WQ0040622_Final Permit_20190904

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
September 4, 2019
J. BRYAN SMITH — PRESIDENT
ATLANTIC OBX, INC. DBA ATLANTIC SEWAGE CONTROL
POST OFFICE BOX 2560
KITTY HAWK, NORTH CAROLINA 27949
Subject: Permit No. WQ0040622
Atlantic OBX DCAR
Distribution of Class A
Residuals
Dare County
Dear Mr. Smith:
In accordance with your permit application request received January 31, 2019, and subsequent
additional information received June 14, 2019, we are forwarding herewith Permit No. WQ0040622 dated
September 4, 2019, to Atlantic OBX, Inc. dba Atlantic Sewage Control for the operation of the subject
residuals management program.
This permit shall be effective from the date of issuance through January 31, 2025, and shall be
subject to the conditions and limitations as specified therein. The Permittee shall submit a renewal
application no later than August 4, 2024.
Please pay particular attention to the monitoring requirements listed in Attachment A. Failure to
establish an adequate system for collecting and maintaining the required operational information shall result
in future compliance problems.
You emailed a letter on June 24, 2019, with the following points which are listed along with
replies:
The opening paragraph of the permit references Title 40 Code of Federal Regulations Part 257,
although there are no conditions in the permit that seem to reference requirements in the Part 257 rules. It
is our understanding that the State of North Carolina uses the 15A NCAC 02T rules along with provisions
found in Title 40 Code of Federal Regulations Part 503 to regulate all land application of residuals, although
Drinking Water Treatment Sludge is excluded in section § 503.6 of Title 40 Code of Federal Regulations
Part 503. There are several conditions in this Class A permit, as well as other Class A permits for bulk
sewage sludge, and the 15A NCAC 02T rules that are in direct conflict with the guidelines set forth in Title
40 Code of Federal Regulations Part 503 for Class A Residuals. In section § 503.10 of the 503 rules it states
that for residuals that meet the ceiling concentrations outlined in Table 1 of § 503.13, the pollutant
concentrations in Table 3 of § 503.13, the Class A pathogen requirements in § 503.32(a), and one of the
vector attraction reduction requirements in § 503.33 (b)(1) through (b)(8) the general requirements in §
503.12 and management practices in § 503.14 do not apply. Sources listed in the Attachment A of this
permit meet those requirements. While the Part 503 rules also contain language that the State Director may
apply more restrictive rules than the EPA, State of North Carolina policy states that NC rules cannot be
14 1n North Carolina Department of Environmental Quality I Division of Water Resources
D. FW 512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
os�a01eww.amrtb ® 919.707.9000

Mr. J. Bryan Smith
September 4, 2019
Page 2 of 6
more stringent than an EPA mandate. We believe this permit and the 2T rules attempt to place requirements
on Class A residuals that the Part 503 rules clearly state do not apply when Class A standards are met. It
seems that in some instances the 2T rules attempt to group together requirements for Class A and Class B
residuals, regardless of the source, while the Part 257 and Part 503 rules have very different definitions and
requirements for each. With that being said, we have provided comments on conditions of this permit below:
Response: Drinking water residuals are not regulated under CFR 503, as you stated. As a result,
they are regulated under CFR 257 for the EPA. This Permit is based on the statutes of the State of North
Carolina and Administrative Code, 15A NCAC 02T .1100.
Condition II.4.
The column labeled "Cumulative Pollutant Loading Rates" should be labeled "Monthly Average
Concentration" / CPLR is not applicable to Class A Residuals
Response: The column labeling has been fixed.
Condition H.7.
Setbacks listed in iv. and vi. of this condition do not match with the setbacks found in 15A NCAC
02T .1108(b). Furthermore, there are no setbacks found in the EPA 503 rules for Class A residuals. The
setback to surface waters can be found in § 503.14. According to § 503. 10, Management Practices found
in § 503.14 do not apply to residuals that meet Class A requirements. We request the Division remove the
setbacks to surface waters from this permit, as it is in conflict with the exemptions in the Part 503 rules.
