WQ0008431_Final Permit_19991130

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
November 30, 1999
Mr. D.E. Benton, City Manager
City of Raleigh
Post Office Box 590
Raleigh, NC 27602
• IT•
AW OFIVA
NCDENR
NORTH CAROLfNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0008431
City of Raleigh
E.M. Johnson Water Treatment Plant
AIum Sludge Landfill
Wake County
Dear Benton:
In accordance with your application received on April 2, 1998, we are forwarding herewith Permit No.
WQ0008431, dated November 30, 1999, to the City of Raleigh, Department of Public Utilities for the
operation of a landfill of sludge program.
This permit shall be effective from the date of issuance until October 31, 2004, shall void Permit No.
WQ0008431 issued November 12, 1993, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring and reporting requirements contained 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 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-
6417. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please contact Kristin Miguez at (919) 733-
5083, extension 524. /l
Sinc
i
Kerr T. Stevens
cc: Wake County Health Department
Raleigh Regional Office, Water Quality Section
Raleigh Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax[phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

y 1 aj� ""ll;:
�::
v

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
SLUDGE LANDFILL 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
City of Raleigh, Department of Public Utilities
Wake County
FOR THE
continued operation of an alum sludge landfill program consisting of the landfill of approximately 26 million
gallons of alum sludge from the City of Raleigh E.M. Johnson Water Treatment Facility, consisting of a lined,
on-site landfill with landfill decant wastewater being pumped by floating pump and overland piping back to
the water treatment plant's existing alum sludge dewatering facilities with no discharge of wastes to the
surface waters, pursuant to the application received on April 2, 1998 and in conformity with the project plan,
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 October 31, 2004, shall void Permit No.
WQ0008431 issued November 12, 1993 and shall be subject to the following specified conditions and
limitations;
I. PERFORMANCE STANDARDS
The land application program shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastes resulting form the operation of this program.
2. 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 program.
3. In the event that the landfill program is not operated satisfactorily, including the creation of
nuisance conditions, the Permittee shall cease disposing of the alum sludge into the landfill area
and take any immediate corrective actions, including the construction of additional or replacement
wastewater treatment or disposal facilities, as may be required by the Division of Water Quality
(Division).

H.
4. The following buffer zones shall be maintained:
a) 400 feet from residences or places of public assembly under separate ownership for
surface application method; however, the buffer zone requirement may be reduced to
a minimum of 100 feet upon written consent of the owner and the appropriate DEM
regional office,
b) 200 feet from residences or places of public assembly under separate ownership for
injection method; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and the appropriate DEM
regional office,
C) 100 feet from "SA and SB" classified waters and public surface water supplies for
both methods,
d) 50 feet from "WS" classified waters and other streams, creeks, lakes, rivers, and
surface water drainage ways for injection method,
e) 100 feet from "WS" classified waters and other streams, creeks, lakes, rivers and
surface water drainage ways for surface application method,
f) 50 feet from property lines for both methods; however, this requirement may be
reduced upon written concurrence from the adjoining property owner and the
appropriate DEM regional office,
g) 50 feet from public right of ways for surface application methods,
h) 25 feet from public right of ways for subsurface disposal methods,
i) 10 feet from upslope interceptor drains and surface water diversions for both methods,
j) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both methods.
Some of the buffers specified above may not have been included in previous permits for this land
application operation. These buffers are not intended to prohibit or prevent modifications, which
are required by the Division, to improve performance of the existing facility. These buffers do,
however, apply to modifications of the land application site. These buffers do also apply to any
expansion or modification of the land application site and apply in instances in which the sale of
property would cause any of the buffers now complied with, for the disposal facilities, to be
violated. The applicant is advised that any modifications to the existing facilities will require a
permit modification.
5. A copy of this permit shall be maintained at the surface disposal site when residuals are being
disposed during the life of this permit. A spill prevention and control plan shall be maintained in
all residuals transport and application vehicles.
OPERATION AND MAINTENANCE RE UIREMENTS
The facilities and disposal sites shall be properly maintained and operated at all times.
2. No sludges other than the following are hereby approved for landfill application in accordance
with this permit:
Permit Estimated
Source County Number Volume
E.M. Johnson Water Treatment Plant Wake NCO082376 26 million gallons
Upon classification of the facility by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall employ a certified operator to be in responsible
charge (ORC) of the surface disposal site. The operator must hold a certificate of the type
classification assigned to the surface disposal site by the WPCSOCC. The Permittee must also
employ a certified back-up operator of the appropriate type to comply with the conditions of 15A
NCAC 8A.0202.
2

