NC0082821_Regional Office Historical File Pre 2018

?-d.C. DEPT. OF
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Canniiie'_Ej�mipb ierltal �ervices Corp.
800 Canonie Drive
May 15, 1995 Porter, Indiana 46304
Phone [phone]
Fax [phone]
91-161-22
Mr. Rex Gleason
Water Quality Regional Supervisor
NCDEHNR
Mooresville Regional Office
919 N. Main Street
Mooresville, NC 28115
pH Adjustment System
Ground Water Remediation System
NPDES Permit No. NCO082821
Southern States Fertilizer Facility
Statesville, North Carolina
Dear Mr. Gleason:
This letter serves to inform you of the anticipated design changes to the Ground
Water Remediation System (GWRS) located at the Southern States Fertilizer Facility
in Statesville, North Carolina. Operation of the GWRS is governed by the National
Pollution Discharge Elimination -System (NPDES) Permit -No. NC0082821-.-.-.Start7up of
the-GWRS �6ddu* rred on December 14-F -1-994.--However, due to problems in achieving
the discharge criteria for pH, the GWRS was shut down on January 27, 1995. Mr.
Mike Parker of the North Carolina Department of Environment, Health, and Natural
Resources (NCDEHNR), Mooresville office was notified regarding this operating
problem and subsequent shutdown by phone on February 13, 1995. At that time, Mr.
Parker stated that design modifications made to the GWRS to meet the NPDES permit
pH discharge limits would not require a new Authorization to Construct. However,
he requested that a detailed letter be submitted to you explaining the design
modifications that will be made to the GWRS. Attachment A of this letter is a copy
of the Explanation of Non -Compliance that accompanied the NPDES permit monthly
monitoring forms to the NCDEHNR Central Files.
Canonie Environmental Services Corp. (Canonie) has modified the design of the GWRS
to include a pH adjustment system. The pH adjustment system will consist of adding
sodium hydroxide to the ground water to raise the pH to the NPDES permitted range
of 6.0 to 9.0. Attached are Figures 1 through 4 showing the engineering design for
the pH adjustment system. The pH adjustment system will consist of the following
items as shown on Figure 3:
PR\W:\91-161\GLEAS0N.616 [May. 15. 19951

d
EXPLANATION OF NON-COMPLIANCE
PERMIT NUMBER NCO082821
The permitted discharge at the Southern States Fertilizer Plant in Statesville North
Carolina results from a Ground Water Remediation System (GWRS) located at the
facility. Startup of the GWRS occurred on December 14, 1994. Due to problems in
achieving the (discharge criteria for pH, the GWRS was shut down on January 27,
1995. A summary of the GWRS operations is presented in the attached Discharge
Summary Log.
The GWRS consists of three ground water recovery wells: RW-2 (approximately 160
feet deep); RW-4 (approximately 118 feet deep); and RW-5 (approximately 70 feet
deep). RW-2 is the main recovery well and produces approximately 80 gallons per
minute (gpm). The discharge from RW-2 contains low levels of site contaminants
(nitrogen compounds). The function of RW-2 is to hydraulically control off -site
migration of impacted ground water. RW-4 and RW-5 produce a combined flow of
10 gpm and were installed upgradient of RW-2 within the ground water plume to
enhance remediation efforts in areas of higher concentrations. Consequently, the
discharge from RW-4 and RW-5 contain relatively high (compared to RW-2) levels of
site contaminants. The discharge from the three recovery wells is. piped to a pump
station located on the Southern States property. The pump station serves to pump
the ground water to its discharge point at Fourth Creek. All NPDES permit monitoring
takes place on the discharge side of the pump station.
When designing the GWRS, pH levels were measured in the recovery wells, or in
monitoring wells in the area where the recovery wells would be located. Historical
ground water data shows that pH values in the shallow soil formations (to a depth of
100 feet below grade) range from 3 to 7. Historical monitoring data also shows that
pH values for ground water in the deeper soil and rock formations (greater than 100
feet deep) range from 6 to 9. Although the pH levels measured in shallow monitoring
wells near RW-4 and RW-5 were below 6, the pH levels recorded in RW-2 and wells
at a similar depth were consistently over 6. Based on this data and the fact that
approximately 89 percent of the discharge would come from RW-2, problems with the
pH level in the GWRS discharge were not anticipated.
PR1W:181.161WP0ES.RPT [Feb.20, 19051
CanonleEnvir=ental

State of North Carolina : . IT
Department of Environment,
Health and Natural Resources udRD 4 Y15WA �
Mooresville Regional Office �IQV o B 1�'�4
�.
James B. Hunt, Jr., Governor 41111 01TfflWe',t R1TPf)j R p1 DC H N FZ
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
November 7, 1994
Southern States Cooperative, Incorporated
Post Office Box 26234
Richmond, Virginia 23260
Attention: Hilton M. Withers
RE: Request for Extension
Southern States/Wayside Estates
Groundwater Incident W 5038
Iredell County, N.C.
Dear Mr. Withers:
Your request for additional time for starting the
remediation system at the above referenced site has been reviewed
by the Groundwater Section of the Mooresville Regional Office.
Based on the information you have provided with your request
for an extension, the request is hereby granted until January 5,
1995. Failure to start-up the remediation system by the extended
due date may result in a recommendation for the assessment of
civil penalties beginning from the original due date.
Should you have further questions regarding this matter,
please call Karen Walker or me at [phone].
Sincerely,
iavv� /' ckv_�'_'�
Barbara S. Christian
Regional Groundwater Supervisor
cc: Incident Management Unit
Thomas F. Beggs, P.E. - Law Environmental, Inc.
KDW/sc
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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STATESVILLE, NORTH CAROLINA
PREPARED FOR
SOUTHERN STATES
COOPERATIVE, INC.
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DATE: 2-9-95 FIGURE 1 DRAWING NUMBER
SCALE NONE 1 91-161—E51

Watson, Edward M
From: Jayson Kilcoyne <[e-mail]>
Sent: Thursday, July 12, 2018 9:43 AM
To: Watson, Edward M
Subject: RE: [External] SSC Statesville -May 2018 DMR and cover letter-NCO082821
Edward,
My cell phone number is 919-632-5072. Attending the meeting from Southern States will be Jennifer Bunting
(Environmental Programs Manager) and John Madden (VP of Insurance and Risk). John is the corporate VP responsible
for SSC's environmental responsibilities. I will be there along with Tom Dunham (VP of Duncklee & Dunham). Tom
was at the previous meeting in December 2015. Bruce Gray is the plant manager and he will be able to answer
maintenance questions. Scott is their electrician and he tends to do most of the checking of the system when we are not
on -site. I'll see you on Monday at 10 a.m.
Regards,
Jayson
Jayson A. Kilcoyne
Project Manager
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898, ext. 108
iayson ci?dunckleedunham.com
mm. du n ckl eed u n h a m. com
DUNCKLEE & DUNHAM
� � E.ti'S:IAVa�TV:A:. GF�LII�.Is.t s 1. fftEt Lc
A Professional Geologic and Engineering Corporation
From: Watson, Edward M[mailto:[e-mail]]
Sent: Thursday, July 12, 2018 9:16 AM
To: Jayson Kilcoyne <[e-mail]>
Subject: RE: [External] SSC Statesville -May 2018 DMR and cover letter-NC0082821
Jayson,
Thank you for the documentation and notification. Can you send me a cell phone contact number. The departmental
cell that I will have on Monday is 704-560-0408, in the event you need to contact me.
Is you're the Southern States corporate person going to attend our meeting? Can the facility maintenance people be
available as well?
See you on Monday.
Regards,
m
1

Watson, Edward M
Edward,
My cell phone number is 919 C32Ok� . Attending the meeting from Southern States will be ennifdrF unt ng
(Env ronmeqtalfiPrggrarns:Manager) and -ohr adden (V ?.ofTnsur.-a"' ce�and R-isk) John is the corporate VP responsible
for SSC s environmental responsibilities. I will be there along with=! omI7unham (VP of Dunekleex&ID�unham). Tom
was at the previous meeting in December 2015 Br Gi ay s fhe�plan1fffi! fag rand='h"0." f Y_b.e able-to�ans�er
,ma nteirai! questions. Scott is their electrician and he tends to do most of the checking of the system when we are not
on -site. I'll see you on londayaat 10 a i.
Regards,
Jayson
Jayson A. Kilcoyne
Project Manager
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898, ext. 108
i ayson((—vdunckleedunham.com
w ww. dunckleedunham.com
DU C'KI EE & DUNTHANI
A Professional Geologic and Engineering Corporation
From: Watson, Edward M[mailto:[e-mail]]
Sent: Thursday, July 12, 2018 9:16 AM
To: Jayson Kilcoyne <[e-mail]>
Subject: RE: [External] SSC Statesville -May 2018 DMR and cover letter-NC0082821
Jayson,
Thank you for the documentation and notification. Can you send me a cell phone contact number. The departmental
cell that I will have on Monday is 704-560-0408, in the event you need to contact me.
Is you're the Southern States corporate person going to attend our meeting? Can the facility maintenance people be
available as well?
See you on Monday.
Regards,
Ed
f
1

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April 14, 1994
LAW
ENGINEERING AND ENVIRONMENTAL SERVICES
Ms. Christine M. DeRoller, Hydrogeologist
North Carolina Department of Environment,
Health, and Natural Resources (NCDEHNR)
Division of Environmental Management
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Subject: Certification Sheet and Schedule of Implementation
Corrective Action Plan
Southern States Fertilizer Plant
Statesville, Iredell County, North Carolina
NCDEE NR Incident No. 5038
Law Environmental Project No. 56-1570
Dear Ms. DeRoller:
N.C. DEPT. OF
ENV IRON M „' _ r
APR 9 5 1994
DIVISION OF ENVIR0I�I�ENi„� rnt��;�u�r�ENT
MOORMILLC,REGIONAL OI•F!CE
On behalf of Southern States Cooperative, Inc. Law Environmental Inc. and Canonie Environmental
Services Corp. acknowledge receipt of your Corrective Action Plan review letter dated March 18, 1994.
As required by your correspondence, we are submitting the attached Certification Sheet and Schedule of
Implementation for corrective action at the site.
Your letter stated that the Corrective Action Plan for this site was satisfactory with the following
modifications:
1. The bottom of recovery well RW-2 will not be permanently sealed until levels of nitrate,
nitrite, total dissolved solids and chloride in K65WTT' and the lowest zone of RW-2 have
been below 2L standards for eight consecutive quarters.
2. All wells except K65W6"B", K65W6"D", and K65W7"D" will be sampled quarterly for the
first year following startup of the groundwater recovery system, then semi-annually
thereafter. The samples will be analyzed as outlined. in Section 5.5 of the plan. All wells
at the site will be gauged quarterly. A report of the results of the site sampling and gauging
will be submitted within 45 days of sample collection.
3. Due to the large volume of groundwater to be pumped at the site, Southern States must
identify potential sources of groundwater contamination off -site and upgradient of or within
the radius of influence of the recovery wells and establish a monitoring program to ensure
that the extraction system is not drawing contaminants on -site.
LAW ENVIRONMENTAL, INC.
2801 YORKMONT ROAD, SUITE 300 • CHARLOTTE, NC 28208
P. 0. BOX 240674 • CHARLOTTE, NC 28224-0674
[phone] • FAX [phone]
ONE OF THE LAW COMPANIES

Ai�
Ms. Chris DeRoller, NCDEHNR Mooresville
April 14, 1994
page 2
Southern States agrees to comply with each of the modifications set forth on the previous page. For the
third item, a study will be conducted to identify potential contaminants which might be generated at
upgradient industrial properties. For example, if an upgradient property owner maintains underground
petroleum storage tanks, a potential for subsurface hydrocarbons may exist. Each property within 1,500
feet of the site boundary will be reviewed, and the potential subsurface contaminants summarized. This
summary of potential contaminants will be submitted to the Mooresville office prior to system startup.
After the corrective action plan is implemented, semi-annual sampling will be conducted for the
subsurface constituents (if any) which have been identified in the study. At this time, we anticipate that
wells K65W6"B", K65W6"D", and K65W7"D" will be sampled because these wells are situated between
the new recovery wells and potential upgradient off -site contaminant sources. If the semi-annual sampling
reveals that the extraction system is drawing contaminants on -site, operation of the system will be
temporarily suspended and an investigation of the contaminant source initiated.
We understand that future site closure will be contingent upon one to two years of consecutive quarterly
data showing nitrate, nitrite, total dissolved solids and chloride levels below 2L standards or showing
asymptotic levels of these constituents.
If you have any questions or comments regarding the information presented herein, please contact us.
Sincerely,
LAW ENVIRONMENTAL NC, INC.
P. Greg Garrett, E.I.T.
;Proj,ngineer
Thomas F. Beggs, P.E.
Principal
cc: Mr. Hilton M. Withers
Southern States Cooperative, Inc.
sAprojectaM15701whedule.cap.
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DIVISION OF ENVIRONMENTAL MANAGEMENT
CERTIFICATION FOR THE SUBMITTAL
OF A CORRECTIVE ACTION PLAN
Responsible Party: Southern States Cooperative, Inc.
Address: P.O. Box 26234
City: Richmond State: VA Zip Code: 23260
Site Name: Statesville Fertilizer Plant
Address: Route 1, Box 639 - Highway 70 East
City: -Statesville State: NC Zip Code: 28677
I, Scott R. Smith Professional Engineer icensed Geologist
(circle one) for Canoni a Environmental Services Corp. ereby certify that the
information indicated below is enclosed as part of the requested Corrective Action Plan (CAP) and
that to the best of my knowledge the data, site assessments, engineering plans and other associated
materials are correct and accurate.
(Each item must be initialed by the certifying licensed professional)
W 4 A listing of the names and addresses of those individuals meeting the
notification requirements of 15A NCAC 2L are enclosed (if applicable).
All Some None (Circle one) of the notification requirements contained in
15A NCAC 2L have been met. A list of any notification requirements not
met is enclosed.
f% A Professional Engineer or Licensed Geologist has prepared, reviewed, or
certified all applicable parts of the CAP in accordance with 15A NCAC 2L
.0103(e).
'5 PS A site assessment is attached which provides the information required by
15A NCAC 2L .0106(g).
A description of the proposed corrective action and supporting
justification is enclosed.
5f.5 Specific plans and engineering details for the restoration of groundwater
quality are enclosed and propose the use of the best available technology
for the restoration of groundwater quality to the levels of the groundwater
standards prescribed in 15A NCAC 2L .0202..
A schedule for the implementation and operation of the CAP is enclosed.
1 A monitoring plan is enclosed which has the capacity to evaluate the
effectiveness of the remedial activity and the movement of the
contaminant plume, and which meets the requirements of 15A NCAC 2L .0110.
The activity which resulted in the contamination incident is not permitted
by the State as defined in 15A NCAC 2L .0106(e) .
(Please Affix Seal and Signature)
Scott R. Smith, P.E.
Certified Engineer
State of North Carolina
GW-100 REV.12/93 No. 18404

April 14, 1994
SCHEDULE OF IMPLEMENTATION
Southern States Fertilizer Plant
Statesville, Iredell County, North Carolina
NCDEHNR Incident No. 5038
1. Submit a complete Authorization to Construct application by April 30, 1994.
2. Submit any additional information requested for the application within 30 days of the request.
3. Install recovery wells RW-4 and RW-5 by May 31, 1994.
4. Begin groundwater recovery by October 1, 1994. (This date is based on the assumption that the
Authorization to Construct application will be approved by the Division within 90 days of the April 30
submittal, and that the system can then be constructed within 60 days. The current semi-annual sampling
plan at the site will be continued until the system is operational.)
5. Install and begin operating additional recovery wells within 60 days of notification by the Division that
they are required.
6. In the event that ground -water effluent does not meet the NPDES criteria, submit a plan for treatment
of the effluent within 60 days of notification by the Division the plan is required. The plan will include
a proposed implementation schedule.
The Division, upon a showing of good cause by Southern States, may extend any of the required
deadlines of the CAP. The term good cause shall include, but not be limited to, any delay or
postponement in the issuance of any relevant or required permit, consent, license or approval to Southern
States by any federal, state or local governmental authority, unless such a delay, or postponement is
caused by Southern States. Southern States must apply for such an extension in writing to the
Mooresville Regional Office prior to the affected deadline.
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Graphic Scale: 1" = 200'
Shallow Aquifer Nitrate Isoconcentratlon Map - July 2017
Statesville Fertilizer Plant DUNCKLEE & DUNHAM
�? Statesville North Carolina ENVIRONMENTAL GEOLOGISTS AND ENGINEERS
Drawn By: Checked By: Project Number: Date: References:
mrw RaC 50200 Oe101)er 2017 Field Notes, NC Oney Test
511 Kcislcr Drive Suite 102 [phone]
Iredall County GIS, Laboratory Test Resul s
Cary, North Carolina 27518 www.dunckleedunham.com
Scale: Size: Layers:: Filename: NC Eng. Licensc No. C-3559 NC Geo. License No. C-261
1" = 200' 11" Z 17110,8,9,10,19-s-whem StacsSues lle Pcnilacr-50200'Fics-Pho,o. Aepott Fgwc 'S've },_1Yw ve

Table 2
Summary of Groundwater Analytical and Field Parameter Results
Southern States, Statesville, North Carolina
ni :s
LabOrata Data
, a
Field Parameters
•_,
N14rate '
Ammonia
-,,,,pHf
temp
onductiv ty
l u-bida
»ORP
;.'
D4it'
5
Well # "bate`
.Standard
Degrees ,
utSlcm
Units °
' Celstas o
2L Standard
10
1.5
K65W6A 1
05/21/15
121" `''
0.12
4.77
19.19
2.986
0.95
149.5
1.4
K65W6B
05/21/15
' 5.8 ''
0.11
4.30
18.54
1.321
1.36
241.9
7.75
K65W6D
05/22/15
NS
NS
NM
NM
NM
NM
NM
NM
K65W6E
05/21/15,
.263 s`-
a
1.5
5.48
17.58
4.463
1.26
110
2.19
K65W6M
05/21/15
0.26
<0.10
5.54
17.5
0.056
14.6
168.3
6.36
K65W6N
OS/21/15
56.1' "r
<0.10
5.20
17.49
0.854
5.50
74.6
0.91
K65W7C
05/22/15
NS
NS
NM
NM
NM
NM
NM
NM
K65W7D
05/20/15
0.07
<0.10
4.88
14.13
0.103
2.77
180.5
1.30
K65W7F
05/20/15
" 16.5
<0.10
5.44
15.32
0.268
0.09
136.4
3.92
K65W7G
05/20/15
'�, 248
. 81.2 n_
NM
NM
NM
NM
NM
NM
K65W7H
05/20/15
0.79
<0.10
4.96
15.27
0.079
0.04
159.2
5.76
K65W7J
05/22/15
146�,°,
3.4' "�
5.05
19.21
1.666
36.5
155.4
1.40
K65 W7K
05/22/15
$7.2. "'
2 8_ ; "'
6.01
16.34
1.226
13.2
103.4
3.13
K65W7L
05/22/15
1d►k ",',
�' 93C: `�
5.24
1 15.69
1.320
3.49
138.5
1.98
Notes:
Bold text indicates above the laboratory method detection limit
Bold text and shaded cell indicate concentration exceeds the A Standard
NS- not sampled - dry well
M- low flow parameters not measured
S'em - milli -Siemens per centimeter
Us - nephelolimetric turbidity units
- millivolts
EV
d, - milligrams per liter

IIIA d
o
Certified Mail # 7015 1520 0002 6984 9362
Return Receipt Requested
May 26, 2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2017-LV-0287
Permit No. NCO082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the February 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample
Location
Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent pH (00400) ' 2/24/2017 6 5.69 Daily Minimum Not Reached
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a
continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent (SOC).
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you have any questions concerning this matter or to apply for an SOC, please contact Edward Watson of
the Mooresville Regional Office at 704-663-1699.
r.
Sincerely,
t-v4 W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
SENDERM,�OMPLETETHIS SECTION COMPLETE THIS SECTION, 'N D
■• Complete items 1, 2, and 3. A. gnature
■ Print your name and address on the reverse 1
so that we can return the card to you. Agent
-❑ Addressee .
■ Attach this card to the back of the mailpiece, e• Received by (P i ted me) C. Date: of Delivery
or on the front if space permits.
1._Article-Addressed_to__ D, Is deliy I �ddil�e§s ni a ene or -Pitem 19 ❑ Yes
SOUTHERN STATES COOPERATIVE INC. If Y S ��n er elivery ad ressingo ❑ No
PO BOX 26234
+RJCI1, %A0ND VA 23260-6234
A'ITN: LAUREN FAULKNER A
dwr/ew 5/26/17 MAY
l
II I IIIIII IIII III I I I I I IIIII III 0 Adult Eice Ty p p r ry Mat s�
III II III I IIIII III ❑ Adult �t nature ❑ �g�steted Mail.
❑ Adult Sig ture Restric ed Delivery Q ftegisfereii Mail Restricted
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2._Article;Number_(T[ansferfrom service /abe/)r _ •❑ collect on Delivery Restricted Delivery ❑ Signature Conti ..rrs:,C . ;1
j ❑ Signature Confirmation
7 0] 5 i 15 2;� i 0 E 2 6� 9 8`4 9 316 2� t 1 Mail Restricted Delivery) 11 t Restrict%d Delivery
500) =
' PS Form 38111,-July 2015`PSN 7530-62-000-9053 ,
_ Domestic Return Receipt
Domestic Mail Only
m
1r
Certified Matl Fee
Er
Extra Services & Fees (check box, add fee as a
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Return Receipt (hardcopy) $ / �i9� y • '
0 ❑ Return Receipt (electronic) $ . 1 'YY Postmarks
r3 ❑ Certified Mall Restricted Delivery $ I i V1� I —
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Total \�
SOUTHERN STATES COOPERATIVE INC.
Ln PO BOX 26234
rr=1 sent RICHMOND VA 23260-6234
171- S(iee ATTN: LAUREN FAULKNER
cry dwr/ew 5/26/17------I--
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

May 26, 2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-LV-0051
Permit No. NCO082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the December 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Limit Exceedance Deficiencv(s):
Sample
Location
Parameter
Limit Reported
Date Value Value Type of Deficiency
001 Effluent pH (00400) 12/29/2016 6 5.88 Daily Minimum Not Reached
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you should need any assistance or would like to discuss this non-compliance situation, please contact Edward`
Watson of the Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

Other Violations/Staff Remarks: f
�`j S��ta�t .FG.i (P�{' �d r� B�� 'l i p�c� ��! �?L✓1/ �� (�r lG� 40

E %O
May 26, 2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-LV-0050
Permit No. NCO082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the January 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Limit.Exceedance Deficiency(s):
Sample
Location
Parameter
Limit Reported
Date Value Value Type of Deficiency
001 Effluent pH (00400) 1/31/2017 6 5.88 Daily Minimum Not Reached
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you should need any assistance or would like to discuss this non-compliance situation, please contact Fdward
Watson of the Mooresville Regional Office at 704-663-1699.
Sincerely,
�. W. Corey Basinger, Regional Supervisor
Water- Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
State of North Carolina i Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

':®MR ReVi& Rec®rd
Facility. 5,;i, . i'er�# Igo lV�'��'�7✓ Pipe No.: poi MbnthlYear: / 2 20l .
s� �.
Other Violations/Staff Rernarlts: C
7`'� `CoUlc�rrv�L�`l,. Y-7/Z + l �..'
6sv
4 7c,,._c �rLct��n�b 3! �"►z !tS" %: c �,rr,,,
�3:93Zf,-, cv� ,v
( io�i1
�iAJ Poo.
p
�jO-ROSi✓1
Regional -Supervisor•Sigri

Geri
Certified Mail # 70151520 0002.8386 8554
Return Receipt Requested
October 13, 2016
Lauren Faulkner
Southern States Cooperative Inc.
P.O. Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF VIOLATION.
Tracking Number: NOV-2016-LV-0557
Permit No. NC0082821
Southern States Fertilizer Plant
Iredell County
Dear Permittee:
A review of the June 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Violation
001 Effluent pH (00400) 6/23/2016 6 5.77 Daily Minimum Not Reached
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a .
continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then -you may wish to consider applying for a Special Order by Consent (SOC).
State of North Caiolina I Environmental:Quality I Water Resources
610 East Center Avenue' Suite 301 Mooresville, NC 28115

If you have any questions concerning this matter or to apply for an SOC, please contact Edward Watson of
the Mooresville Regional_ Office at 704-663-1699.
Sincerely, -
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc! WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File

Certified Mail # 7015 1520 0002 8376 3361
Return Receipt Requested.
June 3, 2016
.Lauren Faulkner,
Southern States Cooperative Inc.
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2016-LV-0286
Permit No. NCO082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the January 2016 Discharge Monitoring Report (DMR) for the subject facility. revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter. Date Value Value Type of Violation
001 Effluent Solids, Total Suspended - .1/7/2016 45 87 Daily Maximum Exceeded
Concentration (C0530)
00.1 Effluent Solids, Total Suspended - 1/31/2016 30 43.5 Monthly Average Exceeded
Concentration (C0530)
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water. Resources may pursue enforcement actions for this and, any additional violations. If the violations are of a
continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent (SOC).
0
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

