HomeMy WebLinkAboutWQ0004268_Meeting Notes_20151202MEETING SUBJECT: Sager Creek
LOCATION:
DATE&TIME:
Attendees
MEETING ATTENDEES LIST
6th Floor Conference Room/FRO
December 2, 2015 (Wednesday) @ 10:00 am
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DEL MONTE FOODS
Allen L Mize
Director Agriculture
and Technical Services
Vegetable Operations
451 Willis Ave
Rochelle, IL 61068
815-562-1303
412-320-7193 efax
830-591-6307 cell
830-278-7562 home
Allen.Mize@delmonte.com
0 Del Monte Foods, Inc.
David Vogl, P.E. • 600 North 15th Street
Regional Environmental Manager Rochelle, IL 61068-1002
815-562-1367 P
815-761-1057 C
david.vogl@delmonte.com
Cultivating Good Food for a Better Life"m
Barber, Jim
From: Barber, Jim.
Sentc Wednesday,! December 02, 2015 4:09 PM
-To: 'allen.mize@delmonte.com'
Cc: Henson, Belinda (belihda.henson@ncdenr.gov); Honeycutt, Tony,.
Subject: Meeting information:
Attachments: 2015'Agronmist report and recommendations Sager Creek.Sampson.pdf, Lundy 14 Fert
rates 2012.pdf
Allen;
Attached is the last agronomist evaluation report provided to the Division during out site visit earlier this year. The
scanned document hasseveral highlighted areas that provide recommendations to Sager Creek concerning the addition
of amendments for soil and crop health: Also there is a-recom..me..ndation.concern.ing reseeding (o.rs riggin if preferred)
if bermuda.grass in bare. areas (specific fields not identified, but it appears as a wholesale.recommendation.for the -site). -
- A's Sager. Creek. operates the waste management system, an.operational record and maintenance record needs to be..
maintainedto document activities undertaken. at the facility. The agronomist recommendations in the' attached report,.
if followed and performed, should be noted in the operation record for inspection by DWR staff during an inspection. An
example of.the information placed in the operational record is below:
date or dates of activities
amounts of amendments applied -(consistent with the recommendation, to; include .lime addition when needed)
labeling information of amendments applied
applies jSager Creek, farmer,:Crop Production Services,.etc: = see.attached CPS report for Lundy.1-8)'
monitoring. wells sampled, along'with effluent sampled. by lab/Sager Creek/third party contractor
contacting farmer for hay removal -
Maintenance records should note activities related to wastewater equipment used by Sager Creek. Examples of noted
activities are -replacing spray heads/risers is specific fields,'calibration data for solid set fields and hard. hose -traveling
.
guns (a,t least once per permit cycle of five years), aeration of fields, reseeding/sprigging of bermuda in fields/zones, etc.
Here are the contacts for the Divisiomof Waste Management— Solid Waste Sectioh,.for perm itting-information
concerning -land applying vegetable pieces:
http://"portal.ncdenr.ore/c/document library/get .file?uuid=ec8a7812-8d7d-4856-8d53-c496OfO98ad9&groupld=383'61
The main contact is Tony Gallagher, -branch supervisor, at 919-707-8280 or tony.gallagher@ncdenr.gov.
As discussed .during out -site visit -of the plant back in. November;: here is the information concerning tax.certification for
equipment:used exclusively (100%) fo.r. recycling activities related to managing vegetable.pieces, metal and
paper/cardboard recycling:
http://Portai.ncdent.org/web/wm`/sw/takcert
' r
If you have air quality permits for equipment at the plant; here is the link for.tax certification with the Division of -Air
Qu.ality(httb:i/d6g.statL.nc.us/contact ). It appears that you .need to contact the regional office concerning the Air
Quality tax certification process. The regional office supervisor to contact is -Steve Vozzo at 910-433-3361 or
steven.vozzo@ncdenr.gov.
