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WQ0010689_Final Permit_20100607
NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director June 7, 2010 MR. ERNEST SHEPARD, PLANT MANAGER BAXTER HEALTHCARE CORPORATION 65 PITT STATION ROAD MARION, NORTH CAROLINA 28752 Dear Mr. Shepard: Dee Freeman Secretary Subject: Permit No. WQ0010689 Name Change of SUEZ Energy BioPower to Baxter Healthcare Corporation North Cove Steam Generation. Plant Ash Distribution Program Distribution of Residual Solids (503 Exempt) McDowell County In accordance with your application of January 22, 2010 informing us of the ownership change froze, SUEZ Energy BioPower, Inc. to Baxter Healthcare Corporation, we are forwarding herewith a modified Permit No. WQ0010689, dated June 7, 2010, to Baxter Healthcare Corporation for the continued operation of the subject ash distribution program. Please be aware that the structure and format of this permit has changed to comply with our current permitting policies. On August 5, 2009, Session Law 2009406, entitled "An Act to Extend Certain Government Approvals Affecting the Development of Real Property Within the State," was enacted by the General Assembly and signed into law. The Act, known as the Permit Extension Act of 2009, extends the expiration date of certain government approvals and permits. The subject permit falls within the scope of this Act and is therefore being extended until November 30, 2013. This permit shall be effective from the date of issuance until November 30, 2013; shall void Permit No. WQ0010689, issued on November 29, 2006; and shall be subject to the conditions and limitations as specified therein- You will note that the expiration date of this permit is the same as that of the permit it is replacing. There are no other changes to the permit. 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 the North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding. AQUIFER PROTECTION SECTION 1636 Pail Service Center, Raleigh, Notch Carolina 27699-1636 Location: 2728 Capital Boulevard, Raleigh, North Carolina 27504 One Phone: 919-733-3221 % FAX 1:919-715-0588; FAX 2: 919-715-60481 Customer Service: 1.877-623-6748 O } far© irla Internet; www.ncwatergua[iN.org An Ewa' Opporlunily ! Affirmative Amon Employer a urall Mr. Ernest Shepard June 7, 2010 Page 2 of 2 If you need any additional information concerning this matter, please contact Mr, David Goodrich by telephone at (919) 715-6162, or via e-mail at david.goodrich@ncdenr.gov. Sincerely, Lor oleen H. Sullins cc: Mr. Jim Henslee, VP of Commercial and Industrial Solid Fuel, SUEZ Energy BioPower, Inc. Mr. Ted Lyon, NC Division of Waste Management - Composting and Land Application Branch McDowell County Health Department Mr. Bradley Bennett, Surface Water Protection Section - Stonnwater Permitting Unit Mr. James E. Meyer, Laboratory Section - Laboratory Certification Unit Asheville Regional Office - Aquifer Protection Section .APS Central Files APS Files NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH PERMIT FOR THE DISTRIBUTION OF RESIDUAL SOLIDS (503 EXEMPT) 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 Baxter Healthcare Corporation McDowell County FOR THE continued operation of an on-site wood ash storage/stockpile site as well as a program for the distribution of wood ash (i.e., ponded and dry wood ashes including front or bottom ash, fly ash, scrubber ash, wood/sawdust, and/or any mixture thereof) generated from the residuals source -generating facilities listed in the most recently -certified Attachment A with no discharge of wastes to surface waters, pursuant to the ownership change notification received on January 28, 2010 as well as the additional information received on March 2, 2010 and in conformity with the project plan, specifications, and other supporting daia 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 November 30, 2013, shall void Permit No. WQ0010689 issued November 29, 2006, and shall be subject to the following specified conditions and limitations: I. SCHEDULES_fplease review the entire permit for reporting, monitoring, and other on-going activities) 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 that Rule 15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application II. PERFORMANCE STANDARDS 1. This permit shall become voidable in the event of failure of the ash distribution program to adequately protect the assigned water quality standards of the surface water and ground water. WQ0010689 Version 2.2 Shell Version 090204 Page 1 of 9 2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface waters or groundwater resulting from this ash distribution program, 3. Diversion ox bypassing of ash or leachate from the on-site ash storage/stockpile site shall be prohibited. All leachate shall be reused as a wetting agent or disposed of through a Division -approved method. 