WQ0005699_Final Permit_20060217

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��� /�Q Michael F. Easley, Governor
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William G. Ross Jr., Secretary
�J 9 North Carolina Department of Environment and Natural Resources
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Alan W. Klimek, P.E., Director
Division of Water Quality
February 17, 2006
MR. ANTHONY D. SMITH, P.E., REGULATORY AFFAIRS OFFICER
WRIGHT CORPORATION
333 NEILS EDDY ROAD
RIEGELWOOD, NORTH CAROLINA 28456
Subject: Permit No. WQ0005699
Wright Corporation
Riegelwood, NC Manufacturing Facility
Surface Disposal of Residual Solids (503 Exempt)
Columbus County
Dear Mr. Smith:
In accordance with your permit renewal application package received on July 17, 2001, we are
forwarding herewith a renewed Permit No. WQ0005699, dated February 17, 2006, to the Wright
Corporation for the continued operation of a surface disposal unit at its Riegelwood, NC Manufacturing
Facility.
This permit shall be effective from the date of issuance until January 31, 2011; shall void Permit
No. WQ0005699, issued on October 11, 1996; and shall be subject to the conditions and limitations as
specified therein. Make note of this permit's expiration date and the fact that a permit renewal application
is due to the Division of Water Quality (Division) no later than six months prior to that date (i.e., see
Condition VI. 8.), as the Division does not send reminders to apply for permit renewal. It should be
noted that the package submitted to apply for this permit renewal was submitted only three and a
half months before the expiration date of the previous issuance of this permit (i.e., submittal date of
July 17, 2001 versus an expiration date of September 30, 2001). It is a permit condition that a
permit renewal application package be submitted on time. The Permittee should make a better
effort to monitor permit expiration dates in the future to avoid potential enforcement action for
failing to submit a timely renewal as well as operating the residuals land application program
without a valid permit.
This permit approves the continued operation of the surface disposal unit for another five-year
permit cycle. Please take the time to review this permit thoroughly as many of the conditions
contained therein may have been added, changed, or deleted since this permit was last issued. 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. Of special interest to you may be the following:
♦ Condition I. 1.: This condition requires that a signing official delegation letter be submitted
to the Division within 30 calendar days of permit issuance.
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
Internet: www.ncwaterquality.org. 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer -50%Recycled/10% Post Consumer Paper Fax [phone]

Mr. Anthony D. Smith, P.E.
February 17, 2006
Page 2
♦ Condition 1. 2.: The construction/operation of water supply well within the compliance
boundary of a permitted waste disposal system is a violation of 15A NCAC 2L .0107 (d).
During the site visit by the Aquifer Protection Section of the Division's Wilmington Regional
Office, it was noted that there are wells located within the compliance boundary of the
surface disposal unit that are being used to supply process water for the chemical
manufacturing process. This condition requires that these wells be labeled as "non -potable"
and be verified for compliance with the well construction standards within 90 calendar days
of permit issuance. Further action is required if the wells are not in compliance with these
standards.
Finally, the Division would like to offer a special note of caution in that, typically, conditions
related to freeboard monitoring and maintenance are added to permits in which the surface disposal unit
being operated is of a lagoon/impoundment type. At this time, the Division has decided to forgo these
requirements in the permit because the unit is rarely used, is covered to prevent stornwater intrusion as
well as rainwater collection, and has an active leachate collection system. If these devices are not
successful in keeping water from collecting in the unit and endangering the structural integrity of the unit
at any time, the Division may modify this permit to include a freeboard requirement.
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 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, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and binding.
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone]or via e-mail at [e-mail].
11
Sincerely,
for Alan W. Klimek, P.E.
cc: Columbus County Health Department
Wilmington Regional Office - Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
APS Files
LAU Residuals Program Coordinator

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NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL
RALEIGH
SURFACE DISPOSAL OF RESIDUAL SOLIDS (503 EXEMPT) 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
Wright Corporation
Columbus County
FOR THE
continued operation of a surface disposal unit consisting of the following minimum components: one
1.14-acre surface disposal unit with a total net capacity of 18,000 cubic yards; a 36-mil Hypalon 9210
bottom liner; a leachate collection system to collect and convey leachate to use/disposal; a stormwater
cover; as well as all associated piping, valves, electrical and instrumentation/control systems, and other
appurtenances necessary to make complete and functional surface disposal unit for the disposal of
residuals from the residuals source -generating facilities listed in Condition I. 6. on an as -needed basis.
The activities associated with the residuals conveyance facilities and surface disposal unit shall
not result in a discharge of wastes to surface waters; shall be pursuant to the permit renewal application
package received on July 17, 2001; and shall be in conformity with the project plans, specifications, and
other supporting data subsequently filed and approved by the Department of Environment and Natural
Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until January 31, 2011; shall void Permit
No. WQ0005699, issued on October 11, 1996; and shall be subject to the following specified conditions
and limitations:
I. PERFORMANCE STANDARDS
1. Within 30 calendar days of this permit's issuance, the Permittee shall submit a letter, signed
by a principal executive officer (i.e., level of vice president or above) with the Permittee, that
specifically delegates the new signing official/responsible party for the purpose of this
permit's reissuance and subsequent compliance (i.e., Mr. Anthony D. Smith, P.E., Regulatory
Affairs Officer). Two copies of the requested information shall be submitted to the
NCDENR-DWQ, Aquifer Protection Section, Land Application Unit, c/o LAU Residuals
Program Coordinator, 1636 Mail Service Center, Raleigh, NC 27699-1636.

