WQ0004500_Final Permit_19970915

State of North Carolina
Department of Environment,
Health and Natural Resources 4 •
Division of Water Quality
James B. Hunt, Jr., Governor Admbwdgmbmdmk
Wayne McDevitt, Secretary ®C H N F1
A. Preston Howard, Jr., P.E., Director
September 15, 1997
Mr. Gordon G. Hanson, Plant Manager
Archer Daniels Midland Company
Post Office Box 10640
Southport, North Carolina 28461
Subject: Permit No. WQ0004500
Archer Daniels Midland Company
Southport Facility
Land Application of Nitro Gro Products
Brunswick County
Dear Mr. Hanson:
In accordance with your renewal request received May 30, 1997, we are forwarding herewith
Permit No. WQ0004500, dated September 15, 1997, to the Archer Daniels Midland Company for the
continued operation of a land application of residuals program.
This permit shall be effective from the date of issuance until August 31, 2002, shall void Permit
No. WQ0004500 issued October 29, 1993 and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will result
in future compliance problems.
Please be advised of condition number I-2 which states that the land application program shall be
effectively maintained and operated as a non -discharge system to prevent the discharge of any Nitro Gro
products to the surface waters due to the operation of this program.
Please be advised that condition number II-8 has been amended to state that for land application
sites without established cover crops the solid Nitro Gro Product must be incorporated into the soil within
24 hours of application. The allowance of 36 hours, and in some cases 72 hours, has been removed due
to numerous odor complaints from residents Iocated near the application sites.
Please be advised of condition VI-10 which states that the Division is.concerned about the high
Sodium Adsorption Ratio (SAR) found in some of the residuals being land applied. Appropriate
measures, including the application of gypsum to balance the ratio if necessary, shall be undertaken to
ensure that the land application sites are not damaged. An agronomist or soil scientist should be consulted
before problems arise.
If any parts, requirements, or limitations contained in this permit are unacceptable to you, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request must be in the form of a written petition, conforming to Chapter 150B of North
Carolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer 27447,
Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If you need additional information concerning this matter, please contact Rick_.:M_ po_ re'at (919) 733-
5083 extension 527.
Sincerely,
�,. Preston Howard, Jr., P.E.
cc: Brunswick County Health Department
Bob Cheek, Groundwater Section Central Office
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Training and Certification Unit (no revised rating)
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
RALEIGH
RESIDUALS LAND APPLICATION 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
Archer Daniels Midland Company
Brunswick County
FOR THE
continued operation of a distribution and land application program utilizing Archer Daniels Midland
Company's biomass/fertilizer products, which are identified as Nitro Gro I, Nitro Gro II, Nitro Gro III,
Nitro Gro IV and Nitro Gro V; Nitro Gro I and II are biomasses created by the aerobic digestion of the
wastewater influent (does not include any domestic wastes) from the plant's biochemical production
processes (citric acid and MSG production), Nitro Gro III is a biomass which results from the controlled
fermentation of sugars to citric acid, Nitro Gro IV is the same as Nitro Gro III with the addition of some
fine sand and grit with diatomaceous filter aid added to facilitate filtration, and Nitro Gro V is a biomass
originating from the fermentation of sugar to MSG; these Nitro Gro products are approved for distribution
and land application to various local area farmlands in Brunswick, Pender, Bladen and Columbus
Counties once the notification requirements of condition I.12 have been met, with no discharge of wastes
to the surface waters, pursuant to the renewal request received on May 30, 1997, and in conformity with
the project plan, specifications, and other supporting data subsequently filed and approved by the
Department of Environment, Health, and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until August 31, 2002, shall void Permit
No. WQ0004500 issued October 29, 1993, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
This permit shall become voidable if the soils fail to adequately absorb the wastes and may
be rescinded unless the sites are maintained and operated in a manner which will protect
the assigned water quality standards of the surface waters and ground waters.
2. The land application program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any Nitro Gro products to the surface waters
due to the operation of this program.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.

