WQ0037094_Final Permit_20140430

Pat McCrory
Governor
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NCDENR
North Carolina Department of Environment and Natural Resources
April 30, 2014
Mr. Michael Brooks -- Corporate Compliance Officer
Howard Fertilizer Company, Inc.
8306 South Orange Avenue
Orlando, Florida 32809
Deaf- Mr. Brooks:
John E. Skvarla, til
Secretary
Subject: Permit No. WQ0037094
Howard Fertilizer Company, Inc.
Distribution of Class A Municipal
Wastewater Treatment Plant Residuals
State-wide Distribution
In accordance with your permit application request received March 27, 2014, we are forwarding
herewith Permit No. WQ0037094.dated April 30, 2014, to the Howard Fertilizer Company, Inc. for the
operation of the subject residuals management program throughout the State of North Carolina. The final
product will be composed of Class A pelletized heat dried biosolids from the South Cross Bayou WRF
Pelletizing Facility in St. Petersburg, Florida, and fertilizer product from Howard Fertilizer. Four blends
will be produced, each having a distinct Nitrogen -Phosphorous -Potassium ratio. The product will be sold
in 50 -pound bags at hardware stores, etc. with a maximum distribution in North Carolina of 2,999 dry
tons per year. This permit authorizes distribution of the product in the form of labeled bags, and does
not allow distribution in the form of hulk residuals as defined in 15A NCAC .02T .1102(8) as
"residuals that are transported and not sold or given away in a bag or other container for application
to the land. "A permit modification would be required for the authorization of product distribution in
the farm of bulk residuals.
This permit shall be effective from the date of issuance until March 30, 2019 and shall be subject
to the conditions and limitations as specified therein. Please pay particular attention to the monitoring
requirements listed in Attachments A and C. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall be in the form 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, NC 27699-6714. Unless such demands are made, this permit shall be final and
binding.
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Phone: [phone] Internet: hb_1/oortal.ncdenr.orolwebAvQ
An Equal Opportunity 1 Affirmative Action Employer — Made in part with recycled paper

Mr. Brooks
April 30, 2014
Page 2 of 2
If you need additional information concerning this matter, please contact David Goodrich at (919)
807-6352 or by email at [e-mail].
Sincerely,
Lor �Amas Reeder, Director
Division of Water Resources, NCDENR
cc: Asheville Regional Office, Water Quality Regional Operations Section
Fayetteville Regional Office, Water Quality Regional Operations Section
Mooresville Regional Office, Water Quality Regional Operations Section
Raleigh Regional Office, Water Quality Regional Operations Section
Washington Regional Office, Water Quality Regional Operations Section
Wilmington Regional Office, Water Quality Regional Operations Section
Winston-Salem Regional Office, Water Quality Regional Operations Section
Rob Wilcox, LS — S&ME, Inc., 3718 Old Battleground Road, Greensboro, NC 27410
Beth Buffington, Public Water Supply Section — Protection and Enforcement Branch
Permit File WQ0037094
Notebook File WQ0037094 j

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF CLASS A MUNICIPAL WASTEWATER TREATMENT PLANT
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
Howard Fertilizer Company
State -Wide Distribution
FOR THE
operation of a residuals management program for the Howard Fertilizer Company, Inc. and consisting of
the distribution of Class A Municipal Wastewater Treatment Plant residuals generated by the approved
facilities listed in Attachment A with no discharge of wastes to surface waters, pursuant to the application
received March 27, 2014, and subsequent additional information received by the Division of Water
Resources, and in conformity with other supporting data subsequently filed and approved by the
Department of Environment and Natural Resources and considered a part of this pen -nit. The use and
disposal of residuals are regulated under Title 40 Code of Federal Regulations Part 503. This permit does
not exempt the Permittee from complying with the federal regulations.
This permit authorizes the distribution of the final product in the form of labeled bags or other container
with a capacity of less than 1.102 short tons or one metric ton, and does not allow its distribution in the
form of bulk residuals as defined in 15A NCAC .02T .1102(8). Conditions of this permit only apply to
activities within North Carolina.
This permit shall be effective from the date of issuance until March 30, 2019 and shall be subject to the
following specified conditions and limitations:
I. SCHEDULES
1. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
WQ0037094 Version 1.0 Shell Version 140324 Page 1 of 7

II. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perforin satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of residuals, contact the appropriate regional office supervisor, and take any immediate
corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
3. Only residuals generated by the facilities listed in Attachment A are approved for distribution in
accordance with this permit.
4. Pollutant concentrations in residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight
basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
n/a
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
5. Residuals that are distributed shall meet Class A pathogen reduction requirements in 15A NCAC 02T
.1106 (a) and (b). Exceptions to this requirement shall be specified in Attachment A.
6. Biological residuals (i.e. residuals generated during the treatment of domestic or animal processing
wastewater, or the biological treatment of industrial wastewater, and as identified in Attachment A)
that are distributed shall meet one of the vector attraction reduction alternatives in 15A NCAC 02T
.1107(a). Exceptions to this requirement shall be specified in Attachment A.
7. Setbacks for treatment and storage facilities shall be as follows:
Setback Description
Setback
feet
Habitable residence or place of public assembly under separate ownership or not
to be maintained as part of the project site
100
Property lines
50
Private or public water supply
1.00
Surface waters (streams — intermittent and perennial, perennial waterbodies, and
wetlands)
50
Wells with exception to monitoring wells
100
WQ0037094 Version 1.0 Shell Version 140324 Page 2 of 7

III. OPERATION AND MAINTENANCE RE UIREMENTS
The residuals management program shall be properly maintained and operated at all times. The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
2. The Permittee shall maintain an approved Operation and Maintenance Plan (O&M Plan) pursuant to
15A NCAC 02T .1110. Modifications to the O&M Plan shall be approved by the Division prior to
utilization of the new plan. The O&M Plan, at the minimum, shall include:
a) Operational functions;
b) Maintenance schedules;
c) Safety measures;
d) Spill response plan;
e) Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
ii. Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii. Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
ii. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event. The sampling plan shall account for
any foreseen fluctuations in residuals quality and indicate the most limiting times for
residuals to meet pathogen and vector attraction reduction requirements (e.g. facilities that
land apply multiple times per year but have an annual sampling frequency, may need to
sample during winter months when pathogen reduction is most likely to be negatively
affected by cold temperatures).
3. All residuals shall be adequately stored to prevent untreated leachate runoff, The finished product
may be placed on a concrete pad, placed under shelter or physically covered until it is distributed to
the buyer. If an alternate storage site is used, approval must be obtained from the Division.
4. A label shall be affixed to the bag or other container in which residuals are sold or given away for
land application, or an information sheet shall be provided to the person who receives Class A
residuals. At a minimum, the label or information sheet shall contain the following:
a. The name and address of the person who prepared the residuals;
b. A statement that residual land application is prohibited except in accordance with the instructions
on the label or information sheet;
c. A statement identifying that this material shall be prevented from entering any public or private
water supply source (including wells) and any surface water (e.g., stream, lake, river, wetland,
etc.);
WQ0037094 Version 1.0 Shell Version 140324 Page 3 of 7

d. A statement that the residuals shall be applied at agronomic rates and recommended rates for its
intended use.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses [corrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1,4 -Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (100.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1, 1 -Dichloroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
IHexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene100.0
( )0
Heptachlor (and its hydroxide)
008
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5 -Trichlorophenol (400.0)
m -Cresol (200.0)
Lead (5.0)
2,4,6 -Trichlorophenol (2.0)
o -Cresol (200.0)
Lindane (0.4)
2,4,5 -TP (Silvex) (1.0)
p -Cresol (200.0)
Mercury (0.2)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10A)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
WQ0037094 Version 1.0 Shell Version. 140324 Page 4 of 7

An analysis shall be conducted on the Class A residuals at the frequency specified in Attachment A,
and the Permittee shall maintain the results for a minimum of five years. The analysis shall include
the following parameters:
Aluminum
Mercury
Potassium
Ammonia -Nitrogen
Molybdenum
Selenium
Arsenic
Nickel
Sodium
Cadmium
Nitrate -Nitrite Nitrogen
Sodium Adsorption Ratio
(SAR)
Calcium
Percent Total Solids
TKN
Copper
pH
Zinc
Lead
Phosphorus
Magnesium
Plant Available Nitrogen
(by calculation)
4. Residuals shall be monitored for compliance with pathogen and vector attraction reduction
requirements at the frequency specified in Attachment A, and at the time indicated in the sampling
and monitoring sections of the approved 0&M plan. The required data shall be specific to the
stabilization process utilized, and sufficient to demonstrate compliance with the Class A pathogen
reduction requirements in 15A NCAC 02T .1106 (a) and (b), and one vector attraction reduction
requirement in 15A NCAC 02T .1107 (a) shall be met. Any exceptions from the requirements in this
condition shall be specified in Attachment A.
5. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall
be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
6. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Reporting
Forms. Instructions for reporting and annual report forms are available at
Lt :// ortal.nedenr.or web/w /a s/lau/re ortin , or can be obtained by contacting the Land
Application Unit directly. The annual report shall be subnutted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
7. Noncompliance Notification
The Permittee shall report by telephone to the Central 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 distribution program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
c. Any time self-monitoring indicates the facility has gone out of compliance with its permit
limitations.
WQ0037094 Version 1.0 Shell Version 140324 Page 5 of 7