Response: The setbacks have been changed to reflect 15A NCAC 02T .I 108(b).
While it is true that these setbacks are not contained in CFR 503, they are contained in 15A NCAC
02T .1108(b). This permit is issued under the authority of the State of North Carolina's regulatory code,
NCAC 02T rules and not under the authority of CFR 503 though reference is made to CFR 503.
Condition II.8.
We request language similar to the condition regarding SAR found in Class B Permits, which does
not require division approval. If the permittee can obtain and implement recommendations without division
approval in Class B permits, we feel the same should apply for Class A permits. As it reads now, the Class
A condition is more stringent than that for Class B.
Response: The Class B standard language for SAR greater than 10 is:
"Prior to land application of residuals containing a sodium adsorption ratio (SAR) of 10 or higher,
the Permittee shall obtain and implement recommendations from at least one of the following: the local
Cooperative Extension Office; the Department of Agriculture and Consumer Services; the Natural Resource
Conservation Service; a North Carolina Licensed Soil Scientist; or an agronomist. The recommendations
shall address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a mechanism for
maintaining site integrity and conditions conducive to crop growth. The Permittee shall maintain written
records of these recommendations and details of their implementation. [ 15A NCAC 02T .0108(b)(1)(A)]"

Mr. J. Bryan Smith
September 4, 2019
Page 3 of 6
In this permit, the language is:
"The Permittee shall not distribute Class A residuals that have a sodium adsorption ratio (SAR) of
10 or higher without prior written Division. approval. To receive Division approval, the Permittee shall
demonstrate that the entity accepting the residuals is: aware of the effects of a high SAR content; has agreed
on proper residual application rates; and has agreed to operational considerations to ensure that the high
SAR content will not adversely impact the receiving sites. Recommendations regarding sodium application
rate, soil amendments (e.g., gypsum, etc.) or a mechanism for maintaining site integrity and conditions
conducive to crop growth can be obtained from the local Cooperative Extension Office; the Department of
Agriculture and Consumer Services; the Natural Resource Conservation Service; a North Carolina Licensed
Soil Scientist; or an agronomist. [15A NCAC 02T .0108(b)(1)(A)]"
The language of the Class B permit is acceptable with the stipulation that the party receiving the
residuals with high SAR be informed that the residuals are in fact high in SAR and that over application of
these residuals is not desirable because of the deleterious affects this may have on the soils. Guidance
should be given as to the proper application rate. The language has been changed to reflect this.
Condition III.3.
Previous Class A permits have been exempted from having an ORC. Is this a new requirement for
Class A permits?
Response: Class A permits still do not have an ORC requirement. The following has been added
to the permit to make it clear that no ORC is currently required at the time this permit was issued. "At the
time this permit was issued, no ORC was required for this facility; however, if in the future the WPCSOCC
requires an ORC, one will be required."
Conditions 111.4. and III.S.
Are these conditions only applicable when transported or land applied by the permittee, or are they
applicable regardless who is doing the land application or transportation? Previous versions of Class A
language clearly state only when being performed by the permittee. The way it reads now is unclear.
Response: Condition III.4. previously stated: "When the Permittee land applies bulk residuals, a
copy of this permit and a copy of O&M Plan shall be maintained at the land application sites during land
application activities. [15A NCAC 02T .0 1 08(b)(1)]"
Condition III.S. previously stated: "When the Permittee transports or land applies bulk residuals,
the spill control provisions shall be maintained in all residuals transport and application vehicles. [15A
NCAC 02T .111 O]"
Since adoption of the new 2T rules in September of 2018, the justification for these are 15A NCAC
02T . I I I0(b) and 15A NCAC 02T . I I I0(a)(4), respectively. The wording has been changed to reflect more
closely the wording of the two parts of the statutory code.

Mr. J. Bryan Smith
September 4, 2019
Page 4 of 6
Conditions III.8.a., d., and k.