4. In the event that the land application program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease applying the Nitro Gro products
to the site(s) and take any immediate corrective actions, including the construction of
additional or replacement treatment or utilization/disposal facilities and/or the incorporation
of the material into the soil.
Maximum site slope for land application of the Niter Go products shall be 10% for surface
application and 18% for subsurface applications.
6. The following buffer zones shall be maintained:
a) 400 feet from residences or places of public assembly under separate ownership for
surface application method; however, the buffer zone requirement may be reduced
to a minimum of 50 feet upon written consent of the owner,
b) 200 feet from residences or places of public assembly under separate ownership for
injection method; however, the buffer zone requirement may be reduced to a
minimum of 50 feet upon written consent of the owner,
c) 100 feet from "SA and SB" classified waters and public surface water supplies for
both methods,
d) 50 feet from "WS" classified waters and other streams, creeks, lakes, rivers, and
surface water drainage ways for injection method,
e) 50 feet from "WS" classified waters and other streams, creeks, lakes, rivers and
surface water drainage ways for surface application method,
f) 100 feet from property lines for surface application; however, this requirement may
be reduced to 50 feet upon written concurrence from the adjoining property owner,
g) 50 feet from property lines for subsurface injection,
h) 50 feet from public right of ways for surface application methods,
i) 25 feet from public right of ways for subsurface disposal methods,
j) 10 feet from upslope interceptor drains and surface water diversions for both
methods,
k) 25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems and surface drainage ditches for both methods,
1) 100 feet from wells, with the exception of an approved groundwater monitoring
well.
7. It is the responsibility of the permit holder to ensure that a copy of this permit and a spill
prevention and control plan shall be made available to all Nitro Gro product transport and
application vehicle operators and to ensure that all such persons are familiar with the
requirements, limitations, and procedures associated with the same.
8. Specific Nitro Gro product application area boundaries shall be clearly marked on each site
prior to and during application.
9. All storage of the solid Nitro Gro products at the industrial facility shall occur only in the
storage area which was authorized by this Division in an Authorization to Construct, which
was issued on June 15, 1992, or in storage areas which are subsequently approved by the
Division for this purpose. An Authorization to Construct will be required for approval of
any new storage areas. All liquids originating from this storage area shall be routed to the
headworks of the ADM wastewater treatment plant.
10. Appropriate measures shall be taken to prevent the direct contact of stormwater with any
staged material. All such staging should occur in locations that are not likely to create
nuisance situations.
11. When removing any staged Nitro Gro product that has been placed either on an
impermeable surface or in contact with the ground surface, care must be taken to remove all
of the product.
2

12. The Wilmington Regional Supervisor, telephone number [phone], and the
appropriate local governmental official (county manager/city manager) shall be notified at
least twenty-four (24) hours prior to the initial application of Nitro Gro products in a
county so that an inspection can be made of the application sites and application method.
Such notification to the regional supervisor shall be made during the normal office hours
from 8:00 a.m. until 5.00 p.m. on Monday through Friday, excluding State Holidays.
II. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities and application sites shall be properly maintained and operated at all times.
2. A suitable vegetative cover, as listed in condition 11.3, shall be scheduled and maintained
for the application site in accordance with the crop management plan approved by this
Division.
3. The application rates shall not exceed the following for the specified crops:
Crop
PAN lbs/acre/ ear
Wheat
100
Barley
100
Milo
100
Oats
100
Corn
200
Fescue Grass
250
Coastal Bermuda Grass
350
Soy Beans
150
Canola
100
Millet
180
Sudan Grass
180
Sorghum
120
Pine Trees
80
In the case of second cropping in the same agronomic year, a soil fertility test shall be
performed to determine the PAN requirements for the second crop; however, in no case
shall more than 75% of the above PAN rates be applied. In no case shall the PAN
application rates exceed a value which will result in the contravention of the groundwater
quality standards in 15A NCAC 2L. Additional crops may be approved, upon request to
the Division.
4. The following Nitro Gro products from the ADM Southport facility are approved for
distribution and land application in accordance with this permit: .
Estimated
Product
Volume (dry tons/year)
Nitro Gro 1
0
Nitro Gro 11
44,044
Nitro Gro III
16,446
Nitro Gro IV
5,014
Nitro Gro V
24,816