2. Within 90 calendar days of this permit's issuance, the Permittee shall label all existing
process water supply wells located inside the compliance boundary of the surface disposal
unit. Any process water supply wells not constructed according to 15A NCAC 2C .0100
shall either be brought into compliance or properly abandoned within the same 90-calendar
day timeframe. The Permittee shall provide written notification of the labeling as well as
proof of well construction standards compliance (i.e., GW-1 form or other certification) or
well abandonment (i.e., GW-30 form) as proof of compliance with this condition. Two
copies of the requested information shall be submitted to the NCDENR-DWQ, Aquifer
Protection Section, Land Application Unit, c/o LAU Residuals Program Coordinator, 1636
Mail Service Center, Raleigh, NC 27699-1636.
3. The surface disposal unit shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastes resulting from the operation of the unit.
4. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of the surface disposal unit.
S. In the event that the surface disposal unit is not operated satisfactorily, including the creation
of nuisance conditions, the Permittee shall cease disposing of the residuals in the unit as
appropriate, contact the Aquifer Protection Section of the Division of Water Quality's
(Division) Wilmington Regional Office, and take any immediate corrective actions as may be
required by the Division.
6. No residuals other than those generated by the following residuals source -generating facilities
shall be approved for disposal in the surface disposal unit in accordance with this permit:
Residuals
Permit
Maximum
Permittee
Source -Generating
County
Number
Dry Tons
Facility
per Year
Riegelwood, NC
Wright Corporation
Manufacturing Facility
Columbus
WQ0003361
As Needed
(Evaporative Lagoon Only)
Only residuals that are non -hazardous under the Resource Conservation and Recovery Act
(RCRA) shall be disposed of in the surface disposal unit.
The pollutant concentrations in the residuals that will be disposed of in the surface disposal
unit shall not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
30
Chromium
200
Nickel
210
9. The surface disposal unit shall have a liner of natural material at least one foot thick that has
been installed and compacted in six-inch layers and meeting a 95-percent standard proctor
dry density and a hydraulic conductivity no greater than 1 x 10-6 centimeters per second or
other lining system deemed by the Division to be acceptable through the issuance of
approved plans and specifications.

10. The following buffer zones shall be maintained:
a. 400 feet between an active surface disposal unit and any habitable residence;
b. 100 feet between an active surface disposal unit and any public or private water supply
source, all streams classified as WS or B, waters classified as SA or SB and any Class I
or Class II impounded reservoir used as a source of drinking water;
c. 100 feet between an active surface disposal unit and any stream, lake, river, or natural
drainage way;
d. 50 feet between an active surface disposal unit and property lines;
e. 10 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (upslope);
f. 25 feet between an active surface disposal unit and any interceptor drains or surface water
diversions (downslope); and
g. 25 feet between an active surface disposal unit and any groundwater lowering and surface
drainage ditches._
Some of the buffers specified above may not have been included in previous permits for this
surface disposal unit. These buffers are not intended to prohibit or prevent modifications that
are required by the Division to improve performance of the existing unit. These buffers do,
however, apply to modifications of the unit. These buffers do also apply to any expansion or
modification of the unit and apply in instances in which the sale of property would cause any
of the buffers now complied with, for the unit, to be violated. The Permittee is advised that
any modifications to the existing unit shall require a permit modification.
11. The surface disposal unit shall not be located in an unstable area.
12. The surface disposal unit shall not restrict the flow of a base flood.
H. OPERATION AND MAINTENANCE REQUIREMENTS
1. The surface disposal unit shall be properly maintained and operated at all times
2. Upon classification by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Pennittee shall designate and employ a certified operator to
be in responsible charge (ORC) and one or more certified operator(s) to be back-up ORC(s)
of the surface disposal unit in accordance with 15A NCAC 8G .0201. The ORC shall visit
the unit in accordance with 15A NCAC 8G .0204 or as specified in this permit and shall
comply with all other conditions specified in these rules.
.3. A copy of this permit shall be maintained on site when residuals are being disposed of in the
surface disposal unit during the life of this permit. A spill prevention and control plan shall
be maintained on site at all times.

