WQ0008490_Final Permit_19931220

State of North Carolina IF-"' JWA
Department of Environment,
Health and Natural Resources 0-11---4A •
Division of Environmental Management
James B. Hunt, Jr., Govemor
Jonathan B. Howes, Secretary C) C F1
A. Preston Howard, Jr., P.E., Director
December 20, 1993
Ray E. Shaw, Jr., Public Utilities Director
City of Greensboro
Post Office Box 3136
Greensboro, North Carolina 27402
Subject: Permit No. WQ0008490
City of Greensboro
Alum Sludge Landfill
Guilford County
Dear Mr. Shaw:
In accordance with your amendment request received September 21, 1993, we are forwarding
herewith Permit No. WQ0008490, dated December 20, 1993, to the City of Greensboro for the operation
of the subject alum sludge disposal landfill. This permit is being issued for a period of two (2) years to
allow the City of Greensboro to remove all sludge from the five (5) existing lagoons in order for the City
to destroy the lagoons and construct the two (2) new lagoons approved under an NPDES authorization to
construct. Once the lagoons are cleaned out and destroyed, the alum sludge landfill will be properly closed
and all additional alum sludge shall be incinerated at the T. Z. Osbourne Wastewater Treatment Plant_ The
closure of the landfill within two years is necessary due to the Environmental Protection Agency's newly
promulgated 503 Regulation which will significantly change the requirements for the ultimate disposal of
sludge by landfilling.
This permit shall be effective from the date of issuance until November 30, 1995 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 will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of North
Carolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
P.D. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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If you need additional information concerning this matter, please contact Mr. Michael D. Allen at
[phone].
Sincerely, n(�
1ni1, r r Y �-�
A. Pres Howard, r., P.E.
cc: Guilford County Health Department
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Jack Floyd, Groundwater Section, Central Office
Training and Certification Unit
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH 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 THE
City of Greensboro
Guilford County
operation of sludge disposal facilities consisting of the landfilling of dried alum sludge from the City of
Greensboro's Lake Townsend Wastewater Treatment Plant to approximately 1.5 acres of land in Guilford
County with no discharge of wastes to the surface waters, pursuant to the request received September 21,
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, 1995 and shall be
subject to the following speed conditions and limitations:
:_0f::)
1. The sludge disposal 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.
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 facility.
3. In the event that the sludge disposal program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease applying sludge to the landfill and
take any immediate corrective actions, including the construction of additional or
replacement wastewater treatment or disposal facilities.
4. The following buffer zones shall be maintained:
a) 400 feet from residences or places of public assembly under separate ownership for
the landfilling of sludge,
b) 100 feet from any private or public water supply source, including any WS-1
waters or Class I or Class H impounded reservoirs and public or private wells, used
as a source of drinking water,

c) 50 feet from waters classified as WS-II, WS-III, B, SA, ORW, HQW, or SB
[from normal high water (or tide elevation)],
d) 50 feet from property lines for the landfilling of sludge;
e) 50 feet from public right of ways for the landfilling of sludge,
f) 10 feet from upslope interceptor drains and surface water diversions for the
landfilling of sludge,
g) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for the landfilling of sludge.
5. A copy of this permit shall be kept at the alum sludge landfill during the life of this permit.
MINUI �� :►1 ►�; h ��_► 3:0141A. .►
1. 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 disposal in accordance
with this permit:
Permit
Sp_urce County Number
Lake Townsend WTP Guilford NC0081671
3. 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, III, 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.
4. Adequate procedures shall be provided to prevent 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 sludge landfill during
active site use. Such controls may include the posting of signs indicating the activities
being conducted at the site.
b. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residual landfill area onto the adjacent property or into the
surface waters or wetlands.
7. No crops for human consumption shall be raised on these sites.
8. Adequate inspection, maintenance and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
2

u1\ fc :01 go] IkA V oats114 Bill"I *a D113 \
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.
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) Date of sludge landfilling,
b) Volume of dried sludge disposed,
c) Percent Solids of sludge disposed.
3. An annual 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 land application occurs at a frequency less than
quarterly, sludge analysis will be required for each instance of land filling.
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
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
Hexachloro-1,3-butadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
3