If you have any questions concerning this matter or to apply for an SOC, please contact Roberto Scheller of
the Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc:' WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement I Init-.Fnfnrrmmnnt M-Io — I.
UNITED STATES POSTAL. SERVICE First-Claes Mail
.�x Postage & Fees Paid
USPS
Permit No. G-10
I
• Sender: Please print your name, address, and_ZIP 4® in this box"
0 m
NCDEQ/WQROS
n
610 EAST CENTER AVE , r
NG G
SUITE 301 > kT 2
MOORESVILLE NC 2811500
-cs
USPS TRACKING#
-n
sr
9590 9403 U.15 I�( )� II p l �ilitlli�liiil'I,IiI jI II IiI IIil 71,1
--�U.S. Postal Service"m
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m7rae
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nJ ❑ Return Receipt (hardcopy) g
Return RecelPt(electronic) $
❑ Certified Mail Restricted Delivery $ �J,� Here ✓J
Adult Signature Required $
I Adult Signature Restricted Delivery
i C3 Postage I l_ 3 20is
ru
I
LSentTo
SOUTHERN STATES COOPER TI INC.
�n $
PO BOX 26234
3 RICHMOND VA 23260-6234
r� ATTN. LAUREN FAULKNER
dwr/rs 6/3/16
I
State of North Carolina I Environmental Quality I Water Resources
610. East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

-... ....... __--_______--_____.... -_-____...... .... ............. ...... ..... .... __.......... ....... ___-__..... _______-_____-__............
From: ]ayson0|coyne
Sent Wednesday, July 11,3O1B1:32PK8
To: Watson, Edward M
Subject: [External] SSC Statesville -May 2018 DIVIR and cover letter-NCO082821
�
`
Edward,
]hebard copy has been mailed to Raleigh. The attached documents are for your records. We will see you at the site on
Monday.
Juvomn
Jayson A. Kilcoyne
Project Manager
jDKeivle,Drive, Suite }02
. Cary, North Carolina 275l8
Office: ol9^858-9898.ext. 108
DUNCKCE-2&DUNHAM
^ =w'�tl
A Professional Geologic and Engineering Corporation

k
�� av C. DEPr-
RES0V-q'CZS AND
AN 0 7 1993
\V
`(� Gilrtalarl ar FfYs;,.:J-�,;::
1 °""' 1�;i0U0? g �i? r f FOd fl it OFFICE NT
State ,of North Carolina -
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor A. Preston Howard, Jr. P.E.
William W. Cobey, Jr., Secretary Acting Director
January 4, 1993
Sam Coon, Operations Manager
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23230
Subject: NPDES Permit Additional Info.
Permit number NCO082821
S.S. Fertilizer Plant
Iredell County
Dear Mr. Coon:
On September 21, 1992, the Division of Environmental Management(DEM) received an
application from Southern States Cooperative requesting a NPDES permit number NC0082821.
Due to concerns with the impact of the discharge to Fourth Creek, DEM requests that Southern
States Cooperative submit a more detailed analysis of the spray irrigation option for the
groundwater for our review. This analysis should include the amount of land needed for treatment
and a cost comparison with the discharge alternative. DEM feels that because of the previous
spray irrigation permit this is a viable alternative. If it is not please explain why in the
analysis.
Please submit this request within 45 days of the receipt of this letter. If not the package will
be returned to you and may be resubmitted upon completion. If you have any questions about what
is requested please feel free to call me at [phone].
cc. •.aresvr:l7g igig ona'ce
Permits and Engineering Unit
Sincerely,
Randy L. Kepler
Environmental Engineer/NPDES Unit
Law Environmental Inc./ Thomas F. Beggs, P.E.
P.O. Box 240674
Charlotte, NC 28224-'0674
Pollution Prevention Pays
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NC0082821
PERMITTEE NAME: Southern States Cooperative, Inc.
FACILITY NAME: S.S. Fertilizer Plant
Facility Status: Proposed
Permit Status: New
Major
Pipe No.: 001
Minor _q
Design Capacity: 0.144 MGD
Domestic (% of Flow):
Industrial (% of Flow):
Comments:
100 %
nitrites �i 'Os
v�ti r,R'
vs, j&W
RECEIVING STREAM: Fourth Creek Je!� f42
Class: C '
Sub -Basin: 03-07-06
Reference USGS Quad: D15SW (please attach)
County: Iredell
Regional Office: Mooresville Regional Office
Previous Exp. Date: 00/00/00 Treatment Plant Class: no classed
Classification changes within three miles:
change to WS-III at the South Yadkin River
Requested by: Randy Kepler & Date: 10/28/92
Prepared by: Date: 2&A.3
Reviewed by: , D,a g 0
�-/ �
Modeler
Date Rec.
#
SA,)
to zq' v
`j a o
1
Drainage Area (mi ) - /6. 5
--� -
Avg. Streamflow (cfs): 46.9
7Q10 (cfs) 7. 5 Winter 7Q10 (cfs) I l F, 30Q2 (cfs) 16
Toxicity Limits: IWC 3 % Acut Chronic Y I'/F
Instream Monitoring:
Parameters
Upstream Location
Downstream Location
Effluent
Characteristics
AotJT;4L-y AV
1 ax
BOD5 (mg/1)
—
NH3-N (mg/1)
74 8 (K 11 CsUMM
y_)
D.O. (mg/1)
TSS (mg/1)
30
S
F. Col. (/100 ml)
pH (SU)
_ 9
Coppez_
MONrTo7- �K
6H w P DES
MonJrroQ- A
N() — N
ko,J T;9
$i�
+X
* Monitoring frequency for NO3-N, TN,TP,copper,chloride should be,,q, least monthly.
**Monitoring frequency for TSS,pH,NH3-N should be in accordance'with treatment
classification or at least 2/month.
TSB recommends that the facility make efforts to meet TP=2 mg/1 and TN=15 mg/1
(monitoring only is recommended in this permit). More stringent controls on nutrient

FACT SHEET FOR WASTELOAD ALLOCATION
t Request # 7180
Facility Name:
NPDES No.:
Type of Waste:
Facility Status:
Permit Status:
Receiving Stream:
Stream Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Topo Quad:
Southern States Fertilizer
NCO082821
Industrial - 100%
Proposed
New
Fourth Creek
C
030706
Iredell
MRO
Kepler
10/28/92
D15SW
A C. DEPT. or NA
rUtAL
nrsouRcEs AND
C0'&fNfLTN£''y D1,;" 'Loper
NT
AM"), 1 9 1993
IMSI04 OF EPY NOMMENTAL MAHAGEMLff
9600VIsw€ ERG19NAA OFFICE -
Stream Characteristic:
USGS #
Date:
Drainage Area (mi2):
46.5
Summer 7Q10 (cfs):
7.5
Winter 7 Q1 0 (cfs):
11.3
Average Flow (cfs):
46.5
30Q2 (cfs):
16 _
IWC (%):
2.89 ">
Wasteload Allocation Summary
(approach taken, correspondence with region, EPA, etc.)
SS Fertilizer plans to remediate nitrate contaminated groundwater. The facility will receive an ,
ammonia limit based on water quality constraints. Because this receiving water eventually enters
High Rock Lake, which is eutrophic, minimum treatment of 15 mg/l total nitrogen and 2 mg/l total
phosphorus is recommended. (More stringent controls on nutrient inputs may be required in the
future)..
Monitoring of inorganic parameters is recommended due to potential impact to the receiving stream
(especially with regard to copper, chlorides). Toxicity testing will be implemented
Special Schedule Requirements and additional comments from Reviewers:
Recommended by: Date: S « 3
Reviewed by
Instream Assessment: T� C\-'l_�r.� ��2 ; :�, Date: I
Regional Supervisor: Date:
Permits & Engineering: Date:
S P 1 4 1993
RETURN TO TECHNICAL SERVICES BY: -

2
Type of Toxicity Test:
Existing Limit:
Recommended Limit:
Monitoring Schedule:
Recommended Limits
TSS (mg/1):
pH (SU):
NH3-N:
Copper (µg/1):
Chloride (µg/1):
NO3-N
TN
TP
TOXICS/CONVENTIONAL PARAMETERS
Chronic
Chronic P/F at 3 %
Aug, Nov, Feb, May
30 Mon. Avg. 45 Daily Max. Frequency
**
6-9
7.8 mg/1 **
monitor
monitor
monitor
monitor
monitor
WQ/EL
NOTE: TSB recommends that the facility make efforts to meet TP=2 mg/l and TN=15 mg/l
(monitoring only is recommended in this permit)
* Monitoring frequency for NO3-N, TN, TP, copper, chloride should be at least monthly.
** Monitoring frequency for TSS, pH, NH3-N should be in accordance with treatment
classification or at least 2/month.
_X Parameter(s) are water quality limited. For some parameters, the available load capacity of
the immediate receiving water will be consumed. This may affect future water quality based
effluent limitations for additional dischargers within this portion of the watershed.
No parameters are water quality limited, but this discharge may affect future allocations.
MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS
Special Instructions or Conditiona
Additional Information attached? (Y or N) If yes, explain with attachments.

Facility Name ('� t E�Tll.6�g(L Permit # ICODL20 —2- ! Pi #
Pipe
CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The effiucntdischarge shall at no tine exhibit chronic toxicity using test procedures Outlined in: �
1.) The North Carolina Ceriodanhnia chronic effluent bioassay
rDce
Procedure - Revised *September 1989) or subsequent versionsP �� (North Carolina Chronic Bi
.oassay
The effiumt concentration at which there may be no observable inhibition of roduction
is 3 % (defined as treatment two in the North Carolina � or oldercant mortality
monitoring using this procedure to establish c document). The permit holder shall perform
Performed after thirty days from the effective date of this compliance with the permit condition. The first test will be
y permit during the months of
�y .Effluent sampling for this tes
permitted final effluent discharge below all tircatmcnt processes. ting shall be performed at the NPDES
All toxicity testing results required as pan of this
Monitoring Form (MR-1) for the month in which rp f w�ast edition will be entered on the Fluent Discharge
Additionally, DEM Form AT-1 (original) is to be sent to the followm' �g the Parameter code TGP3B.
g address:
Attention Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
Test data'shall be complete and accurate and include all s _
association with the toxicity tests, as well"as all dose/respon�ntacTotalcdual chlorine measurements
re the effluent performed
timed in
sample must be measured and reported if chlorine is employed for disinfection of the waste stream, xi�ty
Should any single quarterly monitoring indicate a failure to meet begin immediately until such time that a.single test is passed. Upo�a si gg�s monmonthly monitoring will
revert to quarterly in the months specified above. requirementwill
Should any test data from this monitoring requirement or tests performed by the North Carolina Divi i
Environmental Management indicate potential impacts to the receivin s son of
modified to include alternate monitoring requirements or limits, g gym' this permit may be re -opened and
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival and appropriate environmental controls shall constitute an invalid P g
retesting(within 30 days of initial monitoring event). Failure to submit suitable and
results will consti to
noncompliance with monitoring requirements.
7Q 10 -7 5 CA
'WC C mlitted Flo�wgD .�� MGD
Basin & Sub -basin _ 03o � (o
Receiving Stream _F
County l2.er2ELL,
Recommended by:
Date B 11111 i 3
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'Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr.., P.E., Director
Mr. Charles Anderson
Canonie Environmental
800 Canonie Drive
Porter63(�,4
�.
Dear Mr: Anderson:
N.C. DEPT. of Aril 27, 1994 I (,
LINVIRONMENRT, ARCH
� NATURAL
FS
M fay 4 1994 L
.a •-- 177'v1
ENV. MANACEMEINIT
FAYETTEVILLE REG. OFFICE
OF E
Qlll(S1011 tIV1ROP1tAEHTAI trSRHAG 1Authorization to Construct Request
ect: Application Number AC0082821
AM1OORE�VIIIE REGIONAL NAG
Southern States Cooperative, Inc.
.-Riehniond County
The Division of Environmental Management, Permits and Engineering Unit, hereby acknowledges
receipt of your request for Authorization to Construct wastewater treatment facilities in accordance with
NPDES Permit Number NC0082821. This application has been assigned the number shown above.
Preliminary review indicates that the following items must be provided before final action is taken:
1) A site location map (figure 1), piping layout (figure 3) and specifications cover page
(section 4) signed and sealed by a professional engineer registered in North Carolina.
2) Delegation of signatory authority as required by Part II, Section B.1 Lb. of the NPDES
permit.
Refer to the subject permit application number when providing the requested information. Please
submit three copies of all information to my attention at the address below. Also, please
note that failure to provide this additional information on or before June 1, 1994 will subject your
application to being returned as incomplete.
Please be aware that the Division's regional office, copied below, must provide recommendations
from the Regional Supervisor prior to final action by the Division.
If you have any questions, please contact me at [phone], extension 541.
i,' o o'2CS U l L E
cc: lfayettevMe Regional Office
Southern States Cooperative
Sincerely,
lgiziclh,nvironmental Engineer
NPDES Permits Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 500/6 recycled/ 10% post -consumer paper

State of North Carolina
' Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Vivian H. Burke, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 10, 1993
Mr. Sam Koon
Southern States Cooperative
6606 West Broad Street .
Richmond, Virginia 23230
Subject:. NPDES Permit No. NCO082821
S. S. Fertilizer Plant
Iredell County, NC
Dear Mr. Koon:
Our records indicate that NPDES Permit No. NCO082821 was
issued on December 1, 19931for the discharge of wastewater to the
surface waters of the State from your facility. The purpose of
this letter is to advise you of the importance of.the Permit and
tr.� liabilities in the event of failure to comply with the terms
and conditions of the Permit. If you have not already done so, it
is suggested that you thoroughly read the Permit. Of particular
importance are Pages 4-5.
Pages 4-5 set forth the effluent limitations and monitoring
requirements for your discharge(s). Your discharges) must not
exceed- any of the limitations set forth. The section headed
"Monitoring Requirements" describes the measurement frequencies,
sample types and sampling locations. Upon commencement of your
discharge (or operation), you , must initiate the required
monitoring. The monitoring results must be entered on .the
reporting forms furnished to you -by this Agency. If you have not
received these forms, they should be arriving shortly. If you fail
to receive the forms, please contact this Office as quickly as
possible. I have enclosed a sample of the "Effluent" reporting
form (DEM Form MR-1), plus instructions for completing the form.
It is imperative that all applicable parts be completed, and the
original and one copy be submitted as required.
The remaining Parts of the Permit set forth definitions,
general .conditions and special conditions applicable to the
operation of wastewater treatment facilities and/or-discharge(s).
The conditions include special reporting requirements in the event
of noncompliance, bypasses, treatment unit/process failures, etc.
Also -addressed are requirements for a certified wastewater
treatment plant operator if you are operating wastewater treatment
919 North Main Street, Mooresville; North Carolina 28115 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Sam Koon
Page Two
December 10, 1993
facilities. Any changes in operation of wastewater treatment
facilities, quantity and type of wastewater being treated or
discharged, expansions and/or upgrading of wastewater treatment
facilities must be permitted or approved by this Agency.
Failure to comply with the terms and conditions of an NPDES
Permit subjects the Permittee to enforcement action pursuant to
Section 143-215.6 of the North Carolina General Statutes. A civil
penalty of up to $10,000 per violation plus criminal penalties may
be assessed for such violations. If you find at any time that you
are unable to comply with the terms and conditions of the Permit,
you should contact this Office immediately A Consent Order may be
necessary while pursuing action to obtain compliance.
As a final note, an NPDES Permit is normally issued for a
five-year period. Permits are not automatically renewed. Renewal
requests must be submitted to this Agency no later than 180 days
prior to expiration. Please make note of the expiration date of
your Permit. This date is set forth on Page 1 of the Permit. Also
note that NPDES Permits are not transferable. If you, as the
Permittee, cease to need this Permit, then you should request that
the Permit be rescinded.
As mentioned previously,
advise you of the importance of
Permit and contact this office
you have any questions or need
providing any assistance.
Enclosure
DRG:s1
-the purpose of this letter is to
your NPDES Permit. Please read the
at 704/663-1699 in Mooresville if
clarification. We look forward to
Sincerely,
Dl-�XRe,2Lo4n,
�, P.. E.
Water Quality Regional Supervisor

�- DUNCKLEE
_ & DUNHAM
October 25, 2010
Mr. Bob Sledge
North Carolina Division of Water Quality
Surface Water Protection
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ENVIRONMENTAL CONSULTING & ENGINEERING
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W WW.DUNCKLEEDUNHAM.COM
Reference: Treatment System Reactivation and Status Update
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit NCO082821
Dear Mr. Sledge:
Duncklee & Dunham, P.C. (Duncklee & Dunham), on behalf of Southern States Cooperative, Inc.
(Southern States), by means of this letter is notifying the North Carolina Division of Water Quality
(NCDWQ) Surface Water Protection (SWP) Section of the reactivation of the groundwater treatment
system at the above referenced site. The NPDES permit covers the discharge from the groundwater
remediation system. The permit was placed on an "Inactive" status in May 2010 to service the treatment
system and to reduce the costs associated with monthly reporting of "no flow" and site inspections.
Since May 2010, the pH monitoring system was upgraded, recovery wells were serviced, and the
electrical components upgraded.
The treatment system is scheduled to be reactivated on Tuesday, November 9, 2010. Compliance
monitoring in accordance with the NPDES permit will commence once the system is operating.
MAILING ADDRESS - POS r OFFICE Box 33366 - RALE1G1I. Nop,ni CAROLINA 27636
NORTH CAROLINA Bo\RD of E\AMLNF,RS FOR ENGINEERS, AND SURVEYORS LICENSE C-3i59
NOR H I CAROLINA BOARD FOR LICENSING OF GEOLOCIISTS LFCENSP C 261
NC DENR REGFSTERED ENVIRON,41rNTAL CONSULT ,4Nl'NUMBER 00061

Treatment System Status and Reactivation Update
Southern States Cooperative -Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
October 25, 2010
Page 2 of 2
If you have any questions or require any additional information please do not hesitate to contact
Mr. Jayson Kilcoyne of Duncklee & Dunham at [phone] (la sy on a,dunckleedunham.com) or
Mr. Vance Dann of Southern States at [phone] ([e-mail]).
Sincerely,
Duncklee & Dunham, P.C.
Jayson A. Kilcoyne
Project Environmental Scientist II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist
c: Mr. Rob Krebs — DWQ Surface Water Protection -Mooresville Regional Office (e-copy)
Mr. Vance Dann — Southern States Cooperative, Inc. (e-copy)
Ms. Lauren Barlow - Southern States Cooperative, Inc. (e-copy)
PASouthern States\Statesville Fertilizer - 50200\Forms-Corresp\NPDES-Treatment System Docs\Treatment System Reactivation letter-10249.doc
DtrNCKLEE &DUNHAN'l, P.C.

Air
NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
May 24, 2010
Mr. Vance Dann
Southern States Cooperative, Inc.
6606 W Broad St
Richmond, VA 23260-6234
Resources
Dee`Freeman
Secretary .
JUN 7 2010
Subject: Waiver of Monthly Reporting Requirement
Statesville Fertilizer Plant
NPDES Permit NCO082821
Iredell County
Dear Mr. Dann:
The Division has reviewed your consultant's letter of May 13, 2010, submitted by Jayson A. Kilcoyne of
Duncklee & Dunham. The letter states the subject facility is not producing any wastewater discharge and
will not until October 2010.
After considering the recommendations of the staff in the Mooresville Regional Office, I have agreed to
waive the requirement to submit monthly DMRs for the subject facility, effective May 1, 2010 The DMRs
up through (and including) April 2010-should be submitted as usual.
Be advised that if and when any wastewater discharge resumes, the discharge must be monitored as per
the terms of the NPDES permit and other applicable rules or statutes. Please keep the Mooresville
Regional Office apprised of any pertinent developments that arise regarding this facility, especially if the
discharge is re -activated.
While requirements for operator visitation, monitoring and reporting are being waived, your company is�
still required to pay the Annual Administering and Compliance Monitoring Fee that is associated with this
and all NPDES permits.
If you have any questions, or if you wish to request rescission of this permit, contact Charles H. Weaver, Jr.
at 919 807-6391.
cc: Central Files
,iloo esville_R 1 Office !"Wes B:e11 -?
NPDES Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: www.ncwaterquality.org
Sincerely,
Coleen H. Sullins
Iof
One `
NorthCarohna
An Equal Opportunity/Affirmative Action Employer- 50% Recycled/10%a Post Consumer Paper

DUNCKLEE ENVIRONMENTAL CONSULTING & ENGINEERING
4- 511 KEISLER DRIVE - SUITE 102
7 �H� CARY, NORTH CAROLINA 27518
& D V 1 AM OFFICE: [phone]
W W W.DUNCKLEEDUNHAM.COM
RECEIVED
DIVISION OF WATER C!? �ALI T Y
June 1, 2011 J U N . 3 1"a
MOORESVILLE RE6-iU 'AL OFFICE
Mr. Bob Sledge
North Carolina Division of Water Quality
Surface Water Protection
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Request to Place Permit in "Inactive" Status
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit NCO082821
Dear Mr. Sledge:
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C.
(Duncklee & Dunham) is submitting this letter to inform you that the remediation system at the above
referenced site was shut off on April 20, 2011, and to request that the NPDES permit be placed on an
"Inactive" status. The current NPDES permit is effective until March 31, 2014, and covers the discharge
from a groundwater remediation system.
The groundwater remediation system consists of three groundwater extraction wells, a lift station with
wet well, a sodium hydroxide feed system to adjust the pH of the groundwater, and a surface water
discharge to Fourth Creek.
The remediation system is shut down annually between April and October due to low water table
conditions and the recovery wells going dry. During this period, Southern States is requesting the
NPDES permit be placed on an "Inactive" status to reduce the costs associated with monthly reporting of
"no flow" and inspections.
MAILING ADDRESS - POST OFFICE BOX 33366 - RALEIGH, NORTH CAROLINA 27636
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DENR REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061

Request to Place Permit in "Inactive" Status
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NC0082821
June 1, 2011
Page 2 of 2
If you have any questions or require any additional information please do not hesitate to contact
Mr. Tom Dunham of Duncklee & Dunham at [phone] (TDunhamgDunckleeDunham.com) or
Mr. Vance Dann of Southern States at [phone] (Vance.DanngSSCoon.com).
Sincerely,
Duncklee & Dunham, P.C.
J son A. Kilcoyne
Project Environmental Scientist II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist
Cc: Mr. Wes Bell — DWQ Surface Water Protection — Mooresville Regional Office (e-copy)
Mr. Vance Darin — Southern States Cooperative, Inc. (e-copy)
Mrs. Lauren Faulkner - Southern States Cooperative, Inc. (e-copy)
PASouthem States\Statesville Fertilizer - 50200\Forms-Corresp\NPDES-Treatment System Docs\Inactive Status RequestsUnactive Status
Request- 11121.doc
DUNCKLEE & DUNHAM, P.C.

