WQ0004268_NOV-2007-PC-0397_20070808

W A i Michael F. Easley, Governor
9 • - William:G. Ross Jr., Secretary
Q North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
sU Division of Water Quality
August 8, 2007
Laura J. Mushinski — Director Of, Environmental Quality
Allen Canning Company
305 EastMain
Siloam.;Springs, AR. 72761
Subject: NOTICE OF VIOLATION: NOV-2007-PC-0397 - Resolved
Permit # WQ0004268: Allen Canning Company Surface Irrigation Permit
Sampson County -
Dear Ms. Mushinski: '
After reviewing the information Allen Canning Company supplied in a letter dated 17 June 2007, the
Notice of Violation (NOV) dated 5 June 2007 has been resolved and the compliance issue is closed.
The Division of Water Quality (DWQ) appreciates your prompt response concerning this matter and
providing a remedy to the violation(s) to avoid future compliance issues.
DWQ would like to take this time to remind Allen Canning Company to be vigilant managing their
seasonal fields (D-fields), due to the amount of spray irrigation wastewater Allen Canning Company
must manage on a daily basis
If you have any questionsconcerning this matter, please do riot hesitate to contact either Joel S.
Shields at (910-433-3332) or myself at (910- 433-3336).
Sincerely,
Stephe :. ` hardt,
Regiona quifer Protection Supervisor
cc:
afge
APS Central Office File/Ed Hardee-
APS FRO File: Allen Canning Company #WQ0004268
NorthCaro�
Nattily
N.C. Division of Water Quality/Aquifer Protection Section 225 Green St) Suite 714 Fayetieville, NC 28301 Phone (910)'433-3300
FAX .[phone] Internet: h2o.enr.state.nc.us Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10%,Post Consumer Paper.

JUN 21 2007
DENR - FAYETTEVILLE REGIONAL OFFICE
June 17, 2007
Stephen Barnhardt, L.G.
Regional Aquifer Protection Supervisor
North Carolina Dept of Environment & Natural Resources
225,Green Street, Suite 714
Fayetteville, NC 28301
RE: Notice of Violation NOV-2007-PC-0397
Permit No. WQ0004268
Dear Mr. Barnhardt:
Aliens, Inc. (Aliens) is in receipt of the Notice of Violation dated June 5, 2007 regarding the
April 2007 exceedance of the 12-month floating total for a portion of the company's spray
irrigation system (fields D-6, D-8, and D-9). This letter is intended to satisfy the request to
provide information on actions that have been taken to minimise the potential for a reoccurrence.
Aliens has been working through an issue with DENR on freeboard in the wastewater pond that
resulted due to a misunderstanding on whether the freeboard could be measured from the top of
the modified berm or needed to be measured from the original berm height. Consistent with the
agreed upon resolution of that issue, Aliens has been irrigating as much wastewater as possible
to increase the freeboard in the wastewater pond. The cumulative impact of this effort is 12-
month floating totals are running higher than typical, particularly on the seasonal irrigation
fields. The facility staff continued to use the normal irrigation cycle during the month of April;
but the earlier irrigation applications made the 12-month floating totals higher than typical. As a
result, there was a slight exceedance during April 2007 on three fields.
It is important to note that Aliens contacted DENR as soon as this exceedance was identified, as
indicated by the permit. It is also important to note that the field conditions were good during
the month of April and prior to this, and that the slight exceedance did not have any apparent
impacts on the viability of the. spray irrigation cover crop or on soil conditions. The total amount
of wastewater that was over on these three fields could have been redistributed amongst other
irrigation fields and met the 12-month floating totals for each individual field. (In other words,
the total amount spray irrigated was within the irrigation system capacity, but it was just slightly
out of balance on these three fields.) The May 200712-month floating totals are in compliance_
with the permit limitations for every field.
- General Offices -
305 East Main, P.O. Box 250, Siloam Springs, Arkansas 72761 * Tel: [phone] * Fax: [phone]

Several adjustments have been made in Allens recordkeeping and irrigation field management to
minimize the potential for a reoccurrence, led by Reid Wells. A record of 12-month floating
totals is calculated each month. During the course of the month, on a weekly basis, the
additional irrigation is added to the 12-month floating totals to compare to the limits. If
necessary, applications are reduced during the month to meet the 12-month floating totals.
In addition to these efforts to meet the limitations with the current irrigation system, Aliens has
also been working with the consultants who conducted the hydrogeologic study on Rowan Road
property. Based on the most recent discussions, it seems that the modeling conducted did not
take into account the evapotranspiration that occurs during spray irrigation. The consultant has
agreed to reconsider this approach and Allens is hopeful that the modified approach will make
the Rowan Road property a viable option for spray irrigation.
Please let us know if you have any questions regarding the exceedance or the actions that Aliens
has taken to minimise the potential for reoccurrence. I can be reached at [phone] or
lmushinski@allencanning com. Thank you.
Sincerely,
Director — Environmental Quality
cc: Mr. Joel Shields, DENR
Mr. Tommy Langston, Aliens — Turkey
Mr. Reid Wells, Aliens — Turkey
Mr. Earl Wells, Aliens
Ms. Kathryn Yeager, Allens

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department' of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 5, 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Laura J. Mushinski — Director Of Environmental Quality
Allen Canning Company
305 East Main -
Siloam Springs, AR 72761
Subject: NOTICE OF VIOLATION
NOV-2007-PC-0397
'Permit No. WQ0004268
Allen Canning Company
Sampson County
Dear: Ms. Mushinski:
You are hereby notified .that, having been issued a permit for wastewater disposal for the subject
facility, documentation,of violation of your permit conditions was provided to the Division of Water
Quality.
Violation I: Failure to meet Operations & Maintenance Requirements within Section II (7) (8).
During the month of April 2007, Allen Canning exceeded the perrilit required 12 month floating total
on fields D-6, D-8, & D9.
Required Corrective action. for Violation
Closely monitor spray irrigation activities and report immediately any furtherover applications or.
other reportable conditions as specified by the permit. ,
The Division of Water Quality acknowledges that Reid Wells, ORC for Allen Canning reported the
over application in -4 timely manner as required by the permit. and has been working with our
departMenttoresolve other issues.
N°oTthCarolina '
Naturally
" N.C. Division of Water Quality/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, NC 28301
Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer —50% Recycled/10% Post Consumer Paper

Page 2
Laura Mashinski
June 5, 2007
The Division of Water Quality requests that, in addition to the specified corrective action above,
please submit the following items on or before June 18, 2007:
1. Please include a list of the steps that will be taken to prevent this violation from occurring in the
future.
If over application(s) continue the Division of Water Quality will likely request that Allen Canning
modify the system design to match the wastewater needs of the facility and obtain the appropriate
permits.
Please be advised that this notice does . not prevent the Division' of Water Quality from taking
enforcement actions for this violation or any past or future violation. Furthermore, the Division of
Water Quality has the authority to levy a civil penalty of not more than $25,000.00 per day per
violation.
If you have any questions concerning this matter, please do not hesitate to contact either Joel Shields
(910-433-3332) or myself at (910- 433-3336).
Step Barnharat, .
Regi. Aquifer Protection Supervisor
cc: APS Central Office File

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ALLEN CANNING COMPANY
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305 EAST MAIN
SILOAM SPRINGS, AR 72761
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