WQ0012662_Permit Renewal_20150319

i
Barber, Jim
From:, Barber, Jim
Sent: Thursday, March 19, 2015 5:48 PM
To: Doby, Troy
Subject: RE: Dunbar Foods Residuals Land Application Program - WQ0012662
Attachments: Dunbar residuals Class B WQ0012662.pdf; 006.JPG; 005.JPG
Troy;
Attached is the staff report and updated land application/buffer maps for the Dunbar Class B permit. As to your
questions posed, I'll try and answer the best I can:
1). The only parameters that are of concern or worth having are calcium, magnesium and sodium so the sodium
adsorption ratio can be calculated. The potato waste generated consists of peels, some potato meat and water (supplied
by the City of Dunn that is used in the pressure steam peeler). I don't recall the issue with dropping the parameters but
leaving in BIMS. JR Joshi may have forgotten to change BIMS when he did the permit renewal.
2). No biological waste or domestic waste is involved with the residuals generated by this facility. All domestic waste
from the offices and plant production areas goes to the City of Dunn wastewater treatment plant.
3). No fecal is correct. There will be a fecal requirement in the Class A permit to demonstrate Class A standards. Again,
the material consists of peels, potato meat and water. If any fecal matter is on the potatoes when they arrive at the
plant, it is washed off during the cleaning and screening process prior to the potatoes entering the pressure steam
peeler (see photo 006.jpg).
4). From conversations with Dunbar folks at my meetings and with Bob Branch, the intent is to proceed with the Class B
until a comfort level is reached that no fecal will pop up in sampling. Once Dunbar has several sampling events to work
from under the Class A permit they intend to rescind the Class B permit. I guess Dunbar started under the Class B permit
process in the past due to the fact that the residual waste is "raw product" and needs to be incorporated or injected to
keep from being a odor nuisance. I can only guess that Division personnel back in the 1980's or 1990's recommended
the Class B avenue to minimize sampling costs.
Sorry for the delay in getting this to you. Have been in and out of the office with weather, annual leave and sampling.
Unless you need another staff report or Jon wishes to have a staff report; please use the information in this email and
the Class B (WQ0012662) staff report to proceed on with the Class A permit (WQ0037574).
I will be out of the office tomorrow on leave. I will be out of the office Monday and Weds sampling.and out Tuesday for
a meeting in Anson County at Valley Protein. I should be in the office all day on Thursday and Friday next week if you
need to discuss any of this with me.
Thanks
Jim Barber
From: Doby, Troy
Sent: Tuesday, February 03, 2015 4:26 PM
To: Barber, Jim
Subject: Dunbar Foods Residuals Land Application Program - WQ0012662
Jim,
1

understand you've been talking to Bob Branch about this and much the same concerns as I expressed to him.
I'm attaching a draft permit and also a list of questions for you. Answers and comments always appreciated.
I'll have draft for the Class A residuals permit hopefully by tomorrow.
I'd also like to schedule a time when we can talk about the Carolina Lakes permit renewal while they close it out. (That is
yours as well, isn't it?)
Thanks!
Troy Doby, PhD, PE.
Non -Discharge Permitting Unit
Water Quality Permitting Section
1636 Mail Service Center
Raleigh, NC 27699-1636
919-807-6336
http://portal.ncdenr.org/webriwaaps/lau
2

