WQ0014222_Final Permit_19971112

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
November 12, 1997
Michael A. Smith, Vice President
Valley Proteins, Inc.
Post Office Box 3588
Winchester, Virginia 22604
LTX.MAI
4 Is
A&I
DEHNF1
Subject: Permit No. WQ0014222
Valley Proteins, Inc., Rose Hill, NC Facility
Land Application of Wastewater Residuals
Duplin County
Dear Mr. Smith:
In accordance with your application received on August 1, 1997, we are forwarding herewith
Permit No. WQ0014222, dated November 12, 1997, to Valley Proteins, Inc. for the operation of a
wastewater residuals land application program. The land application of wastewater residuals will occur
through a solid set spray irrigation system onto Field #4 located at the Rose Hill facility which was
originally permitted for the spray irrigation of wastewater under WQ0000485.
Please be advised, the land application of residuals may not occur on the permitted acreage (Field
44) until the spray irrigation of wastewater has been discontinued. In accordance with documentation
provided to the Division, Field #4 will not be converted to spray sludge until April 1, 1998.
This permit shall be effective from the date of issuance until October 31, 2002, 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 fled 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, ple;se contact Mr. Michael D. AlIen at
[phone] extension 547.
Sincer ,
Preston Howard, Jr., P.E.
cc: Duplin County Health Department
Reid Engineering Company, Inc.
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Aff i'mative Action Employer 50% recycled/ 10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RESIDUALS 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
Valley Proteins, Inc.
Duplin County
FOR THE
operation of a wastewater residuals land application program consisting of the application of 245.0 dry
tons per year of residuals from the sources listed in Condition H 5, to approximately 17.47 acres of land in
Duplin County with no discharge of wastes to the surface waters, pursuant to the application received on
August 1, 1997, 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 October 31, 2002, and shall be subject
to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
L The Wilmington Regional Office, telephone number [phone], shall be notified at
least twenty-four (24) hours prior to the initial application of the residuals to a site so that
an inspection can be made of the application sites and application method. 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 land application 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.
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 of Water Quality
(Division).

6. 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 approval from the
appropriate regional office,
b) 200 feet from residences or places of public assembly under separate ownership for
subsurface residual 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 regional office,
c) 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods,
d) 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for surface application,
e) 50 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for subsurface application,
f) 50 feet from property lines for both surface and subsurface application methods;
g) 50 feet from public right of ways for both application methods,
h) 10 feet from upslope interceptor drains and surface water diversions for both
application methods,
i) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both application methods.
7. A copy of this permit shall be maintained at the land application site when residuals are
being applied during the life of this permit. A spill prevention and control plan shall be
maintained at the facility.
8. No residuals at any time shall be stored at any application site, unless approval has been
requested and obtained from the Division.
9. Only residuals from the aerated sludge holding tank are approved to be land applied at this
time. In the future if it is determined that the sludge from the lagoons must be land applied,
then this permit must be amended by Valley Proteins, Inc. prior to application.
10. When wastewater residuals are applied, the Class B pathogen requirements as defined in 40
CFR Part 503 or the Process to Significantly Reduced Pathogens (PSRP) as defined in 40
CFR Part 257 Appendix II shall be met. Additionally, an evaluation must be performed
which demonstrates the residuals ability to comply with this requirement. Upon request, a
copy of this evaluation must be submitted including all test results and calculations.
11. OPERATION AND MAINTENANCE REQUIREMENTS
l . The facilities and application sites shall be properly maintained and operated at all times.
2. A suitable vegetative cover, as listed in condition 114, shall be maintained in accordance
with the crop management plan outlined by the local Extension Office, the Department of
Agriculture, the Natural Resource Conservation Service, or other agronomist, and
approved by this Division.
3. An acceptable pH must be maintained in the soil, residual and lime mixture, greater than
6.0, on all land application sites to insure optimum yield for the crop(s) specified below.
The agronomist shall provide information on the pH best suited for the specified crop and
the soil type.

4. The application rates shall not exceed a hydraulic loading greater than 0.7 inches per hour
or a plant available nitrogen (PAN) loading greater than the following for the specified
crops:
Crop PAN (lb./acre/yr.)
Alfalfa
200
Bermuda Grass (Hay, Pasture)
220
Bermuda Grass (Coastal)
350
Blue Grass
120
Corn (Grain)
160
Corn (Silage)
200
Cotton
70
Fescue
250
Forest (Hardwood & Softwood)
75
Milo
100
Small Grain (Wheat, barley, oats)
100
Sorghum, Sudex (Pasture)
180
Sorghum, Sudex (Silage)
220
Soybeans
200
Timothy, Orchard, & Rye Grass
200
If the approved land application sites are to be double cropped (i.e., a crop in the spring
and a second crop in the fall, with BOTH crops to receive wastewater residuals), then the
second crop shall receive an application of residuals at a rate at least 50% less than the
above PAN rates, due to the fact that organic nitrogen is mineralized slowly over time (i.e.,
a second crop consisting of small grain shall receive have a PAN application rate of no
greater than 50 lb./acre/yr.). This practice will be allowed as long as the second crop is to
be harvested. If the second crop is to be planted for erosion control only, and is to be tilled
into the soil, then no residuals shall be applied to these fields because the nitrogen will
essentially be returned to the soil.
5. No residuals other than the following are hereby approved for land application in
accordance with this permit:
Permit Volume
Source County Number (dry tons/, e�az)
Valley Proteins, Inc. Rose Hill Facility Duplin WQ0000485 246.0
(from the aerated sludge holding tank only)
6. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings (Ibs/acre)
Parameter
CEC < 5
CEC 5 - 15
CEC > 15
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125 .
250
500
Nickel
125
250
500
Cadmium
4.5
9
18
7. Upon classification of the facility by the Water Pollution Control System Operators
Certification Commission (WPCSOCC), the Permittee shall employ a certified land
application/residuals operator to be in responsible charge (ORC) of the land application
program. The operator must hold a certificate of the type classification assigned to the land
application program 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.