We request the Division remove these conditions from the permit. These requirements are
specifically named in § 503.14. It clearly states in § 503.10 that residuals meeting Class A requirements are
exempt from the Management Practices in § 503.14.
Response: This Permit is issued under the authority of the North Carolina administrative codes
NCAC 02T and not under authority of CFR 503. The provisions of Conditions II1.8.a., d., and k. are
specifically contained in NCAC 02T .I 109(a)(1)(a), (d) and (k)
Condition III.8.h.
We request removal of this condition or language that does not require division approval.
According to 15A NCAC 02T. 1103, land application sites onto which Class A non -biological residuals are
applied are deemed permitted if the residuals and activities meet said criteria. We feel it is contradictory to
be deemed permitted by rule but include conditions that must be division approved in those criteria. This
condition is also contradictory, in that it requires residuals to be incorporated if they have been injected. To
meet pathogen/vector requirements or on sites with slopes from 10%-18% one or the other is satisfactory.
The residual sources listed in this permit are non -biological, therefore exempt from meeting
pathogen/vector requirements. These residuals are also effective sources of lime. It is not common
agricultural practice to inject or incorporate lime whether it is a conventional or no -till site. Injection or
incorporation should not be required in this situation.
Response: This Permit is issued under the authority of the North Carolina administrative codes
NCAC 02T and not under authority of CFR 503. The provisions of Condition III.8.h. are specifically
contained in NCAC 02T . 1109(a)(1)(h)
Condition III.8. All remaining conditions
We do not understand why the 2T rules include site -specific conditions when the Part 503 rules
clearly exempt Class A residuals from the General Requirements found in § 503.12 and the Management
Practices found in § 503.14. The only other site -specific conditions found in the Part 503 rules pertain to
pathogen and vector and are only applicable to Class B, both of which do not apply in this case.
Response: This Permit is issued under the authority of the North Carolina administrative codes
NCAC 02T and not under authority of CFR 503. The provisions of Condition III.8. (All remaining
conditions) are specifically contained in NCAC 02T . 1 109(a)(1)(All remaining conditions)
Condition III.10.
We request the Division remove this condition from the permit. This requirement is specifically
named in § 503.14. It clearly states in § 503.10 that residuals meeting Class A requirements are exempt
from the Management Practices in § 503.14.
Response: This Permit is issued under the authority of the North Carolina administrative codes
NCAC 02T and not under authority of CFR 503. The provisions of Condition I1I.10. are specifically
contained in NCAC 02T . 1109(c).

A& J. Bryan Smith
September 4, 2019
Page 5 of 6
Condition IV.7.
We request the Division remove this condition. We feel it is not practical to implement different
record keeping requirements dependent on who is performing the distribution or land application. This
condition also effectively implements Class B record keeping requirements for all permittee performed land
application of Class A residuals. This is a Distribution of Class A Residuals permit, not a Residual Land
Application Permit. Record keeping requirements in Condition IV.6. should suffice for all Class A
Distribution or Land Application, regardless of who it is performed by.
Response: This condition has been removed.
Conditions V.I. and V.2.
The Permittee (Atlantic OBX, Inc.) is a contractor responsible for the transportation and
distribution of residuals. In this case, it should not be the responsibility of the permittee to inspect, maintain,
repair or ensure proper operation of storage at a facility they have no control over. It should be the
responsibility of personnel at the facility where the residuals are produced and covered under the Permit
and/or Operation & Maintenance Plan held by the facility.
Response: The words "Permittee-owned" have been added to the permit to indicate that the
Permittee is responsible for those pieces of the chain the Permittee owns and thus is responsible for.
Attachment A
Both sources on the permit are non -biological; monitoring frequency for pathogen and vector
should be "none" and footnote 6 should be added
Response: Attachment A has been fixed.
Final comment:
We would also like to point out the frequency at which 15A NCAC 02T .0108 Final Action on
Permit Applications to the Division is being cited in permit conditions. There are 41 total conditions in this
permit, 10 of which cite .0108. We feel this section is being used haphazardly and at an alarming rate to
impose additional and unnecessary permit conditions. These conditions are constantly changing and not
only hinder land application operations and marketing of residuals, but also limit access and make it more
difficult for individuals wishing to receive and beneficially reuse residuals to do so.
