NCG060047_CEI_20191108

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Cargill Incorporated
Attn: Arun Nagineni, Crush Superintendent
1579 Underwood Road
Fayetteville, NC 28312
NORTH CAROLINA
Envirximentat Quality
November 8, 2019
Subject: COMPLIANCE EVALUATION INSPECTION
NPDES Stormwater General Permit NCG060000
Cargill Incorporated
Cargill Incorporated, Fayetteville Plant, Certificate of Coverage NCG060047
Cumberland County
Dear Mr. Nagineni:
On October 23, 2019, a site inspection was conducted for the Cargill Incorporated Fayetteville Plant facility located at
1579 Underwood Road, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for
your review. Mr. Terry Crawford, EHS Coordinator, Mr. Scott Schuelke, Regional Safety Leader, Mr. Isaac Harms,
Refinery Superintendent and Ms. Toni Crawford, EHS Administrative Assistant were also present during the inspection
and their time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is
covered by NPDES Stormwater General Permit NCG060000 under Certificate of Coverage NCG060047. Permit coverage
authorizes the discharge of stormwater from the facility to receiving waters designated as Cape Fear River and Locks
Creek, Class C waters in the Cape Fear River Basin.
As a result of the inspection, the facility was found to be in compliance with the conditions of the NCG060000 permit.
Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the
inspection.
Please be advised that violations of the NPDES Stormwater General Permit are subject to a civil penalty
assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs
assistance with understanding any aspect of your permit, please contact me at [phone] or by e-mail at
[e-mail].
Sincerely,
Melissa Joyner
Environmental Specialist
DEMLR
Enclosure: Compliance Evaluation Inspection
Representative Outfall Status Request Form
ec: Terry Crawford, EHS Coordinator (via email)
Scott Schuelke, Regional Safety Leader (via email)
CC' FRO — DEMLR, Stormwater Files
Q North Carolina Department of Environmental Quality I Division of Energy, Mineral and land Resources
Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301
YFrmw�rtiL'w
410.433.3300

Compliance Inspection Report
Permit: NCG060047 Effective: 11/01/18 Expiration: 05/31/21 Owner: Cargill Incorporated
SOC: Effective: Expiration: Facility: Fayetteville Plant
County: Cumberland 1579 Underwood Rd
Region: Fayetteville
Fayetteville NC 28312
Contact Person: Scott Schuelke Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
OnSite Representative(s):
Related Permits:
Inspection Date: 10/23/2019 Entry Time: 09:OOAM
Primary Inspector: Melissa A Joyner 7W
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 11:34AM
Phone:
Mike Lawyer 1r� Phone :[phone] Ext.729
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/-Tobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

permit: NCG060047 Owner- Facility: Cargill Incorporated
Inspection Data: 10/23/2019 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Melissa Joyner and Mike Lawyer met with Mr. Terry Crawford, EHS Coordinator, Mr. Scott Schuelke, Regional Safety
Leader, Mr. Arun Nagineni, Crush Superintendent, Mr. Isaac Harms, Refinery Superintendent and Ms. Toni Crawford, EHS
Administrative Assistant at the Cargill facility. The Stormwater Pollution Prevention Plan (SPPP) was reviewed and was
orderly, containing the information specified in General Permit NCG060000. The percentage of each drainage area which
was impervious was not shown on the site map. The updated site map was emailed to the Inspector shortly after the
inspection. The Analytical and Qualitative Monitoring records were reviewed. Previously, there had been exceedances of
benchmark values (for Chemical Oxygen Demand (COD) and Total Suspended Solids (TSS)), with the facility initiating
monthly monitoring for Outfalls #3 and #5. In January, 2019, semi-annual monitoring was reinitiated for Outfall #3 and in
September, 2019, semi-annual monitoring was reinitiated for Outfall #5. Outfalls #2 and #6 are currently under Tier One for
exceedances of benchmark values for COD and TSS. The facility grounds and Outfalls #1, #2, #3, #4, #5, #6 and #7 were
inspected and appeared to be well -maintained. Outfall #4 used to discharge to a containment area. The discharge is no
longer occurring, therefore Outfall #4 no longer needs to be monitored. This information should be documented in the SPPP.
A Representative Outfall Status Request Form may be submitted to the Fayetteville Regional Office to possibly reduce the
number of outfalls where Analytical Monitoring occurs, where there are very similar stormwater discharges. If Representative
Outfall Status is granted, Qualitative Monitoring would still need to Continue for those outfalls.
Page 2 of 3

Permit: NCG060047 Owner -Facility: Cargill Incorporated
Inspection Date: 10123/2019 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0
❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
N
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
E
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
E
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
N
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
0
❑ ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
0
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ ❑ ❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? N ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
0
❑
❑ ❑
# Were all outralls observed during the inspection?
0
❑
❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division?
❑
❑
E ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
E
❑
❑ ❑
Comment
Page 3 of 3

Division of Energy, Mineral & Land Resources
Stormwater Program
National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
Quality REOUEST FORM
FOR AGENCY USE ONLY
Dflte Received
Year
I Month
Day
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEO in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
N, ri •=5 � . y
2) Facility Information:
Owner/Facility Name
Facility Contact
Street Address
City State ZIP Code
County E-mail Address
Telephone No. Fax:
3) List the representative outfalls) information (attach additional sheets if necessary):
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ No data*
❑ No data*
Outfalls' drainage areas have the same or similar activities? ❑ Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑ Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outiall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars ($10,000).
I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing:
Title:
(Signature of Applicant)
(Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
Mail the entire package to:
NCDEQ DEMLR at the appropriate Regional Office (See map and
addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DEQ Regional Office for your area.
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Washington Regional Office
943 Washington Square Mall
Phone [phone]
Washington, NC 27889
FAX [phone]
Phone [phone]
Fayetteville Regional Office
FAX [phone]
Systel Building,
225 Green St., Suite 714
Wilmington Regional Office
Fayetteville, NC 28301-5094
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone]
Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave.
Winston-Salem Regional Office
Mooresville, NC 28115
585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone]
Phone [phone]
FAX [phone]
Water Quality Main FAX [phone]
Raleigh Regional Office
Central Office
1628 Mail Service Center
1612 Mail Service Center
Raleigh, NC 27699-1628
Raleigh, NC 27699-1612
Phone [phone]
Phone [phone]
FAX [phone]
FAX [phone]
Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009