The wastewater infrastructure. also can. receive tax certification thru the Division of Water Resources for equipment used
exclusively for.wastewater management. Here's the link to DWIt (http:%/portal.ncdenr._ore/web/wq/swp/ps/npdes/tax-
certification ):
Here are a.couple more useful links we:discussed during the meeting this morning:
https://sampson.ces..ncsu.edu/ (NC State ag. extension). .
http://www.ncagr.gov/agronorhi/`uvrwaste.hten (waste analysis; vegetable pieces)
http //www.ncagr.aov/agronomi/rah6me.htm;(NCDA regional agronomist list) . .
As you reviewthe provided information; if you have any questions or wish.to discuss; please call the 910-433-3340 or
email me.
Thanks
Jim. Barber.
Environmental Engineer
NCDENR=DWR-APS
Fayetteville *Reg ional.Office
910-433-3340 voice
916 486-0707 fax
jim.barber(a)_ncdenr.gov -
E-mail correspondence to and from this address may be subject to the North Carolina -Public Records Law and
may be disclosed to third. parties..
Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible.
SAGER CREEK VEGETABLE COMPANY, TURKEY, NC
PROCESS WATER SYSTEMS CORRECTIVE ACTION PLANNING MEETING
NC DEPARTMENT OF ENVIRONMENTAL QUALITY
FAYETEVILLE/RALEIGH, NC
December 2, 2015
Meeting Purpose
The purpose of this meeting is to review and discuss the existing factory process water systems,
discharge permit, and known irrigation management system limitations for crafting a Special
Order by Consent ("SOC") to bring the system back into full compliance with lagoon freeboard
requirements on a year-round basis as well as into" compliance with all operations and
maintenance requirements in the facility's discharge permit (including but not limited to
maintaining site fields in a state where ponding and runoff is not a day-to-day concern particularly
during the late fall and winter season months).
Corrective Action and
Implementation Plan Goals
We seek the regulatory flexibility and time to complete a comprehensive corrective action and
implementation plan for our newly acquired factory by December 31, 2016. The plan will define
current site limitations, identify short as well as longer term corrective action needs, and include
a schedule for fully implementing the required corrective actions as soon as it is technically and
fiscally feasible. The corrective action plan may include different processing of crops, reduced
plant production, modified or new storage ponds, new spray irrigation fields, changes to factory
manufacturing practices, in -plant water flow reductions, or some combination of all of these
actions to bring systems back into hydraulic balance moving into future years. The schedule
provided in the implementation plan will be structured to allow our factory to properly budget,
design, and implement any new systems without interrupting on -going plant production required
to sustain our business during the implementation phases of the project.
A. INTRODUCTIONS
B. QUICK REVIEW OF SITE TREATMENT AND MANAGEMENT SYSTEMS
(REFRESHER FOR THOSE NOT FAMILIAR WITH THE SITE)
1) Vegetable Processing Factory (current factory packing include green beans, sweet
potatoes, russet potatoes, various other greens, and dry beans)
2) Permitted Daily Flow = 415,000 GPD (Monthly Average)
3) Process Water Treatment (in sequence):
• Screening (with off -site management of screenings as cattle feed at two farms)
• Anaerobic/Primary Settling Pond (-3-acres and listed working capacity 50 MG)
• Treated Water Storage Pond (-27-acres)*
• Spray Fields Zones 1-18a (66.76-acres) plus A-D (100.30-acres) = 167.07-irrigable
acres
4) Process Water Flow Monitoring Stations (Discharges Metered to Upper
Anaerobic/Primary Settling Lagoon and to Spray Fields)",***
5) Groundwater Monitoring Wells (13 Monitoring Wells)
Sager Creek/NCDEQ Meeting Agenda
Page 2 of 6
6) Maximum Annual Hydraulic Application Rates by Field (Various by Field = 9.26 — 65.62
inches)
7) Maximum Annual Plant Available Nitrogen Summer (Various by Field = 200-300 lbs.
N/ac)
8) Maximum Annual Plant Available Nitrogen Winter (All Fields = 50 lbs. N/ac)
This lagoon may actually cover more than 27-acres based on our recent review of the pond
layout but this needs to be verified through an on -site survey. Further, current lagoon
depths need to be factored for planning purposes.
