WQ0005910_Final Permit_19920928

State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
September 28, 1992
Mr. W. C. Howard, Jr., P. E.
Water Quality Program Manager
R. J. Reynolds Tobacco Company
Post Office Box 2959
Winston-Salem, North Carolina 27102
A. Preston Howard, Jr., P. E.
Acting Director
Subject: Permit No. WQ0005910
R. J. Reynolds Tobacco Company
Avoca Division
Wastewater Spray Irrigation Facilities
Berde County
Dear Mr. Howard:
On June 2, 1992, the Division of Environmental Management issued Permit No. WQ0005910 to
R. J. Reynolds Tobacco Company for the continued operation of the subject wastewater treatment and
spray irrigation facilities. On July 2, 1992, you submitted a letter (Petition) to the Division which outlined
several requirements and limitations in the permit to which you objected. As a result of the submitted
"Petition," the Division has evaluated the concerns expressed, has modified the permit where appropriate,
and has discussed our position on these issues with you. A summary of the questions or objections raised
by R. J. Reynolds and the Division's position on those questions or objections is contained below:
Objection 1: R. J. Reynolds objects to condition 1.5.b, which specifies that a 150 foot buffer shall be
maintained between wetted areas and property lines. You state that this restriction is new
and that complying with this restriction will require the elimination of needed irrigation
areas.
Regional Offices
Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem
704/251-6208 919/486-1541 704/663-1699 919/571-4700 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

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Response 1: The Division has evaluated this requirement and agrees that this buffer restriction should
not apply to this existing situation. The buffer condition has been modified by adding the
following statement, which clarifies the intention of this condition:
Some of the buffers specified above may not have been included in previous permits for
this waste treatment and disposal system. Those specific buffers are, therefore, not
applicable to existing waste treatment and disposal facilities that were originally permitted
under other buffer requirements. The above specified buffers are not intended to prohibit
or prevent modifications, which are required by the Division, to improve performance of
the existing treatment facility. These buffers do, however, apply to modifications of the
treatment and disposal facilities which are for the purpose of increasing the flow that is
tributary to the facility. These buffers do apply to any expansion or modification of the
spray irrigation areas and apply in instances in which the sale of property would cause any
of the buffers now complied with, for the treatment and disposal facilities, to be violated.
The applicant is advised that any modifications to the existing facilities will require a permit
modification.
Objection 2: R. J. Reynolds objects to condition I.5.c, which specifies that a 100 foot buffer shall be
maintained between wetted areas and wells. You state that this restriction is new and that
complying with this restriction will require the elimination of needed irrigation areas.
Response 2: The same additional statement identified in response 1 above applies in this instance also;
therefore, the Division has no objection to the existing wells that are located approximately
75 feet from the existing wetted areas.
Objection 3: R. J. Reynolds objects to condition 1.51, which specifies that a 100 foot buffer shall be
maintained between wastewater treatment units and wells. You state that the treatment
facility is approximately 66 feet from well number 1, which is used for both process water
and potable water.
Response 3: The same additional statement identified in response 1 above applies in this instance also;
therefore, the Division has no objection to the existing well that is located approximately 66
feet from the treatment facility.
Objection 4: R. J. Reynolds objects to the requirement in condition 111.3 for effluent monitoring of total
coliforms.
Response 4: Effluent monitoring for total coliforms is typically required for spray facilities with
industrial wastewater; however, since the Groundwater Section did not require monitoring
for total coliforms in the monitoring wells, it is appropriate to delete the requirement for
effluent monitoring of total coliforms. This constituent has been deleted from condition
111.3.
Objection 5: R. J. Reynolds requests that additional time be allowed to accomplish that portion of
condition 17V.i, which requires that the elevations be established at the top of all monitoring
well casings and that the depth of water in the wells be measured from the top of the well
casing.
Response 5: This requirement has been imposed so that groundwater flow patterns may be established.
In order to allow adequate time to accomplish this task, a sentence has been added to
condition N.1 which allows ninety days from the issuance of the permit to carry out this
task.

Objection 6: R. J. Reynolds has stated that it needs clarification regarding condition IV.2. You have
asked whether the property line is the compliance boundary on the west side of the spray
field and whether on all other sides the compliance boundary is 500 feet from the spray
site.