NC®ENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
June 16, 2014
CERTIFIED MAIL #7010 1870 0001 1558 1276
RETURN RECEIPT REQUESTED
Ms. Lauren N. Barlow
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230-1717
Subject: Notice of Violation and Notice of Recommendation for Enforcement
Tracking #: NOV-2014-LV-0263
Statesville Fertilizer Plant
NPDES Permit No. NCO082821
Iredell County
Dear Ms. Barlow:
A review of the January 2014 self -monitoring report for the subject facility revealed violations of the
following parameters at Outfall 001:
Date
Parameter
Reported Value
Permit Limit
1/8/14
TSS
67.0 mg/L
45.0 mg/L (Daily maximum)
1/31/14
TSS
33.5 mg/L
30.0 mg/L (Monthly average)
A Notice of Violation and Notice of Recommendation for Enforcement (NOV/NRE) is being issued
for the noted violations of North Carolina General Statute (G.S.) 143-215.1 and NPDES Permit No.
NC0082821. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand
dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance
with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
If you wish to provide additional information regarding the noted violations, request technical
assistance, or discuss overall compliance please respond in writing within 10 days of receipt of this
Notice. A review of your response will be considered along with any information provided on the
January 2014 Discharge Monitoring Report. You will then be notified of any civil penalties that may
be assessed regarding these. violations. If no response is received in this Office within the 10-
day period, a civil penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any problems. The Division
of Water Resources may pursue enforcement actions for this and any additional violations. If the
violations are of a continuing nature, not related to operation and/or maintenance problems, and you
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: http://portal.ncdenr.org/web/wq
An Equal Opportunity %Affirmative Action Employer - 30% Recycled110% Post Consumer paper

NOV-2014-LV-0263, Page 2
i
anticipate remedial construction activities, then you may wish to consider applying for a Special Order
by Consent.
If you have questions concerning this matter, please do not hesitate to contact Ms. Marcia Allocco or
myself at [phone].
cc: Wastewater Branch
MSC 1617 — Central Files Basement
MA
Sincerely,
P
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
■•Complete itemsl;'2; and 3. Also complete
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item 4 if. Restricfdd. gelivery is desired.
■ Print your. nat7i3 hd' address on the reverse
so that We'can f6turn the,card•to you.
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■ Attach this'card10-the back of the mailpiece,
or on the front if space permits.
D.
1. Article Addressed to:
I SOUTHERN STATES COOPERATR!VE
6606 WEST BROAD STREET
RICHMOND VA 23230-1717
A1TN: MS LAUREN BARLCW 3.
dwr/ma 6/16/14
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J de every address d t from it
1? ❑Yes
If YES, enter delivery add " ❑ No
JUN z 0 2014 43'
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0 Registered Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
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6606 WEST BROAD STREET
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DUNCKLEE
- & DUNHAM
February 24, 2014
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (9195 858-9898
W W W .DUNCKLFEDUNHAM.COM
North Carolina Department of Environment and Natural Resources
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Notification of Non -Compliance
Southern States Fertilizer Plant
Statesville, North_Carolina
NPDES Permit Number: NCO082821
To Whom it May Concern:
R�ItI; IC.sw t-'au Jr '� F C±UN I V Y
JU;J 2, LU i,.
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee
& Dunham) is submitting this notification of non-compliance letter for the permitted daily effluent limit
for total suspended solids (TSS) at the above referenced site.
The TSS sample we collected from the treatment system effluent on January 8, 2014, was detected by the
laboratory above the permitted daily maximum allowance of 45 mg/L at a concentration of 67 mg/L.
Upon our arrival on January 8, 2014, we discovered that the treatment system was not cycling water. We
reset the recovery well pumps at the control panel and the pumps began filling the treatment system wet
well. We collected the sample approximately one hour after the pumps were reset. The elevated TSS
detected in the effluent sample is believed to be a direct result of the pumps having been off and restarted
prior to sampling. Therefore, no corrective actions are believed necessary at this time.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to call us as [phone].
Sincerely,
Duncklee & Dunham, P.C.
Senior Peer Review:
F 0�
y
Jayson A. Kilcoyne Thomas S. Dunham
Project Environmental Scientist II Senior Geologist
e-copy: Vance Dann — Southern States Cooperative, Inc.
\\boss\files\Projeets\Southern States\Statesville Fertilizer - 50200\Forms-Corresp\N0V_NCDENR Corres\2014Uan 2014.docx
MAILING ADDRESS — POST_ OFFICE Box 639 — CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTII CAROLINA BOARD FOR LICENs1NG OI: GEOLOGIs'I's L.ICrNSI C-201
NC DENR REGISTERED ENVIRONiME,NTAL CONSULTANT NumBER 00061

EFFLUENT
NPDES PERMIT NO, NCO082821 DISCHARGE.. NO. 001 MONTH January YEAR 2014
FACILITY NAME Southern States Fertilizer Plant CLASS COUNTY iredell
CERTIFIED LABORATORY (1) Pace Analytical Laboratories, Inc. CERTIFICATION NO. 12/40
(list additional laboratories on the backside/page 2 of this form)
OPERATOR 1N RESPONSIBLE CHARGE (ORC) Jayson A. Kilcoyne GRADE I CERTIFICATION 1`10. 992461
PERSON(S) COLLECTING SAMPLES Jayson A. KHcoyne ORC PHONE [phone]
CHECK BOX 1F ORC HAS CHANGED NO FLOW / DISCHARGE FROM SITE
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES x
DIVISION OF WATER QUALITY (SIGNATURE O E A RESPONSIBLE CHARGE) DA" E
1617 HAIL SERVICE CENTER BY THIS SIGN [RE, 1 CERTIFY THAT THIS REPORT IS
RALEIGH. NC 27699-1617 ACCURATE AN COMPLETE TO THE BEST OF MY KNOB"LEDGE.
50050
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00665
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DWQ Form NIK.I (11/04)

Facility Status; (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages, if applicable)
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements r 7X
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time
the permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part II.E.6 of the NPDES permit.
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who managed the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
Ja_yson A.. Kilcoyne
Permittee (Please print or type)
LA-A��- �1- I
Signa re f Pertn ittee* * * Dat
(Requ e unless submitted electronically)
6606 West Broad St., Richmond, VA 23230 804-281-1262 1aufen.bar1owassc000.com 3/31/2014
Permittee Address Phone [Dumber e-mail address Permit Expiration Date
ADDITIONAL CERTIFIED LABORATORIES
Certified Laboratory (2) Duncklee & Dunham, P.C. Certification No.
Certified Laboratory (3) Certification No.
Certified Laboratory (4)
Certified Laboratory (5)
PARAMETER CODES
Certification No.
Certification No.
5484
Parameter Code assistance may be obtained by calling the NPDES Unit at (9I9) 733-5083 or by visiting the Surface
Water Protection Section's web site at h2o.enr.state.nc.us/wgs and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the pemtittee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2

Few= I L
MCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III
Governor Secretary
July 15, 2014
Ms. Lauren N. Barlow
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230-1717
Subject: Response to NOV-2014-LV-0263
Statesville Fertilizer Plant
NPDES Permit No. NCO082821
Iredell County
Dear Ms. Barlow:
Mooresville Regional Office staff reviewed the Southern States Cooperative, Inc. response to the Notice of
Violation and Notice of Recommendation for Enforcement NOV-2014-LV-0263 received on June 25, 2014.
Based upon the review, mitigating circumstances were found that would justify no further action being
taken against Southern States Cooperative, Inc. at this time. Be advised that should noncompliance
continue, enforcement action, including the assessment of civil penalties, could be taken by the Division of
Water Resources in accordance with G.S. 143-215.6A(a)(2).
Thank you for your continued cooperation with the Division of Water Resources. Should you have any
questions regarding the decision by this office in regards to this matter please contact Ms. Marcia Allocco
or myself at [phone].
Sincerely,
t
Michael L. Parker, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617 —"Central Files Basement
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] \ Fax: [phone] \ Customer Service:1-877-623-6748
Internet: htta://Portal.ncdenr.org/web/wg

NCDENR BUG 18 2014
North Carolina Department of Environment and Natural Resources
Pat McCrory Jo hn�E.!SkvarI8'
Governor Secretary
August 12, 2014
CERTIFIED MAIL 7013-2630-0001-8998-0621
RETURN RECEIPT REQUESTED
Ms. Lauren B. Faulkner
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23260-1717
Subject: NOTICE OF VIOLATION -
Southern States Fertilizer Plant
NPDES Permit NCO082821
Iredell County
NOV-2014-LR- 0033
Dear Ms. Barlow:
This is to inform you that the Division of Water Resources did not receive your monthly monitoring report
for May 2014. This is in violation of Part H, condition D(2) of the NPDES permit, as well as 15A NCAC 2B
.506(a), which requires the submittal of Discharge Monitoring Reports no later than the last calendar day
following the reporting period. Failure to submit reports as required will subject the violator to the
assessment of a civil penalty of up to $25,000 per violation. You will be considered noncompliant with the
self -monitoring requirements of your NPDES permit until the report has been submitted.
To prevent further action, please submit said report within fifteen (15) days of receipt of this notice.
Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if
fixture reports are not received within the required time frame during the next twelve (12) reporting months.
The Division must take these steps because timely submittal of discharge monitoring reports is essential to
the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you
have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or
via e-mail at [e-mail].
S ' cer ly,
John fHenncssy
Division of Water Resources, NCDENR
cc: Derek Denard, Compliance & Expedited Permitting Unit
DWR-IVlooresvrlle=Regional Office.Stipervisoi; Surface Water Piotectioii Section
Central Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] Internet: http://www.ncwaterquality.org/
An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper

u
DUNCKLEE
& DUNHAM
January 30, 2012
ENVIRONMENTAL CONSULTING & ENGINEERING
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
WW W.DIINCKLEEDIINHANI.COM
Ms. Marcia Allocco
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Reference: Explanation of Non -Compliance
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NCO082821
Dear Ms. Allocco:
RECE.6fJED
DIVISION 0F',AtPTE=PZ QUALITY
JAN v G 201Z
SVVP
100ORESVILLE OFF ICE
Duncklee & Dunham, P.C. (Duncklee & Dunham) is submitting this notification of non-compliance for a
monthly effluent sampling requirement at the above referenced site.
The site's groundwater pump and treat system was restarted on October 25, 2011, after being shut down
for the six months prior. As part of the startup, operation and maintenance activities were conducted and
the treated water generated was monitored for temperature and pH prior to discharge. The discharge was
within permitted limits.
The goal of the operation and maintenance site visit was to calibrate the pH metering system and to be
sure the groundwater extraction wells and ancillary pumps were working property. A monthly effluent
sample was not collected at the time of the system startup. However, the monthly effluent sampling
schedule was initiated in November and is currently being conducted in accordance with the NPDES
permit. Our failure to collect an effluent sample for the six days the system was operational at the end of
October was an oversight.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to call us as [phone].
Sincerely,
DUNCKLEE & DUNHAM, P.C.
Senior Peer Review:
Jayson A. Kilcoyne
Thomas S. Dunham
Project Environmental Scientist II
Senior Geologist
c: Mr. Vance Dann — Southern States Cooperative, Inc.
P:\Southern States\Statesville Fertilizer - 50200\Forms-Corresp\NOV and NCDENR Corres\2012\Non Comp Letter- I 2044.docx
MAILING ADDRESS - POST OFF1cE Box 33366 - RALEIGFI, Nof-'TI I CAROLINA 27636
NORTH CAROLIN 1 BOARD OF E,x.1l-.I.I.ZERS FOR h1VU1NE.ERS A:�1> 9UR' EYORS LICENSE ENSE C-3559
NfJm H CARROLINA BOARD FOR LICENSING OF GEOW(iisT5 LIC:ENSIi C-261
NC DENR REGISTLRED ENVIROMOE,WAI. CONSUI TAN1' N" UMBLR 00061

Allocco, Marcia
From: Jayson A. Kilcoyne [e-mail]]
Sent: Monday, January 30, 2012 2:34 PM
To: Allocco, Marcia
Cc: 'Tom Dunham'
Subject: Southern States - Statesville Fertilizer Plant effluent sampling letter
Attachments: Non Comp Letter-12044 - E-COPY.pdf
Hi Marcia,
Per our conversation on January 24, 2012, Please find the attached letter explaining the October 2011 treatment system
effluent monitoring. Please let me know if you have any additional questions.
Regards,
Jayson
Jayson A. Kilcoyne
Project Environmental Scientist II
Duncklee & Dunham, PC
511 Keisler Drive, suite 102
Cary, North Carolina 27518
email: iayson a.dunckleedunham.com
phone: [phone], ext. 212
Website: www.dunckleedunham.com
A Professional Geologic and Engineering Corporation

Bell, Wes
From: Jayson A. Kilcoyne [e-mail]]
Sent: Wednesday, October 26, 2011 1:03 PM
To: Bell, Wes
Cc: Meadows, Susan
Subject: Notification of system restart -Southern States -Statesville Fertilizer Plant
Hi Wes,
I restarted the treatment system at the Statesville Fertilizer plant on October 25, 2011. 1 will
continue with the effluent and bioassay sampling schedules beginning in early November.
Regards,
Jayson
Jayson A. Kilcoyne
Project Environmental Scientist II
Duncklee & Dunham, PC
511 Keisler Drive, suite 102
Cary, North Carolina 27518
email: iayson cr.dunckleedunham.com
phone: [phone], ext. 212
Website: www.dunckleedunham.com

Bell, Wes
From: Krebs, Rob
Sent: Thursday, October 28, 2010 7:46 AM
To: Allocco, Marcia; Bell, Wes; Bou-ghazale, Samar; Browder, Dee; Burkhard, Michael W; Ertel,
Debbie; Hood, Donna; Johnson, Alan; Lesley, John; Lespinasse, Polly; Parker, Michael;
Sifford, Barbara; Smith, Kent; Snider, Lon
Subject: FW: Southern States -Statesville Fertilizer Plant treatment system letter
Attachments: Treatment System Reactivation letter-10249 - E-COPY.pdf
FYI
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
Rob Krebs - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
From: Jayson A. Kilcoyne [e-mail]]
Sent: Tuesday, October 26, 2010 7:51 AM
To: Krebs, Rob
Subject: Southern States -Statesville Fertilizer Plant treatment system letter
Please find the attached treatment system reactivation letter for the Statesville Fertilizer Plant. Please let me know if you
have any questions.
Thanks,
Jayson
Jayson A. Kilcoyne
Project Environmental Scientist U
Duncklee & Dunham, PC
511 Keisler Drive, suite 102
Cary, North Carolina 27518
email: iayson�(Tdunckleedunham.com
phone: [phone], ext. 212
Website: www.dunckleedunham.com

DUNCKLEE
& DUNHAM
October 25, 2010
Mr. Bob Sledge
North Carolina Division of Water Quality
Surface Water Protection
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ENVIRONMENTAL CONSULTING & ENGINEERING
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DLJNCKLEEDUNHAM.COM
Reference: Treatment System Reactivation and Status Update
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit NCO082821
Dear Mr. Sledge:
Duncklee & Dunham, P.C. (Duncklee & Dunham), on behalf of Southern States Cooperative, Inc.
(Southern States), by means of this letter is notifying the North Carolina Division of Water Quality
(NCDWQ) Surface Water Protection (SWP) Section of the reactivation of the groundwater treatment
system at the above referenced site. The NPDES permit covers the discharge from the groundwater
remediation system. The permit was placed on an "Inactive" status in May 2010 to service the treatment
system and to reduce the costs associated with monthly reporting of "no flow" and site inspections.
Since May 2010, the pH monitoring system was upgraded, recovery wells were serviced, and the
electrical components upgraded.
The treatment system is scheduled to be reactivated on Tuesday, November 9, 2010. Compliance
monitoring in accordance with the NPDES permit will commence once the system is operating.
MAILING ADDRESS — POST OFFICE Box 33366 — RALEIGFL NORTH CAROLINA 27636
NORTH CAROLINA BOARD OF EXANIMRS FOR ENGINEERS AND SURVEYORS LECENSE C-3559
No iuii CaROUNA BOARD FOR LICENSING OF CI1"01.00STS LICENsia C-261
NC DENR REGISTERED ENVIRONMENTAL CONSUI-TANT NUMBER 00061

Treatment System Status and Reactivation Update
Southern States Cooperative -Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
October 25, 2010
Page 2 of 2
If you have any questions or require any additional information please do not hesitate to contact
Mr. Jayson Kilcoyne of Duncklee & Dunham at [phone] (jayson a,dunckleedunham.com) or
Mr. Vance Dann of Southern States at [phone] ([e-mail]).
Sincerely,
Duncklee & Dunham, P.C.
Jayson A. Kilcoyne
Project Environmental Scientist II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist
Mr. Rob Krebs — DWQ Surface Water Protection -Mooresville Regional Office (e-copy)
Mr. Vance Dann — Southern States Cooperative, Inc. (e-copy)
Ms. Lauren Barlow - Southern States Cooperative, Inc. (e-copy)
P:\Southern States\Statesville Fertilizer - 50200\Forms-Corresp\NPDES-Treatment System Docs\Treatment System Reactivation letter- 10249. doe
DUNCK1.E'F & DUNI [AM, P.C.

A4 iLA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Mr. Vance Dann
Southern States Cooperative, Inc.
6606 W Broad St
Richmond, VA 23260-6234
Dear Mr. Dann:
RECEIVED
June 9, 2011 DIVISION OF WATER QUALITY
JUid 16 2011
Dee Freeman
Secretary
SVVP SECTION
MOORESVILLE REGIONAL OFFICE
Subject: Waiver of Monthly Reporting Requirement
Statesville Fertilizer Plant
NPDES Permit NCO082821
Iredell County
The Division has reviewed your consultant's letter of June 13, 2011, submitted by Jayson A. Kilcoyne of
Duncklee & Dunham. The letter states the subject facility is not producing any wastewater discharge and
will not until October 2011.
After considering the recommendations of the staff in the Mooresville Regional Office, I have agreed to
waive the requirement to submit monthly DMRs for the subject facility, effective May 1, 2011 The DMRs
up through (and including) April 2011 should be submitted as usual.
Be advised that if and when any wastewater discharge resumes, the discharge must be monitored as per
the terms of the NPDES permit and other applicable rules or statutes. Please keep the Mooresville
Regional Office apprised of any pertinent developments that arise regarding this facility, especially if the
discharge is re -activated.
While requirements for operator visitation, monitoring and reporting are being waived, your company is
still required to pay the Annual Administering and Compliance Monitoring Fee that is associated with this
and all NPDES permits.
If you have any questions, or if you wish to request rescission of this permit, contact Charles H. Weaver, Jr.
at 919 807-6391.
;!)incereiy,
r
Coleen H. Sullins
cc: Central Files
M6dresuille=Regional-,Offi_ce-G'Wes. Belly'
NPDES Files
Jayson A. Kilcoyne / Duncklee & Dunham (P.O. Box 33366, Raleigh, NC 27636)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
512 North Salisbury Street, Raleigh, North Carolina 27604 NorthCarolina
Phone: [phone] FAX [phone] I Internet: www.ncwaterquality.org Nahmally
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper

Bell, Wes
From: Vance Dann [[e-mail]]
Sent: Friday, June 22, 2012 9:58 AM
To: Weaver, Charles; [e-mail]
Cc: Bell, Wes; Jim Wright
Subject: RE: DMR submittal waiver for NCO082821
Thank you Charles.
Vance Dann
Manager of Environmental and Homeland Security
Southern States Cooperative, Inc.
6606 West Broad Street (23230)
P.O. Box 26234
Richmond, VA 23260
[phone] office
[phone] mobile
[e-mail]
From: Weaver, Charles [mailto:[e-mail]]
Sent: Friday, June 22, 2012 9:51 AM
To: [e-mail]; Vance Dann
Cc: Bell, Wes
Subject: DMR submittal waiver for NCO082821
The Division received your request to place the subject permit on Inactive status. Please note that the
DMR submittal waiver issued last year [copy attached] remains in force; you are not required to submit
DMRs until that waiver is lifted.
If you have any additional questions, simply reply to this message.
CHW
NOTICE: This e-mail message, including files attached to it, may contain confidential information or
legally privileged information that is intended only for the use of the ADDRESSEE(S) named above. If
you are not an intended recipient, you are hereby notified that any reading, distribution or copying of
information contained in this message, or the taking of any action in reliance upon the information is
strictly prohibited. If you have received this message by mistake, please notify the sender
immediately by reply e-mail, and immediately delete the message and attachments from your system.
Thank you.

Bell, Wes
From: Lauren Faulkner [Lauren. [e-mail]]
Sent: Friday, September 24, 2010 10:43 AM
To: Bell, Wes
Subject: RE: Southern States Statesville Fertilizer Plant
The only problem with that USGS topo map is that it still shows there is a pond with an unnamed tributary running from it
on our property. That pond was filled in years ago and is now a grassy field (you can see it on the satellite photos) and we
are not sure if there is still a ditch that runs from this area that would be collecting runoff. Our consultant was going to be
in Statesville today so he was going to ride by the site to see if he could find where there was a discernible discharge from
our site into this tributary.
Thanks and I will be in touch,
Lauren
From: Bell, Wes [mailto:[e-mail]]
Sent: Wednesday, September 22, 2010 4:42 PM
To: Lauren Faulkner
Subject: RE: Southern States Statesville Fertilizer Plant
Good afternoon, the stormwater runoff does not flow 2.1 miles and directly enter Third Creek; however, the stormwater
does enter an unnamed tributary that flows into Third Creek (as indicated on the USGS topo map). The stormwater
samples would be collected prior to the confluences with this tributary, any groundwater springs that may enter this
ditch (if applicable), or stormwater runoff from adjacent properties.(if applicable). Let me know if this helps. Please
don't hesitate to either call or email me.
Wes Bell - [e-mail]
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Ph:704.663.1699 Fax:[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
From: Lauren Faulkner [mailto:[e-mail]]
Sent: Wednesday, September 22, 2010 11:50 AM
To: Bell, Wes
Subject: Southern States Statesville Fertilizer Plant
Importance: High
Good morning. I was working on completing the individual NDPES permit application for our Statesville Fertilizer Plant
when I realized where Third Creek was. I have talked with our consultant who manages the remediation system at the
plant and collects the DMR samples for that permit about where we could collect a sample for this permit. After looking
over several aerial and site maps, we found that Third Creek is 2.1 miles south from the edge of the southern property
line. We own the property south of the new US 70 and it ends at the first tree line where the first few houses are located.
You referenced the area south of the plant where the runoff was converging with runoff from the east side of the property
next to the railroad spur and creating a discharge than runs south/southwest into the wooded area. Since Southern States

owns all of this property where these areas are discharging into, I do not see where we have a discharge offsite that
travels 2 miles south into Third Creek.
Could you take a look at the maps I've attached and let me know if we still need to apply for a permit and if so, where we
would collect a representative sample where it discharges offsite? Please give me a call if you would like to discuss this
further.
Thanks,
Lauren
Lauren A Faufkner
EnvironmentafProject -9Yfanager
Southern States Cooperative, Inc
804-281 1189

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S
Beverly Eaves Perdu
Governor
■�
HCDEN
North Carolina Department of Environment and Natural Resources
Division of Water Quality
e Coleen H. Sullins Dee Freeman
Director Secretary
April 5, 2010
SAM KOON
SOUTHERN STATES COOPERATIVE INC
PO BOX 26234
RICHMOND VA 23260
SUBJECT: Payment Acknowledgment
Civil Penalty Assessment
Southern States Fertilizer Plant
Permit Number: NCO082821
Case Number: LM-2010-0012
Iredell County
Dear Mr. Koon:
This letter is to acknowledge receipt of check number 900459754 in the amount of $560.37 received from you
dated March 29, 2010. This payment satisfies in full the above civil assessment levied against the subject
facility, and this case has been closed. Payment of this penalty in no way precludes future action by this
Division for additional violations of the applicable Statutes, Regulations, or Permits.
If you have any questions, please call Robert L Sledge at 919-807-6398.
cc: Central Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 One
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748 NorthCarolina
Internet www.ncwaterquality.org 'J����u�Ayy��/�
An Equal Opportunity 1 Affirmative Action Employer v �/ `

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves .Perdue Coleen H. Sullins
Governor Director
March 22, 20,10
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PO BOX 26234
6606 cat swp/jl 3/22/10 '-------------
Post' -- RICHMOND VA 23230 ---------------
sw / l 3/22/10
Richmond, - irgmia
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215.1(a)(6) and NPDES Permit No. NCO082821
Southern States Coopertive Groundwater Remediation System
Iredell County
Case No. LM-2010-0012
Dear Mr. Scribner:
F
Postage $
Certified Fee
Return
Receipt Fee
Odorsement Required)
estdcted Delivery Fee
ndorsement Required) `
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of $560.37
($475.00 civil penalty + $85.37 enforcement costs) against Southern States Cooperative.
This assessment is based upon the following facts: A review has been conducted of the self -monitoring
data reported for December 2009. This review has shown the subject facility to be in violation of the discharge
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville. NC 28115
Plione: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748
Internet: httD:I/Dortal.nodenr.orahueb/wo
An Equal Opportunity \ Affirmative Action Employer — 50% Reeyeled/10% Post Consumer paper
Nne
offfiCarolina
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limitations and monitoring requirements found in NPDES Permit No. NC0082821. The violations are
summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Southern States Cooperative violated the
terms, conditions, or requirements of NPDES Permit No. NCO082821 and North Carolina General Statute
(G.S.) 143-215.1(a)(6) in the manner and extent shown in Attachment A. A civil penalty may be assessed in
accordance with the maximums established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the Director of the
Division of Water Quality, I, Robert B. Krebs, Surface Water Protection Regional Supervisor for the
Mooresville Region, hereby make the following civil penalty assessment against Southern States Cooperative:
$ 25.00
For 1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NCO082821, by discharging waste into the
waters of the State in violation of the permit monitoring
requirement for total nitrogen.
$ 25.00 For _1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NCO082821, by discharging waste into the
waters of the State in violation of the permit monitoring
requirement for total phosphorous.
$ 25.00 For _1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NCO082821, by discharging waste into the
waters of the State in violation of the permit monitoring
requirement for copper.
agile]
$ 25.00
For 1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0082821, by discharging waste into the
waters of the State in violation of the permit monitoring
requirement for chloride.
For _1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0082821, by discharging waste into the
waters of the State in violation of the permit monitoring
requirement for nitrate.
$ 100.00 For 1_ of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NCO082821, by discharging waste into the
waters of the State in violation of the permit daily maximum
effluent limit for total suspended solids.

250.00
$ 475.00
$ 85.37
$ 560.37
For 1 of the one (1) violation of G.S. 143-215.1(a)(6) and
NPDES Permit No. NC0082821, by discharging waste into the
waters of the State in violation of the permit monthly average
effluent limit for total suspended solids.
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the
Findings of Fact and Conclusions of Law and the factors set forth at G.S. 143B-282. I (b), which, are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violations;
(2) The duration and gravity of the violations;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose further
enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

It
M
2. Submit a written request for remission including a detailed justification for such request:
Please be aware that a request for remission is limited to consideration of the five factors listed
below as they may relate to the reasonableness of the amount of the penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred
or the accuracy of any of the factual statements contained in the civil penalty assessment
document. Because a remission request forecloses the option of an administrative hearing, such
a request must be accompanied by a waiver of your right to an administrative hearing and a
stipulation that no factual or legal issues are in dispute. Please prepare a detailed statement that
establishes why you believe the civil penalty should be remitted, and submit it to the Division of
Water Quality at the address listed below. In determining whether a remission request will be
approved, the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-282.I(b) were
wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from
the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) -whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary
remedial actions.
Please note that all information presented in support of your request for remission must be
submitted in writing. The Director of the Division of Water Quality will review your evidence
and inform you of his decision in the matter of your remission request. The response will
provide details regarding case status, directions for payment, and provision for further appeal of
the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider information that
was not part of the original remission request considered by the Director. Therefore, it is very
important that you prepare a complete and thorough statement in support of your request for
remission.
In order to request remission, you must complete and submit the enclosed "Waiver of Right to an
Administrative Hearing and Stipulation of Facts" form within thirty (30) days of receipt of this
notice. The Division of Water Quality also requests that you complete and submit the enclosed
"Justification for Remission Request." Both forms should be submitted to the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

rA
3. File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition
for an administrative hearing. You may obtain the petition form from the Office of
Administrative Hearings. You must file the petition with the Office of Administrative Hearings
within thirty (30) days of receipt of this notice. A petition is considered filed when it is received
in the Office of Administrative Hearings during normal office hours. The Office of
Administrative Hearings accepts filings Monday through Friday between the hours of 8:00 a.m.
and 5:00 p.m., except for official state holidays. The petition may be filed by facsimile (fax) or
electronic mail by an attached file (with restrictions) - provided the signed original, one (1) copy
and a filing fee (if a filing fee is required by NCGS § 150B-23.2) is received in the Office of
Administrative Hearings within seven (7) business days following the faxed or electronic
transmission. You should contact the Office of Administrative Hearings with all questions
regarding the filing fee and/or the details of the filing process. The mailing address and
telephone and fax numbers for the Office of Administrative. Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, NC 27699-6714
Tel: [phone]
Fax: [phone]
One (1) copy of the petition must also be served on DENR as follows:
Mary Penny Thompson, General Counsel
DENR
1601 Mail Service Center
Raleigh, NC 27699-1601
Please indicate the case number (as found on page one of this letter) on the petition.
Failure to exercise one of the options above within thirty (30) days of receipt of this letter, as evidenced by
an internal date/time received stamp (not a postmark), will result in this matter being referred to the
Attorney General's Office for collection of the penalty through a civil action.

