NCG060288_COMPLETE FILE - HISTORICAL_20171025

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. I /V Cc, bp oa. b "
DOC TYPE I ®; HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE ❑ O j 1 ,� l7 a'� S _
YYYYMMDD''-'

tk
i Division of Energy, Mineral, and Land Resources
Land Quality Section I Stormwater Program
a _ National Pollutant Discharge F.Iimination System (NPDLS)
Energy. Mineral & PERMIT OWNER AFFILIATION DESIGNATION FORM
Land Resources
FMV.PnuHVNTM nt,a.1TV llndivirtual LPonliv RPSnnnSih1P fnr PPrmitl
FDR AGENCY USE ONLY
Dw,c Reamed
Year
�Ltond,
DaN
Rs N ,
Use this form if there has been:
NO CHANGE in facility ownership or facility name, but the �ndl�lduh��'<< 111
St 1FIV,a,,,._
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual" mean?
The person is either:
• the responsible corporate officer (for a corporation);
• the principle executive officer or ranking elected official (for a municipality. state. Federal or other public
agency);
• the general partner or proprietor (for a partnership or sole proprietorship);
• or. the duly authorized representative of one of the above.
1) Enter the Permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Individual Permit
IN', �G i a S, 10 1 �o 0 fi
2) Facility Information:
Facility name:
Company/Owner Organization:
Facility address:
(o)) Certificate of Coverage
hf C G Q 1 (P 1) 1 R I 1
Aox Ya&V fvG' L4 L.
Address
iil, s�✓ Ail r _-3 y/
City state zip
TO find the current legally responsible person associated with your permit, go to this website:
htip://(ieq.nc.�-,ov/about/divisions/enert y riiinei-al-land-resources/erier1)v-inIneral-land-perrtiits/stormwater-I)ro(_7ram
and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: J, M Ke/S lit N�
First 411 Last
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit: /J(j1i//Yr %�tf
First N'tI ist
SWIJ-OWNERAF➢:It: 23i�,larch2Ol 7
f'age 1 of

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
Title
Mailing AsUress
X�-W/�_ 16 _ r a 5 , 3
City slate rip
( �r%�') yp • ._ S 3 � i�e.�-'',`5_ /'Pr• �t�y�h�/d��y�dlk✓s
Telephone 1 -msil Address
I'a Number
5) Reason for this change:
A result of: &�J—Flmployec or managernent change
❑ Inappropriate or incorrect designation before
❑ Other
lfotltcr•please erhlurn:
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
17 C Ilkl-_. _ .attest that this application for this change in Owner Affiliation
(person legally responsible for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this form are not completed, this change may not be
processed.
�1
10
Signature _ Date
PLEASE. SEND THE COMPLETFD FORM TO:
Division of Energy. Mineral, and Land RCSO u•ces
Storn���ater'Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more inlormation or staff contacts, please call [phone] or visit the website at:
httpa/de .13c.govlaboLit/divisions/encr�-,v-mineral-land-l-esotn-ces/stormwater-
Page 2 of 2
SWU-OVA NE R AF Fll 23Mar2017

Aim==�
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, R E,
Governor Director
December 4, 2012
Bob O'Neill
Bay Valley Foods LLC
2021 Ste 200
Oak Brook, IL60523
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Bay Valley Foods Faison Processing Facility
COC Number NCG060288
Duplin County
Dear Permittee:
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended),
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCG060000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event' beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part it of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wg/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/web/wa/ws/su/npdessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: 919-' J7-63001 FAX: [phone] a2
Internet: wr.- ,nmaterqua lity.o
An Equal AtSnnafive Action Emi ve-
One
NorthCai-ol ina
,XRtllrralllf

Bob O'Neill
December 4, 2012 t
Page 2 of 2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections B, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections B, C: A lower TSS benchmark of 50 mg/1 for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C: The monitoring parameter Oil & Grease (O&G) has been replaced by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections B, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections B, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
II
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Wilmington Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060288
STORM WATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Bay Valley Foods LLC
is hereby authorized to discharge stormwater from a facility located at:
Bay Valley Foods Faison Processing Facility
354 N Faison Ave
Faison
Duplin County
to receiving waters designated as Panther Creek, a class C;Sw waterbody in the Cape Fear
River Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, II, 111, and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41h day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
February 9, 2011
Mr. Donovan Wayne Brock
354 N. Faison Avenue
Faison, NC 28341
Subject: Compliance Inspection
Bay Valley Foods LLC
Certificate of Coverage NCG060288
Duplin County
Dear Mr. Brock,
Dee Freeman
Secretary
A compliance inspection at the Bay Valley Foods facility in. Duplin County was conducted during the site
visit by the Division of Water Quality on November 2, 2010. A site tour was given to Division of Water
Quality Central Office staff, Jeff Poupart, Gil Vinzani, Tom Belnick, and Region 4 EPA representative,
Pamala Meyers. Dean Hunkele with the Wilmington Regional Office was also in attendance. Enclosed
with this correspondence is a "Compliance Inspection Report". There were no issues of concern noted
during the site inspection.
Should you have any questions concerning the enclosed inspection report, you may contact me at the
letterhead contact information, by phone at 910-796-7343, or via email at linda.willis(a-)ncdenr.gov.
CC: DWQ WirO Files (NCG060 Duplin)
DWQ CO Files
Wilmington Regional Office
127 Cardinal Drive Extension Wilmington, NC 28405
Phone: [phone] / FAX: [phone]
fnternet: vA w ncwater uaiity c rg
Sincerely,
Linda Willis
Environmental Engineer
Surface Water Protection Section
Division of Water Quality
Wilmington Regional Office
North Carolina
Naturally
An Equal Opportunity/Affirmative Action Employer
507 Recycled/ 10% Post Consumer Paper
Customer Service 1-877-623-6748

