WQ0004095_Additional Information Request_20240828

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
August 28, 2024
WILLIAM M. PONTON — GENERAL MANAGER
PCS PHOSPHATE COMPANY, INC.
1530 NC HIGHwAY 306 SOUTH
AURORA, NORTH CAROLINA 27806
Subject: Application No. WQ0004095
Additional Information Request #1
PCS Phosphate Class B Residuals
Program
Land Application of
Class B Residuals
Beaufort County
Dear Mr. Ponton:
Division of Water Resources' Central and Regional staff have reviewed the application package
received on June 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 September 27,
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 R 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
erickson.saunderskdeq.nc.gov. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
James Chandler Stroud — Nutrien — Aurora (Electronic Copy)
Laserfiche File (Electronic Copy)
D EQ �� 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 -
OepaNnent at EnulmnmeMal Duality 919.707.9000

Mr. William M. Ponton
August 28, 2024
Page 2 of 3
A. Cover Letter:
1. No comments.
B. Application (Form: RLAP 06-16):
1. The Back-up Operators in Responsible Charge (ORC) Hugh B. Mills and John A. Braddy that are
listed in Item II1.3. of the application are not designated in our system as operators for this site. The
current Back-up ORC in our system is Raleigh Lee. Please contact the Wastewater Operator
Certification Group to delegate the correct ORCs for this facility. A response to this item is not
needed.
C. Operation & Maintenance Plan:
1. No comments.
D. Summary for Form: RSC 06-16:
1. No comments.
E. Application (Form: RSC 06-16):
1. How were the values for sodium adsorption ratio (SAR) and 5-year maximum adjusted plant
available nitrogen (PAN) in Item II.5. determined? Our calculations with the provided data found
an SAR of 0.05, and 5 year PAN was approximately 4,950 mg/kg using surface application and
5,200 mg/kg for subsurface application.
F. Vicinity Maps:
1. No comments.
G. Process Flow Diagram & Narrative:
1. No comments.
H. Ouantitative Justification:
1. No comments.
I. Sampling Plan:
1. No comments.

Mr. William M. Ponton
August 28, 2024
Page 3 of 3
J. Laboratory Analytical Reports:
1. No comments.
K. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. No comments.
L. Application (Form: LASC 06-16):
1. No comments.
M. County Board Notification:
1. N/A.
N. Application (Form: LOA 06-16):
1. The LOA was signed by Mr. John Prescott on behalf of Reserveco, Inc. as the Land Manager.
However, review of the North Carolina Secretary of State website does not verify whether Mr.
Prescott can sign on behalf of this entity. Please provide documentation to verify that Mr. Prescott
can sign on behalf of this landowner.
O. Setback Waivers:
1. No comments.
P. Vicinity/Setback Maps:
Per the table in Instruction Item B of the LASC form and 15A NCAC 02T .1104(c)(1), setback
maps shall be provided in accordance with the "Map Guidance for Residuals Land Application
Permits". The application map provided does not show many features required by the rule and
guidance, including a delineation of the application area, property lines, setbacks as required by
02T .1108, and a delineation (or a note indicating the delineation) of the compliance and review
boundaries. An updated setback map meeting these requirements shall be provided.
Q. Soil & Agronomic Evaluation:
1. N/A.
R. Updated Cumulative Pollutant Loading Rates (CPLRs):
1. In accordance with Item B in the LASC 06-16 Instructions form, an updated accounting of the land
application site's cumulative pollutant loading rates (CPLRs) shall be provided for all renewed
fields.