WQ0010285_Final Permit_20011025

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
October 25, 2001
MR. ALVIN L. THOMAS, 11, VICE PRESIDENT
SYNAGRo-WWT, INC.
1800 BERING DRIVE, SUITE 1000
HOUSTON, TEXAS 77057
Dear Mr. Thomas:
4 •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0010285
Baltimore Pelletece
Distribution of CIass A
Wastewater Residuals in the
State of North Carolina
Baltimore County, Maryland
In accordance with your permit name/ownership change application received on May 17, 2001, we are
forwarding herewith Permit No. WQ0010285, dated October 25, 2001, to Synagro-WWT, Inc. for the continued
operation of a wastewater residuals distribution program in the State of North Carolina. The product is a Class A
residual that is generated by Baltimore Pelletech®, a heat drying and pelletizing facility located in Baltimore
County, Maryland at the Back River Wastewater Treatment Plant site.
This permit is being reissued to reflect the fact that the entity responsible for permit compliance is now
Synagro-WWT, Inc. On August 14, 2000, Synagro Technologies, Inc. bought the stock of Wheelabrator Water
Technologies, Inc. A condition of the stock purchase agreement was that the name of Wheelabrator Water
Technologies, Inc. be changed to Synagro-WWT, Inc.
This permit shall be effective from the date of issuance until December 31, 2005; shall void Permit No.
WQ0010285, issued to Wheclabrator Water Technologies, Inc. on January 21, 2001; and shall be subject to the
conditions and limitations as specified therein.
Please take time review this permit thoroughly, as some of the conditions contained therein may have
changed since the last issuance of this permit. As always, 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 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 30 days following receipt of this permit. This request
must bd 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, North. Unless such demands are
made this permit shall be final and binding.
1617 Mail Service Center, Raleigh, forth Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

If you need additional information concerning this matter, plgpe contact M,ss. Shannon Mohr Thornburg at
[phone], extension 353.
S inc e
Gregory J. Thorpe, Ph.D.
cc: Ms. Gwen Kraus, Synagro-WWT, Inc.
Asheville Regional Office, Water Quality Section
Fayetteville Regional Office, Water Quality Section
Mooresville Regional Office, Water Quality Section
Raleigh Regional Office, Water Quality Section
Washington Regional Office, Water Quality Section
Wilmington Regional Office, Water Quality Section
Winston-Salem Regional Office, Water Quality Section
Groundwater Section, Central Office
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF CLASS A RESIDUALS
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
Synagro-WWT, Inc.
Baltimore County, Maryland
FOR THE
continued operation of a program for the distribution of Class A wastewater residuals in the State of North
Carolina. The program shall consist of the distribution of up to 10,000 U.S. dry tons per year of a Class A heat -
dried, pelletized product generated from the treatment of municipal wastewater residuals at Baltimore Pelletech`6', a
facility located at the Back River Wastewater Treatment Plant site in Baltimore County, Maryland. The program
shall be operated such that no discharge of waste to surface waters occurs, pursuant to the permit name/ownership
change application received on May 17, 2001 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 December 31, 2005; shall void Permit No.
WQ0010285, issued to Wheelabrator Water Technologies, Inc. on January 21, 2001; and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The residuals distribution program shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastes to waters of the state resulting from the operation of this
program.
2. This permit shall become voidable in the event of failure of the residuals distribution program to
adequately protect the assigned water quality standards of the surface waters and groundwaters.
3. 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 residuals distribution program.
4. In the event that the residuals distribution program is not operated satisfactorily, including the creation
of nuisance conditions, the Permittee shall take any immediate corrective actions as may be required by
the Division of Water Quality (Division).