**Flow meter at lift station in rear of factory and at new pump station at lower water storage
pond.
***Plant sanitary wastewater flows to the plant lagoons are currently not being metered and
screened wastewater being returned to the plant for gutter flushing is not being metered
(return flows to the plant are now being estimated at—100,000 GPD and this estimated flow
is now being subtracted from the flows being metered at the factory lift station for reporting
on the factory monthly DMR)
"Permit does not define winter.
CAN WE EXPECT MORE RESTRICTIVE OR ANY DIFFERENT REQUIREMENTS IN A RENEWED
WASTEWATER IRRIGATION SYSTEM PERMIT (WHICH IS PENDING RENEWAL)?
C. COMPLIANCE UPDATE
1) Current Operations Lagoon Levels*
2) Daily Process Wastewater Discharges
3) Current Site Field Conditions
• Rye grass (surface disked and broadcast seeded) into Bermuda Grass this Fall per
Tony Honeycutt's instructions (this seeding technique will be followed moving
forward to ensure best winter cover)
• It is very difficult to drill seed at the site due to the scattered nature of the site solid
sets (the solid sets do not line-up in neat square blocks for easy maneuvering of
tractors and farm implements)
• Fields fall planted Oct. 11— 26
• Much improved/better rye grass cover this year (this is probably due to the
improved planting technique recommended by Tony Honeycutt)
• Height of rye grass currently at > 2-inches
• Annual Agronomist review of site conditions will take place next spring (Jan. — Mar.
2016) and we plan to implement any recommendations provided in the review in
2016 (this annual review is a permit requirement)
4) Existing site groundwater quality and nitrogen and organic loadings at the site do not
appear to be limiting at this time (this will be analyzed in further depth as part of the
proposed facility corrective action plan)
*Freeboard in the site settling and storage ponds cannot be less than two feet at any time. Be
aware that compliance with freeboard in the large treated water storage pond cannot be less
Sager Creek/NCDEQ Meeting Agenda
Page 3 of 6
than two feet from the top of the pond before its banks were raised to protect the pond from
the nearby stream overtopping its banks in a major flooding event.
D. FACTORY WATER SAVINGS ACTIVITIES COMPLETED TO DATE AND OTHER WATER SAVINGS
CONSIDERATIONS IN PROCESS (OPEN TO ANY NCDEQ IDEAS AND INPUT)
1) Leak Repairs, Reducers, and Float Valves (Short List of Projects Completed in November
2015)*
Project Description
Projected Water Savings
--GPD--
Flume Repairs
18,000
Replace Cooking Canal Packing (North and West Factory Canals)
24,000
Repair Leak on Municipal Water Line Entering Plant
600
Install Water Reducers (Various Systems)
42,000
Wash Reel Water Repairs
6,000
New Float Valves on Various Tanks
63,000
TOTAL ESTIMATED DAILY WATER SAVINGS
153,600
'Note that more costly and technically involved water savings opportunities have been
identified such as modifications/ changes to the factory recirculating cooling tower,
collection/reuse of the Malo cookers cushioning waters, changes to the factory can washers,
use of more lowflow misting nozzles throughout the factory, use of solenoids on various
systems to shut-off fresh water flows when production stops, etc.
2) New SOPs, Employee Training, and Checklists in Process to Ensure Proper Operation of
Equipment to Conserve Water (Short List of Focus Areas Provided Below)
• Daily checks and repairs as needed to assure Malo cooker canals, reservoirs, product
dump tanks, and water return tanks are in good repair and flow controls are correct
• Daily checks on blanchers to assure shells are not cracked and water controls are
functioning correctly
• Daily checks to assure pressure and paddle washers on all lines are functioning
correctly on flow control
• Dry clean-up of all factory areas (before hose wash -down) where possible
• Check and shut -down all running and leaking hoses (in process of equipping all hoses
with spring -loaded shutoff nozzles)
3) Development of Plant Environmental Sustainability Management Team ("Green Team")
• Project in process (water conservation includes both technical and human areas)
• We seek to start a plant -wide environmental protection awareness revolution
(conserving water, energy, recycling, etc.)
