NC0082821_CORRESPONDENCE_20071128

NPDES DOCYNENT SCANNING COVER SHEET
NPDES Permit:
NC0082821
Statesville Fertilizer Plant
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
November 28, 2007
This document is printed on reuae paper -ignore a.uy
content on the reverae aide

R
r> DUNCKLEE
& DUNHAM
November 28, 2007
Mr Sumar Bou-Ghazale
North Carolina Division of Water Quality
Surface Water Protection
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Reference Proposed now Metering Change
Southern States Cooperative, Inc
Statesville Fertilizer Plant
NPDES Permit NCO082821
Dear Mr Bou-Ghazale
ENVIRONMENTAL CONSULTANTS
511 KE181 CR DRIVE -SUITE 102
CARY NORTH CAROLINA 27518
OFFICE (919) 858 - 9898
FACSIMILE (919) 858 - 9899
On behalf of Southern States Cooperative, Inc, (Southern States), Duncklee & Dunham, PC is
requesting a change to the way flow is metered to comply with the requirements of the facility's NPDES
permit Currently, the permitted ground water treatment system has an in -line flow meter for flow
measurement Pursuant to the requirements of the NPDES permit, the meter is calibrated annually, a
process that requires removal shipment to the manufacturer in California for calibration, and
reinstallation The meter is approximately 15 years old and needs to be rebuilt or replaced at a cost of
several thousand dollars We have priced equivalent type replacement meters and found them to be of
similar cost and calibration requirements Therefore, we are proposing to eliminate the metered method
of flow measurement and go to a batch -type measurement system A brief description of the current
treatment system is presented below
Two extraction wells are used to pump nitrate and ammonia -impacted ground to the treatment system for
PH adjustment and discharge into the receiving stream The wells operate seasonally, between November
I and March 31 The extraction wells pump ground water to a wet well adjacent to the treatment system
budding Caustic soda is added to the water in the wet well to adjust the pH Once the pl-1 is adjusted to
the permitted level, the water is pumped via a discharge pump to the receiving stream The in -line flow
meter is installed in the discharge pipe and used to measure the total flow
Duncklee & Dunham is proposing to add motor starter controllers to the extraction well pumps and a
counter to the wet well discharge pump The motor starter controllers will activate and de -activate the
extraction wells as the wet well fills and empties Activate and de -activate level switch controls mounted
at pre-set levels within the wet well energize and de -energize the wet well discharge pump to discharge
the water within the sump The counter will record the number of times the wet well discharge pump is
activated Knowing the volume of the wet well that is discharged during each pump cycle and the
number of times the discharge pump is activated, the total effluent flow can be calculated These
mechanical changes will eliminate the need for the in -line flow meter, otherwise there would be no
material changes to the system
MAU No AUDRi titi - I'o51 0111c1 lion 33366 — RAI I ion NORUI C.AhOI INA 27636

A.- 6
Proposed Flow Metering Change
Southern States - Statesville Fertilizer
November 28, 2007
Page 2 of 2
We believe the proposed change does not change the characteristics of the permitted ground water
treatment process and therefore does not require a permit modification Additionally, the change would
save substantial yearly operation and maintenance costs associated with the flow meter
Your assistance on this matter 1s greatly appreciated If you have any questions please do not hesitate to
call me at [phone] or email me at Tdunham@DunckleeDunham com
Sincerely
DUNCKLEE & DUNHAM, P C
Thomas S Dunham, L G
Senior Project Manager
Senior Peer Review By
RODAK ENGINEERING, P C
Andrew M Rodak, P E
Senior Engineer
c Mr Vance Dann — Southern States Cooperative, Inc (2)
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NPDES Permit-NC00082821
Subject NPDES Permit-NC00082821
From 'Christopher M Fay' <chns@dunckleedunham com>
Date Fri, 9 Feb 2007 07 57 40 -0500
To <susan a wilson@ncmail net>
Susan,
I have a compliance issue at the facility under permit number NC00082821 I talked to two
people in the Mooresville regional office yesterday trying to find out who to talk to about the issue
with no success I have talk to Bob Sledge in the past about the site so I called and emailed him
yesterday with no response Is there somebody that I can contact and discuss the issue?
Christopher M Fay
Project Geologist
DUNCKLEE
K DUNt1AM
Environmental Consultants
511 Keisler Drive, Suite 102
Cary , North Carolina 27511
919 858 9898 Office
919 858 9899 Fax
919 880 8413 Mobile
email chr 5dunckleedunham com
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1 of 1 2/9/2007 2 58 PM