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Date: 3/5/15 County: Harnett
To: Aquifer Protection Section Central Office Permittee:- Dunbar Foods Corp.
Central Office Reviewer: T. Doby Project Name: Dunbar Foods/Dewavne Weeks farm
Regional Login No: ?? Application No.: W00012662
I. GENERAL INFORMATION
1. This application is (check all that apply): ❑ New ® Renewal
❑ Minor Modification ❑ Major Modification
❑ Surface Irrigation ❑ Reuse ❑ Recycle ❑ High Rate Infiltration ❑ Evaporation/Infiltration Lagoon
® Land Application of Residuals ❑ Attachment B included ® 503 regulated El 503 exempt
❑ Distribution of Residuals ❑ Surface Disposal
❑ Closed -loop Groundwater Remediation ❑ Other Injection Wells (includingin situ remediation)
Was a site visit conducted in order to prepare this report? ® Yes or ❑ No. -
a. Date of site visit: 2/11 & 23/15
b. Person contacted and contact information: Carl Hite and Ron Austin
c. Site visit conducted by: Jim Barber and Tony Honeycutt
d. Inspection Report Attached: ❑ Yes or ® No.
Is the following information entered into the BIMS record for this application correct?
® Yes .or ❑ No. If no, please complete the following or indicate that it is correct on the current application.
For Treatment Facilities:
a. Location: Fayetteville Ave (P.O. Box 519) Dunn, NC 28335
b. Driving Directions: From Fayetteville take Hwy 301 North to Dunn. Turn left onto W. Duke St. and left
onto S. King Ave. Drive approximately 0.10 miles to the entrance gate.
c. USGS Quadrangle Map name and number: DUNN, NC (F-24-SE)
d. Latitude: 35.301007 Longitude: -78.617803 (steam pressure peeler and rotary screen)
e. Regulated Activities / Type of Wastes (e.g., subdivision, food processing, municipal wastewater): Pepper
and sweet potato processing and canning. Waste stream is sweet potato skin,some potato meat and water.
For Disposal and Injection Sites:
(If multiple sites either indicate which sites the information applies to, copy and paste a new section into the
document for each site, or attach additional pages for each site)
a. Location(s): Dorman Rd (fields 3- 1, 2, 3 & 4) and Hwy 82 (field 1-2)
b. Driving Directions: From the plant take - Chicken Farm Rd to Longbranch/Dorman road and turn right
toward Erwin onto Dorman. Fields 3-1,2,3 & 4 are on both sides of Dorman Rd. At the end of Dorman,
cross Middle Rd and onto Hwy 82. Drive approx. two miles and field 1-2 is on the left.
c. USGS Quadrangle Map name and number: ERWIN, NC (F-24-SW)
d. Latitude: 35.260047 Longitude: -78.669377 (approx. center of field 1-2)
e. Latitude: •35.293007 Longitude: -78.655974 (approx. center of field 3-1)
f. Latitude: 35.290987 Longitude: -78.649285 (approx. center of field 3-2)
g. Latitude: 35.292573 Longitude: -78.641851 (approx. center of field 3-3)
h. Latitude: 35.286514 Longitude: -78.652559 (approx. center of field 3-4)
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 1

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IL NEW AND MAJOR MODIFICATION APPLICATIONS (this section not needed for renewals or minor
modifications, skip to next section)
Description Of Waste(S) And Facilities
1. Please attach completed rating sheet. Facility Classification:'
2. Are the new treatment facilities adequate for the type of waste arid disposal system?
❑ Yes ❑ No ❑ N/A. If no, please explain:
3. Are the new site conditions (soils, topography, depth to water table, etc) consistent with what was reported by
the soil scientist and/or Professional Engineer? ❑ Yes ❑ No ❑ N/A. If no, please explain:
4. Does the application (maps, plans, etc.) represent the actual site (property lines, wells, surface drainage)? ❑
Yes ❑ No ❑ N/A. If no, please explain:
5. Is the proposed residuals management plan adequate and/or acceptable to the Division. ❑ Yes El No ❑
N/A. If no, please explain:
6. Are the proposed application rates for new sites (hydraulic or nutrient) acceptable?
❑ Yes ❑ No ❑ N/A. If no, please explain:
7. Are the new treatment facilities or any new disposal sites located in.a,100-year floodplain?
❑ Yes ❑ No ❑ N/A. If yes, please attach a map showing areas of 100-year floodplain and please. explain
and recommend any mitigative measures/special conditions in Part IV:
8: Are there any buffer conflicts (new treatment facilities or new disposal sites)? ❑ .Yes or ❑ No. If yes, please
attach a map showing conflict areas or attach any new maps you have received from the applicant to be
incorporated into the permit: .
9. Is proposed and/or existing groundwater monitoring program (number of wells, frequency of monitoring,
monitoring parameters, etc.) adequate? . ❑ Yes ❑ No ❑ N/A. Attach map of existing monitoring well
network if applicable. Indicate the review and compliance boundaries. If No, explain and recommend any
changes to the groundwater monitoring program: s
. 10. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
III. RENEWAL AND MODIFICATION APPLICATIONS (use previous section for new or major modification
systems)
Description Of Waste(S) And Facilities
1. Are there appropriately certified ORCs for the facilities? ® Yes or ❑ No.
Operator in Charge: Carl Hite Certificate #:LA/17586
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 2