Response 6: The compliance boundary is 500 feet from the spray site on all sides where at least 500 feet
exists to the property boundary. If 500 feet separation does not exist, the compliance
boundary is established at the property boundary. In order to clarify this condition, a
sentence has been added which states:
Where 500 feet separation does not exist between the treatment/disposal facilities and the
property line, the compliance boundary shall be established at the property line.
Objection 7: R_ J. Reynolds states that the requirement in condition IV.S to submit a site map with
certain specified features identified was previously accomplished in June, 1986.
Response 7: The Division agrees that this requirement has been previously satisfied and has deleted
condition IV.5.
In accordance with the Notice of Withdrawal of Petition that you executed and submitted, this
permit is final and binding and shall be effective from the date of issuance until April 30, 1997, shall void
Permit No. 3947R, which was issued on October 24, 1986, and shall void Permit No. WQ0005910,
which was issued on June 2, 1992, and subsequently adjudicated, 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 may result in future compliance problems.
If you need additional information concerning this matter, please contact Mr. Randy Jones at 919/
733-5083.
Sincerely,
A. Preston Howard, Jr., P. E.
cc: Bertie County Health Department
Washington Regional Office, Water Quality Section
Washington Regional Office, Groundwater Section
Groundwater Section, Jack Floyd
Training and Certification Unit (no revised rating)
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH
SPRAY IRRIGATION SYSTEM 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
R. J. Reynolds Tobacco Company
Bertie County
FOR THE
continued operation of a 12,500 GPD industrial wastewater treatment facility consisting of a neutralization
basin using lime, two (2) equalization tanks, three (3) aeration basins in series, a clarifier, an aerobic
sludge digester, an aerated lagoon, pumping facilities, and all necessary appurtenances with the discharge
of treated effluent onto approximately 26 acres to serve the R. J. Reynolds Tobacco Company Avoca
Division with no discharge of wastes to the surface waters, pursuant to the adjudication request received
on July 2, 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 is final and binding and shall be effective from the date of issuance until April 30,
1997, shall void Permit No. 3947R, which was issued on October 24, 1986, and shall void Permit No.
WQ0005910, which was issued on June 2, 1992, and subsequently adjudicated, and shall be subject to
the following specified conditions and limitations:
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1. The spray irrigation facilities shall be effectively maintained and operated at all times so that
there is no discharge to the surface waters, nor any contamination of ground waters which
will render them unsatisfactory for normal use. In the event that the facilities fail to
perform satisfactorily, including the creation of nuisance conditions or failure of the
irrigation area to adequately absorb the wastewater, the Permittee shall take such immediate
corrective action to correct the problem, including actions as may be required by the
Division of Environmental Management.
2. The issuance of this pernut shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
3. The sludge generated from these treatment facilities must be disposed of in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
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4. Diversion or bypassing of the untreated wastewater from the treatment facilities is
prohibited.
5. The following buffers shall be maintained:
a) 400 feet between wetted area and any residence or places of public assembly under
separate ownership,
b) 150 feet between wetted area and property lines,
c) 100 feet between wetted area and wells,
d) 100 feet between wetted area and drainageways or surface water bodies,
e) 50 feet between wetted area and public right of ways,
f) 100 feet between wastewater treatment units and wells,
g) 50 feet between wastewater treatment units and property lines.
Some of the buffers specified above may not have been included in previous
permits for this waste treatment and disposal system. Those specific buffers are,
therefore, not applicable to existing waste treatment and disposal facilities that were
originally permitted under other buffer requirements. The above specified buffers
are not intended to prohibit or prevent modifications, which are required by the
Division, to improve performance of the existing treatment facility. These buffers
do, however, apply to modifications of the treatment and disposal facilities which
are for the purpose of increasing the flow that is tributary to the facility. These
buffers do apply to any expansion or modification of the spray irrigation areas and
apply in instances in which the sale of property would cause any of the buffers now
complied with, for the treatment and disposal facilities, to be violated. The
applicant is advised that any modifications to the existing facilities will require a
permit modification.
1. The facilities shall be properly maintained and operated at all times.
2. 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, Ill, 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.
3. A suitable vegetative cover shall be maintained.
4. Irrigation shall not be performed during inclement weather or when the ground is in a
condition that will cause runoff.
5. Adequate measures shall be taken to prevent wastewater runoff from the spray field.
6. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
7. The average annual weekly application rate shall not exceed 0.50 inches per acre.
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8. No type of wastewater other than that from R. J. Reynolds Tobacco Company Avoca
Division shall be sprayed onto the irrigation area
9. No traffic or equipment shall be allowed on the disposal area except while installation
occurs or while normal maintenance is being performed.