4. Three copies of all monitoring and reporting requirements as specified in conditions III 1,
1112 and III 3 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
5. Noncompliance Notification:
The Permittee shall report by telephone to the Winston-Salem Regional Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence with the land filling program which results in the land filling of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the land filling 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
landfill 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.
1. Any groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
2. The C_ m, lance Boundary for the disposal system is specified by regulations in 15 NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary is established
at either (1) 250 feet from the waste disposal area, or (2) 50 feet within the property
boundary, whichever is closet to the waste disposal area. An exceedance of Groundwater
Quality Standards beyond the Compliance Boundary is subject to immediate remediation
action in addition to the penalty provisions applicable under General Statute 143-215.6(1)a.
3. In accordance with 15A NCAC 2L, a REVIEW BQIUNDARY is established around
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.
4

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.
_ ►-4 ANOW1321 DO IV 1 ►
1. This permit shall become voidable unless the sludge disposal 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. Issuance of this permit shall void all previously issued permits regulating the use of the
subject landfill and all Iandfilling activities.
5. 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.
6. 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).
7. 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.
S. A set of approved documents for the subject project must be retained by the applicant for
the life of the permit.
5

9. 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.
10. 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.
11. In any future transfer of this land, a notice shall be given to the new owner that gives full
details of the materials applied or incorporated at this site.
Permit issued this the 20th day of December, 1993
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Presto Howard, Jr., .E., Director
Division 6f Environmental Management
By Authority of the Environmental Management Commission
Permit No. WQ0008490
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RATING SCALE FOR�+CLASSIFICATION OF FACILITIESI
LA�JD
blame of Plant:
Owner or Contact Person: . A lc . u
Mailing Address: t~' t'r o N A7Z6 { '
_A County: (2W-jT__o" � Telephone: a-h9
--.p•NPDES Permit No. NCUO Nondisc. Per. No. Q Wb)? 90*
r_ FwT (ssueDate: -S-1 _91 Expiration Date: I��
Existing Faciiit New Facilityin�t�mA4 - ,. Rated By: r —
- Reviewed (Train. & Vert.) Reg. Office
Reviewed (Train, & Cert.) Central Office
ORC t2L- *hLS Grade
Punt Class: (circle one) _ 1 11 111 IV Total Points
ITBA POINTS (5) SECONDARY TREATMENT WITS
(a) Carbonaceous Stage
(1) Industrial Pretreatment Units andlor (t)Aeration - i-Ggh Purity Oxygen System..... 20
Industrial Pretreatment Program - Diffused Air System ........... 10
(see del•:niGon No. 33) 4 Mechanical Air System (fixed,
