WQ0000884_Notice of Deficiency_20240201

DocuSign Envelope ID: E86D7C42-7809-4BC1-AOA9-CF77BE70BO71
a n`STAZE o.
ROY COOPER a
a+ oGovernor '
ELIZABETH S.BISEP
Secretary `-
RICHARD E.ROGERS,JR. NORTH CAROLINA
Director Environmental Quality
Certified Mail # 7018 0680 0001 9160 6188
Return Receipt Requested
February 1, 2024
John Pike
Butterball LLC
PO Box 10009
Goldsboro, NC 27532-0009
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-GW-0001
Permit No. WQ0000884
Butterball - Mt. Olive WWTF
Duplin County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Butterball - Mt. Olive WWTF on
January 10, 2024. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non-discharge Permit No. WQ0000884. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Wilmington
Regional Office. The following deficiency(s) was noted during the inspection:
Inspection Area Description of Deficiency
Wells Monitoring wells MW-22 and MW-38 through MW-41 exceed 2L Standard for nitrate
In addition, the issues below must also be addressed:
D_E � North Carolina Department of Environmental Quality I Division of Water Resources
Wilmington Regional Office 1127 Cardinal Drive Extemilon I Wilmington,North Carolina 28405
- \ /' 910.796.7215

DocuSign Envelope ID: E86D7C42-7809-4BC1-AOA9-CF77BE70B071
Compliance Issue(s):
Although concentrations of total nitrate-nitrogen (nitrate) do not seem to be an issue in the effluent of the
industrial wastewater treatment plant, it seems to be potentially problematic in groundwater and possibly
surface water samples. Title 15A of the North Carolina Administrative Code, Subchapter 2L, Section .0202
establishes a limit of 10 milligrams per liter (mg/L) in Class GA groundwaters and this limit is duplicated in
the NPDES permit (refer to Permit No WQ0000884, Attachment Q. There are no established limits for
nitrate for the surface water sampling locations and no standards have been established for this compound
in the Northeast Cape Fear River in the vicinity of the site (Stream Index 18-74-(1) and Classification of
C;Sw). However, the EPA has indicated that nitrates in excess amounts in surface waters can accelerate
eutrophication, causing dramatic increases in aquatic plant growth and changes in the types of plants and
animals that live in the stream. This, in turn, affects dissolved oxygen, temperature, and other indicators.
Excess nitrates can cause hypoxia (low levels of dissolved oxygen) and can become toxic to warm-blooded
animals at higher concentrations (10 mg/L or higher) under certain conditions.
Concentrations of nitrate in monitoring wells MW-38 through MW-41 are all above the limit of 10 mg/L and
these wells are also suspected to be the most downgradient wells upgradient of the Northeast Cape Fear
River. Monitoring well MW-22 has also recently been exceeding 10 mg/L nitrate and this well is believed to
be upgradient of the irrigation fields. Monitoring well MW-24 was just below 10 mg/L (at 9.60 mg/L)
during the last sampling event in 9/2023 and has demonstrated an increasing trend. Surface water
samples of nitrate from locations PPI 006, PPI 007 and PPI 009 have inconsistently been above 10 mg/L
and historical sampling results indicate an increasing trend. Surface sampling location PPI 008 has also
historically exceeded 10 mg/L, but not since 2/4/2021 and the trend at this location appears to be
decreasing.
The Division remains concerned about the levels of total nitrate-nitrogen (nitrate) in groundwater and
surface water samples obtained at the site. Attached are graphical representations of levels of nitrate
documented within monitoring well MW-38 and at surface sample location PPI 009. Included within the
graphs are linear best fit lines which depict an increasing trend resulting from the samples to date at both
locations.
Butterball - Mt. Olive WWTF, WQ0000884
Nitrate Levels in MW-38
80.00
•
60.0025
• • •
E • •
v 40.00 • •
+
z 20.00 • • • •
0.00 • •
9/18/2014 1/31/2016 6/14/2017 10/27/2018 3/10/2020 7/23/2021 12/5/2022 4/18/2024
Date
........ W Norlh Carolina Depsrtmento(Envfon al Quality l Division o(Water Resources
Wilmington Regional 0fte 1127 Cardnal Drive Extension I Wilmington Nwh Carolina 2W5
910.796,7215

DocuSign Envelope ID: E86D7C42-7809-4BC1-AOA9-CF77BE70BO71
Butterball - Mt. Olive WWTF, WQ0000884
PPI 009 Nitrate Levels over Time
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10.00 .. •• � •
to • l............. M•
5.00 •......•••�...... •: •
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0.00 MM ft• • •• • • •
9/18/2014 1/31/2016 6/14/2017 10/27/2018 3/10/2020 7/23/2021 12/5/2022 4/18/2024
Date
Although it is understood that activities are being performed to perform repair to various fields each year,
these procedures have been in place for at least a few years and levels seem to continue to increase
despite these efforts. For this reason, the Division requests additional information to justify continuing with
this course of action or a proposal for other actions to reduce nitrate at the site. Along with any response,
please provide a copy of the annual representative soils analysis (i.e., Standard Soil Fertility Analysis), flow
and mass balance information for each spray field as well as any additional information you might feel is
relevant to gain an understanding of the situation. A response is requested within 90 days of receipt of
this letter.
The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.
If you should have any questions, please do not hesitate to contact Bryan Lievre with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
IDOCU igned by:
Cuµ OA,
7F141E73B6F3456...
for
Morelia Sanchez-King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENT
Cc: Lankford Ruffin (via email)
Joshua Batchelor (via email)
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........ W Norlh Carolina Depsrtmento(Envfon al Quality l Division o(Water Resources
Wilmington Regional 0fte 1127 Cardnal Drive Extension I Wilmington Nwh Carolina 2W5
910.796,7215