WQ0023200_Final Permit_20040331

O� wAr�C9 Michael F. Easley, Governor
QG William G. Ross Jr., Secretary
Ujq North Carolina Department of Environment and Natural Resources
p Alan W. Klimek, P.E„ Director
Coleen H. Sullins, Deputy Director
Division of Water Quality
March 31, 2004
MR. GARY L. ALEXANDER, PRESIDENT
CAROLINA GROUND COVERS, INC.
174 RADISSON ROAD
SENECA, SOUTH CAROLINA 29678
Subject: Permit No. WQ0023200
Carolina Ground Covers, Inc.
Clay's Helper Plus Distribution Program
Distribution of Animal Residual Solids
Oconee County, South Carolina
Dear Mr. Alexander:
In accordance with your permit application package received on October 13, 2003, as well as the
additional information received on December 17, 2003 and January 5, 2004, we are forwarding herewith
Permit No. WQ0023200, dated March 31, 2004, to Carolina Ground Covers, Inc. for the subject animal
residuals distribution program.
This permit shall be effective from the date of issuance until February 28, 2009 and shall be
subject to the conditions and limitations as specified therein. Make note of this permit's expiration date
and the fact that a permit renewal application is due to the Division of Water Quality (Division) no later
than six months prior to that date (Le., see Condition V. 7.), as the Division does not send reminders to
apply for permit ,renewal. Be aware that payment of the annual administering and compliance fee, as
stipulated in Condition V. 4. will not automatically renew this permit.
This permit approves the operation of program for the distribution of a composted fertilizer/soil
amendment product, containing poultry animal residuals, that meets exceptional quality standards and is
marketed under the name Clay's Helper Plus throughout the State of North Carolina (i.e., in bulk and in
bags). Note that this permit does not concurrently provide a license to distribute a fertilizer, as is required
by the Fertilizer Section of the NC Department of Agriculture and Consumer Services' Plant Industry
Division. More information about applying for this Iicense may be found at the following web site:
http://www.ncagr.com/plantind/fertiferlics.htm.
Please take the time to review this permit thoroughly. Pay particular attention to the
monitoring requirements in this permit. Be aware that failure to establish an adequate system for
collecting, maintaining, and submitting the required operational information will result in future
compliance problems. The Division wants to remind you about the following issue that was discussed
during the review of this application:
♦ Condition III. 3. and Condition M. 4. require that the product be tested and monitored
regularly for specific parameters as well as for adequate pathogen reduction- It is imperative
that all testing and monitoring be performed such that the results are representative of the
entire row of product. The Division urges you to develop a set of standard operating
procedures and recordkeeping forms to ensure that the State of North Carolina time and
temperature requirements for the composting process are met.
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
DENR Customer Service Center
An Equal Opportunity Action Employer
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Internet http;//h2o.enr.state.ne.us/ndpu
Telephone [phone] Fax [phone]
Telephone [phone]
50% recycled/10% post -consumer paper

If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30 days following receipt of this
permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North
Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail Service
Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final
and binding.
If you need any additional information concerning this matter, please contact Mr. Paul Sherman
by telephone at [phone], extension 529, or via e-mail at [e-mail].
Sin. c rely,
Alan W. Klimek, P.E.
cc: SC Department of Health & Environmental Control -Bureau of Water (Ag. Permitting Division)
NC Department of Agriculture and Consumer Services -Plant Industry Division (Fertilizer Section)
Asheville Regional Office -Water Quality Section
Fayetteville Regional Office -Water Quality Section
Mooresville Regional Office -Water Quality Section
Raleigh Regional Office -Water Quality Section
Washington Regional Office -Water Quality Section
Wilmington Regional Office -Water Quality Section
Winston-Salem Regional Office -Water Quality Section
Water Quality Central Files
NDPU Files
NDPU Residuals Program Coordinator
2

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF ANIMAL RESIDUAL SOLIDS 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
Carolina Ground Covers, Inc.
Oconee County, South Carolina
FOR THE
operation of a program for the distribution of up to 1,341 dry tons per year of a composted fertilizer/soil
amendment product, containing poultry animal residuals, that meets exceptional quality standards and is
marketed under the name Clay's Helper Plus throughout the State of North Carolina (i.e., in bulk and in
bags). The program small be operated such that no discharge of waste to surface waters occurs, pursuant
to the permit application package received on October 13, 2003, as well as the additional information
received on December 17, 2003 and January 5, 2004, 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 apart of this permit.
This permit shall be effective from the date of issuance until February 28, 2009 and shall be
subject to the following specified conditions and limitations:
I. PERFORMANCE STANDARDS
1. The distribution program shall be effectively maintained and operated as a non -discharge
system to prevent the discharge of any wastes to waters of the state resulting from the
operation of this program.
2. This permit shall become voidable in the event of failure of the distribution program to
adequately protect the assigned water quality standards of the surface waters and
groundwater.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface water or groundwater resulting from the operation of this distribution program.