Response: Your comments have been noted.

Mr. J. Bryan Smith
September 4, 2019
Page 6 of 6
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail Service
Center, Raleigh, NC 27699-6714. Otherwise, this permit shall be final and binding.
If you need additional information concerning this permit, please contact Nathaniel Thornburg at
[phone] or nathaniel.thornburgCancdenrgov.
Sincerely,
mda Culpepper, DirectorTf
1 Division of Water Resources
cc: Dare County Health Department (Electronic Copy)
Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Drew Matthews — Soil Plus (Electronic Copy)
Laserfiche File (Electronic Copy)
Digital Permit Archive (Electronic Copy)
Central Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
RALEIGH
DISTRIBUTION OF CLASS A RESIDUALS 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
Atlantic OBX,Inc. dba Atlantic Sewage Control
Dare County
FOR THE
operation of a residuals management program for Atlantic OBX, Inc. dba Atlantic Sewage Control and
consisting of the distribution of Class A residuals generated by the approved facilities listed in Attachment
A, with no discharge of wastes to surface waters, pursuant to the application received January 31, 2019,
subsequent additional information received June 14, 2019, and in conformity other supporting data
subsequently filed and approved by the Department of Environmental Quality and considered a part of this
permit. The disposal of residuals is regulated under Title 40 Code of Federal Regulations Part 257. This
permit does not exempt the Permittee from complying with Federal Regulation 40 CFR Part 257.
This permit shall be effective from the date of issuance through January 31, 2025, and shall be subject to
the following conditions and limitations:
I. SCHEDULES
1. The Permittee shall request renewal of this permit on Division -approved forms no later than August 4,
2025. [15A NCAC 02T .0105(b), 02T .0109]
H. PERFORMANCE STANDARDS
The Permittee shall maintain and operate the subject residuals management program so there is no
discharge to surface waters, nor any contravention of groundwater or surface water standards. In the
event the residuals management program fails to perform satisfactorily, including the creation of
nuisance conditions due to improper operation and maintenance, the Permittee shall immediately cease
distributing residuals, take immediate corrective actions, and contact the Washington Regional Office
supervisor. [15A NCAC 02T .0108(b)(1)(A)]
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface
water resulting from the operation of this residuals management program. [15A NCAC 02T
.0108(b)(1)(A)]
3. Only residuals generated by the facilities listed in Attachment A are approved for distribution in
accordance with this permit. [15A NCAC 02T .1101]
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4. Pollutant concentrations in distributed residuals shall not exceed the following Ceiling Concentrations
or Monthly Average Concentrations, on a dry weight basis:
Parameter
Ceiling Concentration
Monthly Average
Concentration
(mg/kg)
(mg/kg)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
N/A
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
[15A NCAC 02T. I 105(a), 02T. I 105(c)]
5. Class A biological residuals shall meet the pathogen reduction requirements in 15A NCAC 02T
.1106(a). Exemptions to this requirement shall be specified in Attachment A. [15A NCAC 02T
.1106(a), 02T .1106(d)]
6. Class A biological residuals shall meet one of the vector attraction reduction alternatives in 15A NCAC
02T .1107(a). Exemptions to this requirement shall be specified in Attachment A. [15A NCAC 02T
.1107(a), 02T .1107(c)]
7. The facilities and sites herein were permitted per the following setbacks:
a. Setbacks for Class A land application sites are as follows (all distances in feet):
Liquid Cake
Residuals Residuals 1
i. Each private or public water supply source: 100 100
ii. Surface waters such as intermittent and perennial streams, perennial 100 25
waterbodies, and wetlands:
iii. Surface water diversions such as ephemeral streams, waterways, and 25 0
ditches:
iv. Groundwater lowering ditches where the bottom of the ditch 25 0
intersects the SHWT:
v. Each well with exception of monitoring wells: 100 100
vi. Bedrock outcrops:
25 0
' Unless otherwise noted in Attachment A, "cake" residuals are those that have greater than 15%
solids by weight and can be stacked without flowing, as well as can be handled, transported
and spread as a solid (e.g., using a backhoe, front end loader, slinger spreader, broadcast
spreader or other equipment designed for handling solid materials) without leaving any
significant liquid fraction behind.
