NCS000294_COMPLIANCE_20090909

_-STORMWATERTDIVISION-CODING-SHEET'--'�
PERMIT NO.
DOC TYPE
❑ FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
P COMPLIANCE
❑ OTHER
DOC DATE
00109
YYYYM M DD

NCDERR .�.
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Mr. David Bissette
Southern States Cooperative, Inc.
2089 Sam Moss Road
Creedmoor, NC 27522
Subject: Compliance Evaluation Inspection
Stormwater NPDES Permit NCS000294
Southern States Cooperative
Creedmoor, NC
Granville County
Dear Mr. Bissette:
On September 3, 2008, Dave Parnell of the Raleigh Regional Office of the Division of Water Quality,
performed a compliance evaluation inspection (CEI) at Southern States' fertilizer mixing and loading
facility. Your assistance was appreciated. This inspection was conducted to determine the facility's
compliance with its NPDES stormwater permit. Observations during the inspection are as follows:
Dee Freeman
Secretary
1. Although you stated there had been no significant spills in the last three years, there was no list of
significant spills contained within the Stormwater Pollution Prevention Plan (SP3) as required by
your permit. Please include a section tab and list of significant spills within the SP3.
2. The SP3 had not been reviewed and updated during the calendar year as required. The site map had
not been updated to reflect the change from three (3) stormwater discharge outfalls (SDO) to two
(2) SDO, which was agreed upon during the January Ib, 2008 CEI. Please update the
Stormwater Pollution Prevention Plan during the current calendar year.
3. Documented records of employee training were contained within the SP3, as required by the permit.
4. Qualitative and analytical monitoring are required semi-annually by the permit. We discussed and
you have documented, the difficulty in meeting the analytical monitoring requirements set forth by
the permit. When the rainfall conditions have been present, and the timing of sampling and lab
scheduling met, the monitoring requirements were achieved. However; sample results show total
phosphorous levels to be above the'allowable benchmark. Implement an effort to reduce dust,
reduce the deposits of fertilizer on equipment and tires and any other housekeeping measures,
arp' ra
urat;
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
lntemet: www,ntwaterqualily,org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal CpportunilylAOlrrnative Action Employer— 50% Recycled110% Post Consumer Paper

w
southern States Cooperative, Inc. • Page 2
in an attempt to decrease the total phosphorous levels. Failure to conduct the fall 2008
qualitative monitoring was discussed with you during the inspection. You have shown that this was
an oversight by conducting the required periodic inspection in 2009.
5. All Stormwater Discharge Outfalls (SDO) were inspected, as was secondary containment. All were
found to be in compliance.
This facility is considered to be neither compliant nor non -compliant at this time. Please provide a written
response to this letter, within 30 days of the receipt of this letter, detailing the facility's compliance efforts with
respect to the bold items in #1, #2, and #4. If you have any questions regarding the attached report or any of the
findings, please contact me at: [phone] (or email: david.parnell(ci)ncmail.net).
Sincerely,
z At,�
Dave Parnell
Environmental Specialist
Surface Water Protection Section
Enclosure: August 3, 2009 Compliance Evaluation Inspection
cc: RRO/SWP files
Water Quality Central Files

Compliance Inspection Report
Permit: NCS000294 Effective: 03/01/06 Expiration: 02/28/10 Owner: Southern States Cooperative Inc
SOC: Effective: Expiration: Facility: Southern States Coop-Creedmoo
County: Granville 2089 Sam Moss Rd
Region: Raleigh
Creedmoor NC 27522
Contact Person: David Bissette Title: Phone: [phone]
Directions to Facility:
System Classlficatlons:
Primary ORC: Certiflcatlon: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/03/2009 Entry Time: -10:45 AM Exit Time: 12:00 PM
Primary Inspector: David R Parnell Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type: Compliance Evaluation
u
Page: 1

4
Permit: NCS000294 Owner - Facility: Southern States Cooperative Inc
Inspection Date: 09/0312009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCS000294 Owner - Facility: Southern States Cooperative Inc
Inspection Date: 09/03/2009 Inspection Type: Compliance Evaluation Reason for visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
■ ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
■ ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■ ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■ Cl ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑ ■
# Has the facility evaluated feasible alternatives to current practices?
■ ❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
■ ❑ ❑ ❑
# Does the Plan include a BMP summary?
■ ❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■ ❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■ ❑ ❑ ❑
# Does the facility provide and document Employee Training?
■ ❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
■ ❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ■ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
■ ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑ ❑ ❑
Comment: Include in SP3 the list of significant spills, although none were reported
verbally, the Division suggests. that a list be a part of the plan, in order to be readily
available. The SP3 should be reviewed and updated annually, the site plan should
reflect the fact that only 2 SDOs are now being evaluated rather than 3. This change
was made January 16, 2008 by Myrl Nisely.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
Comment: Neglected to conduct the Fall '08 required qualitative monitoring.
Analytical Monitoring Yes No NA WE
Has the facility conducted its Analytical monitoring? 00013
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ■ ❑
Comment: David Bissete is having difficulty with "the rules, parameters and tab
schedules, and the timing and frequency of rainfall events" and therefore has been
unable to meet the requirements in taking the proper sample. The sample reports that
he did have were evaluated during the inspection. Total Phosphorus readings were
elevated: 22.8, Benchmark = 2.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0000
Page: 3

