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HomeMy WebLinkAboutWQ0004268_Questions_20160505Barber, Jim From: Sent: To: Cc: Subject: Tim Ruby <Tim.Ruby@delmonte.com> Thursday, May 05, 2016 8:33 PM Barber, Jim; Thornburg, Nathaniel Henson, Belinda; Honeycutt, Tony; Thornburg, Nathaniel; Risgaard, Jon; Chris Dunton; Allen Mize; Scott Butler; James Knetsch; Gary.MacConnell; David Vogl RE: Sager Creek/Del Monte former Aliens Dear Mr. Barber and Thornburg, we are writing to specifically respond to your questions listed at the end of this email. Please be advised that we are very open to your ideas/ thoughts on some of these regulatory procedural matters, but we did want to respond quickly to your questions. Further, when we meet with your team in the next few weeks, we can also discuss all of these items in greater detail and proceed accordingly. Question #1 Permit name change from Aliens to Vegetable Acquisition Corporation'(d/b/a Sager Creek Foods, Inc:) We believe the site wastewater irrigation system permit still needs to be transferred to Sager Creek Foods, Inc. (f/k/a Vegetable Acquisition Corporation). We may have stopped processing vegetables at the Turkey plant but we still remain responsible for all of the terms and conditions in .the existing permit until and, unless we sell the property (including ongoing groundwater monitoring, annual soil testing, etc.). Further, we still need to have the ability to spray irrigate our pond water until we properly close our ponds and/or the regulatory status of our ponds change. • Question #2 Proposed Permit Modification to Modify/Re-Design Domestic Wastewater System We seek to keep this permit application/ request open until we have fully characterized our site soils and have - determined that a subsurface system may be installed at our site. Be advised that we do not plan to drag our feet on this determination/ project and we have already received corporate budget approval to aggressively proceed with resolving this matter. If our site soils/ conditions will not allow us to construct a subsurface system, we may choose to down -size the EZ-Treat System and reconfigure our existing conveyance systems for spray irrigation of these secondary/disinfected treated waters separately from our current pond waters. Nevertheless, our goal remains to get a properly functioning upgraded system in -place at the plant as soon as possible. Question #3 Application for a Special Order by Consent We believe that the original purpose and goals of the Special Order by Consent Application no longer apply to our plant particularly given the fact that we have stopped processing vegetables. 1 If you recall, we planned to complete a significant amount of work/ tasks and capital over the next 3-5 years to bring our factory back into full compliance with storage pond freeboard requirements on a permanent year-round basis. These proposed studies and work are really no longer applicable to our site and we now seek to work with you on formulating the best regulatory/ environmental paths for our on -site ponds (upper solids settling and lower storage ponds). Question #4 Spray Field and Pond(s) Future We plan to properly manage pond residuals and appropriately stabilize the ponds with your input/ support and guidance. Note that we have already done some preliminary data gathering on measuring residuals volumes and quality. The preliminary/ scoping residuals quality data that we have collected so far is very encouraging (when compared to pollutant limits in Part 503). This makes a lot of sense given the factory has historically processed potatoes and other vegetables. We have also started our preliminary options/ cost analyses but we really need to meet with you to more fully recognize/ define these options. Question #5 Staffing Be assured that we will not and do not plan to shut the doors of our plant and walk away. This week we retained two new operators to help us manage/ maintain our spray field and ponds. This will include making sure that we get our site crops harvested and removed on -time and the site is re -planted as necessary until the regulatory status of our site changes. We hope that this short email adequately addresses your immediate questions/ concerns. _ Sincerely, SAGER CREEK FOODS, INC. Timothy P. Ruby Environmental Water Manager (925) 766-8238 cell (925) 949-0424 office From: Tim Ruby Sent: Wednesday, May 04, 2016 2:58 PM To: 'Barber, Jim' Cc: Henson, Belinda; Honeycutt, Tony; Thornburg, Nathaniel; Risgaard, Jon; Chris Dunton; Allen Mize; Scott Butler; James Knetsch Subject: RE: Sager Creek/Del Monte former Aliens 2 ;. :Dear Mr. Barber, thank