(2) R5$.�z_h' ROW OF PLANT IN GPD f waling or rotor} .............. a
(not applicable to non -contaminated cooling waters, sludge Separate Sludge Reaeration ..... a
handling facilities for water purificalion plants, totally (H) Trickling Filter
dosed cyrle systems (del. No. 11), and facilities High Rate ................... 7
consisling only of Item (4) (d) or Items (4) (d) and (11) (d)) Standard Rate ............... 5
0 — 20,DDD.......................... 1 n *M PackWTower ............... b
20,DDI — 50,DOD.......................... 2 a (111) SiologicaI Aerated Filter or Aerated
50,001 — 100,000 ........................... 8 GG Biological Filter ...................... 10
1D0,001 — 250,00D.......................... 4 Pa (iv) Aeratedl_agoons____................. _ - 10
250,DDI -500,000................. :.......... b
500,001--1,D00,00D .......................... 8 �Qg (v) Rolal-uig Biological Contactors .......... 10
. •10
12,oD0,OD11r(and up) -- rate i point addllional for each (vl) Sand Filters-
200,000 gpd capacity up to a inlerrnittent biological , . , . _ 2
maximum of 36 ;: recirculating biological ...... 3
Design Flow (gpd) _ (vn S12b7zalton Lagoons ......... . .......
(3) PRELIMINARY UNITS (see dernition no. 32) ,- _ {vtn C{arifier .............................. $
(a) Bar Sae ens....................._::: 1 _ (Ix) Single stagesystem y stem for combined
air carbonaceous removal of DOD and
(b) Mechanical Screens, Slatic Screens or ;"- - - nitrogenous removal by nitrification
Comminuting Dev''ices..................'...:.. Z - (see def. No. 12) (points for this Item
(c) Grit Removal ............................... 1 have to be in addition to items (5) (a)
or • _ (} through (5) (a) (v� .................. e
(dJ Mechanical or Aerated Grit Removal ;'::,;;.:+� (x) Nutrient add>fions to enhance BODE
(e) Flow MeasurinflDevice ....................... 1__ - tempval...._.... - .. $
or = (xi} Biological Culture ('Super Bugs"} addition
(f) Instrumenled Flow Measurement_'..........,. .- . 2 to enhance organic compound removal..... S
(g)Preaeralion........................._; 2 (b) Nilrogenous Stage
{1) Aeration - High Purity Oxygen System to
(h) Influent Flow"EquaGzarion , .. ! ` .. Diffused Air Sysleret ..... .. 113
n Grease or Orl Separators - Gravlty. .... 2 =: �L:T w: Mechanical Air System (fixed,
_ > Mechan'xa1 . .. .. S floating, or rotor) ...... ......
8
Dissolved Air Flotation. 8 T Separate Sludge Reaeration .. _ .. S
PrechtorinaGon. ``� ..... f$ K (rT) Trickling Filter • :°
_ }.; ' 7
L (4)`PRiMARYTREATMENT UNITS Standard f�a1e.::.::.;.:... 5
= (a) Sepf� Tank (see definition no. 43) . _ 2 :'' S
_ . -.
... ..:... .. ..-.:.,r. _ packed Towe►............
- (h) Imhoff Tank ........ S -. _ (iii) Biological Aerated Filter or Aerated
(c) Primary Clarifiers..
'..:.. "..' S - :"- t3iolog vat Filter ............ . .. 10
(d) Settling Ponds or Settling Tanks-for•Inorganie `, - �ialating 8ioiogical Contactors ...... 10
Non -toxic Materials (sludge handting facifi6es - (v Sand Filler-
r. for +rater purirication plants, sand, graved t- r intermittanl biological ..
stone, and other mining operations except :_ ,.. '_' fecircutafin9 ttiioTos�cai ........ 9
recreational activities such as em or old ..7 . r` (+) +�
g g vi ClarTer.. .. --
f ..... ... ......

