WQ0018347_Final Permit_20001018

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
October 18, 2000
Mike Davison, President
Roots, Inc.
3120 Weatherford Rd
Independence, MO 64055
1 � •
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NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0018347
Roots, Inc.
Distribution of Animal Waste Products
Cumming, Georgia
Dear Mr. Walraven:
In accordance with your application received on March 14, 2000, we are forwarding herewith Permit
No. WQ0018347, dated October 18, 2000, to Roots, Inc. for the distribution and marketing of a fertilizer
containing animal waste products.
This permit shall be effective from the date of issuance until September 31, 2005, and shall be subject
to the conditions and limitations as specified therein. Please pay particular attention to the monitoring and
reporting requirements contained in this permit. Failure to establish an adequate system for collecting and
maintaining the required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right
to request an adjudicatory hearing upon written request within thirty (30) days following receipt of this peranit.
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, 6714 Mail Service Center, Raleigh, NC 27699-
6714. Unless such demands are made this permit shall be final and binding.
If you need additional information concerning this matter, please pontact Sue Homewood at (919)
733-5083 extension 502.
Sinc el
Kerr T. Stevens
cc: NCDWQ Regional Offices, Water Quality Section
Susan Baker, Fertilizer Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF RESIDUALS OF EXCEPTIONAL QUALITY
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
Roots, Inc.
FOR THE
distribution and marketing of 750 dry tons per year of a fertilizer containing animal waste products,
throughout the State of North Carolina, with no discharge of wastes to the surface waters, pursuant to the
application received on March 14, 2000, and in conformity with the project plan, specifications, and other
supporting data subsequently filed and approved by the Department of Environment and Natural Resources
and considered a part of this permit.
This permit shall be effective from the date of issuance until September 31, 2005, and shall be subject
to the following specified conditions and Iimitations:
I. PERFORMANCE STANDARDS
1. The program for the distribution and marketing of a fertilizer containing animal waste products
shall be effectively maintained and operated as a non -discharge system to prevent the discharge
of any wastes resulting from the operation of this program.
2_ This permit shall become voidable in the event of failure of the distribution and marketing
program to adequately protect the assigned water quality standards of the surface waters and
groundwaters.
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 program.
4. In the event that the distribution and marketing program is not operated satisfactorily, including
the creation of nuisance conditions, the Permittee shall take any immediate corrective actions as
may be required by the Division of Water Quality (Division).
5. When waste residuals are sold or given away, one of the pathogen requirements in 40 CFR Part
503.32(a) must be met_ Additionally, an evaluation must be performed which demonstrates the
residuals ability to comply with this requirement. Upon request, a copy of this evaluation must be
submitted including all test results and calculations.

II. OPERATION_ AND MAINTENANCE REQUIREMENTS
1. For a treated residuals to be sold or given away in bags or other container for application to the
land, the following must be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) must be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters mR/kR m/km Ik
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Nickel
420
420
Zinc
7,500
2,800
2. A label shall be affixed to the bag or other container in which residuals that are sold or given
away for application to the Iand, or an information sheet shall be provided to the person who
receives the residuals sold or given away in any other container for application to the land. The
label or information sheet shall contain the following information:
a. The name and address of the person who prepared the residual that is sold or given away in a
bag or other container for application to the land.
b. A statement that application of the residual to the land is prohibited except in accordance with
the instructions on the label or information sheet.
c. A statement that the residuals shall not be applied to any site that is flooded, frozen or snow-
covered.
d A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored residuals into any surface waters.
e. A statement which identifies that this material shall be prevented from entering any public or
private water supply source (including wells) and any stream, lake, or river.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and
an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee tracking all residual activities. These records
shall include, but are not necessarily limited to the following information:
a. Source and volume of animal waste residuals,
b. Name of recipient of product, volume received, and intended use.