f *�
Permit: NCG060288
SOC:
County: Duplin
Region: Wilmington
Compliance Inspection Report
Effective: 01/02/08 Expiration: 10/31/12 Owner: Bay Valfey Foods LLC
Effective: Expiration: Facility: Faison Processing Facility
354 N Faison Ave
Contact Person: Donovan Wayne Brock
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title: ORC
Certification:
Faison NC 28341
Phone: [phone]
Ext.251
Phone:
Inspection Date: 1110212010 Entry Time: 10:00 AM Exit Time: 11:30 AM
Primary Inspector: Linda Willis rzo, t Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Other Inspection Type: Compliance Evaluation
Permit Inspection Type: Foodlrobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: ® Compliant ❑ Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60288 Owner - Facility: Bay Valley Foods LLC
Inspection Date: 11/02/2010 Inspection Type: Compliance Evaluation Reason for Visit: Other
Inspection Summary:
The site visit was to discuss the chloride variance with Bay Valley Food representative Bill Scott and Donovan Brock.
Those present were permitting unit staff, Jeff Poupart, Gil Vinzani, and Tom Belnick. Dean Hunkele from WiRO
accompanied. Ms. Pamala Myers with Region 4 EPA, Water Protection Division, Municipal and Industrial NPDES Section
was present. A presentation was given to DWQ and the EPA representative to familiarize us with the history of the facility
and the production capabilities. A site tour was conducted. The tour involved a walk through in the vicinity of the
stormwater basin, the lift stations, the pickling vats, the covered area adjacent to the wastewater treatment facility, the
wastewater treatment processes and the discharge. The central office staff and Ms. Pamela Myers viewed two
downstream and the upstream sampling locations. Dean Hunkele and I viewed the two downstream locations. The site
was very well kept with good housekeeping. The stormwater basin was completely empty and the plant was operational
with a discharge, but production was not in operation. The discharge looked good from the wastewater treatment plant.
There did not appear to be any issues concerning good housekeeping.
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# if the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Ywc Kin NA NE
Page: 2

North Carolina
Beverly Eaves Perdue, Governor
NCDENR
Department of Environment and
Timothy Wolf
Corporate Environmental Specialist
Bay Valley Foods
P.O. Box 19057
Green Bay, WI 54307-9057
Subject
Dear Mr, Wolf,
November 18, 2009
Natural Resources
Dee Freeman, Secretary
NPDES Compliance Inspection Report
Bay Valley Foods
NPDES Permit No. NCG060288
Duplin County
I conducted an inspection of the Bay Valley Foods site pertaining to the NPDES Stormwater Permit NCG060288
and the Wastewater Treatment Facility on October 22, 2009. This inspection was conducted to verify that the
facility is operating in compliance with the conditions and limitations specified in NPDES Permit No.s NCG060288
and NC0001970. The findings and comments noted during the inspections are provided in the enclosed copy
of the inspection reports entitled "Water Compliance inspection Report" and "Compliance Inspection Report
Please provide a response in writing (an email is acceptable) identifying the expected date upon which the
surface aerator (from the first aeration basin in series) that is currently out of service will be repaired and placed
back in the aeration basin. Your ORC, Donovan Brock was very helpful during the inspections. Good
housekeeping is being exercised at this facility. It appears that the facility is being operated both properly and
optimally. Your ORC and sludge press operator were commended on their efforts in maintaining the facilities.
It you have any questions concerning this report, you may contact me at the letterhead contact information or
via email at [e-mail],
Sincerely,
Linda Willis
Environmental Engineer I
Enclosure
Cc'. Wilmington Regional Office - (2 copies) NCG060 f Duplin folder), NC0001970 (yellow)
Central Files, Surface Water Protection Section
NorthCar®fina
1601 Mail Service Center, Raleigh, North Carolina 27699-1601 ;Vahmallff
Phone: [phone] FAX [phone] Internet: www.enr.state.nc.tis/ENR/
Ali Equal Opportunity 1 "Armalve Aot[on Fniplover -,50 % Rerydod't 10 IX. Post GonSumsr Pinner

Compliance Inspection Report
Permit: NCGO60288 Effective: 01/02/08 Expiration: 10/31/12 Owner: Bay Valley Foods LLC
SOC: Effective: Expiration: Facility: Faison Processing Facility WWTP
County: Duplin 354 N Faison Ave
Region: Wilmington
Faison NC 28341
Contact Person: Donovan Wayne Brock Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: + Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/22/2009 , Entry Time: 10:00 AM Exit Time: 12:00 PM
Primary Inspector: Linda Willis Phone-. Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/Soaps/Cosmetics/Public Warehousing
Stormwater Discharge COC
Facility Status: N Compliant Q Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60288 Owner - Facility: Bay Valley Foods LLC
Inspection Date: 10/22/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Housekeeping is good. Compliance with the NPDES permit is substantial, The ORC has made efforts to improve
protection for the stormdrain drop inlet that has had high TSS values. Amendments to the plan indicating the efforts taken
are expected to be added to the SWP3.
Page: 2