II.
4. In the event that the distribution 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 product containing animal residuals is sold or given away for application to the land
under the conditions of this permit, one of the Class A pathogen requirements in 40 CFR Part
503.32(a) shall be met. Additionally, an evaluation shall be performed which dernonstrates
the product's ability to comply with this requirement. Upon request, a copy of this
evaluation, including all test results and calculations, shall be submitted.
6. No product containing animal residuals that tests or is classified as a hazardous or toxic waste
under 40 CFR Part 261 shall be sold or given away for application to the land under the
conditions of this permit.
OPERATION AND MAINTENANCE REQUIREMENTS
The distribution program shall be properly operated and maintained at all times.
2. No product containing animal residuals other than that generated by the following facility
shall be approved for distribution in accordance with this permit:
Permit Volume
Facility County Number (Dry Tonsffear)
Alexander Farms, Inc. Oconee (SC) 18,788 -AG' 1,341
(d/b/a Carolina Ground Covers, Inc., Clay's Helper Plus in North Carolina)
a The operational permit for this facility is issued and administered by the South Carolina
Department of Health and Environmental Control.
3. No other product containing animal residuals other than that from the facility specified in
Condition II. 2. shall be distributed under the conditions of this permit. The Permittee shall
request and obtain a permit amendment from the Division for each additional facility prior to
allowing distribution through this program.
4. For a product containing animal residuals to be sold or given away in bags or other container
for application to the land under the conditions of this permit, the following shall be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) shall be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters (mg/kg] (mom
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
—
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
Pa

When distributed under the conditions of this permit, a label shall be affixed to the bag or
other container in which the product containing animal residuals is sold or given away for
application to the land, or an information sheet shall be provided to the person who receives
the product containing animal residuals sold or given away in another container for
application to the land. The label or information sheet shall contain the following
minimum information:
a. The name and address of the person who prepared the product containing animal
residuals that is sold or given away in a bag or other container for application to the
land.
b. A statement that application of the product containing animal residuals to the land is
prohibited except in accordance with the instructions on the label or information sheet.
c. A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored product containing animal residuals into any surface
waters.
c. A statement to help prevent direct application of the product containing animal
residuals to water supply sources and all other waters of the state. For example, "as
with any fertilizer product, do not apply in or new any water supply source or any body
of water, including wells, streams, rivers, and lakes."
d. A statement that application of he product containing animal residuals shall not be
applied to any land that is flooded, frozen, or snow-covered.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee to track all distribution activities within
the State of North Carolina. These records shall include, but are not necessarily limited to,
the following information:
a. Source, amount (i.e., volume), and analysis of each product containing animal residuals.
b. Name of the initial recipient of the product containing animal residuals, the amount (i.e.,
volume) distributed, and the intended use.
3. An analysis shall be conducted by the Permittee on the product containing animal residuals at
least four (4) times per year from the date of permit issuance. The results of all analyses shall
be maintained on file by the Permittee for a minimum of five years. The analysis shall
include the following parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Magnesium
Mercury
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Percent Total Solids
pH
3
Phosphorus
Potassium
Selenium
Sodium
Total Kjeldahl Nitrogen
Zinc
Plant Available Nitrogen
(by calculation)

After the product containing animal residuals has been monitored for two years at the above -
listed frequency, the Permittee may submit a request to the Division for a permit modification
to reduce the frequency of this monitoring requirement. In no case, however, shall the
frequency of this monitoring be less than once per year when the product containing animal
residuals is sold or given away for application to the land during that year.
4. The product containing animal residuals shall be monitored by the Permittee at least four (4)
times per year for compliance with Condition I. 5. of this permit. The monitoring frequency
cycle shall start on the date of permit issuance, and the results of all analyses shall be
maintained on file by the Permittee for a minimum of five years. Data to verify stabilization
of the product shall be maintained by the Permittee. The required data shall be specific to the
stabilization process utilized, but should be sufficient to demonstrate compliance with the
Class A pathogen requirements in 40 CFR Part 503.32(a) clearly. In addition, the EPA
certification statement concerning compliance with pathogen requirements shall be completed
at the above frequency by the proper authority or authorities if more than one is involved,
either the person who generates the product containing animal residuals or the person who
prepares the product to be sold or given away for application to the land.
5. Laboratory analyses and/or operational data, as required by Condition III. 3., and Condition
M. 4. shall be performed/gathered on the product containing animal residuals as it is to be
distributed. Furthermore, analytical determinations made pursuant to the monitoring and
reporting requirements of this permit shall be made by a laboratory certified by the Division
for the required parameter(s) under 15A NCAC 2H .0800 or 15A NCAC 2H .I 100.
6. Three copies of all required monitoring and reporting requirements as specified in Condition
III. 1., Condition III. 2., Condition 111. 3., Condition III. 4., and Condition III. 5. shall be
submitted annually on or before March 1" of the year following the distribution event to the
following address:
NCDENR-DWQ
Water Quality Section
Non -Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification:
The Permittee shall report by telephone to the Water Quality Section of the appropriate
Division regional office (i.e., see Attachment A) 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 distribution program that results in the distribution 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.
c. Any time that self-monitoring information indicates that the distribution program has
gone out of compliance with the conditions and limitations of this permit or the
parameters on which the facility was designed,
d. Any process unit failure, due to known or unknown reasons, that render the facility
incapable of adequate treatment.
LI

