WQ0008431_Final Permit_20140603

Pat McCrory
Governor
A V�
—2:= .��
NCDENR
North Carolina Department of Environment and Natura{ Resources
June 3, 2014
Kenneth Best — Water Treatment Superintendent
City of Raleigh
P.O. Box 590
Raleigh, NC 27602
Dear Mr. Best:
John E. Skvarla, III
Secretary
Subject: Permit No. WQ0008431
E.M. Johnson WTP
Surface Disposal of Water
Treatment Plant Residuals
Wake County
In accordance with your permit renewal request received April 4, 2014, we are forwarding
herewith Permit No. WQ0008431 dated June 3, 2014, to the City of Raleigh for the continued operation
of the subject residuals management program. Please note that this renewed permit shall become
effective on November 1, 2014 (i.e, the day after the expiration date of the existing permit), which differs
from the date of this letter.
This permit shall be effective from November 1, 2014 until October 31, 2019, and shall be
subject to the conditions and limitations as specified therein. Please pay particular attention to the
monitoring requirements listed in Attachments A for they may differ from the previous permit issuance,
Failure to establish an adequate system for collecting and maintaining the required operational
information shall result in future compliance problems.
Please note that on September I, 2006, North Carolina Administrative Code Title 15A
Subchapter 02T — Waste not Discharged to Surface Waters was adopted. Accordingly, this permit
incorporates the requirements of these rules, therefore, please take the time to review this permit
thoroughly.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the forc><;< of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and
binding.
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] L Internet: http.ljportai,ncdenr.orglweb/wg
An Equal Opportunily 1 Affirmative Action Employer — Made in part wish recycled paper

Mr. Best
June 3, 2014
Page 2 of 2
If you need additional information concerning this matter, please contact Chonticha McDaniel at
[phone] or [e-mail].
Sincerely,
�-r ihoms A. Reeder, Director
Division of Water Resources
cc: Wake County Health Department
Raleigh Regional Office, Water Quality Regional Operations Section
Tommy Esqueda — Brown and Caldwell (5430 wade Park Blvd. Suite 200, Raleigh, NC 27607)
Beth Buffington, Public Water Supply Section -- Protection and Enforcement Branch
Permit File WQ0008431
Notebook File WQ0008431

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SURFACE DISPOSAL OF WATER TREATMENT PLANT RESIDUALS PERMIT
hi 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
City of Raleigh
Wake County
FOR THE
continued operation of a residuals management program for the City of Raleigh and consisting of the
surface disposal of Water Treatment Plant residuals generated by the approved facilities listed in
Attachment A to the approved surface disposal site with no discharge of wastes to surface waters,
pursuant to the application received April 4, 2014, and 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. The use and disposal of
residuals are regulated under Title 40 Code of Federal Regulations Part 257. This permit does not exempt
the Permittee from complying with the federal regulations.
The residuals conveyance facilities and a surface disposal unit consisting of the following components:
one portable supernatant return pump; approximately 1,419 linear feet of below -ground six-inch pipeline
to convey residuals to the surface disposal unit and return supernatant from the surface disposal unit for
treatment or disposal; a temporary above --ground six-inch pipeline (i_e., see Condition 1I.8) to distribute
residuals throughout the surface disposal unit; one pump station for the conveyance of returned
supernatant to the sanitary sewer and six 3,750-square foot sand filtration beds (approved to operate under
NDPES Permit No. NC0082376); one six -acre surface disposal unit with a total net capacity of 26 million
gallons; as well as all associated piping, valves, electrical and instrumentation/control systems, and other
appurtenances necessary to make complete and functional residuals conveyance facilities and surface
disposal unit for the conveyance and disposal of ferric sulfate residuals from the City of Raleigh's E.M.
Johnson Water Treatment Plant.
This permit shall be effective from November 1, 2014 until October 31, 2019, and shall be subject to the
following specified conditions and limitations:
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I. SCHEDULES
The Division of Water Resources (Division) shall be notified in writing at least 90 calendar days prior
to the date that the Permittee desires to initiate removal of residuals from the surface disposal unit. A
formal surface disposal unit residuals removal plan, containing site -specific information regarding the
proposed activities, shall be submitted at that time. The residuals removal activities shall not proceed
until the Division provides written approval of the plan and makes any modifications to this permit
that it deems necessary. Submit two copies of the surface disposal unit residuals removal plan to the
NCDENR-DWR, Water Quality Permitting Section, Non -Discharge Permitting Unit, 1636 Mail
Service Center, Raleigh, NC 27699-1636.
2. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
3. At least 180 days prior to the closing of a surface disposal unit, a formal closure plan and post -closure
management care program, as well as an implementation schedule shall be submitted. This
information shall be specific to the surface disposal unit, as well as relate to the Permittee's future
plans for the land. Submittals prepared in accordance with the United States Environmental
Protection Agency's Office of Research and Development document entitled "Process Design
Manual: Surface Disposal of Sewage Sludge and Domestic Septage (EPA/625/R-95/002)" are
acceptable. Submit three copies of all information to the Division of Water Resources, Water Quality
Permitting Section, 1636 Mail Service Center, Raleigh, NC 27699-1636,
H. PERFORMANCE STANDARDS
1. The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease
disposal of residuals to the surface disposal unit, contact the Raleigh regional office supervisor, and
take any immediate corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3, Only residuals generated by the facilities listed in Attachment A are approved for surface disposal in
accordance with this permit.
4. Pollutant concentrations in residuals for surface disposal shall not exceed the following Ceiling
Concentrations (dry weight basis):
Distance from Surface Disposal Unit
Boundary to Closest Property Line
(teeters)
Ceiling Concentration
(milligrams per kilogram)
Arsenic
Chromium
Nickel
25 to < 50
34
220
240
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5. 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.
6. Level gauges shall be maintained at all times to monitor freeboard levels in the surface disposal unit.
7. The above -ground six-inch polyvinyl chloride (PVC) pipeline used for distributing the residuals
within the surface disposal unit may be relocated at any time without prior notification to or approval
from the Division. The distribution pipeline may be constructed above ground as Iong as it is placed
on the interior embankment of the unit only.
8. Setbacks for conveyance facilities and surface disposal units shall be as follows:
Setback Description
Setback
(feet)
Habitable residence or place of public assembly under separate ownership or not to
be maintained as part of the pKoject site
400
Property lines
50
Public right of way
50
Private or public water supply
100
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
wetlands
100
Surface water diversions (ephemeral streams, waterways, ditches)
25
Groundwater lowering ditches (where the bottom of the ditch intersects the SI WT)
100
Subsurface groundwater lowering system
100
Wells with exception to monitoring wells
100
Water lines
10
Swimming pools
100
9. In accordance with 15A NCAC 02L .0107(d), no wells, other than Division approved monitoring
wells, shall be constructed within the compliance boundary, except as provided by 15A NCAC 02L
.0107(g).
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) pursuant to
15A NCAC 02T A 110. Modifications to the O&M Plan shall be approved by the Division prior to
utilization of the new plan. The O&M Plan, at the minimum, shall include:
a) Operational functions;
b) Maintenance schedules;
c) Safety measures;
d) Spill response plan;
e) Inspection plan including the following information:
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i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following inform' ation:
i. Names anal/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event.
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in
responsible charge (ORC) and one or more certified operators as back-up ORCs in accordance with
15A NCAC 08G .0201. The ORC or their back-up shall visit the facilities in accordance with 15A
NCAC 08G. 0204, or as specified in the most recently approved O&M plan (i.e., see Condition
II1.2.), and shall comply with all other conditions of 15A NCAC 08G. 0204. For more information
regarding classification and designation requirements, please contact the Division of Water
Resources' Technical Assistance & Certification Unit at [phone].
4. A copy of this permit shall be maintained at the surface disposal unit when, residuals are being
disposed. The spill prevention and control plan shall be maintained in all residuals transport and
application vehicles.
Freeboard of the surface disposal unit shall not be less than two feet at any time. The freeboard levels
in the unit shall be monitored by an individual level gauge that has readily visible permanent
markings indicating the maximum liquid level at the top of the temporary liquid storage volume,
minimum liquid level at the bottom of the temporary liquid storage volume, and top of the dam (i.e.,
at it lowest elevation within the unit) elevations, Freeboard levels at the unit shall be monitored and
recorded every day that a residuals disposal event occurs, every day that a supernatant decanting
event occurs, and not less than weekly otherwise.
6. Supernatant from the surface disposal unit shall be collected and returned to the treatment facilities at
the E.M. Johnson Water Treatment Plant for treatment and disposal or collected and drained to a
pump station for conveyance to the sanitary sewer for disposal as necessary to maintain the required
freeboard. Diversion or bypassing of supernatant shall be strictly prohibited.
7. 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 conducted at each site.
Adequate provisions shall be taken to prevent surface runoff from any active 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 Division approved
manner.
9. Adequate provisions shall be taken to prevent wind erosion from conveying residuals from the
surface disposal sites onto adjacent properties or into surface waters.
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10. A protective vegetative cover 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 or
otherwise controlled and accessible.
11. Food crops, feed crops and/or fiber crops shall not be grown on an active surface disposal unit, unless
approval has been requested and received from the Division.