• Working to change human behaviors and expectations about water -use
• Employee participation and team work very important for success moving forward
4) Company Wide Product Re -Alignment Manufacturing Study in Progress to Push Efficiency
as well as to Further Mitigate Plant Water Management Regulatory Issues (Total Number
of Pack/Water Discharge Days at the Factory may be Reduced by as Much as 90 Days
Starting as Soon as Next Year)
• Some high water use plant manufacturing (such as green beans and spinach
production) may be shifted to more efficient/modern Del Monte plants in other
Sager Creek/NCDEQ Meeting Agenda
Page 4 of 6
regions of the country that have excess manufacturing capacity and the ability to
properly manage the production wastewater
• Plant production has been further reduced from CPo flay work weeks (no
processing on weekends) to reduce even more process water production and bring
factory discharges more into balance with existing site storage pond freeboard and
spray irrigation system limitations
• Next fall (fall 2016) only cleaned and/or was ed potatoes may be processed at the
factory (this will likely increase factory raw product costs but would measurably
reduce the amount of process wastewater discharged during the rainy and cool
fall/winter season months because the plant will not have to do much washing of
the potatoes before the start of processing)
• Possible shift to more ,¢sy bin production and less production of other more
intensive water use manufacturing crops such as greens
• Smart and measured re -investments in factory processing equipment over the next
3-5 years will improve product through -put and may reduce the need for the factory
to run for so many days (this in turn will reduce the total annual process water
discharges)
E. DOMESTIC SANITARY WASTEWATER
(SEEK TO WORK WITH NCDEQ TO FULLY IMPLEMENT REQUIRED UPGRADES DURING 2016)
1) Description of current systems`
• Septic/Pump Tank(s)
• Chlorination
• Discharge to Industrial Wastewater Line
2) Condition of current systems
3) Proposed corrective action plan (system being designed to serve 400 workers at an
estimated flow of 25 GPD/worker which equates to 10,000 GPD total flow per day)
• New Septic Tank/Recirculation Tanks
• New Conveyance System
• E-Z Treat System
• UV Disinfection
• Spray irrigation of treated wastewater along with plant process water (note that
based on our review of factory piping systems it appears that sanitary wastewater
has historically been part of the plant processing water irrigation stream)
4) Proposed location/placement of new treatment system (see site plans)
5) Projected final system effluent quality (10 mg/L BODS; 10 mg/L TSS; and Fecal Coliforms
< 200 colonies/100 ml) with sample location prior to industrial wastewater line
6) EZ-Treat System Technology Approvals:
• NSF/ANSI Standard 40— Residential Onsite Systems (see NSF Letter)
• NSF/ANSI Standard 245 — Nitrogen Reduction (pending, see NSF Letter)
• NSF/ANSI Standard 350 — Onsite Water Reuse Approval (pending, see NSF Letter)
Note: The above NSF/ANSI standards are the strictest certifications for domestic
wastewater regarding on -site systems
Sager Creek/NCDEQ Meeting Agenda
Page 5 of 6
7) Preliminary project schedule (highly dependent on site permitting/possible public notice
requirements and the weather during the construction phase of the project):
• Design and Preparation of Permit Applications (2 Months)
• NCDEQ Review/Permitting (3 Months)
• Order and Fully Install Equipment (5 Months)
• Start -Up and Training (1 Month)
• Total Project Design, Permitting, Installation, and Start -Up Time (11 Months)
8) Modification of site wastewater irrigation system permit (Will our factory discharge
permit need to be modified to list/include our sanitary domestic wastewater?)
9) Routine monitoring of treated sanitary discharges (Flows, BOD, TSS and Fecal
Coliforms?)
10) Licensed operator needed for new domestic wastewater treatment system?
`NOTE: Factory domestic wastewater combines with the facility's food processing water after
the screening operation and does not pass over the facility process water screens.