5. The lifetime heavy metal loadings shall not exceed the following for the corresponding
Cation Exchange Capacities (CEC):
Lifetime Loadings (lips/acre)
Parameter
CEC < 5
CEC 5 - 15
CEC > 15
Lead
500
1000
2000
Zinc
250
500
1000
Copper
125
250
500
Nickel
125
250
500
Cadmium
4.5
9
18
6. Land application operations that have been previously classified by the Water Pollution
Control System Operators Certification Commission (Certification Commission) will retain
that classification, unless notification is received from the Certification Commission that the
classification has changed. Facilities that have not previously been classified will remain
unclassified until notification is received from the Certification Commission. Upon
classification of the subject water pollution control system or land application operation by
the Certification Commission the Permittee shall employ a certified water pollution control
system operator to be in responsible charge (ORC) of the water pollution control system or
land application operation. The operator must hold a certificate of the type and grade at least
equivalent to or greater than the classification assigned to the water pollution control system
or land application operation by the Certification Commission. The Permittee must also
employ a certified back-up operator of the appropriate type and grade to comply with the
conditions of Title 15A, Chapter 8A, .0202. The ORC of the water pollution control
system or land application operation must visit each Class I system or operation at least
weekly and each Class II, III, and IV system or operation at least daily, excluding
weekends and holidays, and must properly manage and document daily operation and
maintenance of the water pollution control system or land application operation and must
comply with all other conditions of Title 15A, Chapter 8A, .0202.
7. Adequate procedures shall be provided to prevent surface runoff from carrying any land
applied or staged Nitro Gro products onto adjacent property or into any surface waters.
8. For land application sites without established cover crops the solid Nitro Gro Product must
be incorporated into the soil within twenty-four (24) hours of application.
9. For land application sites with established cover crops, the solid Nitro Gro Product must be
delivered and applied within 24 hours of movement of the Nitro Gro Product from the
ADM plant site.- If justifiable time extensions are needed due to inclement weather, ADM
must receive prior approval from the Wilmington Regional Water Quality Supervisor. In
all instances, the appropriate measures must be taken to prevent the occurrence of nuisance
conditions.
10. For areas that are prone to flooding, Nitro Gro products may be applied only during
periods of dry weather. The solid Nitro Gro products must be incorporated into the soil on
these sites within twenty-four (24) hours of land application. When the United States
Weather Service has issued warnings that a hurricane or tropical storm may within the next
36 hours make landfall in Brunswick County, N. C., Nitro Gro product may not be
applied to lands below the 100 year flood elevation until the hurricane or tropical storm has
passed or until the warnings are rescinded.
11. Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying Nitro Gro products onto the adjacent property or into the surface waters.
12. Nitro Gro products shall not be applied to fields that are dominated by soils which are
classified by the Soil Conservation Service as poorly drained, except during periods of low
rainfall or dry weather.
4

13. For soils which are classified by the Soil Conservation Service as very poorly drained
soils, liquid Nitro Gro products shall not be applied in inclement weather or until 24 hours
following a rainfall event of 1/2-inch or greater in 24 hours. For sandy soils, land
application can commence 3 hours after a precipitation event. In both instances, land
application shall not occur on areas of standing water. Any emergency Nitro Gro product
application measures must first be approved by the Division of Water Quality.
MONITORING AND REPORTING REQUIREMENTS
1. Monitoring (including groundwater, surface water, Nitro Gro product, soil, or plant tissue
analyses) deemed necessary by the Division of Water Quality to insure protection of the
environment will be established and an acceptable sampling and reporting schedule shall be
followed. If monitoring data indicates minimal or no concern to the Division, monitoring
requirements may be reduced by the Division upon request by ADM after two annual
reporting periods so long as there has been no significant change in the process.
2. ADM shall maintain field activity records for a minimum of five years from the date of the
distribution or application of Nitro Gro products. These records shall include, but are not
necessarily limited to the following information:
a) type of Nitro Gro product
b) date of application
c) location of application (site, field, or zone #)
d) method of application
e) weather conditions
f) soil conditions
g) type of crop to be grown on field
h) quantity of Nitro Gro product applied in dry tons/acre
i) weekly nitrogen and total solids assays of Nitro Gro products
j) calculated associated PAN (or actual PAN as determined by N.C.D.A.)
k) annual and cumulative totals of dry tons/acre of Nitro Gro product and annual
pounds/acre of PAN applied to each field.
1) net acreage of application area utilized
3. A representative annual soils analysis (Standard Soil Fertility Analysis) shall be conducted
for each site which receives Nitro Gro product in the respective calendar year and the
results maintained on file by the Permittee for a minimum of five years. The Standard Soil
Fertility Analysis shall include, but is not necessarily limited to, the following parameters:
Base Saturation
Manganese
Magnesium
Cation Exchange Capacity
Phosphorus
Sodium
Potassium
Nickel
Lead
Cadmium
Zinc
Copper
pH
Calcium
Nitrogen
4. A quarterly analysis of each Nitro Gro product being land applied during the quarter and an
annual Toxicity Characteristics Leaching Procedure (TCLP) analysis of each Nitro Gro
product being land applied during the year shall be conducted by the Permittee and the
results maintained on file by the Permittee for a minimum of five years. The Division will
consider modifying the analysis and testing requirements after two annual reporting
periods, depending upon the results that are obtained and so long as there has been no
significant change in the process. The Nitro Gro product analysis shall include but is not
necessarily limited to the following parameters:
5