4. No ash that tests or is classified as a hazardous or toxic waste under 40 CFR Part 261 shall be sold or given away under the conditions of this permit. No residuals other than those generated by the residuals source -generating facilities listed in the most recently -certified Attachment A of this permit shall be approved for distribution or land application in accordance with this permit. The following uses shall be approved for the distributed ash under the ash distribution program in accordance with this permit: Type of Ash Approved Uses ♦ Structural/engineered rill (i.e., engineered fill that is properly placed and compacted) for embankments and for bases/ sub -bases under a structure or a footprint of a paved road, parking lot, sidewalk, walkway, or similar structure. ♦ Flowable fill for backfill of potable water mains as approved by the NC Division of Environmental Health, sanitary sewers, and storm drainage structures. ♦ Overlay for secondary roads, residential driveways, farm roads, and high -traffic farm areas as approved by the NC Department of Transportation. Bottom Ash / • Material for traction control during snow and ice events as Fly Ash / approved by the NC Department of Transportation. Scrubber Ash / ♦ Material for manufacturing of concrete products, brick Wood or Sawdust / products, lightweight aggregate, roofing materials, insulation products, plastics, and paints. Mixtures + Substitute for blasting grit, roofing granules, filter cloth precoat for sludge dewatering, as well as bedding for pipes, railroad beds, and underground storage tanks. ♦ Soil nutrient additive, amendment, or other agricultural purpose as approved by the NC Department of Agriculture and Consumer Services. ♦ Raw product for the stabilization of wastewater residuals. ♦ Daily, intermediate, and final cover at a landfill as approved by the NC Division of Waste Management. e Fuel for combustion in boilers, furnaces, etc. for energy recovery. 7. No ash other than that from the residuals source -generating facilities specified in Attachment A shall be distributed under this permit. No uses of the distributed ash other than those specified in Condition II. 6. shall be allowed. The Permittee shall request and obtain a permit amendment from the Division for each additional residual source -generating facility and use prior to distribution through the approved ash distribution program. WQ0010689 Version 2.2 Shell_ Version 090204 Page 2 of 9 The pollutant concentrations in any residuals that are distributed or land applied to any land application site shall not shall not exceed the following Ceiling and Monthly Average Concentrations (i.e., dry weight basis) Parameter Monthly Average Concentration (milligrams per kilogram) Ceiling Concentration (milligrams per kilogram) Arsenic 41 75 Cadmium 39 85 Copper 1,500 4,300 Lead 300 840 Mercury 17 57 Molybdenum n/a 75 Nickel 420 420 Selenium 100 100 Zinc 2,800 7,500 When land applying ash residuals to any site, the following setbacks shall be maintained: Description of Setback Setback (feet) Surface waters (streams — intermittent and perennial, perennial waterbodies, and wetlands) 50 Water supply well orspring' 100 a Unless underlain and overlain by a liner with a maximum hydraulic conductivity of 10-6 centimeters per second. If such a liner/cover is provided, ash shall not be placed within 25 feet of any water supply well or spring. Ash shall not be placed within one foot of the seasonal high water table. 10. The COMPLIANCE BOUNDARY for residuals land application programs is specified by regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The Compliance Boundary for each land application site is established at either 250 feet from the residuals land application area or 50 feet within the property boundary, whichever is closest to the residuals land application area. Per 15A NCAC 2T .0105(h), upon the request by the Permittee the Compliance Boundary may be located closer to the waste disposal area (provided the groundwater standards can be met at the newly established Compliance Boundary). Any approved relocation of the COMPLIANCE BOUNDARY will be noted in the most recently -certified Attachment B of this permit. An exceedanoe of Groundwater Standards at or beyond the Compliance Boundary is subject to remediation action according to 15A NCAC 2L .0106(d)(2) as well as enforcement actions in accordance with North Carolina General Statute 143-215.6A through 143-215.60. 11, The REVIEW BOUNDARY shall be established around each land application site midway between the Compliance Boundary and the perimeter of the residuals land application area. Any exceedance of Groundwater Quality Standards at the Review Boundary shall require action in accordance with 15A NCAC 2L.0106 (d)(1). WQ0010689 Version 2.2 Shell Version 090204 Page 3 of 9 III, OPERATION AND MAINTENANCE RE UMEMENTS The ash distribution program shall be properly and effectively maintained and operated at all times as a non -discharge system to prevent the discharge of any wastes resulting from the operation of this facility or program. 2. In the event that the ash 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. All ash shall be adequately stored to prevent runoff prior to distribution and use. The Permittee shall provide to the recipient of the ash guidance so that the recipient of the ash is aware of guidance regarding how to store the ash adequately to prevent runoff of the ash following distribution and prior to use. 4. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying ash from stockpile/storage areas onto adjacent property or into any surface waters prior to distribution and use. The Permittee shall provide to the recipient of the ash guidance so that the recipient of the ash is aware of guidance regarding how to take adequate provisions to prevent wind erosion and surface runoff from conveying ash from the location of use onto adjacent property or into any surface waters. 