8. Adequate procedures shall be provided to prevent surface runoff from carrying any
disposed or stored residuals into any surface waters.
9. Surface applied residuals will be plowed or disced within twenty-four (24) hours after
application on lands with no cover crop established.
10. For areas that are prone to flooding or within the 100-year flood elevation, residuals may
be applied only during periods of dry weather. The residuals must be incorporated into the
soil within twenty-four (24) hours after application.
11. Appropriate measures must be taken to control public access to the land application sites
during active site use and for the 12-month period following the last residual application
event. Such controls may include the posting of signs indicating the activities being
conducted at each site.
12. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying pollutants from the residuals application area onto the adjacent property or into
any surface waters.
13. Residuals shall not be applied in inclement weather or until 24 hours following a rainfall
event of 1/2-inch or greater in 24 hours. Any emergency residuals disposal measures must
first be approved by the Division.
14. Residuals shall not be applied to any land application site that is flooded, frozen or snow-
covered.
15. Residuals shall not be applied at rates greater than agronomic rates, unless authorized by
the Division.
15. Animals shall not be grazed on an application site for 30 days after residuals application.
Application sites that are to be used for grazing shall have fencing that will be used to
prevent access after each application.
17. Food crops, feed crops and fiber crops that do not come in contact with the residuals shall
not be harvested for 30 days after residuals application.
18. Food crops with harvested parts that touch the residual/soil mixture and are totally above
the land surface (ex. tobacco, melons, cucumbers, squash, etc.) shall not be harvested for
14 months after residuals application.
19. Food crops with harvested parts below the surface of the land (root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after application of residuals
when the residuals remain on the land surface for four (4) months or longer prior to
incorporation into the soil.
20. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after application of residuals when the residuals remain on the land surface for less
than four (4) months prior to incorporation into the soil.
21. Turf shall not be harvested for 1 year after residuals application if the turf is to be placed on
land with a high potential for public exposure.
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.
4

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. source of residuals
b . date of residual application
c. location of residual application (site, field, or zone #)
d . method of application
e. weather conditions (sunny, cloudy, raining, etc_)
f . soil conditions
g . type of crop or crops to be grown on field
h. volume of residuals applied in gallons/acre, dry tons/acre or kilograms/hectare
i. annual and cumulative totals of dry tons/acre of residuals, annual and cumulative
pounds/acre of each heavy metal (which shall include, but not be Iimited to cadmium,
copper, lead, nickel, and zinc), annual pounds/acre of plant available nitrogen (PAN),
and annual pounds/acre of phosphorus applied to each field.
3. A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted
on each site receiving residuals in the respective calendar year and the results maintained on
file by the Permittee for a minimum of five years.
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
The Standard Soil Fertility Analysis (see above) and an analysis for the following
pollutants shall be conducted once prior to permit renewal on soils from each site which has
received residuals during the permit cycle.
Cadmium Lead Nickel
4. A residuals analysis will be conducted annually from the date of permit issuance by the
Permittee and the results maintained on file by the Permittee for a minimum of five years.
If Iand application occurs at a frequency less than annually, a residuals analysis will be
required for each instance of land application. The residuals analysis shall include but is
not necessarily limited to the following parameters:
Cadmium
Nitrate -Nitrite Nitrogen
Copper
% Total Solids
Lead
pH
Nickel
Phosphorus
Zinc
Plant Available Nitrogen (by calculation)
Aluminum
Potassium
Ammonia -Nitrogen
Sodium
Calcium
TKN
Magnesium
5