II.
5. When wastewater residuals are sold or given away, one of the Class A pathogen requirements in 40
CFR Part 503.32(a) and one of vector attraction reduction requirements in 40 CFR Part 503.33 shall be
met. Additionally, an evaluation shall be performed which demonstrates the residuals' ability to
comply with this requirement. Upon request, a copy of this evaluation, including all test results and
calculations, shall be submitted.
OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals distribution program shall be properly operated and maintained at all times.
2. No residuals other than the following are hereby approved for distribution in accordance with this
permit:
Permit Volume
Source Countv Number (U.S._Dry Tons/Year
Baltimore Pelletech° Baltimore (Maryland) S -96-03-2964-G' 10,000
Sewage sludge utilization permit was issued by the Maryland Department of the Environment on
September 10, 1996 and is scheduled to expire on August 26, 2000.
2. No other residuals other than that from the facility specified in Condition 11. 1. above may be
distributed in the State of North Carolina under this permit. The Permittee shall request and obtain a
permit amendment from the Division for each additional facility prior to acceptance of that residual
product into the distribution program.
3. For a Class A residual product to be sold or given away in bags or other container for application to the
land, the following shall be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) shall be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters (rng1g) - (mg/kg)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
----
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
4. A label shall be affixed to the bag or other container in which residuals are sold or given away for
application to the land, or an information sheet shall be provided to the person who receives the
residuals sold or given away in another container for application to the land. The label or
information sheet shall contain the following information:
a. The name and address of the person who prepared the residuals that is sold or given away in a
bag or other container for application to the land.
b. A statement that application of the residuals to the land is prohibited except in accordance with
the instructions on the label or information sheet.
7

The following statement shall be included to help prevent direct application of the product to
water supply sources and all other waters of the state. "As with any fertilizer product, do not
apply in or near any water supply source or any body of water, including wells, streams, rivers,
and lakes."
d. Residuals shall not be applied to any site that is flooded, frozen, or snow-covered.
e. Adequate procedures shall be provided to prevent surface runoff from carrying any disposed or
stored residuals into any surface waters.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to ensure protection of the environment shall be established and an
acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee to track all residuals distribution activities. These
records shall include, but are not necessarily limited to, the following information:
a. Source, amount, and analysis of each residual.
b. Name of the initial recipient of the residuals in the State of North Carolina, the amount distributed,
and the intended point of distribution.
3. A residual analysis shall be conducted by the Permittee at a frequency according to the volume of
product distributed in the State of North Carolina:
Amount of Residuals Distributed
(U.S_Dry TonslYear) Monitoring Freguency
> 0 but < 319 annually
>= 319 but < 1,650 quarterly
>= 1,650 but < 16,500 every 60 days
>16,500 monthly
The testing frequency cycle shall start on the date of permit issuance, and the results of all analyses
shall be maintained on file by the Permittee for a minimum of five years. The residuals analysis shall
include the following parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
PIant Available Nitrogen
(by calculation)

4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the Permittee on
the residuals annually. The TCLP analysis shall include the following parameters (i.e., note the
regulatory level in milligrams per liter in parentheses):
Arsenic (5A)
Cadmium (1.0)
Chlorobenzene (100.0)
o -Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (013)
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)
All residuals included in this permit shall be monitored by the Permittee for compliance with Condition
I. 5. of this permit at a frequency according to the volume of product distributed in the State of North
Carolina:
Amount of Residuals Distributed
(US Dry Tons/Year)
Monitoring Frequency
> 0 but < 319
annually
>= 319 but < 1,650
quarterly
>= 1,650 but < 16,500
every 60 days
>16,500
monthly
The monitoring frequency cycle shall start on the date of permit issuance, and the results of all analyses
shall be maintained on file by the Permittee for a minimum of five years. Data to verify stabilization of
the residuals shall be maintained by the Permittee. The required data shall be specific to the
stabilization process utilized, but should be sufficient to demonstrate compliance with the Class A
pathogen requirements in 40 CFR Part 503.32(a) and the vector attraction reduction requirements in 40
CFR Part 503.33 clearly. In addition, the EPA certification statements concerning compliance with
pathogen requirements, vector attraction reduction requirements, and management practices shall be
completed at the above frequency by the proper authority or authorities if more than one is involved,
either the person who generates the residuals or the person who prepares the residuals to be sold or
given away.
6. Laboratory analyses and/or operational data, as required by Condition III. 3., Condition III. 4., and
Condition III. 5., shall be performed/gathered on the residuals as they are to be distributed.
Three copies of all required monitoring and reporting requirements as specified in Condition M. 1.,
Condition III. 2., Condition III. 3., Condition HI. 4., and Condition III. 5. shall be submitted annually on
or before March I' of the year following the distribution event to the following address:
NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Noncompliance Notification:
4

