
?
Need
to
return
call
by
/
at/
between
and
.
Signature:
Project
No.:
0172.01.005
DISTRIBUTION
Page
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1_
of
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Project
Name:
2004/
2005
304(
m)
Plan
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
01/
16/
04
Time:
2:
00
PM
Company
Name:
Royster­
Clark,
Hartsville,
SC
Contact
Name:
Billy
Pirkle
Phone
No.:
1­
800­
767­
2855,
Ext.
448
Name:
Arash
Hooshangi
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Clarification
of
Manufacturing
Processes
and
Pollutant
Discharges
TOPICS
DISCUSSED
AND
ACTION
TAKEN
Mr.
Pirkle
works
in
Illinois
and
oversees
the
environmental
operation
of
other
Royster­
Clark
facilities
as
well.
I
asked
Mr.
Pirkle
about
the
Hartsville,
SC
facility
and
whether
he
knew
what
subcategory
of
40
CFR
it
was
regulated
under.
Mr.
Pirkle
told
me
that
it
was
regulated
under
40
CFR
418
(
Fertilizer
Manufacturing)
and
has
a
SIC
code
of
2875.
He
explained
the
operation
of
Hartsville
facility
and
told
me
that
presently
in
that
facility
they
do
not
manufacture
anything;
they
only
combine
products.
He
said
that
they
purchase
liquids
(
such
as
sulfuric
acid
or
phosphoric
acid)
and
other
by­
products
and
combine
them
in
a
rotary
drum.
A
reaction
occurs
and
the
result
is
granular
homogenous
fertilizer.
I
asked
him
whether
the
product
was
a
phosphate
fertilizer
and
he
said
that
there
are
40
different
grades
that
are
produced.
Some
grades
contain
phosphate
and
some
grades
do
not
contain
phosphate
at
all.
He
said
that
the
facility
does
not
produce
any
sulfuric
acid,
any
phosphoric
acid,
or
ammonia.
However,
he
mentioned
that
in
the
past
the
facility
used
to
manufacture
"
normal
superphosphates."
He
said
that
the
operation
was
stopped
in
2001.
I
explained
to
him
that
we
are
looking
at
the
data
from
2000
and
so
we
are
interested
to
know
what
manufacturing
operations
occurred
in
that
year.
We
then
discussed
both
40
CFR
418
(
fertilizer)
and
40
CFR
422
(
phosphate)
and
Mr.
Pirkle
made
sure
that
the
Hartsville
facility
did
not
produce
any
products
described
in
the
applicability
section
of
each
subcategory.
Therefore,
we
concurred
that
in
2000
their
facility
conducted
operations
covered
under
40
CFR
418,
subpart
A
for
producing
normal
superphosphate.

I
also
asked
Mr.
Pirkle
about
the
reported
pollutant
discharges
from
the
Hartsville,
SC
facility.
He
said
that
the
discharge
of
pollutants
is
based
on
production
throughput
and
is
not
affected
by
precipitation.
If
such
discharges
fluctuate
and
are
higher
at
times,
that
is
only
due
to
handling
issues.
For
example,
it
is
possible
that
during
loading/
unloading,
chemicals
are
spilled
and
are
discharged
to
the
wastewater.
I
asked
Mr.
Pirkle
how
they
discharged
their
wastewater.
He
explained
that
their
facility
does
not
discharge
any
process
water.
All
process
waters
are
recycled
and
fully
used.
Their
only
water
discharge
is
storm
water
and
their
PCS
permit
is
also
for
storm
water.
Their
storm
water
discharges
are
directly
discharged.
He
also
said
that
the
facility's
sanitary
sewer
goes
to
municipal
treatment
facilities.
?
Need
to
return
call
by
/
at/
between
and
.
Signature:
At
the
conclusion,
Mr.
Pirkle
asked
for
my
contact
information,
the
EPA
project
name
as
well
as
EPA
contacts.
I
gave
him
Carey
Johnston's
name
and
phone
number.