4. Leachate from the surface disposal unit shall be collected and returned to the cooling towers
at the Permittee's Riegelwood, NC Manufacturing Facility, as approved by the Division of
Air Quality, or the evaporative lagoon at the Permittee's Riegelwood, NC Manufacturing
Facility, as approved by the Division under Permit No. WQ0003361, for use/disposal as
necessary to drain leachate properly. Diversion or bypassing of leachate shall be strictly
prohibited.
Adequate provisions shall be taken to prevent wind erosion from conveying pollutants or
residuals from the surface disposal unit onto the adjacent property or into any surface waters.
6. Adequate provisions shall be taken to prevent any surface runoff from occurring from the
surface disposal unit. If runoff cannot be prevented, a collection system shall be installed
with the capacity to handle runoff from a 24-hour, 25-year storm event. All collected runoff
shall be disposed in a manner approved by the Division.
A protective cover (i.e., vegetation, rip -rap, -gravel, etc.) shall be established and maintained
on the embankments of the surface disposal unit (i.e., outside toe of embankment to
maximum liquid level), berms, pipe runs, erosion control areas, and surface water diversions.
Trees, shrubs, and other woody vegetation shall not be allowed to grow on the unit dikes or
embankments. All embankment areas shall be kept mowed, maintained or otherwise
controlled and accessible.
8. Food crops, feed crops, and/or fiber crops shall not be grown on the surface disposal unit,
unless approval has been requested and received from the Division.
9. Animals shall not be grazed on the surface disposal unit, unless approval has been requested
and received from the Division.
10. Appropriate measures shall be taken to control public access to the surface disposal unit
during active use and for the 36-month period following closure of the surface disposal unit.
Such controls may include fencing and the posting of signs indicating the activities being
conducted at the unit.
M. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater., surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to insure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
2. Residuals generated by the approved residuals source -generating facility listed in Condition I.
6. shall be analyzed to demonstrate that they are non -hazardous under RCRA annually. A
corrosivity, ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching
Procedure (TCLP) arialysis shall be conducted on residuals generated by each approved
residuals source -generating facility. If residuals generated by a particular residuals source -
generating facility are disposed of in the surface disposal unit at a frequency less than
annually, the analyses shall be required for each calendar year in which a disposal event
occurs. The results of all analytical determinations shall be maintained on file by the
Permittee for a minimum of five years.
ll

The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
o-Cresol (200.0).
p-Cresol (200.0)
Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene(7.5) Nitrobenzene(2.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol(100.0)
1, 1 -Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene(0.7)
Heptachlor (and its hydroxide) (0.008) Toxaphene (0.5)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol(400.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
3. A representative analysis shall be conducted on residuals generated by the approved residuals
source -generating facility listed in Condition I. 6. at a frequency that is dependent on the dry
tons of residuals disposed of or expected to be disposed of in the surface disposal unit during
the calendar year. The monitoring frequency schedule shall be as stipulated in the following
table:
Amount of Residuals
Amount of Residuals
Disposed
(metric tons per
Disposed
(short tons per
Monitoring Frequency
365-day period)
365-day period)
mDT/yr = 0
DT/yr = 0
No Monitoring Required
0 < mDT/yr < 290
0 < DT/yr < 319
Once per Year
Once per Quarter
290 5 mDT/yr < 1,500
319 5 DT/yr < 1,650
or
Four Times per Year
Once per 60 Days
1,500:S mDT/yr < 15,000
1,650 5 DT/yr < 16,500
or
Six Times per Year
Once per Month
15,000 <_ mDT/yr
16,500 5 DT/yr
or
12 Times per Year
The results of all analyses shall be maintained on file by the Permittee for a minimum of five
years: The analysis shall include the following minimum parameters:
Arsenic
Hexamine
Nickel
Chromium
Formaldehyde
Percent Total Solids
H
The Permittee may utilize test methods in the most -recent update of the document entitled
"Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846),"
published by the United States Environmental Protection Agency's Office of Solid Waste, for
the analysis of the total metal parameters. Analytical results for the total metal parameters
shall be reported on a dry weight basis.