[I 5A NCAC 02T .1108(b)]
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8. Residuals and other sources of Plant Available Nitrogen (PAN) shall not be applied in exceedance of
agronomic rates. Appropriate agronomic rates shall be calculated using expected nitrogen requirements
based on the determined Realistic Yield Expectations (RYE) using any of the following methods:
a. Division's pre -approved site specific historical data for specific crop or soil types by calculating
the mean of the best three yields of the last five consecutive crop harvests for each field.
b. North Carolina Historical Data for specific crop and soil types as provided by North Carolina State
University Department of Soil Science (http://nutrients.soil.ncsu.edu/yields/index.php). A copy
shall be kept on file and reprinted every five years in accordance with Condition IV.6.
c. If the RYE cannot be determined using methods (a) or (b) above, the Permittee may use the RYE
and appropriate nutrient application rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist.
ii. Waste Utilization Plan as outlined by the Senate Bill 1217 Interagency Group - Guidance
Document: Chapter 1
h( ttp //www.nca r. ov/SWC/tech/documents/9th Guidance Doc 100109. df).
iii. Certified Nutrient Management Plan as outlined by the Natural Resources Conservation
Services (MRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards(ftp://ftp-fc.se.egQv.usda.govlNHQ/practice-standards/standards/590.pdo
d. If the RYE and appropriate nutrient application rates cannot be determined, the Permittee shall
contact the Division to determine necessary action.
[I 5A NCAC 02T .1109(a)(1)(K)]
9. Prior to distributing Class A residuals that have a sodium adsorption ratio (SAR) of 10 or higher, the
Permittee shall obtain and implement recommendations from at least one of the following: the local
Cooperative Extension Office; the Department of Agriculture and Consumer Services; the Natural
Resource Conservation Service; a North Carolina Licensed Soil Scientist; or an agronomist. The
recommendations shall address the sodium application rate, soil amendments (e.g., gypsum, etc.), or a
mechanism for maintaining site integrity and conditions conducive to crop growth. The Permittee shall
maintain written records of these recommendations and details of their implementation. The Permittee
shall notify third -party entities of the effects of a high SAR content residuals on their receiving sites.
[15A NCAC 02T .0108(b)(1)(A)]
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III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The Permittee shall operate and maintain the residuals management program as a non -discharge system.
[15A NCAC 02T. 1100]
2. The Permittee shall maintain a Division -approved Operation and Maintenance Plan that shall include:
a. Description of the program, and associated facilities and equipment, in sufficient detail to show
what operations are necessary for the program to function and by whom the functions are to be
conducted;
b. Description of anticipated maintenance of facilities and equipment associated with the program;
c. Include provisions for safety measures, including restriction of access to sites and equipment;
d. Spill control provisions:
i. Response to upsets and bypasses including control, containment, and remediation; and
ii. Contact information for plant personnel, emergency responders, and regulatory agencies;
e. Detailed inspection procedures:
i. Names or titles of personnel responsible for conducting inspections;
ii. Frequency and location of inspections, and procedures to assure that the selected locations and
inspection frequency are representative of the residuals management program; and
iii. Description of record keeping and actions to be taken by the inspector in the event that
noncompliance is observed;
f. Detailed sampling and monitoring procedures:
i. Names or titles of personnel responsible for conducting sampling and monitoring;
ii. Description of monitoring procedures including parameters to be monitored; and
iii. Sampling frequency and procedures to assure that representative samples are collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for any
foreseen fluctuations in residuals quality and indicate the most limiting times for residuals to
meet pathogen and vector attraction reduction requirements.
