WQ0006017_Final Permit_19931123

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B, Howes, Secretary
A. Preston Howard, Jr., P.E., Director
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November 23, 1993
Mr, Curtis Perry, Assistant Town Manager
Town of Beaufort
Post Office Box 390
Beaufort, North Carolina 28516
Subject: Permit No. WQ0006017
Informal Permit Adjudication
Town of Beaufort
Land Application of Wastewater Residuals
Carteret County
Dear Mr. Perry:
On December 11, 1992, the Division of Environmental Management issued Permit No.
WQ0006017 to the Town of Beaufort for the operation of a wastewater residuals land application
program. On January 12, 1993, the Town sent a letter to Ms. Carolyn McCaskill of the Water Quality
Permits and Engineering Unit which objected to some of the restrictions in the permit. The Division has
reviewed the objections expressed in the letter and is reissuing the permit based upon that review. This
approach was recently discussed between Mr. Dave Adkins of the Division's Wilmington Regional Office
and the Town and appeared to be satisfactory. The Town has concerns about the requirement in the permit
concerning the seasonal restriction of residuals on certain sites; therefore, the Division has added a
statement to the permit which allows the Town to make a demonstration that the groundwater table is three
feet below the land surface and thereby allow the land application of residuals beginning March 1 to those
applicable sites. The concerns expressed in your letter and the Division's position on those concerns are
discussed below:
Objection 1: You state that the Town is concerned about the number of fields that have been
deleted or seasonally restricted.
Response 1: 15A NCAC 2H .0219 requires that a one (1) foot vertical separation be maintained
between a wastewater residual application point and the SHWT (seasonal high water
table). In addition, when there is a separation of less than three feet between the
application point of an industrial wastewater residual and the SHWT, 15A NCAC 2H
.0219 requires that a demonstration be made using predictive calculations or modeling
methods which are acceptable to the Director (of DEM) that such land application will
not result in a contravention of classified groundwater standards. Since these
required analyses have not been provided, the Division must limit the land application
of wastewater residuals on the applicable sites; however, rather than totally reject the
applicable sites, the Division has unposed seasonal restrictions to allow the Town
some use of the sites which have the high SHWT. Additionally, a statement has been
added to condition V1.5 to allow the Town to make a demonstration that the
groundwater table is three feet below the land surface, thereby allowing the land
application of residuals beginning March 1 to those applicable sites.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Ernpicyer 50% recycled/ 100/. past -consumer paper

Mr. Curtis Perry
November 23, 1993
Page 2
Objection 2: You request that the seasonal restriction requirements be dropped on Fields CRB 1-I
and CRB 1-2.
Response 2: Fields CRB 1-1 and CRB 1-2 both have some acceptable and some unacceptable
areas. in its assessment of determining the appropriateness of permitting these fields,
the Division must use a conservative judgment, based upon a worst case scenario.
The requirements stated in response 1 above apply to Fields CRB 1-1 and CRB 1-2;
however, a statement has been added to condition V1.5 to allow the Town to make a
demonstration that the groundwater table is three feet below the land surface, thereby
allowing the land application of residuals beginning March 1 to those applicable sites.
Objection 3: You object to the deletion of Site CRB 1-3.
Response 3: Site CRB 1-3 was rejected due to the location of the seasonal high water table
(SHWT). Additionally, there seems to be a side issue regarding the ability to meet
the buffers from residences at this site.
Objection 4: You request that Site CRB 1-4 be limited by seasonal restriction rather than deleting
this site.
Response 4: The Wilmington Regional Office stated that the SHWT at this site was at the surface
and that this site has Rains soils. Due to the poorly drained characteristics of this type
of soil, this site was denied.
Objection 5: You questioned the limitation of allowing application only once every three years on
site CRB 3-1,
Response 5: This site is poorly drained and has a ditch running through the center of a low area of
the site. The Division stands by its original restrictions imposed in the permit.
The Division is hereby reissuing Permit No. WQ0006017. This permit shall be effective from the
date of issuance until November 30, 1997, shall void Permit No. WQ0006017, which was issued on
December 11, 1992, and shall be subject to the conditions and limitations as specified therein. PIease 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, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days after receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes, and filed with the Office of Administrative Hearings, P. O. Drawer 27447,
Raleigh, N. C. 27611-7447. Unless such demands are made, this permit shall be final and binding.

Mr. Curtis Perry
November 23, 1993
Page 3
If you need additional information concerning this matter, please contact Mr. Randy Jones at 919/
733-5083, extension 517.
Sincerely,
0 7
A. Prest6Howard, Jr., P.E.
cc: Carteret County Health Department
Wilmington Regional Office, Water Quality
Wilmington Regional Office, Groundwater
Groundwater Section, Jack Floyd
Training and Certification Unit (no revised rating)
Facilities Assessment Unit
Bio Gro Systems, Inc. (12701 Lancaster Highway, Pineville, NC 28134)