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Backup- Operator in Charge: Grady Dobson & Kathryn Nixa Certificate #:LA/27655 and LA/998720
2. Is the design, maintenance and operation (e.g. adequate aeration, sludge wasting, sludge storage, effluent
storage, etc) of the treatment facilities adequate for the type of waste and disposal system? ® Yes or ❑ No.
If no, please explain: ' -
3. Are the site conditions (soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No. If no, please explain:
4. Has the site changed in any way that may affect permit, (drainage added, new wells inside the compliance
boundary, new development, etc.)? If yes, please explain: NO
5. Is the residuals management plan for the facility adequate and/or acceptable to the Division?
® Yes or ❑ No. If no, please explain:
6. Are the existing application rates (hydraulic or nutrient) still acceptable? ® Yes or ❑ No. If no, please
explain:
7. Is the existing groundwater monitoring program (number of wells, frequency of monitoring, monitoring
parameters, etc.) adequate? ❑ Yes n No -® N/A. Attach map of existing monitoring well network if
applicable. Indicate the review and compliance boundaries. If No, explain and recommend any changes to the
groundwater monitoring program:
8. Will seasonal 'or other restrictions be required for added sites? ❑ Yes ® No ❑ N/A If yes, attach list of sites
with restrictions (Certification B?)
9. Are there any buffer conflicts (treatment facilities or disposal sites)? ❑ Yes or ® No. If yes, please attach a
map showing conflict areas or attach any new maps you have received from the applicant to be incorporated
into the permit: The area around the land application fields has not changed since the last permit renewal in
2006. No new homes have been constructed in the area. The only change to the field acreages is due to better
mapping of the existing fields by Bob Branch and removing areas of fields that are impractical for land
application and haven't been utilized.
10. Is the description of the facilities, type and/or volume of waste(s) as written in the existing permit correct?
Yes or n No. If no, please explain:
11. Were monitoring wells properly constructed and located? ® Yes or ❑ No ® N/A. If no, please explain:
12. Has a review of all self -monitoring data been conducted (GW, NDMR, and NDAR as applicable)? Z Yes or
❑ No n N/A. Please summarize any findings resulting from this review: Last three residuals annual reports
reviewed. The facility land applied 404 DT's in 2012, 276 DT's in 2013 and 271 DT's in 2014.
13. Check all that apply: ® No compliance issues; ❑ Notice(s) of violation within the last permit cycle; ❑
Current enforcement action(s) ❑ Currently under SOC; ❑ Currently under JOC; ❑ Currently under
moratorium. If any items checked, please explain and attach any documents that may help clarify
answer/comments (such as NOV, NOD etc):
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 3

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
14. Have all compliance dates/conditions in the existing permit, (SOC, JOC, etc.) been complied with? El Yes
. No E Not Determined [E] N/A.. If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes or IZ No EI N/A. Ifyes, please explain:
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 4