[15A NCAC 02T A 110(a)]
3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the residuals management program, the Permittee shall designate and employ a
certified operator in responsible charge (ORC), and one or more certified operators as back-up ORCs.
The ORC or their back-up shall visit the facilities in accordance with 15A NCAC 08G 0204 and shall
comply with all other requirement in 15A NCAC 08G 0204. At the time this permit was issued, no
ORC was required for this facility; however, if in the future the WPCSOCC requires an ORC, one will
be required. [ 15A NCAC 02T .0117, 08G .0204]
4. The Permittee shall ensure that an electronic or physical copy of this permit and the Division -approved
Operation and Maintenance Plan is available when the Permittee is land applying bulk Class A
residuals. [ 15A NCAC 02T .1110(b)]
5. The Permittee shall ensure that spill control provisions are available when transporting or land applying
bulk Class A residuals. [15A NCAC 02T .1110(a)(4)]
6. Class A residuals may be staged at the land application site for up to 30 days for biological residuals
and 60 days for non -biological residuals. Class A residuals shall be stored or staged in a manner to
prevent runoff of leachate and other wastewaters generated. [ 15A NCAC 02T .1110(c), 02T .1110(d)]
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7. Adequate measures shall be taken to prevent wind erosion and runoff from the bulk Class A residual
land application sites. [15A NCAC 02T .0108(b)(1)(A)]
8. Bulk Class A residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under section
4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of surface
water or groundwater standards;
d. If the land is flooded, frozen, or snow-covered, or is otherwise in a condition such that runoff of
the residuals would occur;
e. Within the 100-year flood elevation, unless the residuals are injected or incorporated within a 24-
hour period following a residuals land application event;
f. During precipitation events, or within 24 hours following a rainfall event of 0.5 inches or greater
in a 24-hour period;
g. If the slope of the land is greater than 10% when liquid residuals are surface applied, or if the slope
of the land is greater than 18% when liquid residuals are injected or incorporated;
h. If the land does not have an established vegetative cover crop unless the land is a Division -approved
no -till site, or the residuals are injected, or incorporated within a 24-hour period following the
application of residuals;
i. If the vertical separation of the seasonal high water table and the depth of residuals application is
less than one foot;
j. If the vertical separation of the depth to bedrock and the depth of residuals application is less than
one foot;
k. If the application exceeds agronomic rates;
1. If the land application sites are located within a WS-I watershed pursuant to 15A NCAC 02B .0212
or within the Critical Area of a WS-II pursuant to Sub -Item (4)(g) of Rule 15A NCAC 02B .0212,
or within the Critical Area of a WS-III or WS-IV watershed pursuant to Sub -Item (4)(h) of Rules
15A NCAC 02B .0215, and .0216.
[ 15A NCAC 02T. I 109(a)(1), 02T. 1109(b)]
9. The Permittee shall notify all third -party entities receiving bulk Class A residuals that land application
activities occurring on the third-party's property shall meet the requirements in 15A NCAC 02T
.1108(b) and 02T .1109(a)(1) (i.e., Conditions 11.7.a. and 111.8., respectively). [15A NCAC 02T
.1103(a)(4), 02T .1103(a)(5)]
10. Bagged or other container Class A residuals shall have an affixed label or an information sheet provided
to the person receiving the Class A residuals. The label or information sheet shall contain the following:
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
[15A NCAC 02T. I 109(c)]
11. The Permittee shall not distribute bulk Class A residuals to any person or entity known to be applying
residuals contrary to the conditions of this permit. The Permittee shall report to the Washington
Regional Office any person or entity known to be applying residuals contrary to the conditions of this
permit. [15A NCAC 02T .0108(b)(1)(A)]
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IV. MONITORING AND REPORTING REQUIREMENTS
1. The Permittee shall conduct and report any Division required monitoring necessary to evaluate this
program's impact on groundwater and surface water. [15A NCAC 02T .0108(c)]
2. The residuals from each source generating facility shall be analyzed to demonstrate they are non-