Permit: NCG060288 Owner - Facility: Bay Valioy Foods LLC
Inspection Date: 10/22/2009 Inspection Type: Compliance Evaluation
Stormwater Pollution Prevention Plan
Does the site have a Stormwater Pollution Prevention Plan?
# Does the Plan include a General Location (USGS) map?
# Does the Plan include a "Narrative Description of Practices"?
# Does the Plan include a detailed site map including autfall locations and drainage areas?
# Does the Plan include a list of significant spills occurring during the past 3 years?
# Has the facility evaluated feasible alternatives to current practices?
# Does the facility provide all necessary secondary containment?
# Does the Plan include a BMP summary?
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
# Does the facility provide and document Employee Training?
# Does the Plan include a list of Responsible Party(s)?
# Is the Plan reviewed and updated annually?
# Does the Plan include a Stormwater Facility Inspection Program?
Has the Stormwater Pollution Prevention Plan been implemented?
Comment:
Qualitative Monitoring
Has the facility conducted its Qualitative Monitoring semi-annually?
Comment:
Analytical Monitoring
Has the facility conducted its Analytical monitoring?
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
Comment:
Permit and Outfalls
# Is a copy of the Permit and the Certificate of Coverage available at the site?
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment:
Reason for Visit: Routine
Yes No NA NE
®❑ ❑ ❑
0 ❑ ❑ ❑
®❑ ❑ ❑
®❑ ❑ ❑
®❑ ❑ ❑
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®❑ ❑ ❑
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M ❑ ❑ ❑
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®❑ ❑ ❑
IO ❑ ❑ ❑
❑ ❑ ® ❑
❑ ❑ ® ❑
Page: 3

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross Jr., Secretary
Coleen R Sullins, Director
Jl Inuary 2, 2008
Williarn A. Scott. Plant Manager
Bay Valley Foods, 1_1-C
354 North Faison Avenue
Faison, North Carolina 28341
4dM
• •
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL.. RESOURCES
Subject: General Permit No. NCG060000
Bay Valley Foods, LLC
COC NCG060288
Duplin County
Dear Mr. Scott:
In accordance with your application for discharge permit received on June 21, 2005, and again
with revisions on September 2, 2005, we are forwarding herewith the subject certificate of coverage to
discharge under the subject state - NPDES general permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the US Environmental Protection agency dated May 9, 1994 (or as subsequently
amended).
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual
permit application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the
Division of Water Quality. The Division of Water Quality may require modification or revocation and
reissuance of the certificate of coverage,
This permit does not affect the legal requirements to obtain other permits which may be required
by the Division of Water Quality or permits required by the Division of Land Resources, Coastal Area
Management Act, or any other federal or local governmental permit that may be required.
If you have any questions concerning this permit, please contact Ken Pickle at telephone number
[phone] ext. 584.
Sincerely,
4 Coleen H. Sullins
cc: Wilmington Regional Office
DWQ Central Files
Stormwater Permitting Unit Files
SWU-259-011001
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

IF i'
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060288
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Bay Valley Foods, LLC
is hereby authorized to discharge stormwater from a facility located at
Bay Valley Foods, LLC
354 North Faison Avenue
Faison, North Carolina
Duplin County
to receiving waters designated as unnamed tributary to Panther Creek, a class C Sw water in the Cape Fear River
Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
I1, III, IV, V, and V1 of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective January 2, 2008.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day January 2, 2008.
d� e"I&
Coleen 1-1. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

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lFwd: Stormwater/Waste Water Construction Time Line]
4
I* i.
SubJect: [Fwd: Stormwater/Waste Water Construction Time Line]
From: Tom Belnick <[e-mail]>
wte: Ti,u, 15 Sep 2005 15:56:16 -0400
To: Ken Pickle <[e-mail]>, Ken Polilia <Ken.Pohlic,@ncm:til.tiet>
Just an fyi- here's a proposed stormwater reroute/lagoon upgrade construction
schedule from Dean Pickle- anticipated end date is August 2008.
Stit).iect:'Stortnwater/Waste Water Construction Time Line
From: [e-mail]
Uate: Thu, 15 Sep 2005 08:04:03 -0400
To: [e-mail]
CC: Donovan_Brock@bayval leyfoods.coni, [e-mail]
Tom,
Below are three different formats of the Stormwater Waste water time line
that you requested. I hope these fit your needs. Zf you have any questions,
please call.
The Faison tacility does plan to continue the study of pasteurizer water
discharge. L^Ie are currently testing filtering systems and doing other
studies to see if we can directly discharge pasteurizer water in the
future. We will. keep you posted with our progress. Also, it is our
understanding that an ATC construction permit will not be required until
the actual lagoon lining construction begins. G1e believe the rest of the
project is a storm water issue unless you tell us otherwise.
We look forward to seeing you in October.
(See attached file: Storm water Construction Schedule.doc)
(See attached file: haste water - Storm water Timeline.html)(See attached
file: waste Water --Storm G,7ater Time L.i.ne.TIF)
Bill Scott
Plant Manager - Faison Plant
Bay Valley Foods, LLC
800-768-2283 Ext 237
bill—[e-mail]
Waste water - Storm water Timeline
t of 4 9/26/2005 8:45 AM

Fwd: Stormwater/Waste Water Construction Time Line]
Project Start: Wed 9/14/05
Project Finish: Mon 8/25/08
Tasks
2 of 4 9/26/2005 8:45 AM

[Fwd: Stormwater[Waste Water Construction Time Line]
. . . . . .....
Material Lead Time/Staging
........ .... .... . .... ...
4 wks
.
TLIC l/23/0V Mon 2/19/07!1,
.. ..... . ... . . . . . ..........
27
Underground Work/Catch Basins
4 wks:.
Tue 2/20/07Mon 3/19/07
28-�
Site l,.n,(,liticei-itiL,/Coi-npiction Testing
I wki:
Tue 2/20/OTMon 2/26/07
!29
Weather/Soil Delays
2 wk-s:.
'rue 2/27/071 Mon 3/12/07;
Timing - Wait Until Dry Months (Aug)?
r
I day
Tue Tue 3/13/07Tue 3/13/07
..... . ..
. . . .... ...
32 Waste water Liner - Phase 4
166 days:
Mori 1/7/08� Mon /25108
33
New Fiscal Year
Mori 1/7/0S. Mon 1/7/08,
!!34
Design/Bids
8 wks4:
Tue 1/8/08;1 Mon 3/3/08-
...... . .....
!351
Capital Approval
C
2 wksl,
Tue 3/4. Mon 3 17108!
1,361
Material Lead Time
12 %vks::
-rue 3/18/08 Mon 6/9/08;
137
Sludge Removal
i I w k:1
Tue 6/10/081 Mori 6/16/0
38
Site Enaincering
. .
Tue 6/ 10/0&
. . . ... . ..... ...... . ..........
(Lij 6/16/08
39
. ............
Clearing/Grading
2 wks��
'rue 6/17/081 Mon 6/30/08!
140
. ........... . . ..... ... ....... .......
1 Process Piping
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3 of 4 1 9/26/2005 8:45 AM