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
IV INJECTION WELL PERMIT APPLICATIONS (Complete these two sections for all systems that use injection
wells, including closed -loop groundwater remediation effluent injection wells, in situ remediation injection wells, and heat
pump injection wells.)
Description Of Well(S) And Facilities — New, Renewal, And Modification
1. Type ofinjection system:
❑ Heating/cooling water return flow (5A7)
❑ Closed -loop heat pump system (5QM/5QW)
❑ In situ remediation (5I)
❑ Closed -loop groundwater remediation effluent injection (5L/"Non-Discharge")
❑ Other (Specify: )
2. Does system use same well for water source and injection? ❑ Yes ❑ No
3. Are there any potential pollution sources that may affect injection? ❑ Yes ❑ No
What is/are the pollution source(s)? What is the distance of the injection well(s) from the pollution
source(s)? ft.
4. What is the minimum distance of proposed injection wells from the property boundary? ft.
5. Quality of drainage at site: ❑ Good ❑ Adequate ❑ Poor
6. Flooding potential of site:. ❑ Low ❑ Moderate ❑ High
7. For groundwater remediation systems, is the proposed and/or existing groundwater monitoring program
(number of wells, frequency of monitoring, monitoring parameters, etc.) adequate? ❑ Yes ❑ No. Attach
map of existing monitoring well network if applicable. If No, explain and recommend any changes to the
groundwater monitoring program:
Does the map presented represent the actual site (property lines, wells, surface drainage)? ❑ Yes or ❑ No. If
no or no map, please attach a sketch of the site. Show property boundaries, buildings, wells, potential pollution
sources, roads, approximate scale, and north arrow.
Injection Well Permit Renewal And Modification Only:
1. For heat pump systems, are there any abnormalities in heat pump or injection well operation (e.g. turbid water,
failure to assimilate injected fluid, poor heating/cooling)? -
❑ Yes ❑ No. If yes, explain:
2. For closed -loop heat pump systems, has system lost pressure or required make-up fluid since permit issuance
or last inspection?-0 Yes ❑ No. If yes, explain:
For renewal or modification of groundwater remediation permits (of any type), will
continued/additional/modified injections have an adverse impact on migration of the plume or management of
the contamination incident? ❑ Yes ❑ No. ,If yes, explain:
4. Drilling contractor: Name:
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 5

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Address:
Certification number:
5. Complete and attach Well Construction Data Sheet..
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 6

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
V. EVAL UATIONAND RECOMMENDATIONS
1. Provide any additional narrative regarding your review of the application.:
2. Attach Well Construction Data Sheet - if needed information is available
3. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes ® No. If yes, please explain
briefly.
4. List any items that you would like APS Central Office to obtain through an additional information request.
Make sure that you provide a reason for each item:
Item
Reason
5. List specific Permit conditions that you recommend to be removed from the permit when issued. Make sure
that you provide a reason for each condition:
Condition
Reason
6. List specific special conditions or compliance schedules that you recommend to be included in the permit when
issued. Make sure that you provide a.reason for each special condition:
Condition
Reason -
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office; ❑ Hold,
pending review of draft permit by regional office; ❑ Issue upon receipt of needed additional information; E
Issue; ❑ Deny. If deny, please state reasons:
8. Signature of report preparer(s):
Signature of APional supervisor:
Date: //j/
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Application rates and site recommendations by Bob Branchin report dated January 2015 are adequate and
consistent with State and Federal rules and guidelines.
FORM: APSARR.Dunbar Foods WQ0012662 Feb 2015.doc
7