Please be advised that additional penalties may be assessed for violations that occur after the review
period of this assessment. If the violations are of a continuing nature, not related to operation and/or
maintenance problems, and you anticipate remedial construction activities, then you may wish to consider
applying for a Special Order by Consent. If you have any questions about this civil penalty assessment or a
Special Order by Consent, please contact the Water Quality Section staff of the Mooresville Regional Office at
704/663-1699.
� ZZ Zvlo
(Date) Robert B. Krebs
Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments

ATTACHMENT A
CASE NO. LM-2010-0012
Outfall
Date
Reported Value
Permit Requirement
or Permit Limit
001
12/2009
* Failed to monitor for total nitrogen
Monitor Monthly
001
12/2009
* Failed to monitor for total phosphorous
Monitor Monthly
001
12/2009
* Failed to monitor for copper
Monitor Monthly
001
12/2009
* Failed to monitor for chloride
Monitor Monthly
001
12/3/09
* Total Suspended Solids, 65.7 mg/l
45 mg/1 daily maximum limit
001
12/2009
* Total Suspended Solids, 65.7 mg/1
30 mg/l monthly average limit
* Denotes civil penalty assessment

STATE OF NORTH CAROLINA
COUNTY OF IREDELL
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
SOUTHERN STATES COOPERATIVE
PERMIT NO. NCO082821
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LM-2010-0012
Having been assessed civil penalties totaling $ 560.37 for violation(s) as set forth in the assessment
document of the Division of Water Quality dated March 22, 2010, the undersigned, desiring to seek remission
of the civil penalties, does hereby waive the right to an administrative hearing in the above -stated matter and
does stipulate that the facts are as alleged in the assessment document. The undersigned further understands
that all evidence presented in support of remission of this civil penalty must be submitted to the Director of the
Division of Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support of
a remission request will be allowed after 30 days from the receipt of the notice of assessment.
This the
day of
ADDRESS
TELEPHONE
M.
2010

0
JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LM-20M0012
Assessed Party: Southern States Cooperative, Inc.
County: Iredell
Permit Number: NCO082821
Amount Assessed: $560.37
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For
Remission Waiver of �ght to an Administrative Hearing-, and Stipulation of Facts " form to request remission
of this civil penalty. You should attach any documents that you believe support your request and are necessary
for the Director to consider in evaluating your request for remission. Please be aware that a request for
remission is limited to consideration of the five factors listed below as they may relate to the reasonableness of
the amount of the civil penalty assessed. Requesting remission is not the proper procedure for contesting
whether the violation(s) occurred or the accuracy of any of the factual statements contained in the civil penalty
assessment document. Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only
when one or more of the following five factors applies. Please check each factor that you believe applies to
your case and provide a detailed explanation, including copies of supporting documents, as to why the factor
applies (attach additional pages as needed).
(a) one or more of the civil -penally assessment factors in N.C.G.S. 143B-282.1(b) were wrongfully
applied to the detriment of the petitioner (the assessment factors are listed in the civil penalty assessment
document);
(b) the violator promptly abated continuing environmental damage resulting from the violation (i.e.,
explain the steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident (i. e., explain why the violation was
unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will revent payment for the remaining necessary remedial actions
(i.e., explain how payment of the civil penalty will prevent you from performing the activities necessary to
achieve compliance).
EXPLANATION: (use additional pages as necessary)

NORTH CAROLINA DIVISION OF WATER QUALITY
Violator: Southern States Cooperative,Inc.
Facility: Southern States Cooperative Groundwater Remediation
County: Iredell
Case Number: LM-2010-0012
Permit Number: NCO082821
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State, to the public health, or to
private property resulting from the violation;
No harm has been documented; however, total suspended solids discharged in excess of permit limits would be
predicted to cause impacts to the receiving waters such as turbidity. Because monitoring was not conducted for
total nitrogen, total phophosporous, copper, chloride, and nitrate, there is no documentation to conclude that
permit limits were met for these parameters.
2) The duration and gravity of the violation;
The violations were reported during the month of December 2010. Total suspended solids were 46% over the
daily maximum limit and 119% over the monthly average limit. No documentation exists that shows the facility
was compliant with total nitrogen, total phosphorous, copper, chloride and nitrate.
3) The effect on ground or surface water quantity or quality or on air quality;
No impacts are expected on air quality or groundwater. Surface water,quality may have been impacted by total
suspended solids resulting in turbidity in the receiving waters. No monitoring was performed for total nitrogen,
total phosphorous, copper, chloride, and nitrate.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
Approximately $175.00 was saved for total nitrogen, total phosphorous, copper, chloride, and nitrate analyses
that was not performed.
6) Whether the violation was committed willfully or intentionally;
The violation does not appear to be willful or intentional.

7) The prior record of the violator in complying or failing to comply with programs over which the
Environmental Management Commission has regulatory authority; and
No enforcement cases have been assessed in the previous 12 months.
8) The cost to the State of the enforcement procedures.
Staff preparation of enforcement package: 1 Hour $32.54
SWP Regional Supervisor review: 1 Hour $37.83
Clerical Support: $15.00
Total: $85.37
Date Ito Supervisor
Division of Water Quality

MONITORING REPORT(MR) VIOLATIONS for: ReportDate: 03/15/10 Page: 15 of 29
a Permit: % : MRs Between: 12-2009 and 12-2009 - Region: Mooresville Violation Category: Limit Violation Program Category: NPDES WVV-
f Facility Name: % Param Name: % County: % Subbasin: % Violation Action: %
Major Minor: %
PERMIT: NCO076333
FACILITY: Statesville Auto Auction - Statesville Auto Auction WWTP
COUNTY: Iredell
REGION: Mooresville
Limit Violation
MONITORING
OUTFALL/
VIOLATION
UNIT OF
CALCULATED
REPORT
PPI
LOCATION
PARAMETER
DATE
FREQUENCY
MEASURE
LIMIT
VALUE
% OVER LIMIT
VIOLATION TYPE
VIOLATION ACTION
12 -2009
001,
Effluent
Chlorine, Total Residual
12/02/09
2 X week
ug/I
28
35
25
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/04/09
2 X week
ugA
28
44
57.14
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/07/09
2 X week
ug/I
28
31
10.71
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/15/09
2 X week
ugA
28
31
10.71
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/17/09
2 X week
ugA
28
41
46.43
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/28/09
2 X week
ug/I
28
36
28.57
Daily Maximum Exceeded
No Action, BPJ
12 -2009
001
Effluent
Chlorine, Total Residual
12/30/09
2 X week
ugA
28
29
3.57
Daily Maximum Exceeded
No Action, BPJ
PERMIT: NCO082821 FACILITY: Southern States Cooperative Inc - Southern States COUNTY: Iredell REGION: Mooresville
Fertilizer Plant
Limit Violation
` g) - ? P)Q — P d) Z
MONITORING OUTFALL/
VIOLATION UNIT OF
CALCULATED
REPORT PPI LOCATION
PARAMETER
DATE FREQUENCY MEASURE
LIMIT VALUE % OVER LIMIT VIOLATION TYPE
VIOLATION ACTION
12 -2009 001
Effluent Solids, Total Suspended -
12/03/09 2 X month mg/I
45 65.7 46 Daily Maximum Exceeded
None /PU • Db
Concentration
12 -2009 001
Effluent Solids, Total Suspended -
12/31/09 2 X month mg/I
30 65.7 119 Monthly Average Exceeded
None ZSb • by
Mon 4 Vr')r► y
Concentration
d t p 1�ibH s
CA5h
��5, 3
T�!/
Z�r
! I�
Joy
r5-b 0 3,7
Gh )o�•'d�
� z�
rva3
�z �

North Carolina Secretary of State
Page 1 of 1
North Carolina
L/ I DEPARTMENT OFTIgE
} ; 12 Elaine F. Marshall
Secretary
SECRETARY of STATE
`���� ;"' ✓ '
r
PO Box 29622 Raleigh, NC 27626-0622 [phone]
CORPORATIONS
Corporations Horne Cl
Search By Corporate Name V
Search For New & Dissolved
Search By Registered Agent
Important Notice
Resale of Tickets Online
Corporations FAQ
Homeowners' Association FAQ
Tobacco Manufacturers
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PICSOS Authority to Dissolve
Register for E-Procurement
Dent. of Revenue
Date: 3/19/2010
here to:
Document Filings I Sign Up for E-Notifications I
,int apre-populated Annual Report Form I Annual Report Count I File an Annual Report I
Names
Name Name Type
W Southern States Cooperative, Incorporated Legal
ness Corporation Information
SOSID:
0137894
Status:
On Notice
Date Formed:
1/13/1965
Citizenship:
Foreign
State of Inc.:
VA
Duration:
Perpetual
istered Agent
Agent Name:
Registered Office Address:
Registered Mailing Address:
Corporation Service Company
327 Hillsborough St
Raleigh NC 27601
327 Hillsborough St.
Raleigh NC 27603
ONLINE ORDERS
Principal Office Address:
6606 West Broad Street
Start An Order •
Richmond VA 23230
New Payment Procedures
Principal Mailing Address:
PO Box 26234
i
Richmond VA 23230
CONTACT US
z5fock
Corporations Division
TOOLS
Class
Shares No Par Value
Secretary of State Home
99 SEE CERT
0
Secretary of State Site Map
Printable Page
http://www.secretary.state.nc.us/corporations/Corp,aspx?PitemId=4999243 , 3/19/2010

peenrcrnr 1-597-4999243
BUSINESS CORPORATION _.
ANNUAL REPORT
NAME OF BUSINESS CORPORATION: Southern States Cooperative, Incorporated
FISCAL YEAR ENDING: STATE OF INCORPORATION: VA
SECRETARY OF STATE CORPORATE IDNUMBER: 0137894
NATURE OF BUSINESS: Regional Farm
REGISTERED AGENT: C07poration Service Company
REGISTERED OFFICE MAILING ADDRESS: 327 Hillsborough St.
Raleigh, NC 27603
REGISTERED OFFICE STREET ADDRESS: 327Hillsborough St
Raleigh, NC 27601 Wake County
SIGNATURE OF THE NEW REGISTERED AGENT:
SIGNATURE CONSTITUTES CONSENT TO THE APPOINTMENT
PRINCIPAL OFFICE TELEPHONE NUMBER: [phone]
PRINCIPAL OFFICE MAILING ADDRESS: PO Box 26234
Richmond, VA 23230
PRINCIPAL OFFICE STREET ADDRESS: 6606 West Broad Street
Richmond, VA 23230
PRINCIPAL OFFICERS:
Name: Wayne E Shine Nmne: Torn Scribner Name: Leslie T Newton
Title: Assistant Treasurer Title: President Title: Treasurer
Address: Address: Address:
6606 West Broad Street 6606 West Broad Street 6606 West Broad Street
Richmond, VA 23230 Richmond, VA 23230 Richmond, LTA 23230
Name: N Hooper Ancarrow Jr
Title: Secretary
Address:
6606 West Broad Street
Richmond, VA 23230
CERTIFICATION OF ANNUAL REPORT MUST BE COMPLETED BY ALL BUSINESS CORPORATIONS
FORM MUST BE SIGNED BY ANT OFFICER OF THE CORPORATION
DATE
TYPE OR PRINT NAME TYPE OR PRINT TITLE
ANNUAL REPORT FEE: S25 MAIL TO: Secretary of State • Corporations Division • Post Office Box 29525 • Raleigh, NC 27626-0525

DUNCKLEE
& DUNHAM
i L
March 30, 2010
Ms. Marcia Allocco
North Carolina Department of Environment and Natural Resources
Division of Water Quality — Surface Water Protection
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Reference: Response to Compliance Evaluation Inspection
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NCO082821
Dear Ms. Allocco:
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 - 9898
FACSIMILE: (919) 858 - 9899
APR b i 2D1a
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee
& Dunham) is responding to the Compliance Evaluation Inspection Report (inspection report) dated
March 22, 2010, for the above referenced site. The inspection report was issued subsequent to a facility
inspection on March 2, 2010, by Mr. Wes Bell of the North Carolina Department of Environment and
Natural Resources - Division of Water Quality - Surface Water Protection - Mooresville Regional Office
(DWQ). Mr. Bell met with the Operator -in -Responsible Charge (ORC) to conduct an inspection of the
ground water treatment system. Several comments were contained in the inspection report that requires a
written response by the ORC. The responses to the discrepancies are listed below along with the
corrective actions made by the ORC:
1. Record Keeping
The discrepancies noted during the. inspection of the self -monitoring data have been reviewed and the
necessary adjustments and corrections will be applied when completing field notes and submitting
monthly discharge monitoring reports (DMR).
November and December 2009 DMR's have been amended to include missing pH data and
resubmitted to the Mooresville Regional Office and the Central Office in Raleigh. In addition, the
ORC will begin collecting the comprehensive parameter list during the first bi-monthly sampling
event and the shorter parameter list during the second bi-monthly sampling event to ensure the
comprehensive list is analyzed for at least once per month in the event the system is not operational
for a full month.
MAILING ADDRESS — POST OFFICE BOX 33366 — RALEIGH, NORTH CAROLINA

•• • DELIVERY
COMPLETE
SECTION
■ Complete items.1, 2 and 3. Also complete A. Signature
item 4 if Restricted Delivery is desired. ❑ Agent
X
■ Print your name and address on the reverse L✓ ❑Addressee
so that we can return the card to you. B. eceived by rirrted N e), C. Date of Delivery
■ Attach this card to the back of the mailpiece,
or on the froirt if space permits.
' D. Is delivery ress differeriffrom it _ 1? ❑Yes
1. Article Addressed to: � ` ` r ' 0-No -
If YES, enter delivery'adtlress below:�j,\
NER PRESIDENT
NIR TOM SCRIB ,
SOUTHERN STATES COOPERATIVE ' '
PO BOX.26234 3 Service Type \
RICH VA 23230 \0ered
ed Maii Express Mail
swp/j 1 3/22/ 10 ❑�teturn Receipt for Merchandise
d Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes.
2.1, 7008 1140 0002 2?16 8236�
PS Form 38.11,+Fe6ruaryl2004 I ` 'DomestictReturn Receipt to2sss-o2-nn tsao
■ Complete items 1, 2, and 3. Also complete
item 41f Restricted Delivery is desired.
IS Print your name_ and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
CORPORATION SERVICE COMPANY
I
327 HILLSBOROUGH STREET
RALEIGH NC 27603
j swp/j 1 3 /22/ 10
❑ Agent
_ ❑ Addressee
B. R c ived (P' tedl A f9 livery
��
D. Is delivery address different from ite 1? e
If YES, enter delivery address below: ❑ No
3. Service Type
Certified Mail ❑ Express Mail
egistered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery?.(Extra Fee) ❑ Yes
7d08i€],140=`�OC12 (27 6 !8229. '; I(: HIM
iiSForm-381z1, Flebruaryt2004 iDomestic Return Receipt

Response to Compliance Evaluation Inspection
Southern States Cooperative, Inc.
Statesville Fertilizer Facility
March 30, 2010
Page 2 of 2
2. Chemical Feed
Adjustments have been made to the caustic injection pump settings and monitoring system to ensure
the pump ceases injecting caustic solution once pH levels in the wet well reach a pH of 9 s.u.
Additionally, Southern States anticipates upgrading components of the ground water treatment system
during the second and third quarters of 2010.
3. Effluent Pipe
The ORC will promptly inspect the outfall discharge point and ensure that it is accessible for future
DWQ inspections.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to contact Mr. Jayson Kilcoyne at [phone]
[e-mail]) or Mr. Vance Dann of Southern States at [phone]
([e-mail]).
Sincerely,
DUNCKLEE & DUNHAM, P.C.
Jayson A. Kilcoyne
Project Environmental Scientist II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist
e-copy: Mr. Vance Dann — Southern States Cooperative, Inc.
PASouthern States\Statesville Fertilizer - 50200\Forms-Corresp\2010 Correspondence\Response to 3-22-10 Compliance Evaluation Inspection
Report- 1008 Ldoc
DUNCKLEE & DUNHAM, P.C.

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
March 22, 2010
Mr. Jayson A. Kilcoyne
Duncklee and Dunham
511 Keisler Drive, Suite 102
Cary, North Carolina 27511
Subject: Notice of Violation - Effluent Limitations
Tracking #: NOV-2010-LM-0006
Southern States Cooperative Groundwater Remediation
NPDES Permit No. NCO082821
Iredell County
Dear Mr. Kilcoyne:
A review of the November 2009 self -monitoring report for the subject facility revealed a violation of the
following parameter:
Pipe Parameter
001 pH
001 Failure to monitor
001 Failure to monitor
001 Failure to monitor
001 Failure to monitor
001 Failure to monitor
Reported Value
9.08 SU
Total Nitrogen
Total Phosphorous
Copper
Nitrate
Chloride
Permit Limit
6.0-9.0 SU
Monitor Monthly
Monitor Monthly
Monitor Monthly
Monitor Monthly
Monitor Monthly
Remedial actions, if not already implemented, should be taken to correct any problems. The Division of. Water
Quality may pursue enforcement actions for this and any additional violations. If the violations are of a continuing nature,
not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may
wish to consider applying for a Special Order by Consent. You may contact Mr. John Lesley of this Office for additional
information.
If you have questions concerning this matter, please do not hesitate to contact Mr. Lesley or me at 704/663-1699.
Sincerely,
—T�---�
L/---
Robert B. Krebs
Surface Water Protection
Regional Supervisor
cc: Point Source Branch
Ms. Lauren Barlow. Southern States Cooperative, Inc.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] \ Fax: [phone] \ Customer Service: 1-877-623-6748 NorthCarolina
Internet: htin:(IuoitaLncierr.org(web;tiwn Naturally
An Equal Opportunity \ Affirmative Action Employer — 50% Recycled/10% Post Consumer paper

AMA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 22, 2010
Mr. Vance Dann
Manager of Environmental and Homeland Security
Southern States Cooperative, Inc.
Post Office Box 26234
Richmond, Virginia 23260-6234
Subject: Compliance Evaluation Inspection
Southern States Fertilizer Plant
NPDES Permit No. NCO082821
Iredell County, N.C.
Dear Mr. Dann:
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted
at the subject facility on March 2, 2010 by Mr. Wes Bell of this Office. Please advise the facility's
Operator -in -Responsible Charge of our findings by forwarding a copy of the enclosed report.
It is requested that a written response be submitted to this Office by April 12, 2010, addressing
the discrepancies noted in the Record Keeping/Summary (effluent monitoring) and Chemical Feed
(operation concerns) Sections of the attached report.
The report should be self-explanatory; however, should you have questions concerning this
report, please do not hesitate to contact Mr. Bell at [phone].
Sincerely,
Robert B. Krebs
Surface Water Protection Regional Supervisor
Enclosure:
Inspection Report
cc: - Iredell County Health Department
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 (Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service:1-877-623-6748
Internet: http://portal.ncdenr.org/web/wq
An Equal Opportunity1 Affirmative Action Employer — 50% Recycled110% Post Consumer paper
One
NorthCarolina
iltl�l"�1��

United States Environmental Protection Agency
Form Approved.
E P qH Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 15I 31 N00082821 Ill 121 10/03/02 117 18I CI 191 SI 20I
Remarks
211IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIILill
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA - — -----------Reserved------------
67I 1. 5 169 70 14 I 711 NJ 721 NJ 73 L _j 74 751 I I I I I Li
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:42 AM 10/03/02
09/04/01
Southern States Fertilizer Plant
Exit Time/Date
Permit Expiration Date
2582 Salisbury Hwy
Statesville NC 28677
01:15 PM 10/03/02
14/03/31
Name(s) of Onsite Representative (s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Jayson Anthony Kilcoyne/ORC/919-858-9898/
Name, Address of Responsible Official/Title/Phone and Fax Number
Danny Dillon,6606 W Broad St Richmond VA 232606234/VP Contacted
Crops/804-281-1000/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature((�s) l Inspecto ) Agency/Office/Phone and Fax Numbers Date
Wesley N Bell `/ � � MRO WQ//704-663-1699'Ext.2192/ 31� �6
Signature of Q A Revie �jt� _ Agency/Office/Phone and Fax Numbers Date
(Management
�lTocco
Marcia MRO WQ//704-663-1699 Ext.2204/�
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
3I NCO082821 I11 .12I 10/03/02 I17 18Icl
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
The following discrepancies were noted during the review of the facility's self -monitoring data:
- the 10-day interval between the collection of the twice per month samples (ammonia and total suspended
solids) was not adhered to in February 09.
- the "<" values were not calculated properly to determine the monthly average values.
- the pH values were being averaged to determine a monthly average value (no monthly average pH
calculations should be performed).
- the maximum and minimum values were not reported on the DMRs.
- the incorrect parameter code was listed on the DMR for chronic toxicity (should be TGP313).
The ORC performed effluent pH analyses on the effluent in November 09 and December 09; however,
the results were not reported. The ORC has emailed to this Office amended November 09 and December
09 DMRs and will also mail copies of each amended DMR to the Raleigh address. The ORC and staff must
ensure that any effluent analyses, whether or not required by the NPDES Permit, must be performed by the
approved test proceedures and reported on the DMR.
Page # 2

.r
I
Permit: NC0082821 Owner - Facility: Southern States Fertilizer Plant
Inspection Date: 03/02/2010 Inspection Type: Compliance Evaluation
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
n
■ n
Is the facility as described in the permit?
■
n
n n
# Are there any special conditions for the permit?
n
n
■
Is access to the plant site restricted to the general public?
®
n
n n
Is the inspector granted access to all areas for inspection?
■
n
n n
Comment: The subject permit expires on 3/31/14.
Record Keeping
Yes
No
NA NE
Are records kept and maintained as required by the permit?
■
n
n n
Is all required information readily available, complete and current?
■
Cl
n n
Are all records maintained for 3 years (lab. reg. required 5 years)?
❑
n
n ■
Are analytical results consistent with data reported on DM Rs?
■
.n
n n
Is the chain -of -custody complete?
■
n
n n
Dates, times and location of sampling
Name of individual performing the sampling
■
Results of analysis and calibration
Dates of analysis
■
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
n
n
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
n
® n
Is the ORC visitation log available and current?
■
n
n o
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑ n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n n
Is a copy of the current NPDES permit available on site?
■
n
n Cl
Facility has copy of previous year's Annual Report on file for review?
n
n
® n
Page # 3

0
k
Permit: NCO082821 Owner - Facility: Southern States Fertilizer Plant
Inspection Date: 03/02/2010 Inspection Type: Compliance Evaluation
Record Keeoina Yes No NA NE
Comment: The records reviewed during the inspection were organized and well
maintained. Discharge Monitoring Reports (DMRs) were reviewed for the period
December 08 through November 09. Effluent pH and total suspended solids (TSS)
limit violations were reported (amended DMRs) in November 09 (pH) and December 09
(TSS). The monthly monitoring requirements for copper, chlorides, nitrate, total
nitrogen, and total phosphorus were not adhered to in November 09 and December 09.
The Division will separately address these limit and monitoring violations by the
issuances of either an NOV or NOV/civil penalty assessment. See Summary Section
for additonal comments.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
n
n
Are all other parameters(excluding field parameters) performed by a certified lab?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
Cl
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
■
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
•■
n
Comment: On -site pH analyses are performed under laboratory certification #5484.
Pace Analytical Laboratories, Inc. (Certification #s 12/40) has also been contracted to
provide analytical support.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
n
n
®
n
Is sample collected below all treatment units?
®
n
n
❑
Is proper volume collected?
■
n
n
n
Is the tubing clean?
n
❑
■
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n
n
Comment: The subject permit requires effluent grab samples.
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
®
n
n
n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■
n
n
n
Judge, and other that are applicable?
Comment: The facility appeared to be adequately treating the groundwater at the time
of the inspection. The ORC's operation & maintenance log was organized and well
maintained.
('_hnmirnl Gnnrl
Yes No NA NE
Page # 4

s
1
Permit: NCO082821 Owner - Facility: Southern States Fertilizer Plant
Inspection Date: 03/02/2010 Inspection Type: Compliance Evaluation
Chemical Feed Yes No NA NE
Is containment adequate? ■ ❑ ❑ n
Is storage adequate? ■ n n n
Are backup pumps available? ❑ ❑ fl ■
Is the site free of excessive leaking? ■ f_1 n n
Comment: Sodium hydroxide is added to the wet well to maintain pH levels. In
addition, the wet well is equipped with a recirculation pump to ensure adequate mixing
of the sodium hydroxide and groundwater. This ORC indicated that the caustic feed
system has a shutoff level; however, the system did not shut off during the elevated pH
levels in late November 09 and December 09. The permittee and staff must ensure that
the caustic feed system is properly operated and maintained at all times. The permittee
and staff should also have access to a backup/spare pump in case of a pump
malfunction.
Pump Station - Effluent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
n
n
n
Are all pumps present?
■
n
n
n
Are all pumps operable?
n
■
❑
Cl
Are float controls operable?
®
n
n
n
Is SCADA telemetry available and operational?
n
n
n
■
Is audible and visual alarm available and operational?
n
n
n
■
Comment: One of the pumps was not operational.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
n
n
■
n
Is flow meter calibrated annually?
❑
n
■
n
Is the flow meter operational?
n
n
go
(If units are separated) Does the chart recorder match the flow meter?
❑
n
■
n
Comment: Effluent flow calculations are based on pump run times/cycles and pump
volumes.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
nnn■
Are the receiving water free of foam other than trace amounts and other debris?
n
n
❑
If effluent (diffuser pipes are required) are they operating properly?
n
n
®
n
Page # 5

Permit: NC0082821
Inspection Date: 03/02/2010
Effluent Pipe
Owner - Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Comment: The effluent appeared clear with no suspended solids or foam. The
effluent pH was measured at 6.90 s.u. at the time of the inspection. The permittee and
facility staff must ensure that the outfall discharge location is accessible for inspection
by the ORC and/or DWQ Staff.
Yes No NA NE
Page # 6

Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230-1717
Mail Address: P.O. Box 26234
Richmond, Virginia 23260-6234
Telephone [phone]
7
SOUTHERN VAR JU 2 20110U
STATES
February 23, 2009
Attention: Central Files
North Carolina Department of Environment and Natural Resources
Division of Water Quality - Water Quality Section
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Southern States Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit Number: NCOO 82 821
To Whom It May Concern:
I am hereby authorizing Mr. Jayson A. Kilcoyne of Duncklee & Dunham, P.C. in Cary, North
Carolina to sign the monthly Discharge Monitoring, Report (DMR) for the above referenced site.
Please call me if you have any questions.
Sincerely,
Vance Dann
Manager of Environmental and Homeland Security
Southern States Cooperative, Inc.

