WQ0017321_More Information (Requested)_20240328

March 28, 2024
BRANDON PRETZCH – FACILITY LEADER
CARGILL, INCORPORATED
5000 SOUTH BOULEVARD
CHARLOTTE, NORTH CAROLINA 28217-2700
Subject: Application No. WQ0017321
Additional Information Request #1
Cargill Class A Residuals Program
Distribution of
Class A Residuals
Mecklenburg County
Dear Mr. Pretzch,
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on January 4, 2024. However, the Division requires additional information before completing our
review. Please address the items on the attached pages no later than the close of business on April 29, 2024.
Please be aware that the Applicant is responsible for meeting all requirements set forth in North
Carolina rules and regulations. The Applicant is also responsible for any oversights that occur during the
review of the subject application package. The Division may return the application as incomplete pursuant
to 15A NCAC 02T .0107(e)(2) if any omissions are made when responding to the outstanding items in
Sections A through N or the Applicant fails to provide the additional information on or before the above-
requested date.
Please reference the subject application number when providing the requested information. The
Applicant shall sign, seal, and date (where applicable) all revised and/or additional documentation and
submit an electronic response to my attention via the Non-Discharge online portal.
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: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Samuel Emmanuel Dawson, PE – Fiss Environmental Solutions, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Brandon Pretzch
March 28, 2024
Page 2 of 3
A. Overall:
1. It is mentioned in several places of the application that residual material are transported to a
corporation that specializes in horticultural development. However, the current permit notes that
the Permittee is prohibited from directly distributing Class A residuals for marketing and land
application, and the permit would have to be modified to require testing and monitoring of the
material if the Permittee wants to distribute the residuals to organizations who would apply them.
Please provide an explanation of how the material is used in horticultural development at this third
party to determine if it is an activity that requires permitting.
B. Cover Letter:
1. See Item A.1.
C. Application (Form: DCAR 06-16):
1. In accordance with 15A NCAC 02T .0106(b), permit applications shall be signed by a principal
executive officer of at least the level of vice-president or his authorized representative. Mr. Brandon
Pretzch is not listed in our system as an authorized representative to sign on behalf of the Permittee.
To meet permit application submission requirements, one of the following actions shall be taken:
a. Provide an updated application form signed by an authorized permison pursuant to 02T
.0106(b).
b. Mr. Pretzch shall be provided authority to sign permit applications in accordance with 15A
NCAC 02T .0106(c). This delegation of authority shall be provided in writing to the Division
by an authorized person, in this case a principal executive officer pursuant to 02T .0106(b). A
copy of a signature authority delegation letter is provided with this letter.
D. Program Information:
1. See Comment A.1.
E. Operation & Maintenance Plan:
1. No comments.
F. Summary for Form: RSC 06-16:
1. No comments.
G. Application (Form: RSC 06-16):
1. No comments.

Mr. Brandon Pretzch
March 28, 2024
Page 3 of 3
H. Vicinity Maps:
1. No comments.
I. Process Flow Diagram & Narrative:
1. No comments.
J. Quantitative Justification:
1. No comments.
K. Sampling Plan:
1. No comments.
L. Laboratory Analytical Reports:
1. No comments.
M. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. No comments.
N. Recommendations (Response not required):
1. It may be worth discussing with the Division the option of rescinding this permit if Class A material
will not being distributed for marketing or land application purposes in the foreseeable future.