F. PRELIMINARY CORRECTIVE ACTION PLAN STUDY ELEMENTS/TASKS (SUBJECT TO NCDEQ
INPUT AND APPROVAL)
Vr TASK 1: Determine Factory ring +u/auring Processes and Operations (Five -Year Plan)
• Types of crops
• Days of production (5 or 7 day work week, 2 or 3 shift days, etc.)
• Processing days (crop type/impacts daily volumes of wash water production)
• Raw product sourcing and quality analyses (e.g., cleaned and washed potatoes versus
direct field harvested potatoes)
2) TASK 2: Complete In -Plant Fw and L,oa2 1eduction Plan (Water Reduction and
Conservation Plan) — UvD"L!1 / W`/ / 1 •
• Water use survey/ audit (including metering screened water being returned to the
factory for gutter flushing)
• Phased approach (start with the most obvious and lowest -cost water savings options)
• Reuse/recycle water one or more times where possible
• Refine factory SOPs, employee training, etc.
• Life cycle/ROI costing (these costs need to be aligned with any costs that may be
required to expand the land application site or re -do the site pond systems to handle
current plant water flows)
3) TASK 3: Determine Process Wastewater Flow and Loadings (this task to be completed in
parallel with Tasks 1 and 2)
• Daily, weekly, monthly, and annual flows (needed for proper pond and land
application site water balance sizing calculations)
• N and BOD discharges (potential site limiting parameters in addition to too much
water)
• N and BOD seasonal discharges (current permit limits nitrogen discharges to no more
than 300 lbs. PAN/YR and 50 lbs. PAN/winter)
4) TASK 4: Analyze Ability of Existing Factory Treatment/Storage Ponds and Land
Application Sites to Properly Treat and Manage Process Wastewater Flows and Loadings
• Verify sizing, conditions, and limitations of existing treatment ponds
• Complete hydraulic, N, and BOD loading a Iyse
Sager Creek/NCDEQ Meeting Agenda
Page 6 of 6
• Monthlyhydraulic and nutrient balances will closely factor historical rainfall,
temperatures, and evapotranspiration rates
• Projected hydraulic and nutrient loadings will be compared to the site's existing
discharge permit limitations for pond freeboard and spray field applications
• Overall assessment of existing factory process wastewater systems to manage
projected process wastewater flows and loadings
5) TASK 5: Develop and Select Preferred Corrective Actions (the full scope of this task will
be based on the outcome of the above work tasks and in particular the analyses
completed in Task 4). Corrective actions to be evaluated under this task may include
one or more of the following or some combination of the following:
• Different processing of crops
• Reduced plant production
• Changes to factory manufacturing practices
• In -plant flow and loading reductions (source water/wastewater point reductions)
• Modified or new storage ponds
• Expanded spray irrigation (irrigate processing waters across more land)
6) TASK 6: Prepare Implementation Plan, Cost Estimates, and Schedule
• Listing of selected corrective actions
• Cost estimates (preliminary baseline capital and O&M engineering cost estimates)
• Implementation Schedule
"Supplemental Task: The factory also plans to develop a proper closure plan for the pit
(created to increase the lower facility pond banks) located south of Fields A2 and A3. Our goal
is to get this pit area cleaned of debris and to fill or re -grade the pit so that it no longer
collects rainfall.
G. ACTION ITEMS, NEXT STEPS, ASSIGNMENTS, AND ANY OTHER ITEMS
H. MEETING CLOSE
SAGER CREEK VEGETABLE COMPANY, TURKEY, NC.
PROCESS WATER SYSTEMS CORRECTIVE ACTION PLANNING MEETING
NC DEPARTMENT OF ENVIRONMENTAL QUALITY
FAYETEVILLE/RALEIGH, NC
December 2, 2015
A. DOMESTIC SANITARY WASTEWATER
(SEEK TO WORK WITH NCDEQ TO FULLY IMPLEMENT REQUIRED UPGRADES DURING 2016)
1) Description of current system
• Septic/Pump Tank(s)
• Chlorination
• Discharge to Industrial Wastewater Line
2) Condition of current system
3) Proposed corrective action plan (system being designed to serve 400 workers at an
estimated flow of 25 GPD/worker which equates to.1:49 0 GPD total flow per day)
• New Septic/Recirculation Tanks
• New Conveyance System
• E-Z Treat System
• UV Disinfection
• Spray irrigation of treated wastewater along with plant process water (note that
based on our review of factory piping systems it appears that sanitary wastewater
has historically been part of the plant processing water irrigation stream)
4) Proposed location/placement of new treatment system (see site plans)
5) Projected final system effluent quality (10 mg/L BOD5; 10 mg/L TSS; and Fecal Coliforms
< 200 colonies/100 ml) with sample location prior to industrial wastewater line.