[Fwd: Stormwater/Waste Water Construction Time Linel
Tern Selnick <[e-mail]>
Environmental Specialist III
NC Division of Water Quality
Point Source Branch
—'-- —_ - Stormwater/Waste Water Construction Time Line� Content -Type: messagelrl'c822
Content -Encoding: 7bit
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Storm Water Construction Schedule.doq
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Waste water - Storm water Timeline.httnll
Content -Encoding: base64
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Tater Time Line.TIV Content -Type: applicationloctet-stream
Content -Encoding: base64
4 of 4 9/26/2005 8:45 AM

.0-
Bay Valley Foods, Faison, NC Plant
STORM WA'rE R CONTSTRUCTION SCHEDULE
Phase 1:
Reroute Storm water from employee parking lot by main office.
Estimated completion by December 2005
Phase 2:
Reroute Storm water from warehouse and production facility.
Estimated Completion by April 2006
Phase 3:
Reroute Storm water from old parking lot area.
Estimated completion by March 2007
Phase 4•
Install liner for process overflow. ,lo _r �
Estimated completion by August 2008/o/�7�Jr'�Lci

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(Fwd: DPSP - Faison, NC Storm Water / Wastewater Management Plan]
Subject: tFwd: DPSP - Faison, NC Storm Water / Wastewater Management Plan]
From: Tom Belnick <[e-mail]>
Date: 'I'llu, 05 May 2005 12:21:19 -0400
To: Ken Pickle <ken.pickle@ncmaiLnet>
Hi Ken- I'm fowarding the latest from Dean Pickle re: stormwater and other permitting activities currently ongoing at the facility.
-------- Original Message--------
Subject:DPSP-Faison, NC Storm Water / Wastewater Management Plan
Date:Mon, 2 May 2005 10:54:10 -0400
From:Donovan [e-mail]
Tn:[e-mail]
Donovan Brock
Brineyard Manager/ Environmental co-ordinater
Dean Specialty Food Group/Faison, NC
910-267-4711 ext.251
910-267-4866 fax
[e-mail]
----- Forwarded by Donovan Brock/DSFG/Dean Foods on 05/02/2005 10:53 AM
Bill Scott
To: [e-mail]
05/02/2005 10:29 cc: [e-mail], dawn
AM jefferies@ncmail,.net, Donovan Brock/DSFG/Dean Foods@Dean
Foods
Subject: DPSP - Faison, NC Storm Water / Wastewater
Management Plan
Below is an update Dave Schauer sent me concerning our permit, etc. It is
an excellent outline on some of the progress we are making with the issues
at hand.
Dave has been asked to do some work on a new acquisition of Dean Speciality
Foods. Since he will be traveling a lot more than normal have ask him to
send me notes and I will forward them to you. After you settle in from your
vacation I thought it may be beneficial for Donovan and I to sit down with
you and Dawn to see if we can move this issue along toward completion. Let
us know. THANKS
Bill Scott
Plant Manager - Faison Plant
Dean Pickle & Specialty Products
800-768-2283 Ext 237
[e-mail]
----- Forwarded by Bill Scott/DSFG/Dean Foods on 04/29/2005 10:31 AM -----
David Schauer
To: Bill Scott/DSFG/Dean Foods@Dean Foods
04/28/2005 11:29 cc: Donovan Brock
AM Subject: DPSP - Faison, NC Storm Water / Wastewater
Management Plan
Good Morning Bill:
I have been tied up out in California the last few weeks working on the
MorningStar Foods - City of Industry, CA integration project. Because of
this we haven't talked for a while so I want to provide you a brief update
on where we are with development of the comprehensive plan to manage storm
water and wastewater at the Faison plant site and to address ground water
concerns related to the existing storm water control pond.
As we discussed during our meeting on January 12, 2005, our current plan
includes the diversion of a significant amount of the "clean" storm water
from the existing wastewater treatment system. This storm water comes from
building roofs, parking lot run-off, etc. The intent is to reduce the
I of 2 5/5/2005 12:52 PM