-�e I yel , -
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0
RCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
September 25, 2009
CERTIFIED MAIL: 7006 2760 0001 9282 0259
RETURN RECEIPT REQUESTED
Mr. Vance Dann
Southern States Cooperative, Inc.
6606 W. Broad St.
Richmond, VA 23260-6234
Natural Resources
Subject: Whole Effluent Toxicity Reporting Requirements
Effluent Toxicity Testing
NPDES Permit No. NCO082821
Southern States Fertilizer Plant
Iredell County
Dear Mr. McKinney:
Dee Freeman
Secretary
S E P 3 0 2009
This is to inform you that the Environmental Sciences Section has obtained your toxicity self -monitoring
report form for August 2009; however, the form was not sent to this office.
The Environmental Sciences Section obtained the August 2009 toxicity self -monitoring report form
from the Division's Central Files. The required signed original Aquatic Toxicity (AT) Test Form was not
received by this office within the 30 day reporting period, thus the reason for this correspondence.
Please be reminded that the reporting of toxicity self -monitoring data is a dual requirement. Both the
DMR and AT Test forms must be filed no later than 30 days after the end of the reporting period for which the
report is made. AT test forms must be filed with this office while your monthly DMRs must be filed with the
Division's Central Files. In addition, toxicity test results must be reported on your monthly DMR. Mailing
addresses for our office and Central Files are located on the reverse side of this correspondence.
In the future, you are requested to submit the toxicity self -monitoring report form to this office within the 30-
da_reporting period.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemet: hftp://h2o.enr.state.nc.us/esb/
NortliCaro]ina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

The reverse side of this letter contains a summary of important toxicity monitoring and reporting
requirements. Please read this one page summary and if you have any questions, please contact me at 919-743-
8442 or Mr. John Giorgino at 919-743-8441 with the Aquatic Toxicology Unit.
Sincerely,
t w
J
Cindy A. Moore
Supervisor, Aquatic Toxicology Unit
cc: ERob_Krebs:=Mooresville Regional Office
John Lesley —Mooresville Regional Office
Susan Meadows- Aquatic Toxicology Unit
Central Files
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] t FAX: [phone] Customer Service: 1-877-623-6748
Internet: http://h2o.enr.state.nc.us/esb/
One
North Carolina
NahlrallY
An Equal Opportunity 1 Affirmative Action Employer

i
WHOLE EFFLUENT TOXICITY MONITORING AND REPORTING INFORMATION
➢ The following items are provided in an effort to assist you with identifying critical and sometimes overlooked toxicity testing and reporting
information. Please take time to review this information. The items below do not address or include all the toxicity testing and reporting
requirements contained in your NPDES permit. If you should have any questions about your toxicity -testing requirement, please contact Mr. John
Giorgino with the Aquatic Toxicology Unit at [phone] or another Unit representative at the same number.
➢ The permittee is responsible for ensuring that toxicity testing is conducted according to the permit requirement and that toxicity report forms are
appropriately filed.
➢ The reporting of whole effluent toxicity testing data is a dual requirement All toxicity test results must be entered (with the appropriate parameter
code) on your monthly Discharge Monitoring Report which is submitted to:
North Carolina Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, NC 27699-1617
IN ADDITION
Toxicity test data (original "AT" form) must be submitted to the following address:
North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
➢ Toxicity test results shall be fled with the Environmental Sciences Section no later than 30 days after the end of the reporting period (eg,
January test result is due by the end of February).
➢ Toxicity test condition language contained in your NPDES permit may require use of multiple concentration toxicity testing upon failure of any single
quarterly toxicity test. If the initial pass/fail test fails or if the chronic value is lower than the permit limit, then at least two multiple concentration
toxicity tests (one per month) will be conducted over the following two months. As many analyses as can be completed will be accepted. If your
NPDES permit does not require use of multiple concentration toxicity testing upon failure of any single quarterly test, you may choose to conduct
either single concentration toxicity testing or multiple concentration toxicity testing per the Division's WET enforcement initiatives effective July 1,
1999. Follow-up multiple concentration toxicity testing will influencethe Division's enforcement response.
➢ Toxicity testing months are specified by the NPDES Permit, except for NPDES Permits which contain episodic toxicity monitoring requirements (eg, if
the testing months specified in your NPDES permit are March, June, September, and December, then toxicity testing must be conducted during these
months).
➢ Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until
such time that a single test is passed. Upon passing this monthly test requirement, the permittee will revert to the quarterly months specified in the
permit. Please note that your permit mayor may not contain this language.
➢ If your NPDES Permit specifies episodic monitoring and your facility does not have a discharge from January I -June 30, then you must provide
written notification to the Environmental Sciences Section by June 30 that a discharge did not occur during the first six months of the calendar year.
➢ If you receive notification from your contract laboratory that a test was invalidated, you should immediately notify the Environmental Sciences Section
at [phone] and provide written documentation indicating why the test was invalidated and the date when follow-up testing will occur.
➢ If your facility is required to conduct toxicity testing during a month in which no discharge occurs, you should complete the information block located
at the top of the AT form indicating the facility name, permit number, pipe number, county and the month/year of the subject report. You should also
write "No Flow" on the AT form, sign the form and submit following normal procedures.
➢ The Aquatic Toxicity Test forms shall be signed by the facility's Operator in Respensible Charge (ORC) except for facilities which have not received a
facility classification. In these cases, a duly authorized facility representative must sign the AT form. The AT form must also be signed by the
performing lab supervisor.
➢ To determine if your AT test forms were received on time by tlhe Division of Water Quality, you may consider submitting your toxicity test results
certified mail return receipt requested to the Environmental Sciences Section.
Environmental Sciences Section
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: http:iih2o.enr.state.nc.us/esb/
One
NorthCarolina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
August 15, 2008 MW
Mr. Sam Koon _ RECEIVL-
Southern States Cooperative, Inc.
P.O. Box 26234 AUG l S 2008
Richmond, VA 23260
Subject: Renewal Notice RC DENR MR®
NPDES Permit NC00828
Southerrn Stat 1 F' oter Protedi
Iredell County
Dear Permittee:
Your NPDES permit expires on March 31, 2009. Federal (40 CFR 122.41) and North Carolina (15A
NCAC 2H.0105 (e)) regulations state that permit renewal applications must be filed at least 180 days prior
to expiration of the current permit. If you have already mailed your renewal application, you may
disregard this notice.
Your renewal package must be sent to the Division postmarked no later than October 2, 2008.
Failure to request renewal by this date may result in a civil penalty assessment. Larger penalties may be
assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after March 31, 2009, the current permit must be renewed.
Discharge of wastewater without a valid permit would violate North Carolina General Statute 143-215.1;
unpermitted discharges of wastewater may be assessed civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact
me at the telephone number or address listed below.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you
must submit with the permit renewal application. If you have any questions, please contact me at the
telephone number or e-mail address listed below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 North Salisbury Street, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] /[e-mail]
Nne
orthCarolina
Naw?allff
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

NPDES PERMIT NC0082821
SOUTHERRN STATES FERTILIZER PLANT
IREDELL COUNTY
The following items are REQUIRED for all renewal packages:
➢ A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
➢ The completed application form (copy attached), signed- by the permittee or an Authorized
Representative. Submit one signed original and two copies.
➢ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any
such Authorized Representative (see Part II.B.1 Lb of the existing NPDES permit).
➢ A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater -treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by and Municipal or Industrial facilities discharging
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
Send the completed renewal package to:
Mrs. Dina Sprinkle
NC DENR / DWQ / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

n
DUNCKLEE
& DUNHAM
LETTER OF TRANSMITTAL
To: North Carolina Division of Water Quality
Attn: Marcia Allocco, MS
From: Christopher Fay
Date: September 13, 2007
The following document is attached:
( ) Draft Letter / Report
( ) Laboratory Report
( ) Contract or Change Order
For the following action:
(X) For Your Review / Information
( ) As You Requested
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27511
OFFICE: (919) 858 — 9898
FACSMLE: (919) 858 — 9899
SEP 14 2007
NC DENR MR®
DWG -Surface dater Protection
(X) Final Letter / Report
( ) Certification Forms
( ) Other:
( ) For Your Signature & Return
( ) Other
Comments: Attached is the response to a NOV issued in reference to NPDES permit number
NC0082821.
cc: Mr. Vance Dann — Southern States Cooperative, Inc. (2)
Division of Water Quality -Central Files (2)
MAILING ADDRESS - POST OFFICE BOX 33366 - RALEIGH, NORTH CAROLINA 27636

h A.
DUNCKLEE
& DUNHAM
September 13, 2007
Ms. Marcia Allocco
North Carolina Division of Water Quality
Surface Water Protection
610 East, Center Avenue, Suite 30.1
Mooresville, North Carolina 28115
Reference: Response to Notice of Violation
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NCO082821
Duncklee & Dunham Project No. 50200
Dear Ms. Allocco:
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 - 9898
FACMULE: (919) 858'- 9899
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, PC (Duncklee &
Dunham) is submitting this written response to the August 27, 2007, Notice of Violation (NOV) for the
above referenced site dated. The deficiencies on which the NOV is based are presented below in italics
followed by our response.
Deficiency: The correct parameter code for ammonia -nitrogen is 00610 (Nitrogen, Ammonia Total as N)
and it has been incorrectly reported on past Southern States Fertilizer Plant DNVRs as parameter code
00620 (Nitrogen, Nitrate Total as N). You will need -to submit revised DNIRs for December 2006 through
February 2007. Please submit a copy to this Office as well through the normal DMR submittal address in
Raleigh.
Response: Attached are the corrected DMRs for December 2006 through February 2007. Code 00610
will be used for Nitrogen, Ammonia Total. and N on all future DMRs. -
MAILING ADDRESS - POST OFFICE BOX 33366 - RALEIGH, NORTH CAROLINA 27636

Response to Notice of Violation
Southern States - Statesville Fertilizer
September 13, 2007
Page 2 of 2
Deficiency: The monitoring requirements in NCO082821 require Southern States Fertilizer Plant to
monitor the groundwater remediation system effluent for nitrate -nitrogen (NO3-N) only on a monthly
basis. The correct reporting code for nitrate -nitrogen is 00620 (Nitrogen, Nitrate Total as N). However,
a review of submitted DMRs and associated analytical results has shown that the effluent was monitored
for nitrate and nitrite concentrations combined and reported under parameter code 00630 Nitrite plus
Nitrate Total 1 Det. as N but marked as Nitrate on the DM-R. All future monitoring of the effluent for
NCO082821 should include nitrate -nitrogen analyses only not nitrite and nitrate -nitrogen (combined)
analysis.
Response: The 00630 parameter code was incorrectly used ..i?, the DMRs. • The attached DMRs have been
corrected to show the correct parameter code, 00620. A11 timid DMRs will show the 00620 parameter
code. The NOV also indicates the effluent samples were analyzed .for , nitrite -nitrate (combined) not
nitrate -nitrogen. However, the laboratory reports show the effluent samples were analyzed for nitrates as
nitrogen according to EPA method 353.2. The analytical method is not a combination of nitrites and
nitrates. Additionally, the analytical laboratory confirmed that nitrates, riot nitrate -nitrite combined, were
reported. Therefore, it is believed that the nitrate concentrations reported on the DMRs are correct.
If you have any questions please do not hesitate to call me at [phone] or email%& at
[e-mail]. -
Sincerely,
DUNCKLEE & DUNHAM, P.C.
Christopher Fay
Project Geologist
Senior Peer Review By
Thomas . Dunham, L.G.
Senior Geologist
c: Mr. Vance Dann — Southern States Cooperative, Inc. (2)
PASouthem States\Statesville Fertilizer - 50200\Forms-Corresp\Response to NOV-07135.doc
DUNCKLEE & DUNHAM, P.C.

SEP 14 -1
NC DEN',?, MRO
DN-Surface Water Protection

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
'March 28, 2008
Mr. Vance Dann
Southern States Cooperative
6606 West Broad Street
Richmond, VA 23260
Subject: Remission Request of Civil Penalty Assessment
NPDES Permit Number NCO082821
Southern States Fertilizer WWTP
Iredell County
Case Number LV-2007-0482
Dear Mr. Dann:
Coleen H. Sullins, Director
Division of Water Quality
VAR 3 1 2008
M-Surface Water Protection t
I considered the information submitted in support of your request for remission in accordance with G.S.
143-215.6A(f) and have decided to remit the entire civil penalty in the amount of $333..89 and hereby
close our case number LV-2007-0482.
Please be advised that a full reduction of the civil penalty assessment in no way precludes the Division
from taking future enforcement action against the subject facility should additional violations occur.
If you have any questions about this letter, please contact Bob Sledge at [phone], extension 547.
Thank you for your cooperation in this matter.
Sincerely,
Coleen H. Sullins
cc 41i�1o_oresv gxona! [—
Enforcement File
Central Files
N"obl�e1tCarolina
AM rallb
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwatergualitv.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper

I
Mr. Vance Dann
Southern States Cooperative
6606 West Broad Street
Richmond, VA 23260
Dear Mr. Dann:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
# f `,
January 11, 2008�t,,�
J A N 1 F 2008
DWO—Surface Water Protection
Subject: Remission Request of Civil Penalty Assessment
Southern States Cooperative WWTP
NPDES Permit NCO082821
Case Number LV-2007-0482
Iredell County
This letter is to acknowledge your request for remission of the civil penalty levied against the subject
facility (submitted on your behalf by Duncklee & Dunham, P.C.). Your request will be scheduled for
review by the Director and you will be notified of the result.
If you have any questions about this matter, please contact me at [phone], extension 547.
Sincerely,
41-�- Z, J�2/s,
Bob Sledge, Environmental Specialist
Point Source Branch
cc: s Mil eglcsmta' _+ ff1 e a a lt�cns- ent
Enforcement File w/originals
Central Files w/attachments
Christopher M. Fay - Duncklee & Dunham, P.C.
NorthCarolina
Naturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterquality.org Location: 512 N..Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
COUNTY OF IREDELL
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTY AGAINST ) ADMINISTRATIVE HEARING AND
SOUTHERN STATES COOPERATIVE ) STIPULATION OF FACTS
PERMIT NO. NCO082821 )
FILE NO. LV-2007-0482
Having been assessed civil penalties totaling $333.99 for violation(s) as set forth in the .
assessment document of the Division of Water Quality dated December 12, 2007, the
undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in
the assessment document. The undersigned further understands that all evidence presented in
support of remission of this civil penalty must be submitted to the Director of the Division of
Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support.
of a remission request will be allowed after 30 days from the receipt of the notice of assessment.
This the 13 day of _ January , 2008
Duncklee & Dunham P.C.
BY
ADDRESS
PO Box 33366, Raleigh, North Carolina, 27636
TELEPHONE
[phone]

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: L� 2007--0482
Assessed Party: Southern States Cooperative, Inc.
County: Iredell
Permit Number: NC0082821
Amount Assessed: $333.89
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission. Waiver ofRieht to an Administrative Dearing, and Stipulation ofFacts"
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation($) occunfed or
the accuracy of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282.1(c), remission of a civil penalty may be granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S.143B-282.1(b) were
wronufizllyyulied_to the detriment_ of the petitioner (the assessment factors are listed in the civil
penalty assessment document);
X (b) the violator oromvtly abated continuing environmental damage resulting from the
violation . ri e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a rfsult of an accident (i. a, explain why the violation
was unavoidable or something you could notprevent or preparefor);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) uavment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i.e., explain howpayment of the civil penalty will prevent youfrom performing the
activities necessary to achieve compliance).
EXPLANATION: (use additional pages as necessary)

DUNCKLEE
& DUNHAM
January 8, 2008
North Carolina Department of Environment and Natural Resources
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center ;
Raleigh, North Carolina 27699-1617 ' --
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 - 9898
FACSHVJTLE: (919) 858 - 9899
Jn N - 9 2008
Reference: Response to Notice of Violation and Assessment of Civil Penalty for Violations
Southern States Fertilizer Plant
Statesville, North Carolina
.NPDES Permit Number: NCO082821
Case Number LV-2007-0482
To Whom It May Concern:
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee
& Dunham) is responding to the Notice of Violation (NOV) and Assessment of Civil Penalties dated
December 12, 2007 for the above referenced site. The NOV was issued from the office of Robert B.
Krebs, North Carolina Department of Environment and Natural Resources -Division of. Water Quality -
Surface Water Protection - Mooresville Regional Office.
The NOV states the Southern States Fertilizer Plant was in violation of the permitted monthly effluent
limit for total suspended residue (TSR) during the month of February 2007. This letter provides
information surrounding the violation and requests remission of the civil penalty for the reasons stated as
follows.
Upon receipt of the final January 2007 effluent sample results on February 5, 2007, it was determined that
the January 2007 monthly average for ammonia exceeded the permitted level. Within 24-hours of
determining there was a violation, DENR was notified and on February 6, 2007, the treatment system was
shut down. In addition DENR was notified of the non-compliance and actions taken to abate the situation
in correspondence dated February 13, 2007.
Prior to shutting the system down on February 6, 2007, Duncklee & Dunham collected an effluent
sample. The sample exceeded the daily maximum allowed for TSR. However, the NOV states the civil
penalties are being assessed for TSR exceeding the monthly average.
Duncklee & Dunham believes that based on historical effluent testing data for this permit, the small
exceedance of TSR in one effluent sample could have been reduced to below the monthly average permit
limit if additional samples could have been collected. However, the system was shutdown to abate the
MAILING ADDRESS - POST OFFICE Box' 3366 - RALEIGH, NORTH CAROLINA

Southern States Cooperative, Inc.
Statesville Fertilizer. Facility
Response to NOV
January 8, 2008
Page 2 of 2
non compliance for ammonia, and resuming a normal sampling schedule and/or collect additional samples
to achieve a compliant monthly average for TSR was not feasible. Since the system was only operable
for 6 of the 28 days in February, the total TSR load to the receiving stream that month was surely within
acceptable levels. In essence, our prompt response to shut the system down to address the ammonia issue .
hindered our ability to maintain strict compliance with the TSR value in the permit and all for a parameter
that has not shown to have been a problem in the past and is believed to be an anomalous test result. In
the previous three years for which the system has been under.the supervision of Duncklee & Dunham,
there have been no discharge violation limits.
We are therefore requesting the assessment of civil penalties be rescinded for the monthly violation of the
TSR limit.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to call us as [phone].
Sincerely,
DUNCKLEE & DUNEAM P.C.
Christopher M. Fay
Project Geologist
Thomas S. Dunham, L.G.
Senior Geologist
a
eer Review
4ee.Dunc.G.
Senior Hydrogeologist
Mr. Vance Dann — Southern States Cooperative, Inc. (2)
P:\Southem States\Statesville Fertilizer - 50200\Forms-Corresp\NOV 12-12-07.doc
E:
DUNCKLEE & DUNHAM, P.C.

Tot MR VANCE DANN
ru
sent, SOUTHERN STATES COOPERATIVE
C3iiee 6606 WEST BROAD STREET
� or Pc RICHMOND VA
23260 ...........
city, + swpljl 12/ 12/07 _
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23260
Dear Mr. Dann:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen Sullins. Director
Division of Water Quality,
i
2007
i
i
SUBJECT: Notice of Violation and Assessment of Civil
Penalty for Violations of N.C. General Statute
143-215. 1 (a)(6) and NPDES Permit No. NCO082821
Southern States Fertilizer WWTP
Iredell County
Case No. LV-2007-0482
This letter transmits a Notice of Violation and assessment of civil penalty in the amount
of $333.89 ($250.00 civil penalty + $83.89 enforcement costs) against Southern States
Cooperative, Inc..
This assessment is based upon the following facts: A review has been conducted of the
self -monitoring data reported for February 2007. This review has shown the subject facility to be
in violation of the discharge limitations found in NPDES Permit No. NC0082821. The
violations are summarized in Attachment A to this letter.
Based upon the above facts, I conclude as a matter of law that Southern States
Cooperative, Inc. violated the terms, conditions, or requirements of NPDES Permit No.
NCO082821 and North Carolina General Statute (G.S.)143-215.1(a)(6) in the manner and extent
shown in Attachment A. A civil penalty may be assessed in accordance with the maximums
established by G.S. 143-215.6A(a)(2).
Based upon the above findings of fact and conclusions of law, and in accordance with authority
provided by the Secretary of the Department of Environment and Natural Resources and the
Director of the Division of Water Quality, I, Robert B. Krebs, Surface Water Protection Regional
Supervisor for the Mooresville Region, hereby make the following civil.penalty assessment
against Southern States Cooperative, Inc:
N. C. Division of Water Quality, Mooresville Regional Office, 610 E. Center Ave. Suite 301, Mooresville NC 28115 (704) 663-I699 Customer Service
1-877-623-6748

$ 0 For _l_ of the one violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0082821, by
discharging waste into the waters of the State in
violation of the permit daily maximum effluent
limit for total suspended residue.
$ 250.00 For _1_ of the one (1) violation of G.S. 143-
215. 1 (a)(6) and NPDES Permit No. NC0082821, by
discharging waste into the waters of the State in
violation of the permit monthly average effluent
limit for total suspended residue.
$ 250.00
$ 83.89
$ 333.89
TOTAL CIVIL PENALTY
Enforcement costs.
TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken
into account the Findings of Fact and Conclusions of Law and the factors set forth at G.S. 14313-
282. 1 (b), which are:
(1) The degree and extent of harm to the natural resources of the State, to the. public
health, or to private property resulting from the violations;
(2) The duration and gravity of the violations;'
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violations were committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
(8) The cost to the State of the enforcement procedures.
Within thirty days of receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environment
and Natural Resources (do not include waiver form). Payment of the penalty will
not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:

Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission including a detailed justification for
such request:
Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the
penalty assessed. Requesting remission is not the proper procedure for contesting
whether the violation(s) occurred or the accuracy of any of the factual statements
contained in the civil penalty assessment document. Because a remission request
forecloses the option of an administrative hearing, such a request must be
accompanied by a waiver of your right to an administrative hearing and a
stipulation that no factual or legal issues are in dispute. Please prepare a detailed
statement that establishes why you believe the civil penalty should be remitted,
and submit it to the Division of Water Quality at the address listed below. In
determining whether a remission request will be approved, the following factors
shall be considered:
(1) whether one or more of the civil penalty assessment factors in G.S. 143B-
282. 1 (b) were wrongfully applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage
resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous
violations; or
(5) whether payment of the civil penalty will prevent payment for the
remaining necessary remedial actions.
Please note that all information presented in support of your request for remission
must be submitted in writing. The Director of the Division of Water Quality will
review your evidence and inform you of his decision in the matter of your
remission request. The response will provide details regarding case status,
directions for payment, and provision for further appeal of the penalty to the
Environmental Management Commission's Committee on Civil Penalty
Remissions (Committee). Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the
Director. Therefore, it, is very important that you prepare a complete and thorough
statement in support of your request for remission.