AQUIFER PROTECTION SECTION REGIONAL STAFF REPORT
Based on the last two reporting years (2013 & 2014); Dunbar has applied an average of 273 DT's of sweet
potato residuals. The facility is certified for 1500 DT's per year and at current market demand will probably be
under 300 DT's for the foreseeable future. Dunbar is also requesting a Class A permit to market the sweet
potato residual to cattle farmers in the area and also intend to approach other outlets (i.e. Storms Farm in
Bladen County and Butler Farms in Harnett County that both have anaerobic disgesters) about taking material
when row crop fields aren't available.
The certifiedacreage for the next five year permit window is being reduced from 835.70 acres to 492.60 acres.
The acreage available is more than sufficient to manage the residuals being generated are the current production
rate. Average application would be approximately 0.50 DT's/acre if all available acreage is utlized. Realistically
the application rate when using one or two fields annually is around 3 to 5 DT's/acre. Based on the PAN in the
sweet potato residual, the application rate of PAN is typically around 20 to 50 lbs/acre.
Attached with the staff report are revised field application/buffer maps that where received in the Fayetteville
Regional office on 20 February 2015. Two sets are being forwarded to central office so one set can be placed
with the permit to Dunbar and one set for the permit placeded in central file.
The Fayetteville regional office concurs with the predominant soil types identified by Bob Branch for the fields
that remain in the land application program. All fields are row crop fields in a typical corn/wheat/soybean
rotation with no grazing of cattle at this time. Realistic Yield Expectation .(RYE) rates will not be a problem for
the facility based on the available land and Dunbar's own efforts to find other outlets (cattle feed and anaerobic
disgesters for generating methane for power generation) under the Class A permit.
FORM: APSARR Dunbar Foods WQ0012662 Feb 2015.doc 8

r. I The Compliance Boundary is either 250 feet from the residuals land application
area or 50 feet within the property line, whichever is closest. The Review
Boundary is midway between the Compliance Boundary and the perimeter
of the residuals application area.
All locations are approximate and are not survey data.
Data provided by:
USDA National Agricultural Imagery Program
and Harnett County NC GIS
Dunbar Foods Corporation
Land Application Program
DeWayne Weeks Fann

Fields
Surface Wate
Wetland
The Compliance Boundary is either 250 feet from the residuals land application
area or 50 feet within the property line, whichever is closest. The Review
Botmdary is midway between the Compliance Boundary and the perimeter
of the residuals application area.
All locations are approximate and are not survey data.
Data provided by:
USDA National Agricultural Imagery Program
and Harnett County NC GIS
Dunbar Foods Corporation
Land Application Program
DeWayne Weeks Farm

`Division of Water Resources '
State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
January 29, 2015
To: FRO-WQROS: Belinda Henson
From: Troy Doby, Water Quality Permitting Section - Non -Discharge Permitting Unit
RECEIVED/DENRJDWR
Water Quality Regional
FEB 02 2015
Operations Section
Fayetteville Regional Office
Permit Number: WQ0012662 Permit Type: Land Application of Residual Solids (503 Exempt)
Applicant: Dunbar Foods Corporation Project Type: Renewal
Owner Type: Organization Ownerin BIMS? Yes
Facility Name: Dunbar Foods RLAP Facility in BIMS? Yes
Fee Category: None
Comments/Other Information:
Fee Amount: $0
Attached, you will find all information submitted in support of the above -referenced application -for your review,
comment, and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed.
❑ Attach a classification rating sheet.
❑ Attach an Attachment B for Certification.
El Return a completed staff report.
❑ Attach a Well Construction Data Sheet.
❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: J / d/4'/Ziii7 Date: /_,
Page 1 of 1

DIVISION OF WATER RESOURCES
Water Quality Regional Operations Section - Central Office
Regional Office Interoffice Mail Routing Cover Sheet
Date: 6 I fG& 20 IS
To: • ❑ ARO- WQROS
❑ Landon Davidson
FRO- WQROS
❑ Belinda Henson
From:
❑ MRO- WQRC
❑ Michael P+
❑. RRO- WQR
RECE VED!DE RIDWR
Water Ot aHiy Regional
FEB 2 0 2015
O,.era lens Section
Fayetteville Regional Office -
❑ ❑ Other
Other
❑ Danny Sni
❑ WaRO- WQR
❑ David Mai
❑ WiRO- WQR(
❑ Jim Gregsi
❑ WSRO- WQR
❑ Corey Bas'
For your n Rev
Please Respond
receipt
Comments:
(90 i-3- " -(g .1 prac6c.
0 /1301 L. A ,
IZC l�-L l E L1 /75
CnA,6i7 DV95./. 674, 76.--5---C-
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WQROS Regional Office Interoffice Mail Routing Cover Ver. 07/2014