•
0
Permit: NCS000294 Owner -Facility, Southern States Cooperative Inc
Inspection Date: 09/03/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
# Were all outfalls observed during the inspection? ■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ■ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑
Comment:
Page: 4

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Mr. David Bissette,
Southern States Cooperative
2089 Sam Moss Rd.
Creedmoor, NC 27522
00
January 18, 2008
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
1 SUBJECT: , Compliance Evaluation Inspection Report
Southern States Cooperative
Stormwater NPDES Permit NCS000294
Creedmoor, NC
Granville County
Dear Mr, Bissette:
Coleen H. Sullins, Director
Division of Water Quality
On January 16, 2008 I (Myr] Nisely) made a compliance inspection of the Southern States warehouse
facility with your help. It was a pleasure meeting you. The fertilizer mixing and loading facility was in
compliance. Please see the attached inspection checklist. Below are a few highlights from our discussion.
1. The Stormwater Pollution Prevention Plan (SP3) was current except for evidence of employee
training. The home office of Southern States has oversight of the program, including revisions to
the an at. However, you are urged to document an annual update of the SP3, as well.
2. _ Wk>. e not a requirement from DWQ, placing the SP3 and documents created from sampling,
qualitative inspections and employee training into a 3-ring binder would provide a central repository
of information. A manual organized in that way usually helps a permittee carry out the permit
requirements more completely and also expedites our inspections. These records are to be kept for
five years, as stated in the permit.
3. Employee training has been covering spill response, but stormwater awareness should be added.
Browsing through topics on http://www.ncstormwater.orgZpages/sitemappa eg html may be helpful.
Speaking points for training sessions are offered at
http://-www.ncstortnwater.org pages/sitemappage.html.
4. Sampling is now required twice a year in your latest permit on a specific schedule. Because of the
drought in 2007, the only sampling was done in May. Near year's end, you had provided proper
notification to our Central Office explaining the absence of a second round of sampling. The May
results for all outfalls were below the benchmark levels stated in the pen -nit.
5. Observations of conditions around the loading areas and the good analytical indicators mentioned
above indicate that measures taken after the last inspection to reduce dust and other handling losses
of fertilizer are effective.
One N,,ppr hCaro ina
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet www.ncwalerqualitv.ore 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal OpportunitylANirmative Action Employer— 50% Recycled110% Post Consumer Paper

Southern States Coop CEI, January 16,2008 Page 2 02
6. pH is measured at the contra4c aboratory, so is not measured whin a0minute hold time. To be
done correctly, pH is a field measurement made when the samples are collected. Information on a
variety of pH meters may be found by searching "ph meter" online. The meter should be
capable of automatic temperature compensation. In addition to the pH, temperature is to be
recorded, too. Before use on a given day, the meter should be calibrated using buffer solutions.
The calibration is to be documented as part of the analytical report for that sampling round. Finally,
to keep the probe operational the next time a pH is needed, proper storage of the probe in a
�41XICIPYImmend � solution must be done. Otherwise, the probe will dry out and fail to function the next
time.
7. The flow of rainwater to "Outfall 2" spreads into a wide grassy area as sheet flow. No further
sampling at this location will be required.
If you have questions or comments about this inspection, please contact me at 919-791-4255.
Sincerely,
Myrl X
Nisely
Environmental Chemist
Raleigh Regional Surface Water Quality
cc: RRO/SWP files
Central Files

• • V •
Compliance Inspection Report
Permit: NCS000294 Effective: 03/01/06 Expiration: 02/28/10 Owner: Southern States Cooperative Inc
SOC: Effective: Expiration: Facility: Southern States Coop-Creedmoo
County: Granville 2089 Sam Moss Rd
Region: Raleigh
Creedmoor NC 27522
5
Contact Person: David Bissette Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01116/2008
Primary Inspector: Myra Nisely
Secondary Inspector(s):
Entry Time: 01:35 PM
Reason for Inspection: Routine
Permit Inspection Type: Stormwaler Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Certification: Phone:
Exit Time: 03:00 PM
Phone: [phone]
Inspection Type: Compliance Evaluation
Page: 1