d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form 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.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan.
2. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the terms and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
VI. GENERAL, CONDITIONS
Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
3. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., local, state, and federal). Of particular concern; to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCG010000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
4. In the event the residuals program changes ownership or the Permittee changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
5. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T.01 10.
6. Unless the Division Director grants a variance, expansion of the permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
WQ0037094 Version 1.0 Shell Version 140324 Page 6 of 7

7. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15 A
NCAC 02T.0105(e)(3).
Permit issued this the 30th day of April 2014
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
' r
fdr as A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0037094
WQ0037094 Version 1.0 Shell Version 140324 Page 7 of 7

ATTACHMENT A - Approved Residual Sources
Howard Fertilizer Company, Inc.
Residuals Source -Generating Facility
Certification Date: April 30, 2014
Permit Number: WQ0037094 Version: 1.0
Class A Residuals Product Generated for Distribution
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
Monitoring Monitoring
Monitoring
1 /Quart2LiL4 times er ear}
Monitoring
Permit
Maximum
Biological
Frequency for Frequency for
Frequency for
Approved
Owner Facility Name County
Number
Residuals Dry Tons
Per Year
Non -hazardous Metals and
Pathogen &
Mineralization
Frequency for
Approved
Owner
Characteristics z Nutrients 3, s
V
Vector Attraction
Reductions 4,5
Rate
South Cross Bayou Water South Cross Bayou Water Reclamation Florida
Dry
1
Yes 2,999
Annually
See Table Below
.30
Reclamation Facility Facility Pelletizin Facilit
Per Year
Total
Nutrients 3, s
2,999
Rate
Class A Residuals Product Generated for Distribution
I . Maximum Dry Tons per Year for residuals source is the amount of residuals approved for composting, Maximum Dry Tons per Year for Class A residuals is the amount of residuals product
approved for distribution from the permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen and vector attraction reductions as stipulated under permit Condition IVA. Permit application indicated that a fecal coliform density demonstration and heat drying will be
performed to meet pathogen reduction requirements, drying of stabilized residuals will be performed to meet vector attraction reductions. However, other methods listed under 15A NCAC 02T
.1106(b) and. l 107(x) can also be used to demonstrate compliance with this permit requirement.
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per ear
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1 /Year
=319 - <1,650
1 /Quart2LiL4 times er ear}
Monitoring
Monitoring
Monitoring
l/month (12 times per year)
Permit
Biological
Maximum
`bons
Frequency for
Frequency for
Frequency for
Approved
Owner
Facility Name
County
Number
Residuals
Dry
1
Non -hazardous
Metals and
Pathogen &
Mineralization
Per Year
Determination z
Nutrients 3, s
Vector Attraction
Rate
Reductions 4,5
Howard Fertilizer Company, Inc.
Howard fertilizer Company
Florida
Yes
2,999
Annually
Facility
I . Maximum Dry Tons per Year for residuals source is the amount of residuals approved for composting, Maximum Dry Tons per Year for Class A residuals is the amount of residuals product
approved for distribution from the permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of metals and nutrients as stipulated under permit Condition IV.3.
4. Analyses of pathogen and vector attraction reductions as stipulated under permit Condition IVA. Permit application indicated that a fecal coliform density demonstration and heat drying will be
performed to meet pathogen reduction requirements, drying of stabilized residuals will be performed to meet vector attraction reductions. However, other methods listed under 15A NCAC 02T
.1106(b) and. l 107(x) can also be used to demonstrate compliance with this permit requirement.
5. Monitoring frequencies are based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons per ear
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
1 /Year
=319 - <1,650
1 /Quart2LiL4 times er ear}
=>1,650 - X16,500
1160 Days 6 times per ear
=-16,500
l/month (12 times per year)
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