5. Adequate provisions shall be taken to ensure that the transportation of ash does not cause nuisances and hazards to public health and safety or otherwise cause an adverse impact (e.g., transport wet ash in leak -proof trucks or cover dry ash). Upon classification of the ash distribution program by the Water Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee shall designate a certified operator to be in responsible charge (ORC) of the program. The operator shall hold a certificate of the type classification assigned to. the program by the WPCSOCC. The Permittee shall also designate a certified back-up operator of the appropriate type to comply with the conditions of 15A NCAC 8G .0202. 7. When ash is distributed for use as a soil nutrient additive, amendment, or other agricultural purpose as approved by the NC Department of Agriculture and Customer Services, a label shall be affixed to the bag or other container in which the ash is distributed, or an information sheet shall be provided to the person who receives the ash. The label or information sheet shall contain the following minimum information: a. The name and address of the person who prepared the ash that is sold or given away in a bag or other container for application to the land. b. A statement that application of the ash to the land is prohibited except in accordance with the instructions on the label or information sheet. c. A statement regarding all buffers from the area to which the ash product is applied, as specified in Condition 11.9. d. A statement that the ash shall not be applied to any land that is flooded, frozen, or snow-covered. e. A statement that adequate procedures shall be provided to prevent surface runoff from carrying any disposed or stored ash into any surface waters, including the guidance stipulated in Condition 1I1.3. and Condition 1I1.4. WQ0010689 Version 2.2 Shell Version 090204 Page 4 of 9 E A statement that the application rates of the ash shall be limited to those that can be agronomically -justified (i.e., limited to that needed to meet the liming requirements of the crops being grown on the land). IV. MONITORING AND REPORTING REQUIREMENTS 1. 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. The ash from each residuals source -generating facility listed in the most -recently -certified Attachment A of this permit shall be analyzed to demonstrate that they are non -hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity, ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted on residuals generated by each residuals source -generating facility listed in the most recently -certified Attachment A of this permit. The analyses shall be performed at the frequency specified in the most recently - certified Attachment A of this permit, and the results shall be maintained on file by the Permittee for a minimum of five years. If residuals generated by a particular residuals source -generating facility are distributed or land applied at a frequency less than that which is specified in the most recently - certified Attachment A of this permit, the analyses shall be required for each residuals distribution and land application event. Only residuals that are generated by the residuals source -generating facilities that are identified as being exempt from this condition in the most recently -certified Attachment A of this permit shall not be required to comply with this monitoring requirement. If residuals generated by a particular residuals source -generating facility are insufficient to require a land application events during a required sampling period as specified in the most recently -certified Attachment A of this permit (e.g. no land application occur during an entire year when annual monitoring is required), no sampling data is required during the period of inactivity. The Permittee shall submit an annual report, as required in Condition IV. 8., even in the event that no land application events occur during an entire year, the annual report shall include an explanation for missing sampling data. Only residuals that are generated by the residuals source -generating facilities that are identified as being exempt from this condition in the most recently -certified Attachment A of this permit shall not be required to comply with this monitoring requirement. WQOO10689 Version 2.2 Shell Version 090204 Paee 5 of 9 The TCLP analysis shall include the following parameters (i.e.. note the regulatory level in milli per liter in parentheses): Arsenic (5.0) Barium (100.0) Benzene (0.5) Cadmium (1.0) Carbon tetrachloride (0.5) Chlordane (0.03) Chlorobenzene (100.0) Chlorofonn (6.0) Chromium (5.0) zu-Cresol (200.0) o -Cresol (200.0) p -Cresol (200.0) Cresol (200.0) 2,4-D (10.0) 1,4-Dicl-dorobenzen.e (7.5) Nitrobenzene (2.0) 1.2-Dichloroethane (0.5) Pentachlorophenol (100.0) 1,1-Dichlozoethylene (0.7) Pyridine (5.0) 2,4-Dinitrotoluene (0.13) Selenium (1.0) Endrin (0.02) Silver (5.0) Hexachlorobenzene (0.13) Tetrachloroethylene (0.7) Heptachlor (and its t,ydroxide) (0.00$) Toxaphene (0.5) Hexachloro-1,3-butadiene (0.5) Trichloroethylene (0.5) Hexachloroethane (3.0) 2,4,5 -Trichlorophenol (400.0) Lead (5.0) 2 -4,6 -Trichlorophenol (2.0) Lindane (0.4) 2,4,5 -TP (Silvex) (1.0) Mercury (0.2) Vinyl chloride (0.2) Methoxychlor (10.0) Methyl ethyl ketone (200.0) After the residuals have been monitored as specified above for two years at the frequency specified in the most recently -certified Attachment A of this permit, the Permittee may submit a request to the Division for a permit modification to request a reduction of this monitoring requirement. In no case, however, shall the frequency of monitoring be less than once per permit cycle. An analysis shall be conducted on the ash from each residuals source -generating facility listed in the most recently certified Attachment A of this permit. The analysis shall be performed at the frequency specified in the most recently certified Attachment A of this permit, and the results shall be maintained on file by the Permittee for a minimum of five years. The analysis shall include, but shall not necessarily be limited to, the following parameters: Arsenic Lead Phosphorus Barium Magnesium Potassium Cadmium Manganese Selenium Calcium Mercury Silver Chromium Molybdenum Sodium Copper Nickel Zinc Iron pH If residuals generated by a particular residuals source -generating facility are insufficient to require a land application event during a required sampling period as specified in the most recently -certified Attachment A of this permit, no sampling data is required during the period of inactivity. If no land application events occur during a complete calendar year, the Permittee need not make up the missed sampling events for that year. The Permittee sba11 submit a monitoring report annually, as required in Condition IV.S., even in the event that no land application events occur during an entire year. The annual report shall include an explanation for missing sampling data. WQ0010689 Version 2.2 Shell Version 090204 Page 6 of 9 After the residuals generated by a particular residuals source -generating facility have been monitored for two years at the frequency specified in the most recently -certified Attachment A of this permit, the Permittee may submit a request to the Division for a permit modification to reduce the frequency of this monitoring requirement. In no case, however, shall the frequency of this monitoring be less than once per year when a residuals land application event of residuals generated by the residuals source - generating facility occurs during that year. 4. Laboratory analyses of parameters as required by Condition IV. 2. and Condition N. 3. shall be performed/gathered on the residuals as they are to be distributed or land applied. Furthermore, analytical determinations made pursuant to the monitoring and reporting requirements of this permit shall be made by a laboratory certified by the Division for the parameters analyzed. 5. Laboratory analyses of parameters as required by Condition IV. L, Condition IV. 2., and Condition rV. 3. shall be in accordance with 15A NCAC 02B .0505. 6. Proper records shall be maintained by the Permittee tracking all asb distribution activities. These records shall include, but are not necessarily limited to, the following information: a. Source and type of ash distributed; b. Information regarding the standard operating procedures {SOPS} of the residuals source -generating facility during the year, and justification for points where ash samples were taken to ensure that conducted sampling is representative of the ash distributed as a result of varying SOPS; c. Date of ash distribution; d. Name of the initial recipient of the ash, and amount distributed, and the intended use. 7. All records required as part of this permit shall be retained a minimum of five years. 8. Three copies of all required monitoring and reporting requirements as specified in Permit Conditions N.1., N.2., N.3. and IV.7.shall be submitted annually on or before March I" of the year following any distribution event to the following address: NCDENR-DWQ Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27599-1617 Noncompliance Notification The Permittee shall report by telephone to the Asheville Regional Office, telephone number (828) 296- 4500, 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 distribution program which results in the land application of significant amounts of wastes which are abnormal in quantity or characteristic. b. Any failure of the distribution 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 and limitations of this permit or the parameters on which the system was designed. WQ0010689 Version 2.2 Shell Version 090204 Page 7 of 9 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. For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent failure of a storage structure, etc.) outside normal business hours must be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733- 3300. 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. V. INSPECTIONS 1. The Permittee or his designee shall inspect the facilities related to the ash distribution program (i.e., including the ash storage and transport 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. Under the conditions of this permit, the Permittee shall be exempt from inspecting facilities and sites where distributed ash is utilized, as long as the Permittee complies the requirements of Condition III. 3., Condition 111, 4., and Condition III. 7, 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 land application sites or facilities 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 1. This permit shall become voidable unless the activities of the ash distribution program are carried out in accordance with the conditions of this permit, the supporting materials, and in the manner approved by the 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. 