WQ0012896_Final Permit_19960925

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
September 25, 1996
David Crowley, President
Environmental Management Solutions, Inc.
2413 Cypress Court
High Point, North Carolina 27265
Dear Mr. Crowley:
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Subject: Permit No. WQ0012896
Environmental Management Solutions, Inc.
Land Application of Coca-Cola
Guilford County
In accordance with your request received on September 18, 1996, we are forwarding herewith
Permit No. WQ0012896, dated September 25, 1996, to Environmental Management Solutions, Inc. for
the one-time land application of approximately 750,000 gallons of Coca-Cola which was damaged during
Hurricane Fran.
This permit shall be effective from the date of issuance until August 31, 1997, 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, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please contact Mr. Michael D. Allen -at
[phone] extension 547.
Sincerely,
r
A. PrestgnlHoward, Jr.; P.E. ^
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cc: Guilford County Health Department
Winston-Salem Regional Office, Water Quality Section
Winston-Salem Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Facilities Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION 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
Environmental Management Solutions, Inc.
Guilford County
operation of a land application program consisting of the application of approximately 750,000 gallons of
Coca-Cola, to approximately 15.0 acres of land in Guilford County with no discharge of wastes to the
surface waters, pursuant to the request received on September 18, 1996, 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 August 31, 1997, and shall be subject
to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. The Winston-Salem Regional Office, telephone number [phone], shall be notified
at least forty-eight (48) hours in advance of operation of the installed facilities so that an in-
place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
2. This permit shall become voidable if the soils fail to adequately assimilate the wastes and
may be rescinded unless the sites are maintained and operated in a manner which will
protect the assigned water quality standards of the surface waters and ground waters.
3. The facilities 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.
4. 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.
5. In the event that the land application program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease applying residuals to the sites and
take any immediate corrective actions as may be required by the Division.

6. The following buffers shall be maintained:
a) 400 feet between wetted area and any residence or places of public assembly under
separate ownership,
b) 100 feet between wetted area and wells,
c) 100 feet between wetted area and the gully located in the middle of the field,
d) 50 feet between wetted area and property lines,
e) 50 feet between wetted area and drainageways or surface water bodies, and
f) 50 feet between wetted area and public right of ways,
1I. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities and application sites shall be properly maintained and operated at all times.
2. The pH of the material to be land applied shall be raised to a minimum of 7.0 prior to
disposal.
3. A suitable vegetative cover shall be maintained on the disposal fields after application in
accordance with the crop management plan outlined by the local Extension Office of the
Department of Agriculture, or the Soil Conservation Service, or other agronomist, and
approved by this Division.
4. Irrigation shall not be performed during inclement weather or when the ground is in a
condition that will cause runoff.
Adequate measures shall be taken to prevent runoff from the disposal field.
6. No traffic or equipment shall be allowed on the disposal area except while installation
occurs or while normal maintenance is being performed.
7. Public access to the land application sites shall be controlled during active site use. Such
controls may include the posting of signs showing the activities being conducted at each
site.
8. For areas that are prone to flooding or within the 100 -year flood elevation, the Coca-Cola
may be applied only during periods of dry weather.
9. The Coca-Cola shall not be applied in inclement weather or until 24 hours following a
rainfall event of 112 -inch or greater in 24 hours. Any emergency residuals disposal
measures must fust be approved by the Division of Water Quality.
10. The Coca-Cola shall not be applied to any land application site that is flooded, frozen or
snow-covered.
11. Animals shall not be grazed on an application site for 30 days after application. Application
sites that are to be used for grazing shall have fencing that will be used to prevent access
after each application.
III. MONITORING AND REPORTING. REQUIREMENTS
I . Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division of Water Quality 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 application activities.
These records shall include, but are not necessarily limited to the following information:
a. date of application
b. weather conditions (sunny, cloudy, raining, etc.)
c. soil conditions
d. volume of Coca-Cola applied in gallons/acre, dry tons/acre or kilograms/hectare
3, A representative soils analysis (Standard Soil Fertility Analysis) shall be conducted on each
site receiving Coca-Cola prior to application and once all the material has been land applied.
The Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the
following parameters:
Acidity
Calcium
Copper
Magnesium
Base Saturation (by calculation)
Cation Exchange Capacity
Manganese Potassium
Percent Humic Matter Sodium
pH Zinc
Phosphorus
4. Three copies of all required monitoring and reporting requirements as specified in
conditions IIT 1, 1112, and 1113, shall be submitted annually on or before March 1 of the
following year to the following address:
NC Division of Water Quality
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 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 land 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 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 transporting residuals 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.

I V . GROUNDWATER REQUIREMENTS
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983 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).
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.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the residuals storage, transport, and application
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 of Water Quality or other permitting authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises or place on
or related to the application 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
1. This permit shall become voidable unless the land application 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 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 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 of Water Quality 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

4. The following are approved sites for the Coca-Cola application (see attached map):
Application Area [acres]
Site No. Owner/Lessee (excluding buffers)
Jenny Barrow 15.0
TOTAL AVAILABLE ACRES 15.0
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 Water Quality in accordance with
North Carolina General Statute 143-215.6(a) to 143-215.6(c).
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 I5 NCAC 2H .0205
(c)(4).
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.
The Permittee, at Ieast 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 of Water Quality deems necessary in
order to adequately protect the environment and public health.
I0. This permit shall become voidable unless the agreements between the Permittee and the
landowners/lessees are in full force and effect. The land owner agreements are considered
expired concurrent with the expiration date of the permit and must be renewed at the same
time the permit is renewed.
Permit issued this the twenty-fifth day of September, 1996
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Preston Hol ward, Jr., P.E:, Director
Division of W,hter Quality
By Authority of the Environmental Management Commission
Permit Number WQ0012896
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