WQ0012662_Permit Renewal_20010419

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DIVISION OF WATER QUALITY
GROUNDWATER SECTION
April 19, 2001
MEMORANDUM
To: Kim Colson
Through: Debra Watts
From: David Goodrichz,
Subject: Dunbar Food Corporation
Renewal of Existing Permit for the Land Application of Residuals
Hamett County
WQ0012662/GW01063
(J.R. Joshi: DWQ SERG Review Engineer)
The Groundwater Section is in'receipt of the subject application to renew existing Permit
Number WQ0012662, issued on August 16,1996. The existing permit allows the application of 907
dry tons per year of residuals from the Dunbar Food Corporation onto approximately 430 acres of
applicable land in Harnett and Cumberland Counties. The residuals are composed of a fibrous
organic material generated from steam pealing and scrubbing of sweet potatoes before canning. This
is the first renewal of this permit, and the existing permit allows the year-round application of
residuals and does not require groundwater monitoring.
The application areas consist of six fields situated on two sites. The Averasboro Cemetery Site
(Site 1, presented on Figures 1 and 2) has 322 applicable acres on three fields (Fields 4,5 and 6). The
Route 301 Site (Site 2, presented on Figures 3 and 4) has 108 applicable acres on three fields (Fields
1, 2 and 3). A site visit was recently performed by personnel from the Fayetteville Regional Office,
and observations made during the site visit suggested that the fields were being properly managed.
Regional Office personnel noted that the residuals are being injected into the soil instead of applied
at the surface. The injection of residuals causes more nitrogen to be available to the plants, and this
increased nitrogen loading results in a larger minimum area requirement (other factors being equal).
According to the calculations for Plant Available Nitrogen (PAN), the application of 907 dry
tons of residuals per year which has a (subsurface application) PAN concentration of 8.49 pounds of
nitrogen per dry ton results in a loading of 7,700 pounds per year. Allowing for the nitrogen
carryover each year, the five-year adjusted PAN loading was calculated to be 10,394 pounds per
year. The intended -crop with the lowest rate of nitrogen uptake is small grain (with a PAN of 100
pounds per acre per year). The minimum acreage needed is calculated by dividing the adjusted PAN
loading by the minimum nitrogen uptake, and this results in an area of 103.94 acres. During the year
2000, the permittee reportedly applied residuals to only 108 of the 430 acres approved for land
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application.
In consideration of the fact that six fields are being used for the application, activities and that
the application may not be equally distributed among the six fields, the Groundwater Section
recommends that cumulative loading records be kept for each field so that the Division can monitor
where the residuals are being applied, and to enable an individual field to be taken out of service
when its lowest metal loading limit is reached.
The Groundwater Section has reviewed the subject permit renewal application and
recommends reissuance of the permit with the following conditions: .
* 1. Cumulative loading records shall be kept for each of the six fields so that the Division can
monitor where the residuals are being applied, and to enable an individual field to be taken out of
service when its lowest metal loading limit is reached.
2. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for a
disposal system individually permitted after December 31,1983 is established at either (1).250 feet
from the waste disposal area, or (2) 50 feet within the property boundary, whichever is closest to the
waste disposal area. An exceedance of Groundwater Quality Standards at or beyond the Compliance
Boundary is subject to immediate remediation action in addition to the penalty provisions applicable
under General Statute 143-215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the waste disposal
area. Any exceedance of standards at the Review Boundary shall require remediation action on the
part of the permittee.
3. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
If there are any questions please contact David Goodrich at 715-6162.
cc: Art Barnhardt
Permit Files
--GW01063--
*This language differs from that of the shell document.
Page 2 of 2

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FIGURE 2
DUNBAR FOOD CORPORATION
LAND APPLICATION PROGRAM
IIARNETT COUNTY
WQ0012662/GW01063
DETAIL MAP FOR SITE 1

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FIGURE 3
DUNBAR FOOD CORPORATION
LAND APPLICATION PROGRAM
' \1 �• i IIARNETI' COUNTY
WQ0012662/GW01063
is v LOCATION MAP FOR SITE 2
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FIGURE 4
DUNBAR FOOD CORPORATION
LAND APPLICATION PROGRAM
HARNETT COUNTY
WQ0012662/GW01063
DETAIL MAP FOR SITE 2