In order to request remission, you must complete and submit the enclosed
"'Waiver of Right to an Administrative Hearing and Stipulation of Facts" form
within thirty (30) days of receipt of this notice. The Division of Water Quality
also requests that you complete and submit the enclosed "Justification for
Remission Request." Both forms should be submitted to the following address:
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
3. File a petition for an administrative hearing with the Office of
Administrative Hearings:
If you wish to contest any statement in the attached assessment document you
must file a petition for an administrative hearing. You may obtain the petition
form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty (30) days of receipt of this
notice. A petition is considered filed when it is received in the Office of
Administrative Hearings during normal office hours. The Office of
Administrative Hearings accepts filings Monday through Friday between the
hours of 8:00 a.m. and 5:00 p.m., except for official state holidays. The original
and one (1) copy of the petition must be filed with the Office of Administrative
Hearings. The petition may be faxed — provided the original and one copy of the
document is received in the Office of Administrative Hearings within five (5)
business days following the faxed transmission. The mailing address for the
Office of Administrative Hearings is:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
Telephone: [phone] Facsimile: [phone]
A copy of the petition must also be served on DENR as follows:
Ms. Mary Penny Thompson, General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Please indicate the case number (as found on page one of this letter) on the
petition.

Failure to exercise one of the options above within thirty (30) days of receipt of this letter,
as evidenced by an internal date/time received stamp (not a postmark), will result in this matter
being referred to the Attorney General's Office for collection of the penalty through a civil
action.
Please be advised that additional penalties may be assessed for violations that occur after
the review period of this assessment. If the violations are of a continuing nature, not related to
operation and/or maintenance problems, and you anticipate remedial construction activities, then
you may wish to consider Uplyin for a Special Order by Consent. If you have any questions
about this civil penalty assessment or a Special Order by Consent, please contact the Water
Quality Section staff of the Mooresville Regional Office at 704/663-1699.
9
(Date) Robert B. Krebs
Regional Supervisor
Surface Water Protection
Mooresville Regional Office
Division of Water Quality
ATTACHMENTS
cc: Water Quality Regional Supervisor w/ attachments
Compliance/Enforcement File w/ attachments
Central Files w/ attachments
rb/jI

ATTACHMENT A
CASE NO. LV-2007-0482
Outfall Date Parameter Reported Value Permit Limit
001 02/06/2007 Total Suspended 52 mg/1 45 mg/l
Residue
001 * 02/2007 Total Suspended 52 mg/1 30 mg/1
Residue
* Denotes civil penalty assessment

STATE OF NORTH CAROLINA
COUNTY OF I EDELL
IN THE MATTER OF ASSESSMENT
OF CIVIL PENALTY AGAINST
SOUTHERN STATES COOPERATIVE
PERMIT NO. NCO082821
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
WAIVER OF RIGHT TO AN
ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
FILE NO. LV-2007-0482
Having been assessed civil penalties totaling $333.89 for violation(s) as set forth in the .
assessment document of the Division of Water Quality dated December 12, 2007, the
undersigned, desiring to seek remission of the civil penalties, does hereby waive the right to an
administrative hearing in the above -stated matter and does stipulate that the facts are as alleged in
the assessment document. The undersigned further understands that all evidence presented in
support of remission of this civil penalty must be submitted to the Director of the Division of
Water Quality within 30 days of receipt of the notice of assessment. No new evidence in support
of a remission request will be allowed after 30 days from the receipt of the notice of assessment.
This the
day of
ADDRESS
TELEPHONE
2007

JUSTIFICATION FOR REMISSION REQUEST
DWQ Case Number: LV-2007-0482
_Assessed Party: Southern States Cooperative, Inc.
County: Iredell
Permit Number: NC0082821
Amount Assessed: $333.89
Please use this form when requesting remission of this civil penalty. You must also complete the
"Request For Remission. Waiver of Right to an Administrative Hearing, and Stipulation of Facts "
form to request remission of this civil penalty. You should attach any documents that you believe
support your request and are necessary for the Director to consider in evaluating your request for
remission. Please be aware that a request for remission is limited to consideration of the five factors
listed below as they may relate to the reasonableness of the amount of the civil penalty assessed.
Requesting remission is not the proper procedure for contesting whether the violation(s) occurred or
the accuracy .of any of the factual statements contained in the civil penalty assessment document.
Pursuant to N.C.G.S. § 143B-282. 1 (c), remission of a civil penalty maybe granted only when one or
more of the following five factors applies. Please check each factor that you believe applies to your
case and provide a detailed explanation, including copies of supporting documents, as to why the
factor applies (attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282. 1 (b) were
wrongfully�pplied to the detriment of the petitioner (the assessment factors are listed in the civil
penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the
violation (i.e., explain the steps that you took to correct the violation and prevent future
occurrences);
(c) the violation was inadvertent or a result of an accident Q. e., explain why the violation
was unavoidable or something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary
remedial actions (i. e., explain how payment of the civil penalty will prevent youfrom performing the
activities necessary to achieve compliance).
EXPLANATION: (use additional pages as necessary)

NORTH CAROLINA DIVISION OF WATER QUALITY
Violator: Southern States Cooperative
Facility: Southern States Fertilizer WWTP
County: hedell
Case Number: LV-2007-0482
Permit Number: NC0082821
1)
2)
3)
4)
5)
6)
7)
ASSESSMENT FACTORS
The degree and extent of harm to the natural resources of the State, to the public
health, or to private property resulting from the violation;
No harm has been documented; however, total suspended residue in excess of the permitted
monthly limit may contribute to downstream impairment due to low dissolved oxygen and
turbidity.
The duration and gravity of the violation;
The violations occurred during the month of Februmy 2007.
The effect on ground or surface water quantity or quality or on air quality;
No effect on ground water or air quality are expected; however, surface waters could be impacted
by the discharge resulting in stress to aquatic life in the receiving stream.
The cost of rectifying the damage;
The cost is unknown.
The amount of money saved by noncompliance;
A specific monetary amount is unknown. Money could have been saved by failing to visit the site
more often and properly maintain the system.
Whether the violation was committed willfully or intentionally;
No evidence suggests the violations were committed willfully or intentionally.
The'prior record of the violator in complying or failing to comply with programs
over which the Environmental Management Commission has regulatory authority;
and
No cases for limits violations have been assessed against the company.

8) The cost to the State of the enforcement procedures.
The cost to the Mooresville regional Office was $83.89.
Date RO Supervisor
Division of Water Quality

MONITORING REPORT(MR) VIOLATIONS for:
so—Y
Report Date: 06/26/07 Page 6 of 13
MalorrMlnor _.. .... _ ,
r REGION: Mooresville
PERMIT: NCO074799 FACILITY: Pines Mobile Home Park - Pines Mobile Home Park COUNTY: Gaston
1 imit Vinlatintl'—
VIOLATION UNIT OF CALCULATED
MONITORING OUTFALL / DATE FREQUENCY MEASURE LIMIT VALUE VIOLATION TYPE VIOLATION ACTION
REPORT PPI LOCATION PARAMETER f A_
02 -2007 001 Effluent BOD, 5-Day (20 Deg. C) 02/21/07 2 X month mg/l 15 17.4 �Q Daily Maximum Exceeded None
PERMIT: NCO082821
MONITORING OUTFALL /
VIOLATION
DATE FREQUENCY
REPORT. PPI LOCATION
PARAMETER
02 -2007 001 Effluent
Solids, Total Suspended
02/06/07 2 X month
02 -2007 001 Effluent
Solids, Total Suspended
02/28/07 2 X month
COUNTY: Iredell
UNIT OF
MEASURE
LIMIT
mg/l
45�
mg/I
30
KMAVIY. IVIV VI c0u
CALCULATED
VALUE c'l� VIOLATION TYPE
52 1� Daily Maximum Exceeded
52 !k� Monthly Average Exceeded
VIOLATION ACTION
None —
None
L�T''s Home Centers Inc -Iredell Distribution Center COUNTY: Iredell
REGION: Mooresville
PERMIT: NC0085120 FACILITY:
Limit Violation
VIOLATION UNIT OF CALCULATED VIOLATION ACTION
MONITORING OUTFALL / DATE FREQUENCY MEASURE LIMIT VALUE VIOLATION TYPE
REPORT PPI LOCATION PARAMETER
Nitrogen, Ammonia Total (as 02/08/07 Weekly mg/l 35 48 Daily Maximum Exceeded None
02 -2007 001 Effluent N)
02/23/07 Weekly su 9 13.8 Daily Maximum Exceeded None
02-2007 001 Effluent " pH

r
EFFLUENT
IVE
NPDES PERMIT NO. NCO092921 DISCHARGE NO.991 MOETH February YEAR 2007
FACILITY NAME Southern States Fertiliser Plant CLASS COUNTY J7r�r 7
CERTIFIED LABORATORY (1) Pa Ana 3dical Laboratories, Inc. CERTIFICATION N0. 12 / 40 _�V
.
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Chris
PERSON(S) COLLECTING SAMPLES Chris Fay
CHECK BOX IF ORC HAS CHANGED 0 '
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
_ GRADE : ' I I(y I ON NO.987099
_ ORC P=H
D iE
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
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* 7.8 October - April Only
DW Q Four M R 11 C1/04)

Facily S tatits: (Please check one of the follow mg)
✓ �J A nm onitDring data and sam pl-ng finqzencgs m eetpeun its ion ents
'. (including w eskly averages, if applicable) F C om pliant
A 11m onitorng data and -pan pIng f Equenc es do N 0 T m eetpeun ituBgL= ents F T
N oncan pliant
The peon ±tee d:ian2r=portto the D i1iectnrorthe appmpr ata R eghnalO fix any norm plimae thatpotPntially
threatens public health or the e -i onm ent A ny mfonn at on droll ha puvvsied ovally w thin 24 hotus from the tin e the
peml Itee been e aw am of tine c>r= stances. A w r tten sabm issiLDn shallah o be provided w ithm 5 days of the tin e the
peen itf5e beoom es aw am of the cir = stances.
If the facility isnoncom pliant, ply attach a listof oDrrecture actsonsbeing taken and a tin e-table for
in provem ants to be m ade as required by P art IIE .6 of tine N PD E S perm it..
" I certify, underpmalty of law, thatthis doamu entand aILattidrn ents w em p underm y di n or sIDervlsiDn
in acco lance w ith a systan designed tD a.—,rP thatqualifed pemonnelpmperly gatherand evaluate the infl= anon
s zkxm itted. Based cn m y inquiry of the pe=n orpelmns w ho managed the system, or dmse puns dhectly mqDons»ble
fDrgad- erarg the mfDun at bn, the info m ataon sabm ±red is, to the bestof m y ]mow kedge and belief, true, accuiate, and
complete. Ian awam thattii-am am skjn1ficarltpe3a2des forsibm iting alse inibun at hn, mcluding the postbslity of
fines and in p=mm entforknow mg violat ons!
Christopher M. Fay
Peun ittee (Phaar print or e)
Signatum of Peon ittee*** D ate
R equal unless subm - tied ehctmnkalhr)
PQ Box 33366 Raleigh, NC 27636 [phone] [e-mail] 3/31/2009
PemjtteaAddPhone Number e-maalaldzPss Pam itExplatibnDate
ADDITIONAL CERTIFIED LABORATORIES
C er fed Laboratory (2) Duncklee & Dunham P.C.
C efdflcat bn N o . 5484
efdfied LaboiatmyC erdficat:bn N •
C ethfled L abuatDry (4 )
CertifiedLaboiat=y (5)
PARAM ETER CODES
Pa m eterC ode assi1stance m ay be obtained by calling the N PD E S U nitat (919) 733 -5083 orby visiting the Sufacie
W aterp3Dtection Sections w eb site ath2o enrstate nc uis/w as and ]inking tD the unids i if= ation pages.
U -% only units ofm eaauan entdesignat ed in the m..porting facility's N PD ES peon kforzeporksig data.
* N o F bw /1) iarhasge F ran Site: Check this box if no disha2ge oca= and, as a ms11 theme are no data to be
entexed forallof the paran etEm on the D M R forthe entim m cnitorbg period.
* * 0 R C O n Site?: O RC m ustvisitfacility and doom eztvisitatiDn of as mequized per 15A N CAC 8G D204 .
* ** S 33natvse of Perm kite: If signed by otherthan the peon it tEe, then the de-legat hn of the signatory authority m ustbe on
file -with thestateper15A NCAC 2B .0506(b)(2)0).
Page 2

DUNCKLEE
I! �� & DUNHAM
September 13, 2007
Ms. Marcia Allocco
North Carolina Division of Water Quality
Surface Water Protection
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Reference: Response to Notice of Violation
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NCO082821
Duncklee & Dunham Project No. 50200
Dear Ms. Allocco:
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 — 9898
�A FACSEVIILE: (919) 858 — 9899
SEP 2 1 2007 SWF
SEP 18 2007
SEP 2 4 2007
NC D NR MRO
N-SurfaC2, � AAr Protection
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, PC (Duncklee &
Dunham) is submitting this written response to the August 27, 2007, Notice of Violation (NOV) for the
above referenced site dated. The deficiencies .on which the NOV is based are presented below in italics
followed by our response.
Deficiency: The correct parameter code for ammonia -nitrogen is 00610 (Nitrogen, Ammonia Total as N)
and it has been incorrectly reported on past Southern States Fertilizer Plant DMRs as parameter code
00620 (Nitrogen, Nitrate Total as N). You will need to submit revised DMRs for December 2006 through
February 2007. Please submit a copy to this Office as well through the normal DMR submittal address in
Raleigh.
Response:
MAILING ADDRESS - POST OFFICE BOX 33366 - RALEIGH, NORTH CAROLINA 27636

JEP 18 v

Response to Notice of Violation
Southern States - Statesville Fertilizer
September 13, 2007
Page 2 of 2
Deficiency: The monitoring requirements in NCO082821 require Southern States Fertilizer Plant to
monitor the groundwater remediation system effluent for nitrate -nitrogen (NO3-N) only on a monthly
basis. The correct reporting code for nitrate -nitrogen is 00620 (Nitrogen, Nitrate Total as N). However,
a review of submitted D IMs and associated analytical results has shown that the effluent was monitored
for nitrate and nitrite concentrations combined and reported under parameter code 00630 Nitrite plus
Nitrate Total 1 Det. as N but marked as Nitrate on the DAD?. All future monitoring of the effluent for
NCO082821 should include nitrate -nitrogen analyses only not nitrite and nitrate -nitrogen (combined)
analysis.
Response: The 00630 parameter code was incorrectly used on the DMRs. The attached DMRs have been
corrected to show the correct parameter code, 00620. All future DMRs will show the 00620 parameter
code. The NOV also indicates the effluent samples were analyzed for nitrite -nitrate (combined) not
nitrate -nitrogen. However, the laboratory reports show the effluent samples were analyzed for nitrates as
nitrogen according to EPA method 353.2. The analytical method is not a combination of nitrites and
nitrates. Additionally, the analytical laboratory confirmed that nitrates, not nitrate -nitrite combined, were
reported. Therefore, it is believed that the nitrate concentrations reported on the DMRs are correct.
If you have any questions please do not hesitate to call me at [phone] or email me at
[e-mail].
Sincerely,
DUNCKLEE & DUNHAM, P.C.
Christopher Fay
Project Geologist
Senior Peer Review By
Thomas S. Dunham, L.G.
Senior Geologist
c: Mr. Vance Dann — Southern States Cooperative, Inc. (2)
PASouthern States\Statesville Fertilizer - 50200\Forms-Corresp\Response to NOV-07135.doc
DUNCKLEE & DUNHAM, P.C.

■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery. Is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailplece,
i or on the front if space permits.
1. Article Addressed to:
MR VANCE DANN
SOUTHERN STATES COOPERATIVE
6606 WEST BROAD STREET
RICHMOND VA 23260
SWP/ji 12/12/07
A Sigel" c
X Z f Ve
❑Agent
' ❑ Addressee
B:'}�e72��edAy (PAnted Name) �• :Date of Delivery
OS.A e,�
D. is defivery address different from item 1? ❑ Yes
If YES, enter delivery address below-. ❑ No
DEC 1. 7
3. Service Type
Certified Mail ❑ Express Mail
❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
2'1 7006 2760 0001 8494 6417
PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1

EFFLUENT
0
SEP 1.8 2007
swF`
S PERMIT NO. �TC.00828_21_ DISCHARGE NO. M MQtLTH December YEAR 2006
ACILITY NAME Southern States Fertilizer Plant CLASS COUNTY Tredell
L ABORATORY 1 O Pa A rtir-al T.ahnrfltOrieS Inc. CERTIFICATION NO- 12 / 40
ERTIFIED ---
`�' ist additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Chris GRADE-1— CERTIFICATION NO.997099
PERSON(S) COLLECTING SAMPLES .hric Fav ORC PHONE [phone]
CHECK BOX IF ORC HAS CHANGED 0 O FLOW / DISCHARGE FROM SITE
Mail ORIGINAL and ONE COPY to: cr l I 0-7ATTN: CENTRAL FILES x
DIVISION OF WATER QUALITY (SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE
1617 MAIL SERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
RALEIGH NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.

f
Facility Status: (P ]ease check one of the follow ing)
A 11m onitor i ng data and sin plirng frequencies m eetperm InEqui a n ents
(including w eekly averages, if applicable)
C om pliant
A 11m onilDn±ig data and sam plfig frequencies do N O T m eetpe3m itn quan eats El
N orican pliant
The peon ittee sball rr=porttD the D iracbror the appropriate R egional0 fEke any noncom pliance thatpotentially
threatens public health orthe ern= m ernt Any =bmn ation dYtallbe pmv3ded oraIly w ithin 24 hours fOM the tin e the
pemt ki begun e aw axe of the cordon stances. A w rhm srrxn ission dnallalso be pmvied w ithin 5 days of the tine the
peen ittee be=n es aw are of the ciT-m stances.
If the facrlity is nonocm pliant, pleas✓ attach a listof correcthre actions being taken and a tin e-tab3e for
in proven ents to hem ade as required by Part III; b of tine N PD ES permit.
"I certify, underpenalty of law, dmtthm doom entand allattadun eats w ere prepm:ed underm y direcbon or s�pex=on
in acoo2 ance w ith a systan designed tD aeg ] YP thatqualif led pe3mmelpmperly gather and evaluate the infDml ation
sabm fitted. B ase l on m y inquiry of the permn orpermns w h6 m anaged the systEm , orthom pemDns directly 2nEponsdble
fDrgad=lg the arm atom, the inform atom sabm itted is, to the bestofm y know ]edge and belief, b: ue, war ate, and
ocm plete. I am aware thatthem alB sg nifi=tpenalbes fDrsabm 3ttsng fills✓ infnmr anon, including the possibility of
fines and in p=mn entfDrknow ing violations "
Christopher A Fay
Perm ittee (P leas✓ printor type)
lrofc-?
93�natum of Penn ittee*** D ate
J2 equitea runless s-ibm it ted eleC=nkally)
PO Box 33366 Raleigh, NC 27636 [phone] [e-mail] 3/31/2009
PemitteeAddrffi PhcneNumber einaRwidPeunitExpilationDate
ADDITIDNAL CERTIFIED LABORATORIES
Certified Laboratory (2) Duncklee & Dunham P.C.
C ertified Laboratory (3 )
C eatibed L aboizdDW (4 )
C ettifie3 L aboratory (5 )
PARAM ETER CODES
C erdficat hn N o . 5484
C ertificat hn N o .
C ertifIathnNo.
Panam eterC ode asstaance maybe obtained by calling the N PD ES U n itat (919) 73 3 -5083 orby visithg the Surface
W aterPrntection S ectionIs w eb site ath2o anrslata nc risk as and linking tD the units inform atbn pages.
Use only units ofm eaa uem entdesigrnated in the 2Pp03fdng 's N PD E S pear itfDrir=port hg data.
* N o F bw /bisdiarge Frrxn Site: Check this box ifno discharge ocans and, as a rasrl - there are no data t be
ent�md lDranof tine param et mz on the D M R fDrthe enter m cnitD2�hg pemd.
* * 0 R C O n Site? : O R C m ustvidtf-J] and down entviskat hn of i' as raqrired per 15A N CA C 8G .0204.
* * * S i3natrire of P ern✓ itfee: If s aed by otherthan the peon rti>sc, them the de3e9adbn of the s#aatDry authority m ustbe on
fOewiththe srateperl5ANCAC2B .0506 OD) (2) 0).
Page 2

EFFLUENT
NPDES PERMIT NO. NCO082921 DISCHARGE NO. M MQHTH January YEAR 2007
FACILITY NAME Soutbem States Fertilizer Plant CLASS COUNTY Tredell
CERTIFIED LABORATORY (1) Pace Analytical Laboratories, Inc. CERTIFICATION NO. 12 / 40
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Cbris Fav GRADE-1— CERTIFICATION NO. 997099
PERSON(S) COLLECTING SAMPLES ORC PHONE [phone]
CHECK BOX IF ORC HAS CHANGED 0 NO FLOW / DISCHARGE FROM SITE
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES .
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
RALEIGH, NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
rill. milmollimmon,
Ifflommmr,
=11=11
no
ff'oj Me'
ENTER PARAMETERCODE
ABOVE NAME AND UNITS
MR "m
Milne
mm111
Immmim
"111 RE
Mmmm
"111
IMIMENIMMIS
100
M4211m
m
mmmm
"10 1
18MIMISIM,
Iffillm
mmmm"11
Immummm
OEM
IM
mm
11MINEMIM
mmmm
Immilimm",
mmmum
mm
MINE
mmmm.
"11
m1mmml
mmmm"'11
mmiammm
Em
IMM
mmmm
mmmmmmom
IMMIMINME
1 101 =ME
E=N=I=
8111MIMMIM"Em
MEN
* 7.8 October - April Only
DW Q Foirn M R-1.1 (11/W

SEP IS G7

F acrlity Status: (P leap check one of the fD]bw ing)
A llm onitoring data and sun pl-hg frequenciesm eetpera itrnqur ents
(inchudmg w eddy aveiages, if applicable) El
C om pliant
A 31m orritDrang data and sarn piing fmquendes do N 0 T m eetperm itr qunan ents [E
N onoom pliant
The perm ittee .dm reporter the D irbrorthe appmprdate R eghnal0 ffice any nona= pliance thatpotendally
throat am public health or the envumnm ent A ny inform anon d-allbe pmv ded orally w 1hin 24 hours fiom the tin e the
perm ittee bin e aw am of the c:h= stances. A w rrtten aibm inn dm also be pmvEed within 5 days of the tin e the
perm ittee be= es aw are of the ciraa<m stanoes.
If the faciliLy is noncom pliant, pleaseattach a list of correctfire actions being taken and a tan e-table fDr
in proven Ent s tD be m ade as required by Part IIE b of tine N PD E S perm it.
"I may,, 7nr3arpenalty of law, thatdiis doasn entand allat tadmi ents w ere prepared underm y d>e-�n or s.zper�n
in accordance w ith a systan designed tD am i r thatqua]ified peas:nnelpmperly gatherand evaluate the inform ation
mbm fitted. B ased on m y inquay of the person orpermns w ho m ariaged the system , or those persons diractly re-pons:ble
forgathering the inform ataon, the inform aticn aibm >tted is, to the bestofm y know ledge and belief, bare, acamte, and
ccm phte. Ian aw are dmtthem am s#Mantpam1tJes fors.ibm king tam inform atbn, inchrdhg the posmbUty of
fines and in pr oxmi entfDrknow mg violations."
Christopher M. Fay
Peron ittee (P leaseprirtor type)
Signature of Perm ±JBe*** D ate
�Zequuredunless subm itiod electionkally)
PO Box 33366 Raleigh, NC 27636 [phone] [e-mail] 3/31/2009
Peum $1EeAddu PhcneN um ber ein aRaddre Peun itExp:hat bn D atE
ADDTPIONAL CERTIFIED LABORATORIES
C ert ified LaboratDry (2) Duncklee & Dunham P.C.
Certified Laboratory (3 )
C erdfi`d Laboratory (4 )
C erg Laboratory (5 )
PARAM ETER CODES
C ertifimtJon N o . 5484
Param eterC ode as>ist ncie, m ay be obtained by calling the N PD E S U nitat (919) 73 3 -5083 orby visiting the Surface
W atLrPmt 2 cr- on Section's w eb site ath2o snrrstate nc us)(g qs and linking tD the un-Iffs i nfDrm at bn pages.
Use only units ofm ern eitdesignated in the reporting fban ty's N PD E S peon irfDrrr=poxthg data.
* N o Fbw its ia^harge Fran Site: Check tivsbox ifno d-Jecharge o=us and, as a raa'lr- threm are no data tD be
ertmBd foraILof tine parattt etem on die-D MR forthe entie m cnitorarg perod.
* * O R C 0 n S ke? : O R C m ustvisiti<icil>Ljr and do= entvis$adm of as mquite3 per 15A N CA C BG .0204.
* ** S ignatire of Perm it tee: If dj ne3 by odierdmn the peen !tee, then the de]egat hn of the s#nabry authority m ustbe on
fOewith-rthe state perl5A NCAC 2B .0506 (b) (2)
Page 2