5
N
% total solids
Magnesium
Chlorides
Sulfate
Phosphorus
Potassium
Lead
Zinc
Copper
Nickel
Cadmium
Chromium
Sodium
Calcium
Total Nitrogen
Ammonia Nitrogen
Nitrate/Nitrite Nitrogen
pH
Plant Available Nitrogen (by calculation or actual PAN as determined by N.C.D.A.)
The TCLP analysis shall include the following parameters:
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
Cresol
2,4-D
1,4-Dichlorobenzene
1,2-Dichloroethane
1, 1 -Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor (and its hydroxide)
Hexachlorobenzene
Hex achloro-1,3-butadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
Three copies of all monitoring and reporting requirements, as specified in conditions IH.1,
III.2, II1.3, and IIIA shall be submitted annually on or before March 1 of the following
year to the following address:
NC Division of Water Quality
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional. Office, telephone
number [phone], as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence with the land application program which results in the land
application of significant amounts of Nitro Gro product which are abnormal in
quantity or characteristic.
b. Any failure of the land application program resulting in a release of Nitro Gro
product to receiving waters.
Co

c. Any time that self -monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit or the parameters on
which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that render the ADM
facility incapable of producing Nitro Gro product that is consistent with the permit
application.
e. Any spillage or discharge from a vehicle or piping system transporting Nitro Gro
product to the application site.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
Any groundwater quality monitoring as deemed necessary by the Division of Water Quality
shall be provided.
2. No land application of Nitro Gro products shall be undertaken when the seasonal high
water table is less than one foot below land surface.
V . INSPECTIONS
The Permittee or his designee shall inspect, at least quarterly, all Nitro Gro product storage,
transport, and application equipment and facilities to prevent malfunctions and
deterioration, operator errors, and discharges which may cause or lead to the release of
Nitro Gro products to the environment, a threat to human health, or a nuisance. The
Permittee shall keep an inspection log or summary including at least the date and time of
inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the Permittee. This log of inspections shall be maintained by the Permittee for a period
of three years from the date of the inspection and shall be made available upon request by
the Division of Water Quality or other permitting authority.
2. Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, related to the
application program at any reasonable time for the purpose of determining compliance with
this permit; may inspect or copy any records that must be kept under the terms and
conditions of this permit; or may obtain samples of groundwater, surface water, or
leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the land application activities are carried out in
accordance with the conditions of this permit and in the manner approved by this Division.
2. This permit is effective only with respect to the nature and volume of Nitro Gro products
described in the permit application and other supporting data.
.7

This permit is not transferable. In the event there is a desire for the facilities to change
ownership or a name change of the Permittee, a formal permit request must be submitted to
the Division of Water Quality accompanied by an application fee, documentation from the
parties involved, and other supporting materials as may be appropriate. The approval of
this request will be considered on its merits and may or may not be approved.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215.6A to 143-215.6C.
5. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205
(c)(4)•
6. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
7. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
ADM land application program, and if warranted, will extend the permit for such period of
time and under such conditions and limitations as it may deem appropriate.
8. This permit may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division of Water Quality deems necessary in
order to adequately protect the environment and public health.
9. The distribution, transporting, and land application of Nitro Gro products associated with
this permit must be performed by ADM or its contractor.
10. The Division is concerned about the high Sodium Adsorption Ratio (SAR) found in some
of the residuals being land applied. Appropriate measures, including the application of
gypsum to balance the ratio if necessary, shall be undertaken to ensure that the land
application sites are not damaged. An agronomist or soil scientist should be consulted
before problems arise.
Permit issued this the fifteenth day of September, 1997.
NORTH CAR INA EN ONMENTAL MANAGEMENT COMMISSION
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit No. WQ0004500