WQ0013276_More Information (Requested)_20191024

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
October 24, 2019
MANUEL IRUJO — VICE PRESIDENT OF OPERATIONS
NEW ENGLAND FERTILIZER COMPANY
97 EAST HOWARD STREET
QUINCY, MASSACHUSETTS 02169
Subject: Application No. WQ0013276
Additional Information Request
New England Fertilizer Company
DCAR
Distribution of Class A Residuals
Out of State
Dear Mr. Irujo:
Division of Water Resources' Central and Regional staff has reviewed the application package
received August 15, 2019. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on November
23, 2019.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Section A, or failure to provide the additional information on or before the above requested date may
result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders, En /ee2rs/—
Division of Water Resources
cc: Permit Application File WQ0013276
North Carolina Department of Environmental Quality I Division of Water Resources
DK 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 276991617
pwegrore�iow� r 919.707.9000

Mr. Manuel Irujo
October 24, 2019
Page 2 of 2
A. Residuals Quality Information:
The submitted toxicity characteristic leaching procedure (TCLP) analysis results for the Palm
Beach County NEFCO plant contained certain parameters with laboratory non -detect values that
are higher than the TCLP limits. These parameters cannot be verified to be below the TCLP limits
listed in section II.3. of the Residuals Source Certification form (FORM: RSC 06-16). These
parameters include:
a. Endrin;
b. Heptachlor and its Hydroxide;
c. Mercury; and
d. Toxaphene.
Submit documentation from a verified lab that demonstrates that these four parameters meet their
TCLP limits.
2. The nutrient determination for the Palm Beach County NEFCO plant in section II.5.b of the RSC
06-16 form do not contain results for aluminum, ammonia as nitrogen, calcium, magnesium, and
sodium. These parameters are necessary in order to calculate the residual's plant available nitrogen
(PAN) and sodium adsorption ratio (SAR) values. Please submit a nutrient analysis of the residuals
for these parameters.