5 . A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the
Perrmraittee annually. The TCLP analysis shall include the following parameters (please note
the regulatory level in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m-Cresol (200.0)
Cresol (200.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6.0)
o-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
6. All residuals included in this permit must be monitored annually from the date of permit
issuance, for compliance with Condition 110 of this permit. Data to verify stabilization of
the residuals must be maintained by the Permittee. The required data is specific to the
stabilization process utilized, but should be sufficient to clearly demonstrate compliance the
Class B pathogen requirements as defined in 40 CFR Part 503 or the Process to
Significantly Reduced Pathogens (PSRP) as defined in 40 CFR Part 257 Appendix II.
7. Three copies of all required monitoring and reporting requirements as specified in
conditions 111 1, III 2, 1113, III 4, III 5, and III 6 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
Non -Discharge Compliance/Enforcement Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington 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.
IV. 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.
3. No land application of waste activities shall be undertaken when the seasonal high water
table is less than three feet below land surface.
V. INSPECTIONS
1. 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 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 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
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 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. The following are approved sites for residuals application (see attached map[s]):
Application Area [acres]
Site No. _ Owner/Lessee (excluding buffers)
Duplin County
Field #4 Valley Proteins, Inc. 17.47
TOTAL AVAILABLE ACRES 17.47
5. 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.
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.
8. 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 welfth day of November, 1997 -
NORTH C OLINA E NTAL MANAGEMENT COMMISSION
r
'A. Preston oward, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0014222

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RATING SCALE FOR CLASSIFICATION 'OF WATER POLLViION CONTROL SYSTEMS
Name of Facility: VA"r, Iat. i?-se MILL
Owner or Contact Person: l+ tc- +Ae.L- Swarm, , VP
Maiiino Address: Po hex 1; 8Bg 22-G04
County: DJVL%A3 Telephone:_ (SAol $Z-) - z590
Present Classification: KoKC (59aAV) New Facility Existing Facility ✓
NPOES Per. No. NC00 -- Nondise. Per. No. W9oot4111 Health Dept. Per. No "
Rated by: M+c4otr� lka-Len Telephone: ')33-5063,4e,47 Date:,.(t_5-5?
Reviewed by: Health Dept Telephone:
Regional Office Telephone:
Central Office Telephone:
ORO: Grade: Telephone:
Check Classifieation(s): Subsurface Spray Irrigation LandAppliealion +�
Wastew'aier Classification: (Circle One) 1 11 Ill N Total Points:
4:�P.^�ce�ee51,�'�R�TE��`'TR7_FO+_11PM=rvTV.'11;7-IAR>vR.�/�'TE{.'�?A4?O�l+t'�'J5�'zlik:p��,.�T?C�h'�i►�LL
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NFL L.Mr FYFi,ATT FRJ'J ClAeSr-r-Aii0N
(check a:- un!Ls Thal apply)
1� �seplic tanks
2 p»p tiriks
3. stphor, or purnp-dosing systems
acne filters
5—grease trapinitmeptor
E oillwa;!' separators
7�_ svbsviace tree:men! and disposal:
-----___gravity
pressure
SPRAY IRR► ATCN M-A.S. iFC4TION
(duck aa, units thal apply)
1�
_preliminary trealmenl (definhion no. 32 )
2
lagoon
a-
septic: tanks
A —Pump
tanks
S—pu►nps
6�
xand fillers
7_
__,+grease lrWiinterceptor
$,
eltlwater aeparsiors
R _disinlection
tp�_
lehemica+ sddilioh for
riuirientlalgae control
11_ spray Irrigation of wasiewaler
Frelresimeni of weslewaler In excess of there components -shall be rated using the point rating
systerr and will require an operator with an appropriate dual eartifiestlon.
LANn E r-P.I^.ATI0N1RESiDUA:S CLASSIM&T1ON (A;�pies onty to pemift holder)
1.— Lane aTp'ialion o' biosoLds, residuals or conleminsied sells on a designated she.
HI,STE1'.'A7ER7P%EAT'MF-P,11 €AC4Lr3YCLkSSIFCATK)N
The 1o'!ow,n; Syslems shag! be assigned A Cass I dassllicalion, nf7 Iel% the flow lc of a signifitanl quantity or the teehnolopy Is
unvsuz!:y complex. tc re;vice WnSideralien by the Commission on a case-byt+.ss besis: (Check 1,1 Appropriate)
Separator Syslems consisting only D! physl.-a' se;.a•alion, pumps and disposal;
2. Septi: Tank/Send Filter Systems consisting only of septic tanks, dosinr Lpparalus, pumps,sand fillers, drsinieclion
and dates dlsrharge;
3—Lerner, Systems consisting only o! preliminary trealmerif, lagoons, pumps, disinloVion, necessary chemical
uea'men! for algae or nulrienl control, and direct discha+pe;
4- Closed•loop Fryele Syslems;
R,emediatio^ Systems consisting only of pumps, air -stripping, carbon adsorption, disinie:cion and
disposal;
6 Fish fares with dscha*ge In wface waters;
7�wz,e- Pant stodge hanc;,ng ant baJ•wrsh wait, Itasimetlt; -
16 pro.jessirip consisli% of sueening and disposal. -
:, S':ng:e•lamby discharging systems with the e:ceplion e.. Aerobic Trealmeni Units, will betiassified H permitted slier
July 1. 1Kat is upon inspection by the Division, 11 is found Thal She system is nos being adequwely operated or
m7=n',etned. Sur3, systems will be notified of the classiliralion or the Commission. in writing_