4. Adequate procedures shall be taken to prevent any surface runoff from carrying any disposed or
stored sludge material into any surface waters.
5. Appropriate measures must be taken to control public access to the landfill site during active site
use. Such controls may include fencing and the posting of signs indicating the activities being
conducted at each site.
6. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
pollutants from the sludge landfill area onto the adjacent property or into the surface waters.
The pumping of supernatant/storrnwater from the alum landfill to the water treatment plant shall
not cause or allow any discharges to the groundwater or any surface waters. No nuisance
conditions shall be created by this pumping process.
Stormwaters shall be prevented from flowing onto the alum sludge landfill area.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed. If monitoring data indicates or
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 Iimited to the following information:
a. source of sludge,
b. date of sludge landfilling,
c. volume of sludge landfilled,
d. weather conditions, and
e. annual and cumulative totals of alum sludge.
3. A quarterly sludge analysis and annual Toxicity Characteristics Leaching Procedure (TCLP)
analysis shall be conducted by the Permittee and the results maintained on file by the Permittee for
a minimum of five years. If landfill 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 shall include the following parameters:
Arsenic (5.0)
Cadmium (1.0) M
Chlorobenzene (100.0)
o -Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0. 13)
Lead (5.0)
Methoxychlor (10.0)
Pentachlorophenol (100.0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5 -TP (Silvex) (1.0)
Barium (100.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chloroform (6.0)
Chromium (5.0)
m -Cresol (200.0)
p -Cresol (200.0)
2,4-D (10.0)
1,4 -Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachloroethane (3.0)
Lindane (0.4)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Toxaphene (0.5)
2,4,5 -Trichlorophenol (400.0)
2,4,6 -Trichlorophenol (2.0)
Vinyl chloride (0.2)
4. Three copies of all required monitoring and reporting requirements as specified in conditions 111 1,
1112, and I11 3, shall be submitted annually on or before March I of the following year to the
following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699.1617
5. Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919)
571-4700, 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 Iand application program resulting in a release of material to receiving
waters.
c. Any time that self-monitoring information indicates that the facility has gone out of
compliance with the conditions dnd 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 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 five (5) 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.
4

IV. GROUNDWATER REQUIREMENTS
The lagoon shall have a liner of natural material of least one foot in thickness, compacted to 95%
proctor standard dry density and installed and compacted in layers no thicker than six inches, with
a hydraulic conductivity of no greater than I x 10-5 cm/sec.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
The COMPLIANCE BOUNDARY for the disposal system (see Attachment) is specified by
regulations in 15A NCAC 2L, Groundwater CIassifications and Standards. The Compliance
Boundary for the disposal system is established at either (1) 250 feet from the waste disposal area,
or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is subject
to immediate remediation action in addition to the penalty provisions applicable under General
Statute 143-215.6A(a)(1).
Also in accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the waste
disposal area. Any exceedance of standards at the Review Boundary shall require remediation
action on the part of the Permittee.
V. INSPECTIONS
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 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 disposal site or
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; and
may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the landfill application activities are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by this Division.
9
2. This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data.

I This permit is not automatically transferable. In the event that 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 accompanied by an application fee, documentation from the parties involved, and
} other supporting materials as may be appropriate. The approval of t1lis 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
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
5. 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).
6. 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.
7. A set of approved documents for the subject project must be retained by the applicant for the life
of the permit.
S. 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.
9. This permit may be modified, or revoked and reissued to incorporate any conditions, limitations
and monitoring requirements the Division deems necessary in order to adequately protect the
environment and public health,
Permit issued this the thirtieth day of November, 1999
NORTH C OLINA ENV ONMENTAL MANAGEMENT COMMISSION
-GKcrr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0008431

D M
398]
RM
z-, I
MR\lN
,S! I H FEE -
3980
r
MA
Nut, tllk�l
41
3978
\j
55f
397-7 \.N,
;39
2000
3976
V
J4
L
3975
20000-

• 3' s r, r 5 r fJ�1 AffGcl,�, �A �. jJ• C��y of KA1e,��
. � % "„"'•..� ..r' �•• N.. f .. � G/rl. Joi,Noi+ �pfCr i'AhT `
itG�c.n�/
�r� n R .J',•• �.••'`✓ ~r'~ �,'f LOi. Iiah44 /Jtl�wr��,r
1-7
.r �~���'''.��� _• ..! 'f%� /JI d •� rte./r .. � i.�`!O�/ � � ,, '`t�..__,
''PROPOSED ALUM SLUDGE
r' E _ '
-- / ti .
SURFACE DESPOSM, FACIUTY �; �, •.. .............
..
j1