wastes to the surface waters, pursuant to the application
received August 14, 1991 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, 1993, and shall be subject to
the following specified conditions and limitations:
I. PERFQRMANCE STANDARDS
The Wilmington Regional Office, phone no. 919/395-3900, 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 5:00 a.m. until 5:00 p.m. on Monday
through Friday, excluding State Holidays. Also the New Hanover 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 may
be 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 IS
months following sludge application.
7. Maximum slope for sludge application shall be 10% for surface application and 18% for
subsurface applications.
S. The following buffers zones shall be maintained:
a) 400 feet from residences or places of public assembly 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 and the appropriate
DEM regional office,
b) 200 feet from residences or places of public assembly 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 and the appropriate DEM.
regional office,
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; however, this requirement may be
reduced upon written concurrence from the adjoining property owner and the
appropriate DEM. regional office,
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 114 must be conducted
as to their ability to demonstrate compliance with this requirement.
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.
2

II. OPERATION 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 II 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:
Chrops_ _ _ _ PAN (lbs/acreZ
Bermuda Grass 300
Small Grains 150
4. No sludges other than the following are hereby approved for land application in accordance
with this permit:
Permit Estimated
Sotirce County -Number Volume dry tons ear
Takeda Chemical Products USA, Inc. New Hanover NCO059234 104.07
5. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Parameter (lbs/acre)
CEQ< 5
CEC 5-15
_CEC > 15
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125
250
500
Nickel
125
250
500
Cadmium
4.5
9
18
6. Upon classification of the facility by the Certification Conunission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to the classification assigned to the wastewater treatment facilities 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.
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.
3

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.
III. MONITORING AND REPORTING REQUIREMENTS
1. 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. 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 applied to each field.
3. A representative annual soils analysis (Standard Soil Fertility 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. The Standard Soil Fertility Analysis
shall include, but is not necessarily limited to, the following parameters:
% Base Saturation
Manganese
Magnesium
Cation Exchange Capacity
Phosphorus
Sodium
Potassium
Nickell
Leadl
Cadmiuml
Zincl
Copperl
pH
Calcium
Exchangable Sodium Percentage Test
Soils analysis for these parameters shall be conducted once prior to permit renewal
on each site which has received sludge during the permit cycle.
4

4. A quarterly sludge analysis and annual Toxicity Characteristics Leaching Procedure
(TCLP) analysis 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
The sludge analysis shall include but is not necessarily limited to the following parameters:
% total solids
Chlorides
Phosphorus
Lead
Copper
Cadmium
Sodium
Total Nitrogen
Nitrate/Nitrite Nitrogen
Calcium
Sodium Absorption Ratio
Magnesium
Sulfate
Potassium
Zinc
Nickel
Chromium
Calcium
Ammonia Nitrogen
pH
Plant Available Nitrogen (by calculation)
- SAR (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)
Hexachlorobenzene
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
5. Three copies of all monitoring and reporting requirements as specified in conditions 1111,
1112, III 3 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
6. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office telephone no.
919/395-3900, 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:
5

IV.
Any occurrence with the Iand 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.
GROUNDWATER REOIUIREMENTS
1. Prior to beginning waste disposal operations on the new disposal field, one (1) additional
monitor well, shall be installed downgradient to monitor groundwater quality. The well(s)
shall be constructed such that the water level in the well is never above or below the
screened (open) portion of the well at any time during the year. However, the exact
location and construction details for these wells shall be approved by the Wilmington
Regional Office, from which a well construction permit must be obtained.
2. The new monitoring wells shall be sampled initially after construction. All of the
monitoring wells (1 new and 3 existing wells) shall continue to be sampled every March,
July, and November for the following parameters:
NO3
Ammonia Nitrogen
IDS
TOC
pH
Water Level
Chloride
NO2
Total Suspended Solids
Orthophosphate
Nickel
Zinc
*Isopropyl Alcohol
Sodium
*Acetone
Chromium
*Methanol
Volatile Organic Compounds -
In November only (by Method 1 or Method 2 below).
Method 1: Method 6230D (Capillary - Column), "Standard Methods For The
Examination of Water and Wastewater", 17th ed., 1989.
Method 2: Method 502.2 "Methods For The Determination of Organic Compounds in
Drinking Water", U.S. EPA - 600/4-88/039.
* To be sampled in November only, utilizing EPA methods with the detection limit.
The measurement of water level must be made prior to sampling for the remaining
parameters.
C

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. The
depth of water in each well shall be measured from the surveyed point on the top of the
casing.
If TOC concentrations greater than 10 mg/1 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 occurring
TOC concentration in the downgradient wells shall be subject to the additional sampling
and analysis as described above.
If any volatile organic compounds are detected by method 6230D, or the equivalent method
502.2, then EPA methods 604 and 611 must also be run to detect other organic compounds
which may be present. The results of all analyses specified in the monitoring requirements,
including 604 and 611 if required, must be submitted simultaneously.
The results of the sampling and analysis shall be sent to the N.C. Division of
Environmental Management on Form GW-59 (Compliance Monitoring Report Form) every
April, August, and December.
3. The Compliance Boundary delineated on the attached site map for the disposal system is
specified by regulations in 15A NCAC 2L, Groundwater Classifications and Standards.
An exceedance of Groundwater Quality Standards beyond the Compliance Boundary is
subject to the penalty provisions applicable under General Statutel43-215.6(1)a. The sale
of property, by the Permittee, which is within or contiguous to thedisposal site, may alter
the location of the Compliance Boundary.
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the sludge disposal area 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 DEM Director within 14 days. The Director shall
then establish a modified Compliance Boundary which will be done as a modification to the
Permit.
The REVIEW BOUNDARY delineated on the attached site map for the disposal system is
specified by regulations in 15 NCAC 2L, Groundwater Classifications and Standards. A
REVIEW BOUNDARY is established around disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. When the
concentration of any substance equals or exceeds the maximum allowable concentration of
that substance at the REVIEW BOUNDARY, as determined by monitoring, the permittee
shall either (i) demonstrate, through predictive calculations or modeling, that natural site
conditions, facility design and operational controls will prevent a violation of standards at
the Compliance Boundary; or, (ii) submit a plan for the alteration of existing site
conditions, facility design or operational controls that will prevent a violation of standards
at the Compliance Boundary, and implement that plan upon its approval by the Director.
4. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
C]

V . INSPECTIONS
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. GENERAL CONDITIONS
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. This permit shall become voidable unless the agreements between the Permittee and the
landowners/lessees are in full force and effect.
5. The following are approved sites for sludge application (see attached map):
Site No. Owner/Lessee Application Areal acres
1 Takeda Chemical Products USA, Inc. 635
1- Application Area excludes buffer areas.
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 143-215.6A to 143-215.6C.
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 15 NCAC 2H .0205
(c)(4).

8. 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 govemment
agencies (local, state, and federal) which have jurisdiction.
9. A set of approved documents for the subject project must be retained by the applicant for
the life of the permit_
10. 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.
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.
12. Issuance of this permit hereby voids Permit No. 16176 issued May 11, 1988.
Permit issued this the 24th day of January, 1992
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMNUSSION
George T. Ever,
Division of Environ
By Authority of the
'ermit No. WQ0005458
Management Commission
X

Permit No. WQ0005458
January 24, 1992
'.a neer's Certification
1, , 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
10
Registration No