you for this email. Be advised that our factory is being closed and has stopped processing vegetables indefinitely. Please give me a few days to more properly/ fully respond to your questions below. However, be assured that we plan to properly staff/ close our factory -and have already begun to work on plans for our ponds (pond surveys and residuals volume and quality measurements are now in process). Further, be aware that we are now designing a smaller domestic wastewater treatment system for the factory (subsurface pressure manifold system for 60 employees @ 1,500 GPD). Note that we are still working on the soil analyses/ suitability aspects for the new subsurface treatment system, but the goal here is to stop discharging factory domestic. wastewater to the pond/ spray irrigation system. We would like to meet with you in a few weeks after we have more fully formalized our factory long term plans to gain your input/ ideas particularly with respect to the future of the factory ponds and spray irrigation system. Again, we appreciate your on -going he'Ip/ support. Sincerely, SAGER CREEK FOODS, INC. Timothy P. Ruby Environmental Water Manager (925) 766-8238 cell (925) 949-0424 office From: Barber, Jim [mailto:iim.barber@ncdenr.gov] Sent: Wednesday, May 04, 2016 1:01 PM To: Tim Ruby; Chris Dunton Cc: Henson, Belinda; Honeycutt, Tony, Thornburg, Nathaniel; Risgaard, Jon Subject: FW: Sager Creek/Del,Monte former Aliens Tim Ruby; I'm forwarding an email that I sent to Dan Barnett's attention a couple of weeks ago. Based on the information provided in your letter/email dated 29 April 2016; the question concerning the ORC and Back Up ORC has been addressed by the executed Water Pollution Control System form indicating Randall Jarrell and Chad Leinbach will be the operators. If you would, please provide a response to Nathaniel Thornburg (permitting branch supervisor — central office) concerning items 1, 2 and 3 below so the current- applications in-house can be dealt with appropriately (i.e. returned or processed). Thanks for your assistance. Jim Barber Environmental Engineer NCDEQ-DWR-WQRO Fayetteville Regional Office 910-433-3340 voice - 910-486-0707 fax iim.barberancdenr.gov 3 y ,. 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. `-A Go Green! Print this email only when necessary. Thank you for helping NCDENR be environmentally responsible. ******************* From: Barber, Jim Sent: Friday, April 22, 2016 12:11 PM To:'dbarnett@scvegco:com' <dbarnett@scvegco.com> Cc: Henson, Belinda (belinda.henson@ncdenr.gov) <belinda.henson@ncdenr.gov>; Thornburg, Nathaniel <nathaniel.thornburg@ncdenr.gov>; Allen, Trent <trent.allen@ncdenr.gov>; Honeycutt, Tony <tony.honeycutt@ncdenr.gov>; Risgaard, Jon <jon.risgaard@ncdenr.gov> Subject: FW: Sager Creek/Del Monte former Aliens Dan Barnett; The following link (http://clintonnc.com/news/8847/economic-headwinds-blow-jobs-away) was brought to my attention this morning by a co-worker that lives in Sampson County. After a few discussions and emails internal to DWR, a few questions have arisen. If the announcement made in the Sampson Independent is indeed a final decision concerning the future of the .plant;;what needs to happen with the following items/issues in house with the Division of Water Resources: 1). Permit name change from Allens to Vegetable Acquisition Corporation (d/b/a Sager Creek Foods, Inc. — see attached map and Sec. of State listing). Also attached is an email between Tim Ruby and Nathaniel Thornburg concerning the permit change; 2). Proposed permit modification to modify/re-design domestic wastewater system; 3). Special Order of Consent since the facility has brought the spray irrigation lagoon into compliance with the 24" freeboard requirement by minimizing wastewater production due to operational changes within the plant and eliminating certain vegetable production at the facility; Another issue that we wish to inquire about is the future of the spray irrigation system and lagoon system (i.e. upper solid settling and Tower storage) going forward: If the closure this summer is definite, who will remain to oversee the lagoon and spray irrigation system if the plant is not purchased by another entity? If you wish to discuss, please give Belinda Henson a call at 910-433-3326 or Jim Barber at the number below. Thank you Jim Barber Environmental Engineer NCDEQ-DWR-WQRO Fayetteville Regional Office 910-433-3340 voice 910-486-0707 fax jim.barber(ancdenr.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. 4 3 . . '40.•A Go Green! Print this email only when necessary. 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