e. Any spillage or discharge from a vehicle or piping system during transportation of
residuals or product containing animal residuals.
Persons reporting such occurrences by telephone shall also file a written report in letterform
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. INSPECTIONS
1. The Permittee or his designee shall inspect the storage, transport, and treatment facilities
related to the distribution program 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 trade, 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 distribution 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; and may obtain samples of groundwater, surface water, or leachate.
V. GENERAL CONDITIONS
1. This permit shall become voidable unless the distribution program is operated in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by
the Division.
2. This permit shall be effective only with respect to the nature and volume of product
containing animal residuals described in the application and other supporting data.
3. 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 Statutes § 143-215.6A through § 143-215.6C.
4. The annual administering and compliance fee shall be paid by the Permittee within 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).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC
.0500.
FJ

6, This permit may be modified, revolted, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the
distribution program described therein, and if warranted, shall extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
8. This permit shall not be automatically transferable. In the event that there is a desire for the
distribution program to change ownership or to change the name of the Permittee, a formal
permit request shall be submitted to the Division documentation from the parties involved
and other supporting materials as may be appropriate. The approval of this request shall be
considered on its merits and may or may not be approved.
Permit issued this the thirty-first day of March, 2004.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Alan W. Klimek, P.E., Director '
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0023200
0

Attachment A
DIVISION OF WATER QUALITY REGIONAL OFFICES
Asheville Regional Office
Fayetteville Regional Office
Mooresville Regional Office
WQ Supervisor
WQ Supervisor
WQ Supervisor
2090 U.S. Highway 70
Wachovia Building, Suite 714
919 North Main Street
Swannanoa, NC 28778
Fayetteville, NC 28301
Mooresville, NC 28115
Phone: [phone]
Phone: [phone]
Phone: [phone]
Fax: [phone]
Fax: [phone]
Fax: [phone]
Avery Macon
Anson Moore
Alexander Lincoln
Buncombe Madison
Bladen Robeson
Cabarrus Mecklenburg
Burke McDowell
Cumberland Richmond
Catawba Rowan
Caldwell Mitchell
Harnett Sampson
Cleveland Stanly
Cherokee Polk
Hoke Scotland
Gaston Union
Clay Rutherford
Montgomery
lredell
Graham Swain
Haywood Transylvania
Henderson Yancey
Jackson
Raleigh Regional Office
WQ Supervisor
3800 Barrett Drive
Raleigh, NC 27609
Phone: [phone]
Fax: [phone]
Chatham
Durham
Edgecombe
Franklin
Granville
Halifax
Johnston
Lee
Nash
Northampton
Orange
Person
Vance
Wake
Warren
Wilson
Winston-Salem Regional Office
WQ Supervisor
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
Fax: [phone]
Alamance Rockingham
Alleghany Randolph
Ashe
Stokes
Caswell
Surry
Davidson
Watauga
Davie
Wilkes
Forsyth
Yadkin
Guilford
Washington Regional Office
WQ Supervisor
943 Washington Square Mall
Washington, NC 27889
Phone: [phone]
Fax: [phone]
Beaufort
Bertie
Camden
Chowan
Craven
Currituck
Dare
Gates
Greene
Hertford
Hyde
Jones
Lenoir
Martin
Pamlico
Pasquotank
Perquimans
Pitt
Tyrell
Washington
Wayne
II
Wilmington Regional Office
WQ Supervisor
127 Cardinal Drive Extension
Wilmington, NC 28405-3845
Phone: [phone]
Fax: [phone]
Brunswick New Hanover
Carteret Onslow
Columbus Pender
Duplin