NCG500205_waiver_20241016

Weaver, Charles
From: Weaver, Charles
Sent: Wednesday, October 16, 2024 9:54 AM
To: [e-mail]'
Cc: '[e-mail]'; '[e-mail]'; '[e-mail]';
Fontenot, Katie; Brantley, Mark
Subject: NCG500205 - waiver for low pH values due to instream conditions.
Importance: High
During a prior stormwater permit inspection, the Division noted that instream pH levels at your facility are affected by
naturally acidic groundwater and instream water conditions. As a result, the Stormwater program noted that Tier Two
requirements would not apply.
For consistency within the water quality program, please note that the lower pH limit of 6.0 standard units in General
Permit NCG500000 is provisionally waived due to instream conditions at your facility. We will not pursue enforcement
action for pH values that are naturally below the 6.0 standard unit level.
If you later determine that you can sample your facility's wastewater prior to it entering the stream, the 6.0 standard
units limit will apply to data from such samples. Contact Katie Fontenot in the Fayetteville Regional Office to discuss
sampling locations/techniques; she is copied on this message.
Carefully document where and when your samples are collected, so that the impact of instream pH levels can be
addressed.
Let me know if you have any questions.
Charles H. Weaver
Environmental Specialist II
Division of Water Resources
919-707-3616
charles.weaver(d.)deg. nc. gov
(mailing address) 1617 Mail Service Center, Raleigh, NC 27699-1617
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Permit: NCGO60029 Owner - Facility: Campbell Soup Supply Company L.L.C.
Inspection Date: 0611412011 Inspection Type: Compliance Evaluation Reason for visit: Routine
Inspection Summary:
A stbrmwater pollution prevention plan has been developed and implemented. As noted in this inspection checklist, a
copy of a General Location (USGS) map needs to be added to the plan. The plan is being updated annually with the last
update being performed in November 2010.
This facility has been granted a variance on pH monitoring due to the naturally occurring acidic groundwater and surface
water that occurs in this region. The benchmark values in the permit for pH are within 6.040 standard units but samples
of area surface waters and the stormwater outfalls are consistenetly below the minimum 6.0 su. So for the pH parameter,
this facility currently does not have to enter into the Tier Two provisions. Also, there was one benchmark exceedance
during the last sampling period for total suspended solids at one outfall that receives flow from a dirt and gravel parking
lot. Options need to be looked at and action needs to be taken to insure the benchmark value is not exceeded two times
in a row. If that happens then analytical monitoring will have be performed monthly.
Qualitative and analytical monitoring is being performed semi-annually, as required. This facility does not meet the criteria
to perform analytical monitoring for vehicle maintenance areas.
Page: 2

Weaver, Charles
From: Fontenot, Katie
Sent: Tuesday, October 15, 2024 8:36 AM
To: Weaver, Charles
Subject: Fw: NCG060029 - pH waiver questions (Campbell Soup)
Attachments: Regulatory Relief from Monthly Monitoring -Union Corrugating Company_NCG030520.doc; Cambell
Soup Notes from a Storm water inspection.pdf
Good Morning Charles,
Sorry for the late response I was waiting on a response from DEMLR since I could not locate anything useful in
laserfiche myself. Attached I have the summary from the DEMLR inspection that Cambell Soup gave me. Let
me know if you need any additional information.
Thanks,
Katie Fontenot
Environmental Specialist II
Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
[e-mail]
Office: 910-433-3327
Cell (preferred): 919-896-9715
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Taylor, Bailey L <[e-mail]>
Sent: Friday, October 11, 2024 1:33 PM
To: Fontenot, Katie <[e-mail]>
Subject: RE: NCG060029 - pH waiver questions
Hey Katie,
I reached out to Mike Lawyer to get some clarification from him, and he mentioned that the pH variance was a footnote
in previous permits that stated "If pH values outside this range are recorded in sampled stormwater discharges, but
ambient precipitation pH levels are lower, then the lower threshold of this benchmark range is the pH of the
precipitation instead of 6 standard units. Readings from an on -site or local rain gauge must be documented to
demonstrate background concentrations were below the benchmark pH range."

I don't have any specific memos or letters pertaining to this scenario, but I do have an old letter that was sent to a
different facility for Regulatory Relief from Monthly Monitoring which is a similar situation. I don't know if that helps but
let me know if you think of anything else Q
3airey Taylcn,
Senior Environmental Specialist
North Carolina Department of Environmental Quality
Division of Energy, Mineral and Land Resources
Cell: [phone]
Office: [phone]
[e-mail]
_ . DE
225 Green Street
Suite 714
Fayetteville, North Carolina 28301
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Fontenot, Katie <[e-mail]>
Sent: Thursday, October 10, 2024 8:43 AM
To: Taylor, Bailey L <[e-mail]>
Subject: NCG060029 - pH waiver questions
Bailey,
Inn not sure if you can help me or if you can send me to someone else who can. I was doing a inspection at
cambell soup and they are out of their pH benchmark due to the natural acidic conditions of the river in
Robeson county. Cambell soup showed me the attached summary from the inspection that is associated with
permit no. NCG060029. We would like to grant them a pH wavier as well but our permit writer wanted to see
if you guys had a memo for this? I tried looking in laserfiche and I didn't see anything. I just wanted to see if
there was something more official then the summary from a inspection that was dated 2011 or see if yall had
any background info on this seems to be a issue with the PH for all of their permits.
Thanks!
Katie Fontenot
Environmental Specialist II
Department of Environmental Quality
Division of Water Resources
Fayetteville Regional Office
[e-mail]
Office: 910-433-3327
Cell (preferred): 919-896-9715

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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
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