EFFLUENT
NPDES PERMIT NO. NCO092921 DISCHARGE NO.991 MQ=H February YEAR 2007
FACILITY NAME Southern States Fertilizer Plant CLASS COUNTY Iredell
CERTIFIED LABORATORY (1) Pace Analytical Laboratories, Inc. CERTIFICATION NO. 12140
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Chris GRADE-1— CERTIFICATION NO. 987089
PERSON(S) COLLECTING SAMPLES Chr� iyFa4 ORC PHONE [phone]
CHECK BOX IF ORC HAS CHANGED 0 O FLOW / DISCHARGE FROM SITE
Mail ORIGINAL and ONE COPY to: �/o /o—)
ATTN: CENTRAL FILES x
DIVISION OF WATER QUALITY (SIGW&TURE OF OPERATOR IN RESPONSIBLE CHARGE) DATE
1617 MAIL SERVICE CENTER BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
RALEIGH NC 27699-1617 ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
II I
��
11 11
WIT, MIN
room,
11.11
11..
Mom
r, M
1im,
11-.1
NMI,
iu.
* 7.8 October - April Only
DW Q Foam M R 11 (11/b4)

SLID 1, 8 07

Fac ty Stab -is: (Pleas check one of the fbllow ing)
A llm on>inring data and sam pling ftaquenc3esm eetpemn its ents
(including w eekly averages, if applicable)
C om pliant
A llm ohviDring data and sin pling ftl?quenc:hs do N 0 T m eetpemh it2Bqui mu ents M
N onocm pliant
The pe3m ±tee .d1al1 ur=porttD the D itecbrorthe appmpriata-R egionalO f ce any nonCom phance thatpot endaIly
djmatens public health or the en=m ent A ny inf= anon dmnbe pmvsied orally w $h ¢h 24 hours firm tine tin e the
peum ittee been a aw a3n of the cax:n>thh stances. A w 2 i subm is ion ✓halla]be pmviied w ithirh 5 days of tine till e the
perm >ttee beoom es aw a3e of the cit= stmnces.
If the facility is nonocm pliant, plea attach a list of ooriectare actions being taken and a tit e-table for
in provan ents tD be m ade as requ>z by P artI[ E b of the N PD E S perm it.
"I ceitify, underpena]ty of law , thatd-is doaun ent and allatta m ents w ere prgDamad underm y din or s hpenrision
in acocizlanoe w ith a systan desi3ned tD ass 1YP thatqualif ied penscnnelpmperly gatherand evaluate the infDam anon
sabm itted . B ased on m y JnquiLy of the person orperscns w ho m anaged the cyst ffn , orthosr persons dJiectly mgDonsble
forgathering the mfoum at on, the infDum ation sabm -tied is, to the bestof m y ]mow ledge and belief, true, accurate, and
ocm p3ete . I an aw a1a ttatthe-te aha s# nlfica ntpe7al :Ies fDr subm i t-hg film inf= anon, including the possub2ity of
fines and in pimornn entfDrknow irng violations "
Christopher A Fay
Pe1m ithee (P ]ease print or e)
Signatum of Perm ittee*** D ate
OR equit ed unless subm fitted eledb�nically)
PO Box 33366 Raleigh, NC 27636 [phone] [e-mail] 3/31/2009
Pam ittBeAddress PherneNumber e{nailaddxffi PernitExpiratimDate
ADDTPIDNAL CERTIFIED LABORATORIES
Ceitif ed LabohatDry (2) Duncklee & Dunham P.C.
C ei fied L abouatry (3 )
CeitifiedLabouatDry (4)
CesterLabola=y (5)
PARAM ETER CODES
C ertifi`aton N o . 5484
Pardm eterC ode asaistance maybe obtained by cal]irng the N PD ES U nitat (919) 733 -5083 orby visiting the Surtce
W aterPmtac�n Section's w eb site ath2o snrrstate nc uas/w qs and linking io the units mforn anon pages.
U se only units ofm eas „Rn entdesignated in the mportng facility's N PD ES peon itformpoat hg data.
* No F Sow fib is:harge Fran Site: Check this boat if no disc n e ooaus and, as a, ' - there are no data to be
ent>mad fDraILof the paran eters on the D M R fDrthe ent hz m cnimring petiad.
* * 0 R C O n S it e? : 0 R C m ustvis:tfacility and do=n entvmtadon of firil as hacn 1 rFd per 15A N CA C 8G A204 .
** * S ignabn-e of Perm ittee: If si3 nel by otherdm the peon itiee, then the delegatiDn of the sr3nat ny authority m ustbe on
flewiththestateperl5ANCAC2B .0506(b)(2)0).
Page 2

Mr. Hilton Withers
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23260
Subject:
Dear Mr. Withers:
__Y_
Michael F. Easley ovemo MIA
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
August 27, 2007
Notice of Violation
Southern States Fertilizer Plant
NPDES Permit No. NCO082821
Iredell County
Coleen H. Sullins, Director
Division of Water Quality
Upon a recent file review for Southern States Fertilizer Plant, this Office found that our
compliance monitoring system had not flagged Southern States Fertilizer Plant for the self -
reported ammonia permit violations during January and February of 2007. The compliance
system generates violations after the data from your monthly Discharge Monitoring Reports
(DMRs) has been entered and compared with the requirements of your permit, NC0082821. A
physical review of the submitted DMRs showed that one of the required parameters was not
reported with the correct parameter code and another parameter is not being monitored correctly
as per the permit requirements.
The correct parameter code for ammonia -nitrogen is 00610 (Nitrogen, Ammonia Total
as N) and it has been incorrectly reported on past Southern State Fertilizer Plant DMRs as
parameter code 00620 (Nitrogen, Nitrate Total as N). You will need to submit revised DMRs for
December 2006 through February 2007. Please submit a copy to this Office as well through the
normal DMR submittal address in Raleigh.
The monitoring requirements in NCO082821 require Southern States Fertilizer Plant to
monitor the groundwater remediation system effluent for nitrate -nitrogen (NO3-N) only on a
monthly basis. The correct reporting code for nitrate -nitrogen is 00620 (Nitrogen, Nitrate Total
as N). However, a review of submitted DMRs and associated analytical results has shown that
the effluent was monitored for nitrate and nitrite concentrations combined and reported under
parameter code 00630 Nitrite plus Nitrate Total 1 Det. as N but marked as Nitrate on the DMR.
All future monitoring of the effluent for NCO082821 should include nitrate -nitrogen analyses
only not nitrate and nitrite -nitrogen (combined) analyses.
-11
NC®ENR
None hCarolina
Naturally
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: �u_���c.n��e:ncrdrilin.or, 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Mr. Hilton Withers
Page 2
August 27, 2007
It is requested that your response regarding the reporting and monitoring violations be
received in this Office by September 27, 2007. If you have questions concerning this matter,
please do not hesitate to contact me at [phone].
Sincerely,
Marcia Allocco, MS
Environmental Chemist
Surface Water Protection
MA

July 12, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Hilton M. Withers
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23230
Subject: NOTICE OF VIOLATION
NOV-2006-PC-0293
Compliance Evaluation Inspection
Southern States Fertilizer Plant GWRS
NPDES Permit NCO082821
Iredell County
Dear Mr. Withers:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on June 22, 2006, by James B. Bealle III of this office. Please
inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the
enclosed report.
It is requested that a written response be submitted to this office by July 31, 2006,
addressing the deficiencies noted in the Effluent Sampling, Laboratory, and Flow
Measurement - Effluent sections of the report. In responding, please address your comments to
the attention of Mr. John E. Lesley.
The report should be self-explanatory; however, should you have any questions
concerning this report, please contact Mr. Bealle or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
enclosure
cc: Central Files
Iredell County Environmental Health Division
jb

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040 0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NI 2 15I 31 NCO082821 111 121 06/06/22 117 18I CI 19I SI 20I II
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------- ---------------- Reserved ------- --------- ---
67I , 2.0 169 70 13 I 711 DI 721 NJ 73 W 74 751 I I I I I I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
02:00 PM 06/06/22
05/05/01
Southerrn States Fertilizer Plant
Exit Time/Date
Permit Expiration Date
2582 Salisbury Hwy
Statesville NC 28677
03:30 PM 06/06/22
09/03/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Christopher Michael Fay/ORC/919-858-9898/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Hilton M Withers,6606 W Broad St Richmond VA 23260//704-872-6361/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit N Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program N Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
James Bealle MRO WQ//704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
John E Lesley MRO WQ//704-663-1699 Ext.270/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
NCO082821 I11 12I 06/06/22 1" 18ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary).
Page # 2

Permit: NCO082821 Owner - Facility: Southerrn States Fertilizer Plant
Inspection Date: 06/22/2006 Inspection Type: Compliance Evaluation
Permit
Yus
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
n
n
■
n
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
n
■
n
n
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
n
n
n
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
❑
rl
Is the chain -of -custody complete?
■
n
n
n
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs I
■
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
n
n
■
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator on each shift?
n
n
■
n
Is the ORC visitation log available and current?
■
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Facility has copy of previous year's Annual Report on file for review?
n
n
■
n
Comment: Discharge Monitoring Reports (DMRs) were reviewed for May 2005
through April 2006. No violation(s) reported.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
n
n
■
n
Page # 3

Permit: NCO082821 Owner - Facility: Southerrn States Fertilizer Plant
Inspection Date: 06/22/2006 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA
NE
Is sample collected below all treatment units?
■
n
n
n
Is proper volume collected?
■
n
n
n
Is the tubing clean?
❑
n
■
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
❑
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
n
■
n
n
Comment: Temperature data must be recorded immediately; pH data must be
recorded within the allowable 15 minute holding time. Be advised that all parameters
including field parameters must be performed by certified personnel or laboratory.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
n
■
n
n
Are all other parameters(excluding field parameters) performed by a certified lab?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
n
n
n
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
n
■
n
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
n
n
■
n
Comment: The facility is not monitoring field parameters as specified in the NPDES
Permit effective April 1, 2004. Pace Analytical Services, Inc. (Certificate No. 12) is
under contract to provide analytical support.
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n
n
■
Judge, and other that are applicable?
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
n
n
n
Is flow meter calibrated annually?
n
■
n
n
Is the flow meter operational?
■
n
n
n
(If units are separated) Does the chart recorder match the flow meter?
■
n
n
n
Comment: A Great Lakes Instruments magnetic flow transmitter is being utilized at the
facility. Be advised that the accuracy of the magnetic flow transmitter must be verified
and documented annually. Effluent flow readings are documented and maintained on
file.
Effluent Pipe Yes No NA NE
Page # 4

Permit: NC0082821
Inspection Date: 06/22/2006
Owner - Facility: Southerrn States Fertilizer Plant
Inspection Type: Compliance Evaluation
Effluent Pipe
Is right of way to i`iP, ouifall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
N/-- %I- MA MC
n.nn■
nnn■
Page # 5

DUNCKLEE
July 27, 2006
Mr. John E. Lesley
North Carolina Division of Water Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Reference: Response to Notice of Violation
NOV-2006-PC-0293
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NCO082821
Duncklee & Dunham Project No. 50200
Dear Mr. Lesley:
ENVIRONMENTAL CONSULTANTS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: (919) 858 - 9898
FACSRvIILE: (919) 858 - 9899
AND ?-s1fJ1JRAL
JUL 28 2000
WATER QUbv Tv
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, PC (Duncklee &
Dunham) is submitting this written response to the Notice of Violation (NOV) for the above referenced
site dated July 12, 2006. The deficiencies and written comments on which the NOV was based are
presented below in italics followed by our response. The corrective action system is currently in the
normal summer shut -down period with restart scheduled for November 2006.
Effluent Sampling
Is the facility sampling performed as required by the permit? No.
Comment: Temperature data must be recorded immediately; pH data must be recorded within the
allowable 15 minute holding time. Be advised that all parameters including field parameters must be
performed by certified personnel or laboratory.
Response: Upon resumption of the corrective action system in November 2006, Duncklee & Dunham
personnel will collect a water sample from the sampling port on the system's discharge pipe.
Temperature and pH will thereby be measured and recorded immediately upon sample collection. See the
following response for information regarding personnel certification.
MAILING ADDRESS - POST OFFICE BOX 33366 - RALEIGH, NORTH CAROLINA 27636

--,k
Response to Notice of Violation
Southern States - Statesville Fertilizer
July 26, 2006
Page 2 of 2
Laboratory
Are field parameters performed by certified personnel or laboratory? No.
Comment: The facility is not monitoring field parameters as specified in the NPDES Permit effective
April 1, 2004. Pace Analytical Services, Inc. (Certification No. 12) is under contract to provide
analytical support.
Response: Duncklee & Dunham has applied for and received a temporary certification number from the
North Carolina Wastewater Laboratory Certification Program. The certification is for pH and the
certification number is 5484. The certification will be finalized prior to resumption of the corrective
action system in November 2006.
Flow Measurement — Effluent
Is flow meter calibrated annually? No.
Comment: A Great Lakes Instrument magnetic flow transmitter is being utilized at the facility. Be
advised that the accuracy of the magnetic flow transmitter must be verified and documented annually.
Effluent flow readings are documented and maintained on file.
Response: The flow meter has been shipped to the manufacturer for calibration. The meter will be
reinstalled prior to resumption of the corrective action system in November 2006 and calibrated annually
thereafter.
If you have any questions please do not hesitate to call me at [phone] or email me at
[e-mail].
Sincerely,
DUNCKLEE & DUNHAM, P.C.
OhomasnDu m, L.G.
sellior vGologlst
Senior Peer Review By
David L. Duncklee, L.G.
Senior Hydrogeologist
c: Mr. Vance Dann — Southern States Cooperative, Inc. (2)
P:\Southern States\Statesville Fertilizer - 50200\Forms-Corresp\Response to NOV-06107.doc
DUNCKLEE & DUNHAM, P.C.

W ATE9QG
Michael F. Easley
roved-91f
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Hilton M. Withers
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23230
Dear Mr. Withers:
July 12, 2006
7003 2260 00013494 6519
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: NOTICE OF VIOLATION
NOV-2006-PC-0293
Compliance Evaluation Inspection
Southern States Fertilizer Plant GWRS
NPDES Permit NCO082821
Iredell County
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on. June 22, 2006, by James B. Bealle III of this office. Please
inform the facility's Operator -in -Responsible Charge of our findings by forwarding a copy of the
enclosed report.
It is requested that a written response be submitted to this office by July 31, 2006,
addressing the deficiencies noted in the Effluent Sampling, Laboratory, and Flow
Measurement - Effluent sections of the report. In responding, please address your comments to
the attention of Mr. John E. Lesley. -
The report should be self-explanatory; however, should you have any questions
concerning this report, please contact Mr. Bealle or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Surface Water Protection Regional Supervisor
enclosure
cc: Central Files
Iredell County Environmental Health Division
jb
North Carolina Division of Water Quality, Mooresville Regional Office One
610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 NorthCarolina
Phone: [phone] I Fax: [phone] / Internet: mm.ncwaterquality.org
An Equal Opportunity / Affirmative Action Employer — 50% Recycled / 10% Post Consumer Paper Natmrallff

United States Environmental Protection Agency
Form Approved.
E p /� Washington, D.C. 20460
f�/ 1
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I NJ 2 1 51 31 NCO082821 111 121 06/06/22 117 181 CI 191 GI 20I
J LJ J J
Remarks
2111111111Jill 111111111111111111111111111111111U6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA -------------- --------- Reserved----------------
67I 2.0 169 70 71 p 72 I N I 73 W 74 751 I I I I I I 180
u ll �t
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
Southerrn States Fertilizer Plant
02:00 PM 06/06/22
05/05/01
Exit Time/Date
Permit Expiration Date
2582 Salisbury Hwy
Statesville NC 28677
03:30.PM 06/06/22
09/03/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Christopher Michael Fay/ORC/919-858-9898/
Name, Address of Responsible Official/Title/Phone and Fax.Number
Hilton M Withers,6606 W Broad St Richmond VA 23260//704-872-6361/ ContactedNo
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
James Bealle MRO WQ//704-663-1699/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
/
John E Lesler ........ MRO WQ//704-663-1699 Ext.270/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit: NCO082821
Inspection Date: 06/22/2006
Owner - Facility: Southerrn States Fertilizer Plant
Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
is the facility as described in the permit?
■
❑
❑
❑
# Are there any special conditions for the permit?
❑
®
❑
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
❑
❑
Is all required information readily available, complete and current?
■
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
n
❑
Are analytical results consistent with data reported on DMRs?
■
❑
❑
❑
Is the chain -of -custody complete?
■
❑
❑
❑
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
■
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑
❑
■
❑
Is the ORC visitation log available and current?
■
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
❑
Cl
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
■
❑
Comment: Discharge Monitoring Reports (DMRs) were reviewed for May 2005
through April 2006. No violation(s) reported.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
■
❑
Page # 3

Permit: NCO082821
Inspection Date: 06/22/2006
Effluent Sampling
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Owner _ Facility: Southerrn States Fertilizer Plant
Inspection Type: Compliance Evaluation
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Yes No NA NE
■❑np
■n❑Q
13000
■000
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? O ■ Q ❑
Comment: Temperature data must be recorded immediately; pH data must be
recorded within the allowable 15 minute holding time. Be advised that all parameters
including field parameters must be performed by certified personnel or laboratory.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ❑ ■
Are all other parameters(excluding field parameters) performed by a certified lab?
■
❑
❑
0
# Is the facility using a contract lab?
■
❑
❑
Q
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
Cl
❑
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
■
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Q
❑
■
❑
Comment: The facility is not monitoring field parameters as specified in the NPDES
Permit effective April 1, 2004. Pace Analytical Services, Inc. (Certificate No. 12) is
under. contract to provide analytical support.
Operations & Maintenance
Yes
No
NA
NE
Is the plant generally clean with acceptable housekeeping?
■
n
n
n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Q
❑
■
171
Judge, and other that are applicable?
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
Q
❑
Is flow meter calibrated annually?
❑
■
❑
❑
Is the flow meter operational?
■
❑
11
Q
(If units are separated) Does the chart recorder match the flow meter?
■
❑
❑
11
Comment: A Great Lakes Instruments magnetic flow transmitter is being utilized at the
facility. Be advised that the accuracy of the magnetic flow transmitter most be verified
and documented annually. Effluent flow readings are documented and maintained on
file.
Effluent Pipe
Page # 4 .

Permit: NC0082821
Inspection Date: 06/22/2006
Owner - Facility: Southerrn States Fertilizer Plant
Inspection Type: Compliance Evaluation
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
❑ ❑ ❑
❑ ❑ ❑ ■
❑❑uD
Page # 5

Michael F. Easley, Govemo
Q, W A 7 F9 William G. Ross Jr., Secretary
` p� QG
North Carolina Department of Environment and Natural Resources
Uj Alan W. Klimek, P. E. Director
Division of Water Quality
o Y
Coleen H. Sullins, Deputy Director
Division of Water Quality
February 9, 2004
Mr. Sam Koon
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23260
Dear Mr. Koon:
Post -it® Fax Note 7671
TO L,�\f1tS F
Co./Dept.
Phone #�et,��j
Fax # /G r 4
Date �WC4. Pages
From ,.�AWA.a E!e<Q
Co. W c z
(Phone # /� � 1•� 1-1
rFax # �`�7
Subject: Notice of Deficiency
Compliance Evaluation Inspection
Southern States Fertilizer Plant
NPDES Permit No. NCO082821
Iredell County, NC
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection
conducted at the subject facility on February 6, 2004 by Mr. Barry Love of this Office.
Please inform the facility's Operator -in -Responsible Charge of our findings by forwarding a
copy. of the enclosed report.
It is requested that a written response be submitted to this Office by February 24,
2004 addressing the deficiencies noted in the Flow Measurement Section of the report. In
responding, please address your comments to the attention of Mr. Richard Bridgeman.
The report should be self-explanatory; however, should you have any questions,
please do not hesitate to contact Mr. Love or me at [phone].
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Iredell County Health Department
N�o;tltCarolina
,Nat1lCU��J Division of Water Quality, Mooresville Regional Office, 919 North Main Street, Mooresville NC 28115 [phone] Customer 8

IN
4
■ Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
■ Print your name and address on the reverse
so that we can return the card to you.
■ Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article.Addressed to:
MR HILTON WITHERS
SOUTHERN STATES COOPERATIVE
6606 WEST BROAD STREET
RICHMMOND VA 23230
swp/ib 7/12/06
A. 'nature
❑ Agent
❑ Addre
B. Received by ( drtfed Name) _ C. Date of Del,
D. Is delivery address different from item 1? ❑ Yes
If YES, enter delivery address below: ❑ No
Service Type
Certified Mail ❑ Express Mail
❑ Registered ❑ Return Receipt for Merchandise
❑ Insured Mail ❑ C.O.D.
4. Restricted Delivery? (Extra Fee) ❑ Yes
_z..Ari 7223 2262 2221 3494 6519 I
pp& Form 38111 Fet�ruary;2004i ( Dorr(estid Return Receipt to2sss-o2-M-ts4o

It
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Section A: National Data System coamg p.e., ram.,
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
yr/mo/day Inspection Type Inspector Fac Type
Transaction Cade NPDES 191 q 1 20 I I
1 Dt 2 (_I 3I NC0082821 111 121 04/02/06 17 18 U LJ LJ
LJ
Remarks . ,, , I , I I I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating �B1 CA
74 75, I I �I 8�
67 1.5 69 70 u 71 L=J 72 U 73 W
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also includeFExit
e/Date Permit Effective Date
POTW name and NPDES permit Number) M 04/02/06 00/11/01
Southerrn States Fertilizer Plant
/Date Permit ExpirationDai2582 Salisbury Highway 04/03/31M 04/02/06
Statesville NC 28677
Other Facility Data
Name(s) of Onsite Representative(s)mtles(s)/Phone and Fax Number(s)
Vance Dann/Manager, Environmental Engineering/804-281-1262/
Bruce T. Cray/Plant Manager/704-872-6361/
Matthew M. Gustis/Senior Engineer/704-357-8600/
Name, Address of Responsible Official(fitte/Phone and Fax Number Contacted
Sam Koon,6606 West Broad Street Richmond VA 23260//804-281-1262/ No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Flow Measurement Operations k Maintenance Records/Reports
Permit
ility Site Review
Effluent/Receiving Waters Laboratory
Self -Monitoring Program Fac.
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessai
Name(s) and Signature(s) of Inspector(s)
,. �-
Barry Love
Signature of Management Q A Reviewer
Richard M Bridgeman
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Agency/Office/Phone and Fax Numbers Date
:; `f
MRO WQ//704-663-1699/704-663-6040
Agency/Office/Phone and Fax Numbers Date
704-663-1699/704-663-6040

PERMIT:
The permit authorizes the continued operation of an existing 0.144 MGD groundwater remediation
system consisting of three recovery wells, a lift station with wet well, flow meter, and caustic solution tank
with pH measuring device.
The permit for this facility became effective on November 1, 2000 and will expire on March 31,
2004. The permittee has submitted a request for permit renewal.
RECORDS AND REPORTS:
Records and reports consisting of monthly monitoring reports, chain of custody forms, lab analysis
reports, flow charts and Operator -in -Responsible Charge/maintenance log were reviewed at the time of the
inspection. The records were organized and well maintained.
FACILITY SITE REVIEW/OPERATIONS & MAINTENANCE:
Groundwater is piped from three recovery wells to a wet well where a caustic solution (25%
NaOH) is added for pH adjustment and then discharged via a 1.5 mile long outfall line. All treatment units
seemed to be operating properly, and the facility was well maintained.
LABORATORY:
Pace Analytical Services, Inc. has been contracted to provide analytical support. The laboratory
was not evaluated during this inspection.
EFFLUENT/RECEIVING WATERS:
The facility discharges into Fourth Creek, which is a Class C water in the Yadkin — Pee Dee River
Basin. The receiving stream was not evaluated at the time of the inspection.
SELF -MONITORING PROGRAM:
Self -monitoring reports were reviewed for the period November 2002 through October 2003.
All monitoring frequencies were correct, and no limit violations were reported.
FLOW MEASUREMENT:
Effluent flow is measured continuously by a magnetic flow meter with a circular dart recorder
and totalizer. The flow meter was last calibrated by Water Specialties on October 18, 1999. The flow
meter should be calibrated on a regular basis, but at a minimum of once per year. The EPA accepted
accuracy range for flow measuring devices is +/-10 percent of the actual flow.