hazardous under the Resource Conservation and Recovery Act (RCRA). Residuals that test or are
classified as a hazardous or toxic waste under 40 CFR Part 261 shall not be land applied. The analyses
(i.e., corrosivity, ignitability, reactivity, and toxicity characteristic leaching procedure (TCLP)) shall be
performed at the frequency specified in Attachment A, and the Permittee shall maintain these results
for five years. Any exemptions from the requirements in this condition shall be specified in Attachment
A. The TCLP analysis shall include the following parameters, and the Federal regulatory level (mg/L)
is in parentheses:
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Chlorobenzene (100.0)
Heptachlor (and its epoxide)
0.008
Tetrachloroethylene (0.7)
Hexachlorobenzene (0.13)
Toxaphene (0.5)
Chloroform (6.0)
Hexachlorobutadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
[15A NCAC 13A .0102(b), 02T .1101, 02T .1105]
WQ0040622 Version 1.0 Shell Version 190710 Page 6 of 10

3. The residuals from each source generating facility shall be analyzed at the frequency specified in
Attachment A, and the Permittee shall maintain the results for a minimum of five years. Each analysis
shall include the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
Plant Available Nitrogen
(by calculation)
[15A NCAC 02T .1101]
4. Residuals shall be monitored for compliance with pathogen and vector attraction reduction
requirements at the frequency specified in Attachment A. The monitoring results shall specify the
stabilization process utilized, and demonstrate compliance with the Class A pathogen reduction
requirements in 15A NCAC 02T .1106(a), and one vector attraction reduction requirement in 15A
NCAC 02T .1107(a) shall be met. Any exemptions from the requirements in this condition shall be
specified in Attachment A. [15A NCAC 02T .1106(a), 02T .1107(a), 02T .1111(c)]
5. Representative samples of residuals that are prepared for distribution shall be collected and analyzed.
[15A NCAC 02T. I I I l(a)]
6. The Permittee shall maintain records for all bulk Class A residual distribution events. These records
shall include the following:
a. Residuals source (as listed in Attachment A);
b. Date of distribution;
c. Name and address of residuals recipient;
d. Volume of residuals distributed to each recipient; and
e. Intended use of residuals.
[15A NCAC 02T .0108(c)]
One hard copy and one electronic copy of an annual report shall be submitted on or before March I"
The annual report shall meet the requirements described in the Instructions for Residuals Application
Annual Reporting Forms. Instructions for reporting and annual report forms are available at
httn://dea.nc.Eov/about/divisions/water-resources/water-resources-hermits/wastewater-branch/non-
discharge-permitting-unit/reporting-forms, or can be obtained by contacting the Non -Discharge Branch
directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
[15A NCAC 02T .111l(d)]
WQ0040622 Version 1.0 Shell Version 190710 Page 7 of 10

8. Noncompliance Notification
The Permittee shall report to the Washington Regional Office, telephone number [phone],
within 24 hours of first knowledge of the:
a. Any process unit failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of
adequate residual treatment.
b. Any failure resulting in a discharge to surface waters.
c. Any time self -monitoring indicates the program has gone out of compliance with its permit
limitations.
d. Distribution of residuals abnormal in quantity or characteristic.
e. Any discharge from a vehicle or piping system transporting residuals.
Emergencies requiring reporting outside normal business hours shall call the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone]. All
noncompliance notifications shall file a written report to the Washington Regional Office within five
days of first knowledge of the occurrence, and this report shall outline the actions proposed or taken to
ensure the problem does not recur. [15A NCAC 02T .0108(b)(1)(A)]
V. INSPECTIONS
1. The Permittee shall perform inspections and maintenance to ensure proper operation of the Permittee's
storage and distribution facilities. [ 15A NCAC 02T .1110(f)]
2. The Permittee shall inspect the Permittee's residuals transport facilities to prevent malfunctions, facility
deterioration, and operator errors that may result in discharges of wastes to the environment, threats to
human health, or public nuisances. The Permittee shall maintain an inspection log that includes the
date and time of inspection, observations made, and maintenance, repairs, or corrective actions taken.
