WQ0005458_Final Permit_19930630

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
Jaynes B. Hunt, Jr., Governor
June 30, 1993
Mr. John A. Henriksen, President
Takeda Chemical Products USA, Inc.
Post Office Box 2577
Wilmington, North Carolina 28402
Jonathan B. Howes, Secretary
Subject: Permit No. WQ0005458
Takeda Chemical Products USA, Inc.
Land Application of Sludge
New Hanover and Pender Counties
Dear Mr. Henriksen:
In accordance with your application for permit renewal received December 1, 1992 we are
forwarding herewith Permit No.WQ0005458, dated June 30, 1993, to Takeda Chemical Products USA,
Inc. for the continued operation of a land application of sludge program.
This permit shall void Permit No. WQ0005458 issued January 24, 1992 and shall be effective
from the date of issuance until May 31, 1998, 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
7041251-6208 919/486-1541 704/663-1699 919/571-4700 919/946-6481 919/395-3900 9191896-7007
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Page 2
Mr. Henriksen
Takeda Chemical Products USA, Inc.
Pemnit No. WQ0005458
June 30, 1993
If you need additional information concerning this matter, please contact 1C±xs; Angela Y. Griffin at
919/ 733-5083.
Sincerely,
A. Pres n Howard, Jr., P.E.
Director
cc: New Hanover County Health Department
Pender County Health Department
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Jack Floyd, Groundwater Section Central Office
Training and Certification
Facilities Assessment Unit

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
continued operation of a sludge land application program consisting of the application of approximately
104.07 dry tons per year of sludge from the Takeda Chemical Products USA, Incorporated's wastewater
treatment facility to approximately 6.75 acres of land using fifteen (15) solid set sprinklers in New
Hanover and Pender Counties with no discharge of wastes to the surface waters, pursuant to the
application received December 1, 1992 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 void Permit No. WQ0005458 issued January 24, 1992 and shall be effective
from the date of issuance until May 31, 1998, and shall be subject to the following specified conditions
and limitations:
I. PERFQRMANCE STANDARDS
I . 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.
2. 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.
3. 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.
4. 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.

5. No crops for direct human consumption shall be raised on these sites for a period of 18
months following sludge application.
6. Maximums slope for sludge application shall be 10% for surface application and 18% for
subsurface applications.
7. The following buffer 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) 50 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.
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.
9. No sludge at any time shall be stored at any application site.
II. 9PERATIQN AND MAINTENANCE REQUIREMENTS
The facilities and disposal sites shall be properly maintained and operated at all times.
2. A suitable vegetative cover as listed in condition H 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:
-CropPAN bs acre ar
Bermuda Grass 300
Small Grains 150
2

4. No sludges other than the following are hereby approved for land application in accordance
with this permit:
Permit Estimated
Source County Number Volume ( dry tonslyca
Takeda Chemical New Hanover NC0059234 104.07
Products USA, Inc.
S . The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lif lb cr
P. am=t
CEC < 5
CEQ- 15
CEC > 1
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 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.
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 Iand 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.
3

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.
1,301 !R" 1"WROM H 330) tal 101M 31 u
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
Magnesium
Phosphorus
Potassium
Leadl
Zinc
pH
Manganese
Cation Exchange Capacity
Sodium
Nickell
Cadmiuml
Copper
Calcium
l Soils analysis for these parameters shall be conducted once prior to permit renewal on
soils from each site which has received sludge during the permit cycle.
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.
4

The sludge analysis shall include but is not necessarily limited to the following parameters:
5
0
% total solids
Magnesium
Chlorides
Sulfate
Phosphorus
Potassium
Lead
Zinc
Copper
Nickel
Cadmium
Chromium
Sodium
Calcium
Total Nitrogen
Ammonia Nitrogen
Nitrate/Nitrite Nitrogen
pH
Plant 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, I-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
Three copies of all monitoring and reporting requirements as specified in conditions I11 1,
1112, 1113, and III 4 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
Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington 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 with the land application program which results in the land
application of significant amounts of wastes which are abnormal in quantity or
characteristic.
k'

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.
1. Within 90 days of permit issuance, monitoring well MW-3 shall be abandoned according to
15 NCAC 2C .0113.
2. Within 90 days of permit issuance, one (1) monitor well, downgradient to replace MW-3,
shall be installed to monitor groundwater quality at the review boundary. The well 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. The exact location of this well shall
be approved by the Wilmington Regional Office and shall be constructed in accordance
with the conditions of this permit
3. The new monitor well shall be sampled initially after construction. All four (4) wells (MW-
1, MW-2, MW-3, and MW-4) shall be sampled every March, July and November for the
following parameters:
NO3 Ammonia Nitrogen
TDS TOC
pH Water Level
Chloride NOz
Total Suspended Solids Orthophosphate
Nickel Zinc
*Isopropyl Alcohol Sodium
*Acetone Chromium
*Methanol
Volatile Organic Compounds - In November Only (by method 1 or 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 detection limits sufficient
to meet North Carolina groundwater standards.
1.1

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 monitoring well.
If TOC concentrations greater than 10 mg/l 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.
4. For the new MW-3, the GW-1 form shall be submitted along with the initial GW-59 form.
5. 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 Statute143-215.6(1)a.
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the spray field, or 50 feet within the property
boundary.
Any sale or transfer of property which affects the location of the compliance boundary shall
be reported immediately to the Director. The permittee shall not transfer land within an
established compliance boundary unless the permittee has satisfied all the requirements of
15A NCAC 2L. 107 (e and f).
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.
6. Any groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
7

i ►.
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.
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.
The following are approved sites for sludge application (see attached map(s)):
Site No. Owner/Lessee Application Areal acres
Takeda Chemical Products USA, Inc. 6.75
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 government
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, revolved 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 30th day of June, 1993
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
LLL , &T�& c�
A. Preston oward, Jr., P.., Director
Division o nvironmerctal Management
By Authority of the Environmental Management Commission
Permit No. WQ0005458
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State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street - Raleigh, North Carolina 27611
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
MEMORANDUM
To: Training and Certification
From: Angela Y. Griffin
Subject: fillGl�ODU��
Date: 130 47449f- ';�.3
A. Preston Howard, Jr., P.E.
Director
Please be advised that no new rating sheet is needed becaus%� '<� ,e-
J
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/5714700 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