The Permittee shall report by telephone to the Water Quality Section of the appropriate Division
regional office (i.e., as specified in Attachment A), 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 residuals distribution program that results in the land application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the residuals distribution program resulting in a release of material to receiving
waters.
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 residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
Persons reporting such occurrences by telephone shall also file a written report in letterform 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.
IV. INSPECTIONS
The Permittee or his designee shall inspect the residuals storage, transport, and treatment 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 treatment 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.
V. GENERAL CONDITIONS
1. This permit shall become voidable unless the distribution activities are carried out in accordance with
the conditions of this permit, the supporting materials, and in the manner approved by this Division.
2. This permit shall be effective only with respect to the nature and volume of residuals described in the
application and other supporting data.
1 This permit shall not automatically transferable. In the event that there is a desire for the
facility/residuals distribution program to change ownership or there is a name change of the Permittee,
a formal permit request shall be submitted to the Division accompanied by documentation from the
parties involved and other supporting materials as may be appropriate. The approval of this request
shall 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
throuh §143 -215 -6C -
C,
5

5. The annual administering and compliance fee shall be paid by the Permittee within 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 shall not preclude the Permittee from complying with any and all statutes,
rules, regulations, or ordinances that may be imposed by other government agencies (i.e., Iocal, state,
and federal) which have jurisdiction including, but not limited to, applicable river buffer rules in 15A
NCAC 2B .0200, soil erosion and sedimentation control requirements in 15A NCAC Chapter 4 and
under the Division's General Permit NCG0100000, and any requirements pertaining to wetlands under
15a NCAC 2B .0200 and 15A NCAC 2H .0500.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its extension.
Upon receipt of the request, the Commission shall review the adequacy of the facilities described
therein, and if warranted, shall extend the permit for such period of time and under such conditions and
limitations as it may deem appropriate.
This permit may be modified, or revoked and reissued to incorporate any conditions, Iimitations, and
monitoring requirements the Division deems necessary in order to adequately protect the environment
and public health.
Permit issued this the twenty-fifth day of October, 2001.
NORTH OLIVA E O NTAL MANAGEMENT COMMISSION
f Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0010285

Attachment A
DIVISION OF WATER QUALITY REGIONAL OFFICES
Asheville Regional Office
WQ Supervisor
59 Woodfin Place
Asheville, NC 28801
Phone: [phone]
Fax: [phone]
Avery
Macon
Buncombe
Madison
Burke
McDowell
Caldwell
Mitchell
Cherokee
Polls
Clay
Rutherford
Graham
Swain
Haywood
Transylvania
Henderson
Yancey
Jackson
Raleigh Regional Office
WQ Supervisor
3800 Barrett Drive, Suite 101
Raleigh, NC 27609
Phone: [phone]
Fax: [phone]
Chatham
Nash
Durham
Northampton
Edgecombe
Orange
Franklin
Person
Granville
Vance
Halifax
Wake
Johnston
Warren
Lee
Wilson
Winston-Salem Regional Office
WQ Supervisor
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
Fax: [phone]
Alamance Rockingham
Alleghany Randolph
Ashe
Stokes
Caswell
Surry
Davidson
Watauga
Davie
Wilkes
Forsyth
Yadkin
Guilford
Pitt
Fayetteville Regional Office
WQ Supervisor
Wachovia Building, Suite 714
Fayetteville, NC 28301
Phone: [phone]
Fax: [phone]
Anson
Moore
Bladen
Robeson
Cumberland
Richmond
Harnett
Sampson
Hoke
Scotland
Montgomery
Pitt
Washington Regional Office
WQ Supervisor
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]
Beaufort ,Jones
Bertie
Lenoir
Camden
Martin
Chowan
Pamlico
Craven
Pasquotank
Currituck
Perquimans
Dare
Pitt
Gates
Tyrell
Greene
Washington
Hertford
Wayne
Hyde
Mooresville Regional Office
WQ Supervisor
919 North Main Street
Mooresville, NC 28115
Phone: [phone]
Fax: [phone]
Alexander
Lincoln
Cabarrus
Mecklenburg
Catawba
Rowan
Cleveland
Stanly
Gaston
Union
Iredell
Wilmington Regional Office
WQ Supervisor
127 Cardinal Drive Extension
Wilmington, NC 28405-3845
Phone: [phone]
Fax: [phone]
Brunswick New Hanover
Carteret Onslow
Columbus fender
Duplin