11--wd: DPSP - Faison, NC Storm Water / Wastewater Management Plan]
overall hydraulic burden on the treatment system to improve operating
efficiency and to free up capacity. A second equally important goal is to
control the effectual design volume of the new wastewater equalization (EQ) O
lagoon (formerly known as the "storm water pond"). In doing, so we will
be able to complete construction on the lagoon which includes the �
installation of the lagoon liner that will provide greater protection of 42
the groundwater.
We recently completed a comprehensive site survey and now have an
up-to-date detailed set of site plans to utilize in the preparation of the
facility storm water pollution prevention plan (SWPPP). We are currently
in the process of preparing the SWPPP and the storm water permit
application for coverage In cooperation with a professional engineering
consultant. The SWPPP and the storm water permit application will be
prepared to reflect the existing storm water conditions at the site.
Proposed changes to the current site storm water collection system will be
incorporated into a future SWPPP modification due to the anticipated timing
on the construction.
using the recently completed site survey data, we have been able to develop
a comprehensive plan to divert clean water from the wastewater system and
the EQ lagoon. Based upon Our engineering estimates the new EQ lagoon
management plan will provide for adequate capacity to manage a 25-year
storm event. Under our current plan only storm water run-off collected Qib
from the tank yard would flow to the EQ lagoon. A 2000-gallon per minute
fossil fuel fired backup pump would be installed to pump water from the
lagoon directly to the wastewater treatment system to prevent lagoon
overflow in the event of an unusually significant (25-year) storm event. A
second wastewater line from the EQ lagoon to the treatment lagoons would
have to be installed to handle this amount of flow. The remaining site
storm water that can not be diverted to direct discharge would continue to
go to the existing wastewater treatment system. The mixing of process
wastewater with tank yard storm water run-off would not occur. Water
accumulated in the new EQ lagoon would then be pumped back to the
wastewater system during dry periods using the existing pumps.
John Rudolph, our professional engineer, is currently working on the piping
and engineering plans to divert the storm water from the parking lot and
roof drains away from the new EQ lagoon. This work must be completed
before the work on the new EQ lagoon can begin, due to the logistics of
managing storm water during the construction period. The engineering plan
for the EQ lagoon itself is essentially complete.
We are also currently setup to conduct a full-scale pilot test of the
carbon filtration system for the pasteurizer cooling water outfall. It is
anticipated that this system will reduce BOD below the 5 mg/L mandated by
the State so that we can apply for a permit modification to discharge this
water via a second outfall and further reduce the amount of "clean" water
that is going to the treatment system.
If you have any questions or concerns regarding our plans, please contact
me.
Thank you,
djs
David J. Schauer, CHMM
Environmental, Health, Safety & Security'Director
Dean Specialty Foods Group, LLC
P.O. Box 19057
Green Bay, WI 54307-9057
Tel: [phone], Ext. 384
Fax: [phone]
Mob: [phone]
tam.belnick@ncmai].net
N.C. DENR/DWQ/NPDES
919-733-5D83,ext. 543
2 of 2 5/5/2005 12:52 PM

F WATF
Michael F. Easley
Governor
C/] William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
MEMO
February 9, 2005
To: Dawn Jeffries, DWQ Eastern NPDES Program Unit
CC: Bradley Bennett - SPU; Mike Randall = SPU; Tom Reeder - WSB
From: Ken Pickle, DWQ Stormwater Permitting Unit
Subject: Dean Specialty Foods Group and stormwater
Conclusions
1. The rainwater flows from the brine tank farms are, not permittable as stormwater
discharges under North Carolina's stormwater NPDES program.
2. It appears that Dean Foods should apply for a NPDES stormwater permit for runoff
from selected other portions of the facility.
Background relevant to stormwater considerations
Dean Foods occupies a 32-acre site in Faison, North Carolina. The facility processes
cucumbers, onions, and peppers to produce pickles, relish, and similar products. About half
of the cucumbers received begin processing outside in 864, 800-bushel FRP tanks
configured in two brine tank farms. Currently rainwater in the tank farms is collected and
routed through the WWTP. Dean desires to increase production and consequently to
increase wastewater flow through their WWTP and their NPDES wastewater outfall. Since
the wastewater discharge has a flow limit in the current permit, Dean proposed to remove a
portion of the collected rainwater from the brine tank farm in order to make flow capacity in
the WWTP available for increased wastewater flow from increased production. Specifically,
Dean proposed to retain and treat the first flush of the runoff, recognizing that for some
pollutants it would probably be the most polluted fraction. Dean proposed to discharge the
remainder of the collected rainwater as stormwater under an NPDES stormwater permit.
(Discussion
As promised in our meeting with Dean Foods on January 12, 2005, DWQ's Stormwater
Permitting Unit has evaluated whether or not any portion of the runoff from the two brine
tank farms can be considered a permittable discharge of stormwater under North Carolina's
stormwater NPDES program.
My observations in one tank farm on January 12, 2005 included the following.
a. A fluid leak at a pump adjacent to a brine tank.
b. A fluid dripping from some of the brine piping running between the tanks.
c. Evidence of water wash -down of the area around the brine tanks.
d. Splashing of brine fluid onto the paved surface during the handling of pickles
by the pickle -pumper truck.
e. Numerous brine tanks with brine levels 2" - 4" from the top rim of the tanks
(the brine tanks are open -top tanks.)
f. Numerous surface inlet grates in the one tank farm area.
NCDENR
Customer Service Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
1 800 623-7748

Dawn Jefferies
Page 2
February 8, 2005
2. Based on my observations of the wastewater fluids, and my observation of the
physical configuration of pavement and drainage grates, it is clear that mixing of
wastewaters and stormwaters occurs during a rain event. Further, it appears that a
rainfall volume of approximately 3" would cause an overflow of at least some of the
brine tanks, releasing brine (now a wastewater) to be mixed with the stormwater.
3. GS 143-211(b) states, "It is the public policy of the State to maintain, protect, and
enhance water quality within North Carolina." Further in GS 143-213(18)b, the
following definition is recorded, "'Industrial waste' shall mean any liquid, solid,
gaseous, or other waste substance or a combination thereof resulting from any
process of industry, manufacture, trade or business, or from the development of any
natural resource." (emphasis added) Accordingly, DWQ has established the
precedent that when stormwaters are mixed with wastewaters, the whole is treated
as wastewater. That approach seems applicable in the present case of the brine tank
fa rm.
4. Dean Specialty Foods suggested that they might capture and route to the WWTP
some early fraction of the runoff flow as a sort of first flush treatment, and then let
the later fraction of runoff be considered as stormwater and released under a
stormwater permit. But that doesn't eliminate the leaking pumps or pipes from the
later flow. In fact, in a large rain, the chance of an overflow from the brine tanks
increases as time passes, suggesting that the later fraction of runoff (the fraction to
be released under a stormwater permit) might contain an additional wastewater
component from the brine tank overflows. So, even with the proposed first flush
segregation, the subsequent rainfall runoff can still be mixed with wastewater.
Therefore the entire flow should be treated as wastewater.
S. So, I conclude that surface runoff from the area of the brine tank farms cannot be
permitted under an NPDES stormwater permit.
6. )ust to re -iterate a topic covered in the meeting, it does appear that Dean should
check the runoff from other areas of the facility to see if a stormwater permit should
be obtained. They certainly are an industry covered under the NPDES stormwater
permitting program. If they have a point source discharge of stormwater from other
industrial activity areas, then a permit is required. Also, the determination of
whether a general permit or an individual permit is most appropriate deserves some
attention from DWQ staff.

