WQ0037094_More Information (Requested)_20190523

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
May 23, 2019
MICHAEL BROOKS — CORPORATE COMPLIANCE OFFICER
HOWARD FERTILIZER COMPANY, INC.
8306 SOUTH ORANGE AVENUE
ORLANDO, FLORIDA 32809
Subject: Application No. WQ0037094
Additional Information Request
Howard Fertilizer Company, Inc.
Distribution of Class A Residuals
State-wide Distribution
Dear Mr. Brooks:
Division of Water Resources' Central and Regional staff has reviewed the application package
received April 18, 2019. However, additional information is required before the review may be completed.
Please address the items on the attached pages no later than the close of business on June 24, 2019.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through C, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely,
rick S nders, Engineer
Division of Water Resources
cc: Rob Willcox — Willcox & Mabe Soil Solutions, LLC (Electronic Copy)
Permit Application File WQ003 7094
Q1 North Carolina Department of Environmental Quality I Division of Water Resources
c::r;0-0`D E
V 512 North Salisbury Street 1 1617 Mail Service Center ! Raleigh, North Carolina 27699-1617
wwe� 919.707.9000

Mr. Michael Brooks
May 23, 2019
Page 2 of 2
A. Residuals Source Certification Form DCAR 06-16 Application.
The toxicity characteristic leaching procedure (TCLP) analysis submitted is missing four
parameters needed to demonstrate that residuals are non -hazardous under RCRA.
Hexachloroethane and 2,4,5-Trichlorophenol results were not provided in the supporting
documentation. Endrin and Heptachlor parameters also had laboratory non -detect values that are
higher than the TCLP limits, meaning that the results can't be verified to be under those limits.
Submit documentation from a verified lab that demonstrate that these four parameters are below
their TCLP limits.
2. The nutrient determination results submitted do not include a value for aluminum. Submit
documentation from a verified lab to determine the aluminum concentration.
B. Operation & Maintenance O&M Plan 15A NCAC 02T. 1110
1. Please include a short narrative detailing how the finished product shall be delivered to North
Carolina.
Section I. and II. of the submitted O&M plan do not completely cover the requirements of an O&M
plan required by 15A NCAC 02T .I I IO(a) regarding the operation of the program, equipment
involved (other than the concrete storage bins), and maintenance schedules. According to 15A
NCAC 02T . I I I O(a)(1)-(2), the O&M plan shall describe the operation of the program and
equipment in sufficient detail to show what operations are necessary for the program to function
and by whom the functions are to be conducted, and anticipated maintenance of the facilities that
are associated with the program. Please submit a revised O&M plan that satisfies these rule
requirements.
3. The O&M Plan submitted in the application reference a Spill Control Plan, a Spill Prevention Plan,
and a Spill Control, Containment and Cleanup Plan. Each of these documents are said to be attached
but they appear to be missing. Submit these documents for review. Please keep in mind that these
documents should fulfill the requirements listed in 15A NCAC 02T . I I I O(a)(4) and should include
provisions for spills that occur during transportation.
C. Site Mai):
1. Please provide a site map of the fertilizer generating facility owned by Howard Fertilizer Company,
Inc. This map should include the location's address as well as parcel boundaries and the location
of the residuals storage/treatment facilities.