00
00
I
Permit: NCS000294 Owner - Facility: Southem States Cooperative Inc
Inspection Date: 01/16/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
i
Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ 1113
# Does the Plan include a General Location (USGS) map?
■
❑ ❑
❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑ ❑
❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑ ❑
❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑ ❑
❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑ ❑
❑
# Does the facility provide all necessary secondary containment?
■
❑ ❑
❑
# Does the Plan include a BMP summary?
■
❑ ❑
❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑ ❑
❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑ ❑
❑
# Does the facility provide and document Employee Training?
❑
■ ❑
❑
# Does the Plan include a list of Responsible Party(s)?
■
❑ ❑
❑
# Is the Plan reviewed and updated annually?
■
❑ ❑
❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑ ❑
❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑ ❑
❑
Comment: Employees receive spill response training, but not stormwater specific
training. The inspector was asked to identify training aids for future employee training.
Qualitative Monitoring
Yes
No NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
■
❑ ❑
❑
Comment:
Analytical Monitoring
Yes
No NA
NE
Has the facility conducted its Analytical monitoring?
■
❑ ❑
❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
■
❑ ❑
❑
Comment: Because of drought conditions, only one sampling round was possible in
2007, in May. Values for all three outfalis were less than benchmark values. There is a
need to be able to measure pH in the field within the 15 minute hold time.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑
# Were all outfalls observed during the inspection? ■ ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ■ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ .
Page: 3

t ti
00
Permit: NCS000294 Owner -Facility: Southern States Cooperative Inc
Inspection pate: 01/16/2008 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Outfali #2 serves a small watershed, and the flow spreads before it runs
into dense grass as sheet flow. This outfall can be removed from the stormwater plan.
Page: 4

F W A TF Michael F, Easley, Governor
0 ApG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Raleigh Regional Office
-i
p Y Alan W. Klimek, P.E. Director
Division of Water Quality
November 22, 2005
Mr. David Bissette
Southern States
P.O. Box 582
Creedmoor, NC 27522
Subject: Inspection Report
Southern States — Creedmoor
NCS000294
Granville County
Dear Mr. Bissette:
On Thursday, November 10, 2005, I conducted a compliance evaluation inspection at the
subject facility. This visit was conducted in conjunction with the review of your application for
continued coverage under individual stormwater permit number NCS000294. Your assistance
during the inspection was very helpful and was appreciated. Below are the findings and
recommendations from the site visit.
The site is a fertilizer distribution center. No manufacturing takes place on site. All
products are stored inside a building (except for one lime pile).
2. A review of the facility's records was conducted. The facility has records of all
analytical and qualitative monitoring conducted for the last five years. Several
readings for ammonia and nitrates were notably high from outfall 001 and outfall 003.
Outfall 001 drains the west side of the fertilizer building and the south side of the
building where bulk fertilizer is brought in and transferred into the building. Outfall
003 drains the east side of the fertilizer storage building including the area where
fertilizer is loaded onto delivery trucks.
3. General housekeeping around most of the property was good. Some fertilizer residue
was noted around the area where bulk fertilizer is brought in and loaded into the
storage area. Pictures of this area are attached for reference, This is likely the cause
of the elevated nitrogen readings from outfall 001. We discussed Southern States
evaluating ways to reduce the nitrogen loss from that area including covering the
loading conveyer system.
Raleigh Regional Office 1628 Mail Service Center phone [phone] Customer Service
Water Quality Section Raleigh, NC 27699-1628 facsimile [phone] 1-877-623-6748
+ram.
As*�
,lqcbE- R R

• i t�.
Southern States NCS000294
November 28, 2005
Page 2 of 2
4. Some fertilizer dust was being blown onto the grounds in the breezy conditions as a
truck was being loaded for delivery. Southern States agreed to evaluate the use of
some kind of synthetic "sock" or other device on the end of the conveyer belt that
loads delivery trucks to prevent dust from and fertilizer from escaping onto the
property.
5. The facility's new permit will contain "benchmark values" which will give you an
idea of when you need to check the effectiveness of your BMP's and/or review and
update your Stormwater pollution prevention plan.
Please respond within 30 days of your receipt of this letter with information detailing your
evaluation ways to reduce the nutrient loss from the areas surrounding the incoming and
outgoing fertilizer load areas. If you have any questions or if I can be of any assistance please
feel free to call me at [phone].
ySincerelon Langley 14
Environmental Specialist H
Cc: RRO Files
Central Niles
Bethany Georgoulias

,r
0 0
Southern States S000294
November 28, 2005
Page 3 of 3
Area where fertilizer is brought in and loaded into the storage building. Note some fertilizer
1 / 10/2005
Relation of loading area to storm drain leading to outfall 001, NCS000294 11/10/2005