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
WASTEWATER RESIDUALS 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
Town of Beaufort
Carteret County
FOR THE
operation of a wastewater residuals land application program consisting of the application of approximately
34.4 dry tons per year of residuals from the Town of Beaufort wastewater treatment facility to
approximately 66.5 acres of land in Carteret County with no discharge of wastes to the surface waters,
pursuant to the informal adjudication request submitted on January 12, 1993, 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 November 30, 1997, shall void Permit
No. WQ000601.7, which was issued on December 11, 1992, and shall be subject to the following
specified conditions and limitations:
I. PERFORMANCE STANDARDS
The Wilmington Regional Office, telephone number 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 8:00 a.m_ until 5:00 p.m. on
Monday through Friday, excluding State Holidays. Also the Carteret 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 adcquately 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.
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 18
months following sludge application.
7. Maximum slope for sludge application shall be 10% for surface application and 18% for
subsurface applications.
8. 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) 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 11) prior to application or
incorporation. An evaluation of all sludges as specified in condition H 4 must be conducted
as to their ability to demonstrate compliance with this requirement. Upon request, a copy
of this report must be submitted to the Assistant Chief for Operations, Division of
Environmental Management, Water Quality Section, Operations Branch, PO Box 29535,
Raleigh, NC 27626-0535.
It. An alternative means of residuals stabilization, to meet EPA requirements for at Ieast PSRP
lgyels, shall be available in the event that the present method of residuals stabilization fails
.to meet PSRP levels.
12. Specific sludge application area boundaries shall be clearly marked on each site prior to and
during sludge application.
2

13. No sludge at any time shall be stored at any application site.
II. OPERATION AND MALNTENANCE 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:
Croy _
PAN (lbs/acreZyear)
Wheat
100
Barley
100
Oats
100
Soybeans
150
Corn Grain
160
Corn Silage
220
4. No residuals other than the following are hereby approved for land application in
accordance with this permit:
Permit Estimated
ounce_ County Number Volume (dU tons/year)
Town of Beaufort WWTP Carteret NCO021831 34.4
5. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings (ibs/acre)
PPgamet
CEC < 5
CEC 5 - 15
Lcad
500
1000
Zinc
250
500
Copper
125
250
Nickel
125
250
Cadmium
4.5
9
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 1 facility at
least weekly and each Class 11, 111, 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 residuals material into any surface waters.
8. Animals shall not be grazed on residuals applied land within a 30-day period following the
residuals 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 residuals 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.
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. MONITORINCz AND REPQRTING 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 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 punt 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.
0

% Base Saturation
Magnesium
Phosphorus
Potassium
Leadl
Zincl
pH
Manganese
Cation Exchange Capacity
Sodium
Nickell
Cadmiumx
Copperl
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 shall be conducted by the Permiuee 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 sludge analysis shall include but is not necessarily limited to the following parameters:
% 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, if requested, 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
Hexac hloro- 1, 3- bu tadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Tiichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
5. All sludges included in this permit must be monitored for compliance with condition 110 of
this permit_ Data to verify stabilization by a process to significantly reduce pathogens (as
described. in 40 CFR Part 257, Appendix 11) must be maintained by the Penxmittee. The
required data is specific to the stabilization process utilized, but should be sufficient to
clearly demonstrate compliance with 40 CFR Part 257.
5

6. Three copies of all monitoring and reporting requirements as specified in conditions 111 1,
III 2, 111 3, III 4, and III 5 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
7. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone
number 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:
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.
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.
IV. QRQUNDWATER REQUIREMENTS
1. Any groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
2. No land application of waste activities shall be undertaken when the seasonal high water
table is less than three feet below land surface.
3. The Compliance B_oundary 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 Statute 143-215.6(1)a. The sale of property, by the Permittee,
which is within or contiguous to the disposal site, may alter the location of the Compliance
Boundary.
7-
For facilities permitted on or after December 30, 1983, the Compliance Boundary is
established at the lesser of 250 feet from the perimeter of the disposal field or 50 feet within
the property boundary.
X,

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 for the disposal system is specified by regulations in 15A
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; ar,
(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.
V . INSPECTIONS
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.
VI. GENERAL CONDITIONS
1. 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.
7

5. The following are approved sites for sludge application (see attached map(s)):
Site No.
Owner/Lessee
Application Areal acres
CRB 1-12
Dewitt D. Page
4.9
CRB 1-2 (North)2
Dewitt D. Page
9.4
CRB 1-2 (South)2
Dewitt D. Page
9.0
CRB 2-12
Ruby K. Simmons
6.4
CRB 2-22
Ruby K. Simmons
5.4
CRB 3-13
Harry D. Lockey
31.4
Total
66.5
1- Application Area excludes buffer areas
2 - These land application sites designated as CRB 1-1, CRB 1-2 (North), CRB 1-2
(South), CRB 2-1, CRB 2-2, and CRB 3-lare partially covered in soils having a seasonal
high water table at depths ranging from ground surface to two (2) feet below land surface;
therefore, no residuals shall be applied to these sites from December 1 through March 31;
however, upon satisfactory demonstration to the Wilmington Regional Supervisor that the
groundwater table is three feet below the land surface, residuals may be applied beginning
on March 1.
3 - Field CRB 3-1 is poorly drained and has a ditch running through the center of the low
area which encompasses a large percentage of the available site area once required buffers
are in place. The contractor shall flag the low areas for non usage and the site shall be used
for surface application only one time per three year period and as per the seasonal period
listed above.
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 revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division of Environmental Management deems
necessary in order to adequately protect the environment and public health.

Permit issued this the 23rd day of November, 1993.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Preston oward, Jr., Pk., Director
Onvironrotntal
Division of Management
By Authority of the Environmental Management Commission
Permit No. WQ0006017
E

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