3. A product analysis shall be conducted every 60 days from the date of permit issuance by the
Permittee. The results of all analysis shall be maintained on file by the Permittee for a minimum
of five years. The product analysis shall include the following parameters:
Cadmium
Nickel
Copper
Zinc
Lead
Aluminum
pH
Ammonia -Nitrogen
Phosphorus
Calcium
PIant Available Nitrogen (by calculation)
Magnesium
Potassium
Nitrate -Nitrite Nitrogen
Sodium
% Total Solids
TKN
4. All residuals included in this permit must be monitored 60 days from the date of permit issuance,
for compliance with condition 15 of this permit. Data to verify stabilization of the residuals must
be maintained by the Permittee. The required data is specific to the stabilization process utilized,
but should be sufficient to clearly demonstrate compliance with the pathogen requirements in 40
CFR Part 503.32(a). In addition, the EPA certification statements concerning compliance with
pathogen requirements and management practices must be completed every 60 days by the proper
authority or authorities if more than one is involved, either the person who generates the residuals
or the person who prepares the residuals to be sold or given away.
5. Three copies of all required monitoring and reporting requirements as specified in conditions 1112
1113, and III 4 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
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
b. Noncompliance Notification:
The Permittee shall report by telephone to the appropriate DWQ Regional Office (as outlined in
attachment 1) 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 residual distribution program which results in the application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving waters.
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 facility incapable
of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.

Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) 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. INSPECTIONS
L The Permittee or his designee shall inspect the residuals storage, transport, and treatment facilities
to prevent malfunctions and deterioration, operator errors and discharges which may cause or lead
to the release of wastes to the environment, a threat to human health, or a nuisance. The
Permittee shall maintain 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 five years
from the date of the inspection and shall be made available to the Division or other permitting
authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentials, enter and inspect any property, premises or place on or related to the treatment site
or facility 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;
and may obtain samples of groundwater, surface water, or leachate.
V. GENERAL CONDITIONS
This permit shall become voidable unless the distribution activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by this
Division.
2. This permit is effective only with respect to the nature and volume of residuals described in the
application and other supporting data.
3_ This permit is not automatically transferable. In the event that 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 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 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 15 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.
The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Conunission will review the adequacy of the facilities
described therein, and if warranted, will extend the permit for such period of time and under such
conditions and limitations as it may deem appropriate.

This permit may be modified, or revoked and reissued to incorporate any conditions, limitations
and monitoring requirements the Division deems necessary in order to adequately protect the
environment and public health.
Permit issued this the 18"' day of October, 2000.
NORT OLINA IR NMENTAL MANAGEMENT COMMISSION
-A� Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ001.8347

ATTACHMENT 1
DIVISION OF WATER QUALITY REGIONAL OFFICES
Asheville Regional WQ Supervisor
Washington Regional WQ Supervisor
Raleigh Regional WQ Supervisor
59 Woodfin Place
943 Washington Square Mall
Post Office Box 27687
Asheville, NC 28801
Washington, NC 27889
Raleigh, NC 27611
[phone]
[phone]
[phone]
Fax [phone]
Fax [phone]
Fax [phone]
Avery Macon
Beaufort Jones
Chatham Nash
Buncombe Madison
Bertie Lenoir
Durham Northampton
Burke McDowell
Camden Martin
Edgecombe Orange
Caldwell Mitchell
Chowan Pamlico
Franklin Person
Cherokee Polk
Craven Pasquotank
Granville Vance
Clay Rutherford
Currituck Perquimans
Halifax Wake
Graham Swain
Dare Pitt
Johnston Warren
Haywood Transylvania
Gates Tyrell
Lee Wilson
Henderson Yancy
Greene Washington
Jackson
Hertford Wayne
Hyde
Fayetteville Regional WQ Supervisor Mooresville Regional WQ Supervisor
Wilmington Regional WQ Super.
Wachovia Building, Suite 714
919 North Main Street
127 Cardinal Drive Extension
Fayetteville, NC 28301
Mooresville, NC 28115
Wilmington, NC 28405-3845
[phone]
[phone]
[phone]
Fax [phone]
Fax [phone]
Fax [phone]
Anson Moore
Alexander Lincoln
Brunswick New Hanover
BIaden Robeson
Cabarrus - Mecklenburg
Carteret Onslow
Cumberland Richmond
Catawba Rowan
Columbus Pender
Harnett Sampson
Cleveland Stanly
Duplin
Hoke Scotland
Gaston Union
Montgomery
Iredell
Winston-Salem Regional WQ Supervisor
585 Waughtown Street
Winston-Salem, NC 27107
[phone]
Fax [phone]
Alamance Rockingham
Alleghany Randolph
Ashe
Stokes
Caswell
Surry
Davidson
Watauga
Davie
Wilkes
Forsyth
Yadkin
Guilford