intap:/Iken.I)ick[c%40clwcl.denr.ncmaiLnet n cros.ncmai1.net:143/fetc...
Subject: RE: Dean Pickle and Specialty Products stormwater permit
From: "Bromby, Craig A." <[e-mail]>
Date- Mon, 21 Feb 2005 17:20:50 -0500
To: "Ken Pickle" <[e-mail]>
I appreciate it. I don't think we are going forward to the NPDES Committee until
April at the earliest, so there is only a moderate degree of immediacy, but I
appreciate any attention you can give this.
-----Original Message -----
From; Ken Pickle [mailto:ken.pickle0ncmail.net]
Sent: Monday, February 21, 2005 4:25 PM
To: Bromby, Craig A.
Subject: Re: Dean Pickle and Specialty Products stormwater permit
Thanks for this analysis, Craig. I'll take a look, and discuss it with
those that know more than I do.
Ken
Bromby, Craig A. wrote:
Dave Schauer and I have discussed the possibility of a separate stormwater outfall
at its Faison facility, and he asked if I could summarize those thoughts for you.
Reportedly, the suggestion was made by DWQ that stormwater runoff from the brine
tankyard could not be permitted as a stormwater flow, ostensibly because under some
conditions, the tanks will overflow (I am told this happens rarely and only under
extreme rainfall conditions). The assertion that there is some regulatory
prohibition to the permitting of stormwater runoff from the brine tankyard is
incorrect. Keep in mind that whether DWQ elects as a policy matter to issue a
permit for stormwater runoff, including stormwater runoff from the tankyard, at a
separate outfall under the stormwater permitting program, is a different question
than whether or not it can be legitimately permitted under a stormwater permit
within the bounds of the state and federal stormwater permitting programs. It is
clear that this stormwater runoff can be lawfully permitted under the provisions of
40 CFR 122.26 and 15A NCAC 2H .0126.
The threshold question for this analysis is whether there is a legal distinction
between stormwater runoff and industrial wastewater within the NPDES regulatory
scheme. The rule (40 CFR 122.26, which is adopted by reference at 15A NCAC 2H
.0126) regulates "storm water associated with industrial activity," which is
defined as "the discharge from any conveyance that is used for collecting and
conveying storm water and that is directly related to manufacturing, processing or
raw materials storage areas at an industrial plant . . . the term includes, but is
not limited to, storm water discharges from industrial plant yards; . . _ material
handling sites; refuse sites; sites used for the application or disposal of process
waste waters; . . . sites used for residual treatment, storage or disposal; . . .
storage areas (including tank farms) for raw materials, and intermediate and final
products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water." The foregoing
definition describes the water that might overflow out of the tanks in the tankyard
-- that water overflows in response to stormwater, the same as if waste or process
materials are washed off in stormwater flow by precipitation. The nature of storm
water that is regulated is that it is in contact with product or wastewater. if
the opposite were true, it would not be regulated. 1.
The assertion that the water in the tanks is "process" water that properly must go
through the treatment system leading to a permitted outfall is correct if the
overflow water would otherwise flow out of the tank and directly to waters of the
State unregulated -- it might be characterized as a bypass pursuant to 40 CFR
122.41 if the water was intentionally diverted from the tanks to a point of
discharge. Those are not the facts of this situation. There would not be an
intentional diversion. The overflow water (or its residue in the tankyard), under
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r
these facts, would be discharged through a separately permitted outfall. Thus, no s
bypass and no unpermitted discharge. Again, the policy question is separate from
the question of whether the discharge of runoff can be lawfully permitted, but,
presumably, such a policy would have to be coherent in the regulatory sense.
Regulated stormwater flows are those which are generated by precipitation and which
are anticipated to carry a pollutant load associated with industrial activity and
are channeled to discharge points into surface waters (there are treatment systems
which depend on stormwater flows to push water through the treatment -- i.e.,
settling ponds -- but this is a point source wastewater discharge like any other --
it is not referred to as "stormwater" because it is contained in a wastewater
treatment device, but, in a regulatory sense, it is indistinguishable). The
elements of NPDES-regulated discharges are (1) discharge (2) of pollutant (3)
through a point source (4) to waters of the U.S. If stormwater flow is not
channelized to a point source, it would not be subject to the NPDES permit
requirement for lack of a point source, irrespective of an association with
industrial activity or the presence of pollutants. If stormwater is channelized to
a point source but there is no association with an industrial activity (or a MS4),
it would generally not be regulated as point source discharge because the
regulatory element which would be missing would be pollutants (a case -by -case
determination can be made if a pollutant is added to stormwater runoff irrespective
of whether the runoff is associated with one of the industrial activities
identified by EPA at 40 CFR 122.26).
Overflows from tanks occur in direct response to precipitation events. Those
flows, or flows containing the residue which is left on the yard, may then be
collected, channelized, and discharged. The pollutants of concern are chloride and
BOD. If chloride were the sole pollutnat of concern it would not make regulatory
or technical sense to route those stormwater flows to a treatment plant which does
not remove chloride. The fact that there may be a BOD component to the stormwater
flow is of regulatory concern only if the BOD levels are markedly higher than BOD
levels of other sources of stormwater runoff from the plant facility. There is
virtually no stormwater that does not have a BOD component -- including stormwater
off a pristine field or forest. The issue is whether the BOD that is discharged is
going to be within permissible limits without further treatment. In this case, BOD
levels may be addressed by dilution from the stormflow -- again, indistinguishable
from any other stormwater.
Regulated stormwater is treated, in theory, exactly like "process wastewater" --
there is recognition that the pollutants in the stormwater are less concentrated
than in process wastewater and may not be easy to collect and treat, thus general
permits tend to be used more liberally, but it is not because stormwater discharges
are exempt from the NPDES process, or even distinguishable from the NPDES process.
Many state regulatory agencies divide the development and processing of permits for
"industrial wastewater" and "stormwater." That division is artificial. It is done
more for organizational and work allocation reasons, than for any reason relating
to the structure of the regulations. It is not one compelled by law or regulatory
logic.
EPA has apparently limited the DWQ's discretion with regard to determining a
technology -based effluent limit, although by reference to no rules, and apparently
driven only by "guidance." Since the issue at it is presented by the Dean facility
is presented in the context of a variance, its resolution calls for regulatory
creativity, if we expect to give any purpose and meaning to the variance. if the
limits under a variance continue to diminish, tracking the incremental improvements
that the permittee continues to find in waste reduction and pollution prevention,
notwithstanding the fact that it can be demonstrated that there have been no
improvements in treatment technology, the variance becomes merely a device for a
gradual wind -down, barring some technological breakthrough.
In fact, an approach which continues to ratchet limits downward with each
incremental improvement achieved by pollution prevention or waste reduction
provides a strong disincentive to make or explore any improvements. What it
accomplishes is to say to a discharger for whom no treatment technology exists, if
you make incremental improvements unrelated to treatment technology we will reduce
your limits proportionally. Attempts to realize effluent improvement by pollution
prevention and waste reduction become self-defeating because the ability to expand
2 of 3 2/25/2005 9:14 AM