G!
Laboratory analyses as required by Condition III. L, Condition III. 2., Condition
be performed/gathered on the residuals as they are to be disposed of in the surf
unit. Furthermore, analytical determinations made pursuant to the monitoring and reporting
requirements of this permit shall be made by a laboratory certified by the Division for the
required parameter(s) under 15A NCAC 2H .0800 or 15A NCAC 21-1.1100.
Proper records shall be maintained by the Permittee tracking all disposal activities associated
with the surface disposal unit. All records shall be kept by the Permittee for a minimum
period of five years from the date of disposal. These records shall include, but shall not
necessarily be limited to, the following information:
a. Source and date of residuals disposed of in the surface disposal unit;
b. Volume of residuals disposed of in the surface disposal unit in gallons per year, dry tons
per year, or kilograms per year;
c. Cumulative volume of residuals disposed of in the surface disposal unit in gallons or
cubic yards;
d. Remaining volume in the surface disposal unit in gallons or cubic yards; and
e. An estimate of the remaining useful disposal life for the surface disposal unit in years.
6. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition III. 3., Condition 111. 4., and Condition III. 5. shall be
submitted annually on or before March 1st of the year following the disposal event to the
following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Noncompliance Notification:
The Permittee shall report by telephone to the Aquifer Protection Section of the Division's
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 surface disposal activities that results in the disposal of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the surface disposal activities resulting in a release of material to receiving
waters.
c. Any time that self -monitoring information indicates that the surface disposal unit 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 renders the surface
disposal unit incapable of adequate residual treatment.
e. Any significant spillage or discharge (i.e., greater than incidental) from a vehicle or
piping system transporting residuals to the surface disposal unit.
Occurrences outside of normal business hours (i.e., from 8:00 a.m. until 5:00 p.m. on
Mondays through Fridays, except State Holidays) may also be reported to the Division's

Emergency Response personnel at one of the following telephone numbers [phone],
[phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letterform
within five 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.
IV. GROUNDWATERREOUII2EMENTS
1. Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the surface disposal unit is specified by
regulations in 15A NCAC 2L (i.e., Groundwater Classifications and Standards). The
Compliance Boundary for surface disposal units individually permitted after December
31, 1983, shall be established at either (1) 250 feet from the unit or (2) 50 feet within the
property boundary, whichever is closest to the unit. An exceedance of Groundwater
Quality Standards at or beyond the Compliance Boundary is subject to immediate
remediation action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around the surface disposal unit
midway between the Compliance Boundary and the perimeter of the surface disposal
unit. Any exceedance of Groundwater Quality Standards at the Review Boundary shall
require action in accordance with 15A NCAC 2L .0106 (d)(1).
2. Other Requirements:
a. Any additional groundwater quality monitoring, as deemed necessary by the Division,
shall be provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the surface disposal unit 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 or other
permitting authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the surface disposal unit at any reasonable time for the purpose of determining compliance
with this permit; inspect or copy any records that must be kept under the terms and conditions
of this permit; and obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
A set of all plans and specifications approved by the Division as well as any as -built plans for
the surface disposal unit shall be retained by the Permittee for the life of the unit.

2. This permit shall become voidable unless the disposal activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by
this Division.
3. This permit shall be effective only with respect to the nature and volume of wastes described
in the application and other supporting data.
4. This permit shall not be automatically transferable. In the event that there is a desire for the
surface disposal unit to change ownership or a name change of the Permittee, a formal permit
request shall be submitted to the Division accompanied by documentation from the parties
involved and other supporting materials as may be appropriate. The approval of this request
shall be considered on its merits and may or may not be approved.
5. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina
General Statutes § 143-215.6A through § 143-215.6C.
6. The annual administering and compliance fee shall be paid by the Permittee within 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).
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 (i.e., local, state, and federal) which have jurisdiction, including, but not limited to,
applicable river buffer rules in 15A NCAC 2B .0200, erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCGO10000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC 2H
.0500.
The Permittee, at least six months prior to the expiration of this pemut, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the surface
disposal unit described therein and, if warranted, shall extend the permit for such period of
time and under such conditions and limitations as it may deem appropriate.
9. This permit may be modified, or revoked and/or reissued to incorporate any conditions,
limitations, and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
10. The Division shall be notified in writing at least 180 calendar days prior to closing of the
surface disposal unit. A formal closure plan and a post -closure management care program for
the surface disposal unit shall be submitted at that time. This information shall be specific to
the surface disposal unit as well as relate to the Permittee's future plans for the land. A
schedule for implementing both the closure plan and the post -closure management care
program shall be provided as well. The Division will accept a submittal that has been
prepared in accordance with the document entitled "Process Design Manual: Surface
Disposal of Sewage Sludge and Domestic Septage (EPA/625/R-95/002)," published by the
United States Environmental Protection Agency's Office of Research and Development.
Submit two copies of all information to the NCDENR-DWQ, Aquifer Protection Section,
Land Application Unit, c/o LAU Residuals Program Coordinator, 1636 Mail Service Center,
Raleigh, NC 27699-1636.

Permit issued this the seventeenth day of February.
NORTH
MANAGEMENT COMMISSION
for Man W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number W00005699

333 Neils Eddy Rd
Riegelwood NC
28456-9570 US
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