The Permittee shall maintain this inspection log for a period of five years from the date of inspection,
and this log shall be made available to the Division upon request. [15A NCAC 02T .0108(b)(1)(A),
02T .1110(f)]
Division authorized representatives may, upon presentation of credentials, enter and inspect any
property, premises, or place related to the distribution sites or facilities permitted herein at any
reasonable time for determining compliance with this permit. Division authorized representatives may
inspect or copy records maintained under the terms and conditions of this permit, and may collect
groundwater, surface water, or leachate samples. [G.S. 143-215.3(a)(2)]
WQ0040622 Version 1.0 Shell Version 190710 Page 8 of 10

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to a
Division enforcement action. [G.S. 143-215.6A, 143-215.6B, 143-215.6C]
2. This permit is effective only with respect to the nature and volume of wastes described in the permit
application, and Division -approved plans and specifications. [G.S. 143-215.l(d)]
3. Unless specifically requested and approved in this permit, there are no variances to administrative codes
or general statutes governing the construction or operation of the facilities permitted herein. [15A
NCAC 02T .0105(n)]
4. The issuance of this permit does not exempt the Permittee from complying with all statutes, rules,
regulations, or ordinances that other jurisdictional government agencies (e.g., local, state, and federal)
may require. [15A NCAC 02T .0105(c)(6)]
5. If the permitted residuals program change ownership, or the Permittee changes their name, the
Permittee shall submit a permit modification request on Division -approved forms. The Permittee shall
comply with all terms and conditions of this permit until the permit is transferred to the successor -
owner. [G.S. 143-215.1(d3)]
6. This permit is subject to revocation or modification upon 60-day notice from the Division Director, in
whole or part for:
a. violation of any terms or conditions of this permit or Administrative Code Title 15A Subchapter
02T;
b. obtaining a permit by misrepresentation or failure to disclose all relevant facts;
c. the Permittee's refusal to allow authorized Department employees upon presentation of credentials:
i. to enter the Permittee's premises where a system is located or where any records are required
to be kept;
ii. to have access to any permit required documents and records;
iii. to inspect any monitoring equipment or method as required in this permit; or
iv. to sample any pollutants;
d. the Permittee's failure to pay the annual fee for administering and compliance monitoring; or
e. a Division determination that the conditions of this permit are in conflict with North Carolina
Administrative Code or General Statutes.
[I 5A NCAC 02T .0110]
WQ0040622 Version 1.0 Shell Version 190710 Page 9 of 10

7. Unless the Division Director grants a variance, expansion of the facilities permitted herein shall not
occur if any of the following apply:
a. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has been convicted of
environmental crimes under G.S. 143-215.613, or under Federal law that would otherwise be
prosecuted under G.S. 143-215.6B, and all appeals of this conviction have been abandoned or
exhausted.
b. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has previously abandoned
a wastewater treatment facility without properly closing the facility.
c. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid a civil
penalty, and all appeals of this penalty have been abandoned or exhausted.
d. The Permittee or any parent, subsidiary, or other affiliate of the Permittee is currently not compliant
with any compliance schedule in a permit, settlement agreement, or order.
e. The Permittee or any parent, subsidiary, or other affiliate of the Permittee has not paid an annual
fee.
[15A NCAC 02T .0120(b), 02T .0120(d)]
S. This permit shall not be renewed if the Permittee or any affiliation has not paid the required annual fee.
[15A NCAC 02T .0120(c)]
Permit issued this the 4t' day of September 2019
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
(Dmda Culpepper, Director
ivision of Water Resources
By Authority of the Environmental Mana fent Commission
Permit Number WQ0040622
WQ0040622 Version 1.0 Shell Version 190710 Page 10 of 10

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LOCATION MAP
Figure
Drawn by:
T r
SOIL PLUS
Granville Farm Class A (WQ0033587)
Reviewed bv: CSC
Elizabeth City, North Carolina
Date: Sept'15
Soil Plus Project # 200705.1310