3. 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 Statutes § 143- 215.6A through § 143-215.6C. 4. 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 2T .0105 (e). WQ0010689.Version 2.2 Shell Version 090204 Page 8 of 9 5. 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 government agencies (local, state, and federal) that have jurisdiction. 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 NCG010000, and any requirements pertaining to wetlands under 15A NCAC 02B .0200 and 02H .0500. 6. This permit may be modified, revolved, and/or reissued to incorporate any conditions, limitations and monitoring requirements the Division deems necessary in order to protect the environment and public health adequately. 7. This permit shall not be automatically transferable. In the event that there is a desire for the ash distribution program to change ownership or to change the name of the Permittee, a formal permit request shall be submitted to the Division 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. Permit issued this the 7th day of June, 2010. NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION i 'Cole,9KS. Sullins, Director Di sion of Water Quality By Authority of the Environmental Management Commission Permit Number WQ0010689 WQ0010689 Version 2.2 Shell Version 090204 Page 9 of 9 ATTACHMENT A - Approved Residual Sources Permit Number: WQ0010689 Version: 2.2 Baxter Ilealthcare Corporation Certification Date: 06/07/2010 Note: As of the date of this permit's issuance on June 7, 2010, the standard operating procedures (SOPS) for this facility consist of one-half of the wastewater recycle facilities permitted under Permit No. WQ0001512 to be shut -down and drained to dewater the ponded scrubber ash to the greatest extent possible. Dry fly ash and dry wood/sawdust are added to the ponded scrubber ash and mixed in order to render the ash suitable for land application. The ash is then removed and stored/stockpiled on site until it is distributed for use. Dry bottom ash is landfilled off-site. It shall be permissible for the described SOPS to be modified with no prior approval from the Division, and the 3,200 -dry ton per year maximum distribution volume permitted may include the various ashes either distributed as individual products or as mixtures in varying permutations. The Permittee shall take care to adjust the ash sampling program such that it is reflective of the SOPS currently being employed (i.e., see Condition IVA. for information regarding representative sampling). Monitoring frequencies are based on the actual dry tons applied per year, unless specified. The Monitoring Frequency Requirements Table below shall be used to determine appropriate sampling frequency. The Permittee is responsible for managing program to assure that adequate sampling is performed. Monitoring Fre u ncy Requirements Dry Tons Generated (short tons per year) Monitoring Frequency (Established in 40 CFR 503 and 15A NCAC 02T .111 <319 1/Year =>319 - <1,650 1/ Quarter 4 times per year =>1,650 - X16,500 Monitoring =>16,500 or greater 1/month (12 times per ear) Frequency Maximum for Monitoring Approved Permit Dry Tons Condition Frequency for Mineralization Owner Facility Name Count Number Issued By Is 503? Per Year IV. 2. a Condition IV. 3. a Rate Baxter North Cove Healthcare Steam Corporation Generation Plant McDowell WQ0001512 DWQ Non -503 3,200 See below See below n/a Total I 1 1 3,200 Note: As of the date of this permit's issuance on June 7, 2010, the standard operating procedures (SOPS) for this facility consist of one-half of the wastewater recycle facilities permitted under Permit No. WQ0001512 to be shut -down and drained to dewater the ponded scrubber ash to the greatest extent possible. Dry fly ash and dry wood/sawdust are added to the ponded scrubber ash and mixed in order to render the ash suitable for land application. The ash is then removed and stored/stockpiled on site until it is distributed for use. Dry bottom ash is landfilled off-site. It shall be permissible for the described SOPS to be modified with no prior approval from the Division, and the 3,200 -dry ton per year maximum distribution volume permitted may include the various ashes either distributed as individual products or as mixtures in varying permutations. The Permittee shall take care to adjust the ash sampling program such that it is reflective of the SOPS currently being employed (i.e., see Condition IVA. for information regarding representative sampling). Monitoring frequencies are based on the actual dry tons applied per year, unless specified. The Monitoring Frequency Requirements Table below shall be used to determine appropriate sampling frequency. The Permittee is responsible for managing program to assure that adequate sampling is performed. Monitoring Fre u ncy Requirements Dry Tons Generated (short tons per year) Monitoring Frequency (Established in 40 CFR 503 and 15A NCAC 02T .111 <319 1/Year =>319 - <1,650 1/ Quarter 4 times per year =>1,650 - X16,500 1/60 Days (6 times per ear =>16,500 or greater 1/month (12 times per ear) WQ0010689 Version 2.2 Attachment A Page 1 of 1