inial):I/[e-mail],ii1.net:143/fete...
that the discharger might have tried to create is shut off, at best, but it is more
accurate to describe it as punishment for the discharger's creativity and
diligence, an odd twist on "polluter pays." The notion in the variance of
preventing economic harm becomes lost because the state effectively acts to ensure
that harm will occur, but only over time, and, ironically, in direct response to
the good faith efforts of the discharger. This cannot be what the General Assembly
intended in the language of 143-215.3(e).
Dean has suggested another means of potential relief to this paradox. If it could
reroute some of its stormwater flow through a separate outfall, the treatment
system would operate more efficiently (with more lower and more predictable flows)
and the mass of chloride going through the process and the treatment system (which
doesn't treat it in any event) would be less. There would be no change in total
mass of chloride delivered to the stream as a result of a separate stormwater
outfall because the treatment system does not remove chloride and it is well
documented that there is no treatment for chloride, so whether the chloride
transits through the treatment system should be irrelevant. The chloride in the
stormwater would continue to be discharged to the stream. The difference would be
that it would be delivered during a rainfall event, likely resulting in lower
concentrations in the stream at any particular time because of the dilution factor.
So, (1) no difference to the stream, except perhaps a positive one, (2) a more
efficient treatment system for the pollutants that the system actually is capable
of treating.
Permitting a separate stormwater outfall for all stormwater flows might remove some
additional increment of chloride through the wastewater treatment plant outfall,
which could be used to increase production with no additional effect on the stream.
In any event, it is a vehicle by which it could be assured that a certain component
of chloride would only be discharged to the stream during periods of higher
(precipitation driven) flow in the receiving water, which would likely have a
positive effect on the stream. It also decreases the peak flows through the
wastewater treatment system, which would generally allow for more consistent
performance of than system. On the whole, it appears to be a win -win. Monitoring
of the stream for chloride levels will continue as the best device for determining
the extent of the effect on the stream. If it indicates a negative trend, the
permit could be reassessed at that time.
I would be interested in your reactions and comments.
Craig A. Bromby
Hunton & Williams I.LP
P.O. Box 109
Raleigh, NC 27602
(o) 919.899.3032
(f) 919.899.3209
3 of 3 2125/2005 9:14 AM