MACTEC
T. OF [a�pq �, ,tJJ "e 9
par1D itT��" F:e s1n C1,9i�CloS
February 24, 2004 R���r'? ' r, �,.:3r �A 0Pt
Mr. Richard Bridgeman
North Carolina Department of Environment
and Natural Resources
Division of Water Quality
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
FEB 2 5 20016,
AT`"
Subject: Response to NCDENR Compliance Evaluation Inspection
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit No. NCO082821
MACTEC Project No. 6228-04-1072
Dear Mr. Bridgeman:
On February 6, 2004, Mr. Barry Love of the North Carolina Department of Environment and Natural
Resources (NCDENR) visited the subject site to perform a Compliance Evaluation Inspection on the
ground -water recovery system. Mr. Bruce Gray and Mr. Vance Dann of Southern States Cooperative,
Inc. (Southern States) and Mr. Matthew Gustis of MACTEC Engineering and Consulting, Inc. were also
in attendance. On February 9, 2004, Mr. Rex Gleason of the NCDENR sent a Notice of Deficiency
(NOD) to Southern States in Richmond, Virginia. The NOD indicated a deficiency under the Flow
Measurement Section of the report. The following is a response to that deficiency:
• "Effluent flow is measured continuously by a magnetic flow meter with a circular chart
recorder and totalizer. The flow meter was last calibrated by Water Specialties on October
18, 1999. The flow meter should be calibrated on a regular basis, but a minimum of once
per year. The EPA accepted accuracy range for flow measuring devices is +/-10 percent of
the actual flow."
Response: The calibration of the flow meter was an oversight by MACTEC. The system
currently operates for five months of the year from November 1 to March 31 due to historically
high ammonia concentrations. Upon system shut down activities. in April 2004, MACTEC will
remove the flow meter and have it calibrated by McCrometer located in California. Following
calibration activities, MACTEC will ensure annual calibration activities as part of the operations
and maintenance schedule for the Southern States facility in Statesville, North Carolina. Future
calibration activities will be performed when the system is non -operational between April 1 and
October 31.
MACTEC Engineering and Consulting
2801 Yorkmont Road . Charlotte, NC 28208
704-357-8600 • Fax: [phone]

Mr. Richard Bridgeman
Page 2
February 24, 2004
If you have any questions regarding the information presented herein please contact the undersigned at
[phone]
Sincerely,
MACTEC ENGINEERING AND CONSULTING, INC.
001,
Matthew M. Gustis, P.E. Christopher L. Corbitt, P.G.
Senior Engineer Principal
cc: Mr. Vance Dann — Southern States Cooperative, Inc., Richmond, Virginia.
Mr. Bruce Gray — Southern States Cooperative, Inc., Statesville, North Carolina
MMG/CLC:mmg

„ ,Notice of Incomplete Discharge Monitoring Report
Permit Number:
Facility: S li V"`t zX4'h r P�y
County: Q C -e LI
DMR Month and Year: Q(,AD 2 kr '—jDos
The Division of Water Quality deems the aforementioned DMR as incomplete due to the
following reason(s): (Please seethe highlighted areas on the attached DMR for
details.)
❑ The written values are illegible.
❑ ' The Average, Maximum, and/or the Minimum data points have been omitted.
❑ The Units of Measure have been omitted or are incorrect.
❑ The DMR Parameter Codes have been omitted.
Ld Other:

OS W A r��QG Michael F. Easley, Governor
�\ y William G. Ross Jr., Secretary
r North Carolina Department of Environment and Natural Resources
-i
Q 'C Alan W. Klimek, P. E. Director
Division of Water Quality
Date: December 6, 2005
Hilton M Withers
6606 West Broad Street
Richmond, VA 23230
Subject: Notice of Incomplete Discharge Monitoring Report NCO082821
Dear Permittee:
The purpose of this letter is to call your attention to problems with the recent submittal of the Discharge
Monitoring Report (DMR) from your facility. As you may know, the data recorded on your DMR is keyed
into the Division's database. Our data entry staff has informed me of problems with your recent DMR
submittal. Until these problems have been corrected, your DMR will be considered incomplete. Please
see the attached form along with a copy of the problem DMR for details regarding the DMR's deficiency.
Incomplete or illegible DMRs affect our staff's ability to provide a timely and effective evaluation of DMR
submittals. Please be aware that until the Division receives a corrected DMR, you may be considered
noncompliant with your NPDES permit and 15A NCAC 02B .0506, and you may be subject to further
enforcement action. Please take the necessary steps to correct the problems and submit two copies of the
amended DMR within fifteen (15) days of the date of this letter to the following address:
Attention: Michele Phillips
Division of Water Quality
Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Future DMR submittals with the same or similar problems will be unacceptable. If you have any questions
about the proper completion of DMRs, please contact Michele Phillips at 919-733-5083 Ext. 534. Thank
you for your assistance in this matter.
cc: Mooresville Regional=Office __,
Central Files
Sincerely,
Michele Phillips OFFICE
®EC 08 ( I
NoAhCarolina
Naturally
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Phone: [phone] Customer Service
Internet: hffp1/h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 Fax: [phone]
An Equal Opportunity/Affirmative Action Employer

Michael F. Easley
b
W ATFR Governor
NCDENR William G. Ross, Jr., Secretary
tlua
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
August 15, 2003
Hilton M. Withers
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23230
Subject: Renewal Notice
NPDES Permit NCO082821
Southerrn States Fertilizer Plant
Iredell County
Dear Permittee:
Your NPDES permit expires on March 31, 2004. Federal (40 CFR 122.41) and North Carolina (15A NCAC 2H.0105(e))
regulations require that permit renewal applications must be filed at least 180 days prior to expiration of the current permit. If
you have already mailed your renewal application, you may disregard this notice.
To satisfy this requirement, your renewal package must be sent to the Division postmarked no later than October 3,
2003. Failure to request renewal of the permit by this date may result in a civil assessment of at least $500.00. Larger penalties
may be assessed depending upon the delinquency of the request.
If any wastewater discharge will occur after March 31, 2004, the current permit must be renewed. Discharge of
wastewater without a valid permit would violate North Carolina General Statute 143-215.1; unpermitted discharges of wastewater
may result in assessment of civil penalties of up to $25,000 per day.
If all wastewater discharge has ceased at your facility and you wish to rescind this permit, contact Bob Sledge of the
Division's Compliance Enforcement Unit at [phone], extension 547. You may also contact the Mooresville Regional
Office at [phone] to begin the rescission process.
Use the enclosed checklist to complete your renewal package. The checklist identifies the items you must submit with
the permit renewal application. If you have any questions, please contact Valery Stephens at the telephone number or e-mail
address listed below.
Sincerely,
I lma
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
R4lroresville Regional Office;V/lter Quzltj Sex tion�
NPDES File
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 520 (fax) 919 733-0719
VISIT us ON THEINTERNET@http://h2o.enr.state.nc.us/NPDES e-mail: [e-mail]

NPDES Permit NCO082821
Southerrn States Fertilizer Plant
Iredell County
The following items are REQUIRED for all renewal packages:
❑ A cover letter requesting renewal of the permit and documenting any changes at the facility since
issuance of the last permit. Submit one signed original and two copies.
❑ The completed application form (copy attached), signed by the permittee or an Authorized
Representative. Submit one signed original and two copies.
❑ If an Authorized Representative (such as a consulting engineer or environmental consultant) prepares
the renewal package, written documentation must be provided showing the authority delegated to any,
such Authorized Representative (see Part II.B.11.b of the existing NPDES permit).
❑ A narrative description of the sludge management plan for the facility. Describe how sludge (or other
solids) generated during wastewater treatment are handled and disposed. If your facility has no such
plan (or the permitted facility does not generate any solids), explain this in writing. Submit one signed
original and two copies.
The following items must be submitted by any Municipal or Industrial facilities discharging
process wastewater:
Industrial facilities classified as Primary Industries (see Appendices A-D to Title 40 of the Code of Federal
Regulations, Part 122) and ALL Municipal facilities with a permitted flow >_ 1.0 MGD must submit a
Priority Pollutant Analysis (PPA) in accordance with 40 CFR Part 122.21.
The above requirement does NOT apply to privately owned facilities treating 100%
domestic wastewater, or facilities which discharge non process wastewater (cooling
water, filter backwash, etc.)
PLEASE NOTE:
Due to a change in fees effective January 1, 1999, there is no renewal fee required with your
application package.
Send the completed renewal package to:
Mrs. Valery Stephens
NC DENR / Water Quality / Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617

W A TF
O 17
r
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Hilton M. Withers
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D, Acting Director
Division of Water Quality
AND
MAR 1 1 2002�o��;i9..� ,
L:
f MAR 2 2 2002
f-:
SUBJECT: Notice of Violation and Assessment of Civil Penalties for Reporting Requirement Violations
NPDES Permit No. NCO082821
Southern States Cooperative GW Remediation Facility
Iredell County
LT 01-003
Dear Mr. Withers:
This letter transmits a Notice of Violation and Assessment of Civil Penalty assessed against Southern States
Cooperative in the amount of $ It VCO• CO
This assessment is based upon the following facts: the February and March 2001 toxicity self -monitoring report
forms were not filed with the Environmental Sciences Branch of the Division of Water Quality within the thirty (30) day
reporting period in accordance with the monitoring and reporting requirements contained in your NPDES Permit.
A previous Notice of Violation for failure to report the February 2001 toxicity self -monitoring data was sent to
the facility by certified mail dated April 25, 2001. Within the Notice, it was stated, "...if within the next twelve (12)
months, future reports are not received within the required time frame, you.may be assessed a civil penalty."
Based upon the above fact(s), I conclude as a matter of law that Southern States Cooperative violated or failed
to act in accordance with the requirements of G.S. 143-215.65. A civil penalty of not more than $10,000.00 may be
assessed against a person who fails to file, submit or make available any documents, data or reports required by G.S.
143-215.65.
Based upon the above facts(s) and conclusions of law, I hereby assess Southern States Cooperative a
$ Mcb. 00 civil penalty for this second violation of G.S. 143-215.65, pursuant to the authority delegated to me
by North Carolina Environmental Management Commission Regulation 15 NCAC 2J .003 and G.S. 143-215.6A(h). Any
continuing violation(s) may subject you to additional penalties.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
_.
Customer Service
1 800 623-6748

Within thirty days receipt of this notice, you must do one of the following:
1. Submit payment of the penalty:
Payment should be made directly to the Department of Environment, Health, and Natural
Resources (do not include waiver form). Payment of the penalty will not foreclose enforcement
action for any continuing or new violation(s). Please submit payment to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
OR
2. Submit a written request for remission or mitigation including a detailed justification for
such request.
A request for remission or mitigation is limited to consideration of the reasonableness of the
amount of the penalty and is not the proper procedure for contesting the accuracy of any of the
statements contained in the assessment letter. Because a remission request forecloses the option
of an administrative hearing, such a request must be accompanied by a waiver of your right to an
administrative hearing and a stipulation that there are no factual or legal issues in dispute. You
must execute and return to this office the attached waiver and stipulation form and a detailed
statement which you believe establishes whether:
(a) one or more of the civil penalty assessment factors in G.S. 143B-282.1(b) were
wrongfully applied to the detriment of the petitioner;
(b) the violator promptly abated continuing environmental damage resulting from the
violation;
(c) the violation was inadvertent or a result of an accident;
(d) the violator had been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial
actions.
Please submit this information to the attention of:
Ms. Coleen Sullins
Water Quality Section Chief
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Please note that all information presented in support of a request for remission must be submitted
in writing. The Director of the Division of Water Quality will review the information during a
bimonthly enforcement conference and inform you of his decision in the matter of the remission
request. His response will provide details regarding case status, directions for payment and
provision for further appeal of the penalty to the Environmental Management Commission's

Committee on Civil Penalty Remissions. Please be advised that the Committee cannot consider
information that was not part of the original remission request considered by the Director and
therefore, it is very important that you prepare a complete and thorough statement in support of
your request for remission.
OR
3. Submit a written request for an administrative hearing:
If you wish to contest any statement in this assessment letter, you must request an administrative
hearing. This request must be in the form of a written petition to the Office of Administrative
Hearings and must conform to Chapter 150B of the North Carolina General Statutes. You must:
File your original petition with the
Office of Administrative Hearings
6714 Mail Service Center
Raleigh, North Carolina 27699-6714
and
Mail or hand -deliver a copy of the petition to
Mr. Dan Oakley
General Counsel
Department of Environment and Natural Resources
1601 Mail Service Center
Raleigh, North Carolina 27699-1601
Failure to exercise one of the options above within thirty days as evidenced by a date stamp (not
a postmark) indicating when we received your response, will result in this matter being referred to
the Attorney General's Office with a request to initiate a civil action to collect the penalty. Please
be advised that additional assessments may be levied for future violations which occur after the
review period of this assessment.
If you have any questions, please contact Mr. Matt Matthews, Supervisor of the Aquatic
Toxicology Unit, or Mr. Kevin Bowden at [phone].
S' rely,
egory 1 T , Ph.D.
3 a
Dat
Attachments
cc: Region 4t4 t rcr sir
Point Source Compliance/Enforcement File
Aquatic Toxicology Unit
Central Files

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor.
Wiliam G. Ross Jr., Secretary
Gregory J. Thorpe, PhD., Acting Director
April 19, 2002
JIM WRIGHT
6606 WEST BROAD STREET
RICHMOND, VA 23230
Dear Mr. Wright:
1 � •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
APR 2 6 2002
IVQa8 r ���.i? L i,) � is�e7 Ivy c�'uJ
; a :ter 9
r•'.e � it ie�'taJ G
SUBJECT: PAYMENT ACKNOWLEDGEMENT
CIVIL PENALTY ASSESSMENT
SOUTHERN STATES
IREDELL COUNTY
PERMIT NO: NCO082821
LT 01-003
This letter is to acknowledge receipt of check No. 819277 in the amount of $1,000.00 received from
you dated April 03, 2002. This payment satisfies in full the civil assessment levied against
the subject facility and this case has been closed. Payment of this penalty in no way precludes future
action by this Division for additional violations of the applicable Statutes, Regulations or Permits.
If you have any questions, please call Bob Sledge at [phone].
Sincerely,
IVLColeen Sullins, Chief
Water Quality Section
Cc: Enforcement File #: LT 01-003
ti_ �MRO�Regional_Offic—e Superaisor�:::
Central Files
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

lk
March 25, 1994
LAW
ENGINEERING AND ENVIRONMENTAL SERVICES
Ms. Christine M. DeRoller, Hydrogeologist
North Carolina Department of Environment,
Health, and Natural Resources (NCDEHNR)
Division of Environmental Management
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
N.— I EPT. OF
EiRC:`QvIE :T, iiEALTR s
R !'•1ti ; E R RIESOURCES
iIAR 2- 8 994
�IAAIiGIF1LIYE
11�11ii ' u . u.l ;V1Vri6 OFFICE
Subject: Abandonment of Recovery Wells RW-1 and RW-3
Installation of Recovery Wells RW4 and RW-5
Southern States Fertilizer Plant
Statesville, Iredeli County, North Carolina
NCDEHNR Incident No. 5038
Law Environmental Project No. 56-1570
Dear Ms. DeRoller:
This letter serves to confirm our March 25; 1994 telephone conversation regarding the subject project.
As we discussed, Southern States Cooperative, Inc. intends to abandon Recovery Wells RW-1 and RW-3
at the Statesville site. Well abandonment will be conducted in general accordance with NCAC Title 15A
Subchapter 2C.0113. Also, Recovery Wells RW-4 and RW-5 will be installed as set forth in Section 5.3 -.
of the January, 1994 Corrective Action Plan for the site submitted by Canonie Environmental Services
Corporation.
This work is scheduled to be completed by May 15, 1994. Our full schedule of implementation will be
forthcoming prior to April 15, as requested in your March 18 Review of Corrective Action Plan_
correspondence.
Please contact me if my understanding of our conversation was inaccurate, or if you object to the -
proposed field work described herein. Your assistance with this project is greatly appreciated.
Sincerely,
LAW ENVIRONMENTAL NC, INC.
Thomas F. Beggs, P.E.
Principal
cc: Mr. Hilton M. Withers
Southern States Cooperative, Inc.
LAW ENVIRONMENTAL, INC.
2801 YORKMONT ROAD, SUITE 300 • CHARLOTTE, NC 28208
P. 0. BOX 240674 • CHARLOTTE, NC 28224-0674
[phone] 9 FAX [phone]
ONE OF THE LAW COMPANIES

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NCO082821
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 1.43-215. 1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Southern States Cooperative, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Statesville Fertilizer Plant
2552 Salisbury Highway
Six Miles East of Statesville
Iredell County
to receiving waters designated as Fourth Creek in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective August 1, 2019.
This permit and authorization to discharge shall expire at midnight on March 31, 2024.
Signed this day. 7/8/2019
DocuSigned by:
,'.:ZVIiL �~'i'7c'Y.vicrl�srt.
8328B44CE9EB4A1...
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page I of 7

DocuSign Envelope ID. CE09F386-lC34-4CEB-B476-38E5F37F2553
I Permit NC0082821
- -SUPPLEMENT TO PERMIT COVER SHEET- -
_ All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this
permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority
to operate and discharge from this facility arises under the permit,conditions, requirements, terms; and provisions included
herein.
Southern States Cooperative, Inc..
is hereby authorized to:
1. Continue to operate an existing 0.144 MGD groundwater remediation system with the following
components:
♦ Three recovery wells
♦ Lift station with wet well
♦ Caustic solution tank with pH measuring device
The facility is located six miles east. of Statesville at the Statesville Fertilizer Plant, off U.S. Highway
70, in Iredell. County; and
2. Discharge from said treatment works at the location specified on the attached map into Fourth Creek
[HUC: 0304010204021, classified C waters in subbasin 03-07-06 of the Yadkin -Pee Dee River Basin.
Page 2 of 7

DocuSign Envelope ID: CE09F386-lC34-4CEB7B476-38E5F37F2553
Permit NCO082821
PART I
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B.0400 et seq., 02B.0500 et seq.]
Grade 1 Physical Chemical WPCS [15A NCAC 08G .0302]
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee
is authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the
Permittee as specified below:
EFFLUENT CHARACTERISTICS
eDMR Code
LIMITS
MONITORING REQUIREMENTS
Monthly Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Location
Flown (MGD) 50050'
Monitor & Report
Continuous
Recording
Effluent
Total Suspended Solids (mg/L) C0530
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
NH3 as N (April 1— October 31) (mg/L) C0610
7.8 mg/L
35.0 mg/l
2/Month
Grab
Effluent
NH3 as N (November 1 — March 31) (mg/L) C0610
Monitor & Report
2/Month
Grab
Effluent
pH (su) 00400
> 6.0 and < 9.0 standard units
2/Month
Grab
Effluent
Copper (pg/L) 01042
Monitor & Report
Monthly
Grab
Effluent
Chlorides (mg/L) 00940
Monitor & Report
Monthly
Grab
Effluent
Total Nitrates (NO3 — N) (mg/L) 00620
Monitor & Report
Monthly
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN) (mg/L) C0600
Monitor & Report
Monthly
Grab
Effluent
Total Phosphorus (mg/L) C0665
Monitor & Report
Monthly
Grab
Effluent
Hardness — Total as
00900
CaCO3 or Ca+MG m /L 3
Monitor & Report
Monthly
Grab
Effluent
Chronic Toxicity4(mg/L) TGP3B
Monitor & Report
Quarterly
Grab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using NC DWR's eDMR system. See
Condition A. (3.).
2. All volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is not
feasible, then the discharger shall record the approximate time that discharge began and ended,'along with the
instantaneous flow at the time of the effluent sampling.
3. Effluent hardness sampling should be performed in conjunction with sampling for hardness dependent metals
(Copper).
4. Chronic Toxicity (Ceriodaphnia dubia) 7-day pass/fail test at 3% in February, May, August and November.
See condition A. (2.).
Conditions:
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 7

DocuSign Envelope ID: CE09F386-lC34-4CEB-B476-38E5F37F2553
Permit NCO082821
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
115A NCAC 02B.02001
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 3 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in. the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
February, May, August and November. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 201.0) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
:Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all.
concentration/response data, and.be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample. must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow,froin the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the f6rm. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Page 4 of 7

DocuSign Envelope ID: CE09F386-lC34-4CEB-B476-38E5F37F2553
Permit NCO082821
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY), continued
Should any test data from this monitoring requirement or tests performed by the "North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Form submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will. require immediate follow-up testing to be completed no later than the
last day of the month following the month of the initial monitoring.
A. (3.) ELECTRONIC REPORTING O.F DISCHARGE MONITORING REPORTS
(G.S. 143-215.1(B)l
Federal regulations require electronic submittal. of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on. December 21,
2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Reporting
Records Retention
Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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DocuSign Envelope ID: CE09F386-lC34-4CEB-B476-38E5F37F2553
Permit NC0082821
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or.
alternative forms approved by the Director. Duplicate signed copies -shall. be submitted to the mailing
address above. See "How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
Sewer Overflow/Bypass Event Reports;
Pretreatment Program Annual Reports; and
Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from. Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information. from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
- each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on EPA's NPDES
Electronic Reporting Rule is found at: http://www2.epa. ovg /compliance/final-national-12ollutant-
discharge-elimination-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Repuest a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin. submitting monitoring data and reports. The duration of a temporary
waiver shall not exceed 5 years and shall thereupon. expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re=applies for and is granted a
new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers
are not transferrable. Only permittees with an approved reporting waiver request may submit
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DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NCO082821
monitoring data and reports on paper to the Division for the period that the approved reporting
waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
httn://dea.nc. izov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (I I .)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following
web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
'7 certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible.for gathering the information,
the information submitted is, to the best of my knowledge and belief, trice, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations. "
A. (4.) NUTRIENT REOPENER FOR HIGH ROCK LAKE
[NCGS 143.215.1 (b)]
This permit may be reopened and modified to implement nutrient requirements in. accordance with any
future TMDL and/or nutrient management strategy for High Rock Lake.
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NPDES Permit Standard Conditions
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PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 125.1, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. 1n the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling. .
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 unL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual saunple
collection, or
.(3) Variable rime/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24.of the expected total daily flow at
the treatment system, or
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(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
Influent samples shall not be collected more than once per hour.
>= Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
:Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
'Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWR or "the Division" "
The Division of Water Resources, Department of Environmental Quality.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
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Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 31.1 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water .Resources.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant treasured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Pennittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Pei mittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405.of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306; 307, 308, 31.8, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
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imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject fo a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
g. Any person may be assessed an administrative penalty by the Administrator for violating section 30.1, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a pennit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to mininuze or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing". (Part II.C.4), "Upsets" (Part II.C.5) and "Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319..Furthernore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this pen -nit shall be construed to preclude the institution of any legal action or relieve the Pennittee
from any responsibilities, liabilities, or penalties to which the Pennittee is or may be subject to under NCGS 1.43-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1.321. Furthennore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
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7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 15013-23].
8. Duty to Provide Information
The Pennittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Pennittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue pennits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing pennit.) [40 CFR 122.21(d)] Any Pennittee that has not
requested renewal at least 180 days prior to expiration, or any Pennittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Pennit .Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge .
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) ' For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if-
(1) The authorization is made in writing by a person. described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual. occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
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c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, infonnation, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the infbr tnation; the information submitted is, to the best of my
knowledge and belief; true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of fines and imprisonment for knowing violations. "
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Ternination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02R .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC); of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in .R.esponsibl.e Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
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(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
y Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
Proper Operation and Maintenance
The Pennittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the'Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
[I.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during nonnal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal. periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
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(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the. upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. :Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Pennittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H '.0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records.
Representative Sampling
Samples collected and measurements taken, as required herein, shall be. representative of the pennitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wasfestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.410)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1. 1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on- the. last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
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NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part .l of
this permit and based on the manufacturer's -pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Pefmittees should contact the Division's
Laboratory Certification Section (9.19 733-3908) or visit https:Hdeq.nc.gov/about/divisions/Nvater-resources/water-
resources-data/water-sciences-home-page/laboratory-certification-branch for information regarding laboratory
certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41.1.
6. Records Retention
Except for records of monitoring information required by this pen -nit related to the Pennittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
y all calibration and maintenance records
> all original strip chart recordings for continuous. monitoring instrumentation
copies of all reports required by this permit
r copies of all data used to complete the application. for this permit
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These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(l)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
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particular NCGS 143-215. 1 (b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this pen -nit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Pennittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submssion shall also be
provided within 5 days of the time the Pennittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part H.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Pennittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the .Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical. failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
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of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41 ].
12. Annual Performance Reports
Permittees who own or operate facilities that primarily collect or treat municipal or domestic wastewater and have
an average annual flow greater than 200,000 gallons per day shall provide an annual report to the Permit Issuing
Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The report shall summarize the
performance of the collection or treatment system, as well as the extent to which the facility was compliant with
applicable Federal or State laws, regulations and niles pertaining to water quality. The report shall be provided no
later than sixty days after the end of the calendar or fiscal year, depending upon which annual period is used for
evaluation.
The report shall be sent to:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
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PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Pennittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.l(a5) [SL 2011-394], no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
c. Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been.
submitted by the Permittee and approved by'the Division.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (1.00 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3). Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific treasures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
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PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this pennit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and 0) and 15A NCAC 02H .0903(b)(11)]
Interference
.Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite .POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [I 5A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02.H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
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A11 POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the pennit.
For purposes of this paragraph; adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Pennittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Perniittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestrearns with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using -the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
(3) Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence .of toxic gases, vapors, or fames within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Pennittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
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3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee maybe necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.440)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.440)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey(IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(0(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.440)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Pernuttee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMR$ (as required by Parts I1.1) and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this pen -nit (or any subsequent permit modification) the
Permittee shall submit to the,Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
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enforceable :Pretreatment Standards as defined by 40 CFR 403.3 (1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all IUPs. Permitted [UP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [1.5A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtQ
The Permittee shall ensure that an Authorization to Construct permit (AtQ is issued to all applicable .Industrial
Users for the constriction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (]UP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)]
7. POTW inspection & Monitoring of their ]Us
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Penmittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;
b. Sample all Significant Industrial Users (SIUs) at least once per calendar year for all SIU permit_limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.440)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 1.5A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [I 5A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(0(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
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NC DEQ / Division of Water Resources / Water Quality Permitting Section
:Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Sunnmary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial. Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division,
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on .Industrial Data Summary Forms (ID SF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (IUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 021­1 .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record'Kegping
The Pennittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC. 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [I 5A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
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