Dunbar Foods Corporation
P.O. Box 519 - Dunn, NC 28335 Phone [phone] Fax [phone]
NC DENR 2/6/15
To Whom It May Concern,
It has come to my attention that our company, Dunbar Foods
Corporation, sent maps in for our Land Application Permit
Renewal, and' may not have had the buffers and boundaries clearly
defined. We have corrected the maps and I have -included 3 sets
of updated maps. If any other questions or concerns arise please
do not hesitate to contact me.
Thank you,
Michael Mulier
Agricultural Representative
Dunbar Foods
910-892-3175
[e-mail]
REcEIVEDIDENRIDWR
FEB 11 2015
Water Quali
Permitting Section

Permit Number WQ0012662
Central Files: APS _ SWP _
1/29/2015
Permit Tracking Slip
Program Category
Non -discharge
Permit Type
Land Application of Residual Solids (503 Exempt)
Primary Reviewer
troy.doby
Coastal SWRuIe
Permitted Flow
Facility
Status
In review
Version
B
Project Type
Renewal
Permit Classification
Individual
Permit Contact Affiliation
Robert T. Branch
LSS
311 B S Westgate Dr
Greensboro
NC 27407163C
Facility Name
Dunbar Foods Residuals Land Application Program
Location Address
PO Box 519
Dunn
Owner
NC 28334
Major/Minor
Major
Facility Contact Affiliation
Region
Fayetteville
County
Hamett
Owner Name
Dunbar Foods Corporation
Dates/Events
Owner Type
Non -Government
Owner Affiliation
Ron Austin
Manager Plant
PO Box 519
Dunn
NC 28334
Orig Issue
6/1/1996
App Received
1/27/2015
Regulated Activities
Draft Initiated
Scheduled
Issuance
Vegetable & fruit processing
Outfail
Public Notice Issue
Requested /Received Events
Effective -
Expiration
RO staff report received
RO staff report requested
Additional information requested
Additional information received
Waterbody Name
Streanilndex Number Current Class . Subbasin

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
. Governor
January, 29, 2015
Ron Austin — Plant Manager
Dunbar Foods Corporation
PO Box 519
Dunn, NC 28335
Dear Mr. Austin:
Donald R. van der Vaart
Secretary
Subject: Acknowledgement of
Application No. WQ0012662
Dunbar Foods Residuals Land
Application Program
Residuals Management System
Harnett County
The Water Quality . Permitting Section acknowledges receipt of your permit application and
supporting documentation received on January 27, 2015. Your application package has been assigned the
number listed above, and the primary reviewer is Troy Doby.
Central and Regional Office staff will perform a detailed review of the provided application; and
may contact you with a request for additional information. To ensure maximum efficiency in processing
permit applications, the Division of Water Resources requests your assistance in providing a timely and
complete response to any additional information requests.
Please note that processing standard review permit applications may take as long as 60 to 90 days
after receipt of a complete application. If you have any questions, . please contact
Troy Doby at [phone] or [e-mail].
Sincerely,
GY4
cD Jon Risgaard, Supervisor
Division of Water Resources
cc: Fayetteville Regional Office, Water Quality Regional Operations Section
Robert T Branch — 8646 West market Street - Suite 111; Greensboro NC 27409
([e-mail])
Permit File WQ0012662
Non -Discharge Permitting Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] Internet: http:llportai.ncdenr.orglwebhvq
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