12. Animal grazing shall not be permitted on an active surface disposal unit, unless approval has been
requested and received from the Division.
13. This permit shall become voidable if operation of the surface disposal sites causes contravention of
surface water or groundwater standards, and may be revoked unless the surface disposal sites are
maintained and operated in a manner that will protect the assigned surface water and groundwater
quality standards.
IV. MONITORING AND REPORTING REOUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses [corrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)J shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.008)
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
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3. An analysis shall be conducted on residuals from each source generating facility at the frequency
specified in Attachment A, and the Permittee shall maintain the results for a minimum of five years.
The analysis shall include the following parameters:
Arsenic
pH
Nickel
Chromium
Percent Total Solids
4. Laboratory parameter analyses shall be performed on the residuals as they are disposed, and shall be
in accordance with the monitoring requirements in 15A NCAC 02B .0505.
5. The Permittee shall maintain records tracking all residual surface disposal events. At a minimum,
these records shall include the following:
a. Date and freeboard level measurements in the surface disposal unit;
b. Source and date of residuals disposed of in or removed from the surface disposal unit;
c. Volume of residuals disposed of in or removed from the surface disposal unit in gallons per year,
dry tons per year, or kilograms per year;
d. Cumulative volume of residuals disposed of in or removed from the surface disposal unit in
gallons or cubic yards (i.e., excluding freeboard);
e. Remaining volume in the surface disposal unit in gallons or cubic yards (i.e., excluding
freeboard); and
f. An estimate of the remaining useful disposal life for the surface disposal unit in years (i.e.,
excluding freeboard).
6. Three copies of an annual report shall be submitted on or before March lit. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting
Forms. Instructions for reporting and annual report forms are available at
htt-p://,Dortal.ncdenr.org/web/wq/4ps/lau/rgportinR, or can be obtained by contacting the Land
Application Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 791-
4200, 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 surface disposal program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the surface disposal program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
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Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form within five days
following first knowledge of the occurrence. This report shall outline the actions taken or proposed to
be taken to ensure that the problem does not recur.
V. INSPECTIONS
1, The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan.
2. Prior to each bulk residuals surface disposal event, the Permittee or his designee shall inspect the
residuals storage, transport and application facilities to prevent malfunctions, facility deterioration
and operator errors resulting in discharges, which may cause the release of wastes to the
environment, a threat to human health or a public nuisance. The Permittee shall maintain an
inspection log that includes, at a minimum, the date and time of inspection, observations made, and
any maintenance, repairs, or corrective actions taken. The Permittee shall maintain this inspection log
for a period of five years from the date of inspection, and this log shall be made available to the
Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit.
3. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCGO10000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
5. In the event the residuals program changes ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
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6. The Permittee shall retain a set of Division approved plans and specifications for the life of the
facilities permitted herein.
The Permittee shall maintain this permit until all permitted facilities herein are properly closed or
permitted under another permit issued by the appropriate permitting authority pursuant to 15A NCAC
02T .01050).
8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110.
9. Unless the Division Director grants a variance, expansion of the permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
10_ The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 3"d day of June 2014
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
r o . Reeder, Director
Divi 'on of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0008431
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ATTACHMENT A - Approved Residual Sources
City of Raleigh — E.M. Johnson WTP
Certification Date: June 3, 2014
Permit Number: WQ0008431 Version: 3.0
Owner
FacilityName
Count y
Permit Number
Biological
Residuals
Maximum Dry Tons
Per Year �, s
Monitoring Frequency
for Non -hazardous
Characteristics z
Monitoring Frequency
for Metals 3
City of Raleigh
E.M. Johnson WTP
Wake
03-92-010
No
1,500
Annually
See Table Below
T AM
1,500
1. Maximum Dry Tons per Year is the amount of residuals approved for surface disposal from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition 1V.2.
3. Testing of metals as stipulated under permit Condition 1V.3.
4. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per ear)
Monitoring Frequency
(Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
I/Year
=>319 —1,650
1/ Quarter (4 times per year)
=>1,650 - <16,500
1/60 Days (6 times Rer ear)
=>16,500
1/month 12 times per ear)
5. Water Treatment Plant residuals are exempt from meeting the pathogens and vector attraction reduction requirements, provided they are not mixed with residuals that have been generated during
the treatment of domestic wastewater, the treatment of animal processing wastewater, or the biological treatment of industrial wastewater. The Water Treatment Plant residuals must be treated
and processed in a manner as to not meet the definition of "Biological Residuals" as defined in 15A NCAC 02T .1102(6).
If no disposal events occur at the surface disposal units during a required sampling period (e.g. no surface disposal occur during an entire year when annual monitoring
is required), then no sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data.
Page 1 of 1

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