imap:Hken.pickle%40dwq.denr. ncmai 1. [e-mail]. net:143/fete
Subject: [Fwd: Re: definition of industrial wastewater]
From: Ken Pohlig <[e-mail]>
Date: Fri, 14 Jan 2005 08:31:31 -0500
To: [e-mail], [e-mail]
FYI. Just wanted to make sure you've seen these e-mails.
By the way, my boss (Cecil Madden) said he remembers a project some years ago (really a sewer
collection project) associated with the Town of Robbins (in the Fayetteville Regional Office) where a
poultry processor was connected into the sewer collection system. Apparently because of some high
wash water flows (or maybe stormwater flows, not sure) from the poultry processor flowing into the
Town's sewer collection system, DWQ allowed the construction of a "special" sewer pump station,
where the pump station would pump the "first flush" to the WWTP, but the �radry
't know how
that was d fined � assed into some "stormwater disharge". Please talson of the
Fayetteville Regional Office for more information on this system, i you want to follow up on this.
I only mention this because Cecil says this is one example of where a "first flush" concept has been used
in permitting by our Division in the past.
Ken Pohlig
Construction Grants & Loans Section
715-6221
-------- Original Message--------
Subject:Re: definition of industrial wastewater
Date:Thu, 13 Jan 2005 16:50:25 -0500
From. -Bobby Blowe <[e-mail]>
Organization: Chief, Construction Grants and Loans Section
To:Ed Beck <[e-mail]>
CC:Dave Goodrich <[e-mail]>, coleen.sul tins @ ncmai 1. net, Rick Shiver
<[e-mail]>, Tom Reeder <[e-mail]>, Bradley Bennett
<[e-mail]>, Daniel Blaisdell <Daniel.B laisdell @ ncmail. net>, Cecil
Madden <[e-mail]>, Ken Pohlig <[e-mail]>
References: <[e-mail]> <[e-mail]>
<[e-mail]> <[e-mail]>
We are certainly not going to make that call and will bow out of the discussion until its resolved.
Ed Beck wrote:
All
Dave is right that the discussion yesterday at Dean should be considered to be brainstorming. I also
agree that we should proceed carefully with how we categorize the stormwater/wastewater sources on
site and what we approve them to do. I think we all became aware of details that were not evident
prior to the site visit. We shouldn't lose site of the intent of the project which was to line the existing
collection point to eliminate the impact to groundwater. The revelation that process wastewater can
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currently enter the basin, however, must now be considered as well as the degree to which we expect
them to collect stormwater from the tank area.
While Ken accepted the assignment to determine if the stormwater falling on the tank area is
stormwater or wastewater, I suggest that it is not that simple and needs to be considered by all of the
involved groups.
I am available for further discussion and consideration.
Ed Beck
Bobby Blowe wrote:
ATC review has been placed on hold pending the resolution of the NPDES / SW issues.
Dave Goodrich wrote:
Dean's has a variance from water quality standards for chloride. There are very few of these
issued statewide, and they are considered to be very serious situations with much review,
negotiation, and rancor by the Division, EPA, and the EMC (NPDES Committee). To say that
we need to proceed carefully would be understatement.
Dean's continues to try to minimize the escape of chloride from their site. Generally, they're
doing a good job and we have come to the point of fine tuning their chloride removal as opposed
to gross improvements. The initial improvements in chloride control were the result (primarily)
of the replacement of old wooden brining tanks with "leak proof' fiberglass tanks. There are
hundreds of these in the "tank yard". The tanks were periodically dumped out and sometimes
overflowed after high rainfall.
Recently, Dean's requested that we allow stormwater from the brineyards and some other areas,
such as parking lots and building roof drains, to be issued a general stormwater permit. We told
them that such permits were only issued for "de minimus" discharges, which such stormwater
could not be considered in this case, although I was admittedly focused on the stormwater from
the brineyard. Dawn, Ken, Mike Randall, and Ed visited with them yesterday to discuss a
different approach. They want to segregate the non -process stormwater from the parking lots,
etc. and discharge this stormwater directly to the stream. I believe everyone was in favor of this
part of the pro osal rovided that this is in fact benign stormwater runoff. However, they want
to know if they can route the stormwater that fills on the brineyard to a stormwater pond, which
is designed to overflow directly into the creek. Although I wouldn't rule this out without
additional information, it seems to me that it would be highly unlikely that we would want to
approve this part of the plan. It is too likely that chloride levels would be above the stream
standard of 230 mg/L. In addition, the discharge would also have to meet 5 mg/L of BOD5 since
it enters a zero -flow stream. David Schauer, Dean's corporate environmental manager, told the
Division that this discharge would never meet 5 mg/L of BOD5.
The meeting sounded like a bit of a brainstorming session at some point. Nothing wrong with
that -- but 1 wonder if we should be processing the ATC further until some final decisions are
made. It might be better to simply return it, although I realize that's no longer my call.
Another fact that came to light during the discussion was that the stormwater pond that
discharges (at times of high flow) directly into the stream could currently contain process
wastewater flow. As I understand it, this is because the existing piping mixes process
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imap://ken.pickle%40dwq.denr.nemai 1. net @ cros.nemail.net:143/fete.
wastewater with stormwater flow prior to water entering the pond. At the risk of sticking my
nose where it doesn't belong again - isn't this an illegal discharge and shouldn't we be putting a
stop to this? Ironically, not accounting for this additional chloride load (although it could be
quite small) may actually hurt the facility during the permitting process since their chloride limit
will be based on their past performance, which could be artifically lower than reported because
of this activity.
Ed may be able to correct and/or clarify some of this information since my understanding is
based on a hasty de -briefing from Dawn Jeffries who was going on vacation.
[e-mail] wrote:
hadn't heard anything. Coleen
-- Original Message --
Date: Wed, 12 Jan 2005 16:08:43 -0500
From: Bobby Blowe <[e-mail]>
To: Colcen Sullins <[e-mail]>
Subject: definition of industrial wastewater
Ken Pohlig just returned from what must have been a very interesting
meeting with the Dean Pickle folks, RO folks, SW folks, etc. (We have an
ATC request that Ken is working on) Apparently there was much discussion
on the definition of stormwater/process water,etc. and what to do with
it. We're only involved because of issues which may have to be resolved
before the ATC can issue, but you may be hearing more from the other
folks involved, if you haven't already.
Construction Grants & Loans Section
1633 Mail Service Center
Raleigh, NC 27699-1633
Phone: [phone]
Fax: [phone]
Cot-a.;?:ruc,t.:i.on Grans-:; Fi Lozins Section
1633 Mail Service Center
Raleigh, NC 27699-1.633
Phone: [phone]
Fax: (919) '715-6229
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