6) EZ-Treat System: technology approvals
NSF/ANSI Standard 40 — Residential Onsite Systems (see NSF Letter).
NSF/ANSI Standard 245 — Nitrogen Reduction (pending, see NSF Letter).
NSFI/ANSI Standard 350 —Onsite Water Reuse Approvals (pending, see NSF Letter).
(these are the strictest certifications for domestic wastewater regarding on -site
systems)
7) Preliminary project schedule (highly dependent on site permitting and the weather
during the construction phase of the project): 3f - 1 ' V
• Design and Preparation of Permit Applications (2 Months) `r
• NCDEQ Review/Permitting (3 Months)
• Order and Fully Install Equipment (5 Months)
• Start -Up and Training (1 Month)
• Total Project Design, Permitting, Installation, and Start -Up Time (1 n )
8) Modification of site wastewater irrigation system permit (Will our factory discharge
permit need to be modified to list/include our sanitary domestic wastewater?)
9) Routine monitori n of treated sanitary dijarges (Flows, BOD, TSS and Fecal
Coliforms?)
10) Licensed operator need'd for new domestic astewater treatment system?
NOTE: Factory domestic wastewater combines with the facility's food processing water after
the screening operation and does not pass over the facility process water screens.
NSF NSF International
OFFICIAL LISTING
NSF International Certifies that the products appearing on this Listing conform to the requirements of
NSF/ANSI Standard 40 - Residential Wastewater Treatment Systems
This is the Official Listing recorded on October 16, 2014.
E-Z Treat
P.O. Box 176
Haymarket, VA 20618
703-753-4770
Facility: Rocky Mount, NC
Rated
Capacity
Model Number Gallons/Day Classification
#600 600 Class I
#1200 1200 Class I
Note: Additions shall not be made to this document without prior evaluation and acceptance by NSF International.
1 of 1
C0173848
789 N. Dixboro Road. Ann Arbor, Michigan 48105-9723 USA
1-800-NSF-MARK / 734-769-8010
www.ns£org
NSF International
October 29, 2015
Mr. Carl Perry
E-Z Treat Systems, LLC
1700 Davis St
Rocky Mount, NC 27803
Dear Carl,
I am writing to provide E-Z Treat written permission to use the preliminary data for the E-Z Treat
model #600 Wastewater Treatment system currently under test for NSF/ANSI Standard 245 and
NSF/ANSI Standard 350-Wastewater.
Currently the unit is meeting the requirements of both NSF 245 and 350. The unit is producing an
average of 66% Nitrogen Reduction, and producing an average effluent Turbidity of 2 NTU, CBOD
of 2 mg/L, TSS of 2 mg/L, and E. Coli of 6 MPM/100 ml.
This test will be completed at the end of November 2015, and at that time, if the criteria still meet
the requirements of the Standards; we will Certify the E-Z Treat #600 treatment system to
NSF/ANSI Standard 245, and 350-Wastewater Official Listing.
Please contact me with any questions you may have.
Sincerely,
Sharon Steiner
Business Unit Manager
Wastewater Treatment Unit Program
734-827-6846 (Voice)
734-827-7790 (Fax)
steiner@nsf.org (E-mail)
cc: corporate correspondence (CO0173848)
P.O. Box 130140 Ann Arbor, MI 48113-0140 USA
734-769-8010 1-800-NSF-MARK Fax 734-769-0109
E-Mail: info@nsf.org Web:http://www.nsforg