WQ0043432_Additional Information Request_20220808

ROY COOPER Governor lktv
ELIZABETH S. BISERSecretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
August 8, 2022
OSCAR BETANCOURT — CHIEF EXECUTIVE OFFICER
CARDIN FOODS, INC.
4250 ORCHARD PARK BOULEVARD
SPARTANBURG, SOUTH CAROLINA 29303
Subject: Application No. WQ0043432
Additional Information Request
Cardin Foods Class A Residuals
Program
Distribution of Class A Residuals
Out of State
Dear Mr. Betancourt:
Division of Water Resources' Central and Regional staff has reviewed the application package
received May 11, 2022. 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 September 7, 2022.
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 Sections A through C, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
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 an
electronic response submitted to my attention at: https://edocs.deq.nc.�zov/Forms/NonDischarfze-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Rob Willcox — Willcox & Mabe Soil Solutions, PLLC (Electronic Copy)
Laserfiche File (Electronic Copy)
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
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Mr. Oscar Betancourt
August 8, 2022
Page 2 of 2
A. Distribution of Class A Residuals (FORM: DCAR 06-16) Application:
1. No comments.
B. Operation and Maintenance Plan (O&M Plan):
1. In accordance with 15A NCAC 02T . 111 0(a)(4)(B), contact information for program personnel,
emergency responders, and regulatory agencies shall be provided in the spill control provisions.
Please provide an updated Spill Control Plan to include contact information in the "Notification"
section.
C. Residuals Source Certification (FORM: RSC 06-16) Form:
1. Section I, Item 1. of the RSC form did not include a name for this facility. Please provide a name
for this facility in this section.
2. Section I of the form indicates that the facility involves the treatment of 100% industrial
wastewater, that is a "Product of washed potatoes". However, it is unclear from this information,
the submitted O&M Plan, the program information, and the process flow documents whether the
"product of washed potatoes" would be categorized as a residual as a part of the 15A NCAC 02T
.1100 rules. According to 15A NCAC 02T .0103(30), a residual is:
"any solid, semi -solid, or liquid waste, other than effluent or residues from agricultural
products and processing, generated from a wastewater treatment facility, water supply
treatment facility, or air pollution control facility permitted under the authority of the
Commission. "
In 15A NCAC 02T .103(31), "Residues from agricultural products and processing" means:
"solids, semi -solids, or liquid residues from food and beverage processing and handling
silviculture, agriculture, and aquaculture operations permitted under the authority of the
Commission that are non -toxic, non -hazardous, and contain no domestic wastewater. "
Based on what was provided, this material could be considered a "residue from agricultural
products and processing", provided there is no domestic wastewater contributed. Please verify
whether the residue from this facility meets the definition of a residual based on the 02T rules. If it
does not, it would not be covered under this program and this application may be rescinded and the
North Carolina Department of Agriculture and Consumer Services (NCDACS) shall be contacted
about the land application of this material.
Section II, Item 5.c, the sodium adsorption ratio is 9.32, which is close to limit of 10 that shall
require the Permittee to obtain professional recommendations to address the sodium application
rate prior to land application. The Division recommends notifying 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 so that you are prepared for
any such requirements.
4. The quantitative justification for residuals production rate did not provide a justification for the
requested 500 dry tons per year. Please provide an explanation.