.AY OR ADVANCED TREATMEWTI WT (10) t:hIEMiCAL ADD17fON SYSTEM (Sj (Ske de5nilion No. 9)
Activated Carbons Beds
1►et M 4_, _ ; _" (riot applicable to chemiW' eMiligns rated as item
without carbon roger mr*n .................... 3 i3) G7. (5) (a} 4x�. (s) (a}. #5) (6j.'Ci} @). {I) [e).
lwith vubon regeneration ........ ... _ - 7 5 ;; ,
•(9) (a). (9) (b), w (9) (c) 5 points wadi: List:
(b) Powdered or Granular Activated Carbon Feed - • - - _ _ . _ . . S
without carbon regeneration ........... .: - _-S _ _ .. S
with carbon regenenticxs ..............7f 5
Ak
-d) Det�ifi -cl a! ''arng ., Procrss (separate process) n�te 30 - _ - .. • _ - S
(e) Etedrodirslysis ................... . S
(11) RMISCELUWEOtlS 1N+ilTS
Foam Separation ............................... - 5
�ja) Holdingg Ponds, Holding Tangs or Settling Ponds
(g) ion ExchvVe.........................._... S _ for Organic or Toxic Mal"Is including master,
th) Land Application of Treated Eh7uenl _ _ " - from mining operations containing nitrogen and/or
(see definition no. 22b) (not applicable for - phosphorous compoundsinamounts significantly
sand, caravel, alone and other srrni�ar mining greater than is common for domestic wastewater 4
(1) on
(b) lEffluenl Flow Equalization (not applicable to storage
on agri..... . managed sites {See der. basins which are inherent in land application systems). 2
..---...•.. -----•�.•..........•.•. 1Q - (c) Stage Discharge (not applicable to storage basins
u ty high rate -infiltration on non -agriculturally ` ': inherent in land appficalion.systems 5
,managed silts (includes rotary distributors (d) Pumps-3
and skr ar fixed nozzle systems) ........... K (a) Stand -By Power Supply 8
(WI) by subsurface disposal (includes low pressure ( Thermal Pollution Control Device-_. 8
pipe systems and gravity systems except at
plants consisting of septic lank and s►iuiiiea-
6on tomes only) ............................
4 - - TOTAL POINTS
nMicroscreens . ................................ 5
(j) Phosphorus Aemoaal by Siologicat Processes CLASSIFICATION
(See del. No.261 ............................ to
(k) Polishing Ponds - without aeration ....... 2 Class l_. �. _._ 6 - 25 Points d—'— 2
with aeration .......... 5 " Bass 1 26- So Points
¢) Post Aerator► - cascade .............. O Vass III 51- 65 Points
dDused or mechanical ... 5 Class N 66- up Points
(m) Reverse Osmosis ............................... 5
(n) Sand or Mixed -Media Riers - low rate ........... 2 Facilities having a rating of one through four points. lndus'rve.
Ir'ghrate .......... 5 do not require a certified operator. Classification of at other
(a) Treatment processes lot removal of metal cw facilities requires a comparable grade operator in responsible
cyanide.................................... is charge.
{p) Treatment processes ror removal of bxie
matedats oilier than melai or cyanide ......... 15 FacaTit;es having an activated sludge process wM be assigned
a minimum classification of Class IL
t SLUDGE TREATMENT Facilities having treatment processes for the removal of metal
(a) Sludge Digestion Tanis - Heated ............... 10 or Cyanide will be assigned a minimum elassirrcation cf Class IL
Aerobic .... _ ......... 5
Unheated ............. S Facilities having treatment processes for the biological removal
(b) Sludge Stabiiizalion (chemical or therrnal) ....... 5 of phosphorus will be assigned a minimum classification of Class
(e) Sludge Drying Beds - GrmTy .......... - ..... ' 2 ILI.
Vacuum Assisled ....... 3
(6) Slerdge Ehrinason ........ • .................... 5 In -plant processes and related control equipment which are an
(e) Sludge Conditioner (cherrica! or thermal) ........ 5 Integral part of industrial production shall not be Considered waste
(1) Sludge Thidener(.gravity)...................... 5 treatment LrKewise, discharges of wastewater from residences
(9) Dissolved Air Flolalion Uni havinga design flow of 1.000
(not a Gcable To a unit rates as r gpd or less• shag not be subject b
( PP (3) {� ........ 16 rating. .
(h) Sludge Gas UtTmalion (include gas storage) .... 2
(i) Sludge /folding Tank- Aerated................ 5 ADDITIONAL COMMENT$;
f�ZZ �.h �06MS Non -aerated............ C _
{j Sludge incinerator - (not including activated
cabon regeneral'ion) ..... 10 StlriC cs:�
(k) Vacuum Finer, Centriruge or Filler Press or other
similar dewalering devices .................... 10 -
(a) SLUDGE DISPOSAL [ucluding inn}neraled ash) -
(a) Lagoons .................................... • ... 2 ;
(b) Land AppLcalion (surface and subsurface) S �t a% �•+a "I tt " / }�C Q - " ;. _
(see definirron 22a)
where the fae7ty holds the Land app. permit ... 10 f,t�., n
-by conlreclir,g to a land appfcalion operator who it �` C-a b v...' �w $A
_w holds the land applcation p unlit ................ 2
-fared application of sludge by a contractor who does
not hold the permit for the waslewater treatment _. "' t �•_F._w r.
fac"lily where the sludge is generated ......... 10
5 y
(c) tandGfled (burial) ..............................= r
(i ,INFECTION�...-
(a) Chlorinalion............................. 0 -
(b) Dechlorination.....................:.
(c) Ozone ......................
(d) Radiai'ron........................
:� 5 y