10. Public access to the land application sites shall be controlled during active site use. Such
controls may include the posting of signs showing the activities being conducted at each
site.
11. Freeboard in the lagoon shall not be less than two (2) feet at any time.
1. Any monitoring (including groundwater, surface water, soil or plant tissue analyses)
deemed necessary by the Division of Environmental Management to insure surface and
ground water protection will be established and an acceptable sampling reporting schedule
shall be followed.
2. Adequate records shall be maintained by the Permittee tracking the amount of wastewater
disposed. These records shall include, but are not necessarily limited to the following
information:
a) date of irrigation,
b) volume of wastewater irrigated,
c) field irrigated,
d) length of time field is irrigated,
e) continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for
each field,
i) weather conditions, and
g) maintenance of cover crops.
3. The effluent from the subject facilities shall be monitored by the Permittee at the point prior
to irrigation every March, July and November for the following parameters:
BOD5 TS S
pH Sodium
NH3 as N Calcium
Magnesium
Sodium Adsorption Ratio by Calculation
4. Three copies of all operation and disposal records (as specified in condition IU 2) and all
effluent monitoring data (as specified in condition TII 3) and any other data as may be
required shall be submitted on or before the last day of the following month to the
following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
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IV.
5. Noncompliance Notification:
The Permittee shall report by telephone to the Washington Regional Office, telephone no.
[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 at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such
as the dumping of the contents of a sludge digester, the known passage of a slug of
hazardous substance through the facility; or any other unusual circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate wastewater treatment such as mechanical or electrical failures
of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-
pass directly to receiving waters without treatment of all or any portion of the
influent to such station or facility.
d. Any time that self -monitoring information indicates that the facility has gone out of
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following Furst 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. The six existing monitor wells shall continue to be sampled every March, July, and
November for the following parameters:
NO3
TOC
Ammonia Nitrogen
Water Level
Bromide
NO2
Volatile Organic Compounds -
ON&
pH
Chlorides
Barium
Total Suspended Solids
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 edition, 1989
Method 2: Method 502.2 " Methods for the Determination of Organic Compounds
in Drinking Water", United States Environmental Protection Agency -
600/4-88/039
The measurement of water level must be made prior to sampling for the remaining
parameters.
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Within ninety days of permit issuance, 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 analysis 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.
2. The Compliance Boun = for the disposal system is specified by regulations in 15 NCAC
2L, Classifications and Water Quality Standards applicable to the groundwater of North
Carolina. An exceedance of Groundwater Quality Standards beyond the Compliance
Boundary is subject to penalty provisions applicable under General Statute 143-215.6A.
The sale of property, by the Permittee, which is within or contiguous to the disposal
system site may alter the location of the Compliance Boundary.
For facilities permitted prior to December 30, 1983, the Compliance Boundary is
established at the lesser of 500 feet from the lagoon and spray field, or the property
boundary, whichever is less. Where 500 feet does not exist between the treatment/disposal
facilities and the property line, the Compliance Boundary shall be established at the
property line.
If the title to any property which may affect the location of the Compliance Boundary is
changed, the permittee shall notify the Division Director within 14 days. The Director shall
then establish a modified Compliance Boundary which will be done as a modification to the
Permit.
The REVIEW BOUNDARY 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.
3. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
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1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the wastewater treatment 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 to
the Division of Environmental Management or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the disposal site and facility at any reasonable time for the
purpose of determining compliance with this permit; may inspect or copy any records that
must be kept under the terms and conditions of this permit; or may obtain samples of
groundwater, surface water, or leachate.
► WIVA 12103►1 !►
1. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans, specifications, and other supporting data.
2. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Pernttee, 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
Permitme. to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6A to 143-215.6C.
5. 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.
6. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of the project.
7. The annual administering and compliance fee must be paid by the Permittee within thirty
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 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.
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9. The subject wastewater treatment and disposal facilities shall be connected to an operational
publicly owned wastewater collection system within 180 days of its availability to the
subject facilities, if the subject wastewater treatment or disposal facilities are in
noncompliance with the terms and conditions of this non -discharge permit or the governing
statutes or regulations. Prior to the initiation of these connection activities, appropriate
approval must be received from this Division.
Permit issued this the 28th day of September, 1992.
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A. Preston Howard, Jr., P. E.
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit Number WQ0005910
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