WQ0003924_Regional Office Historical File Pre 2018

ROY COOPER
Governor
MICHAEL S. REGAIN
secreCanr
S. DANIEL SMITH
Dita:ctor
NORTH CAROLINA
Environmental Quality
May 7, 2020
Certified Mail # 7018 0360 0002 2099 8047
Return Receipt Requested
Perry Keister - Partner
Linco Partnership
288 Whitehouse Drive
Lincolnton, NC 28092
Certified Mail # 7018 0360 0002 2099 8054
Return Receipt Requested
Perry Keister — Partner
Linco Partnership
5200 Old Harding Road
Nashville, TN 37064
- Subject: Status pf Facility _
_ Linco. Partnership =Lincolnton WWTF
Permit No. WQ0003924
Wastewater Irrigation System
Lincoln County
Dear Mr. Keister:
The staff of the Mooresville Regional Office (MRO) has received documentation indicating the
Industrial User Pretreatment Permit, number 0028, issued by the City of Lincolnton to Celadon
Recycling Solutions was revoked by the City of Lincolnton effective April. 27, 2020. This issue
requires Division of Water Resources (DWR) to ask how all wastewaters are being handled at the
site and who is operating the site.
Please respond in writing to the following items:
1. Describe and provide documentation of all domestic and industrial wastewater streams
and how both are being handled and disposed of.
2. Specifically describe how any parts of the wastewater treatment system described in Non -
Discharge Permit #WQ0003924 are being utilized.
3. Provide information about the ownership and operation 'f the site including details of the
relationship between Linco Partnership and Celadon Recycling Solutions as it may relate
to wastewater at the site.
North Cai-olitia Departinent ofEnvironmental t�taaiity l '9:vision ofWater ResoUrces
Mooresvilie P.egional Office ; 610 East Center Avenue Suite 301 1 Ivtooresville. North Carolina 28115
.
704.6611699

4. Provide a list of all parties that may be involved in the Linco Partnership that may be
involved in the operation and maintenance of the site as it may relate to wastewater at the
site.
5. Provide a list of all other entities providing waste streams to the site that may contribute
to the wastewater streams.
6. Describe site activities related to the handling of rinsate from totes or any other vessels.
7. Describe site activities and number of occurrences that may have resulted in any spills of
wastewater and activities taken to clean up any spills.
8. Provide the name and license number of the currently designated Operator in Responsible
Charge of the permitted Non -Discharge system.
Please respond to the above noted items within 10 calendar days of receipt of this letter. Your
response will be used to determine if further action is necessary by the Division.
A review of our files indicates the subject Non -Discharge permit was issued on March 26, 2019,
as a result of Linco Partnership's written request to change ownership. Please be advised that
several conditions of the permit require written and .verbal notification to DWR prior to operation
of the Non -Discharge wastewater treatment system. Also, please be advised that the subject permit
only allows for waste streams as described in your permit application.
Should you have any questions, feel free to contact our office by phone at 704-235-2198 or by
email at edward.watsongnedenr.gov.
Sincerely,
DocuS*ign�eyd by,
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
CC: Brent Burch, DWM-Hazardous Waste Section (via email)
Sean Morris, DWM- Hazardous Waste Section (via email)
Jason Watkins, DWM- Soil Waste Section (via email)
Deb Aja, DWM-Solid Waste Section (via email)
Vivien Zong, PERCS Unit-NCDWR (via email)
Donald Burkey, Lincolnton WWTP (via email)
Steve Reid, Operator Certification (via email)
EPA Region IV, Atlanta, Georgia

A
,4
FILE
R,M: COOPER
N,11CHAEL S. RLCit\I',J
S. DANIEL SMITH
Ohv� fo
NOR i H CAROLINA
Environmental Quality
June 5, 2020
Certified Mail # 7016 1370 0000 2593 7650
Return Receipt Requested
Perry Keister - Partner
Linco Partnership
288 Whitehouse Drive
Lincolnton, NC 28093
Certified Mail # 7016 1370 0000 2593 7667
Return Receipt Requested
Perry Keister — Partner
Linco Partnership
5200 Old Harding Road
Nashville, TN 37064
Subject: NOTICE OF VIOLATION and
NOTICE OF INTENT TO ENFORCE
NOV-2020-PC-0261
Linco Partnership
Permit No. WQ0003924
Wastewater Irrigation System
Lincoln County
Dear Mr. Keister:
Your response to the Division of Water Resources' (Division) letter requesting information was
received on May 19, 2020. A review of your response along with the subject permit and file
revealed the violations indicated below:
1. Failure to designate an Operator in Responsible Charge (ORC)
Your subject permit in Condition III OPERATION AND MAINTENANCE
REQUIREMENTS, Item 2. states, "Upon the Water Pollution Control System Operators
Certification Commission's (WPCSOCC) classification of the subject non -discharge
facilities, in accordance with 15A NCAC 08G .0200 the Permittee shall designate and
employ a certified operator in responsible charge (ORC) and one or more certified
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No. -Ili Cc, oiina Dep.vi: icM cd `` i inmmentel Qt:ai;?t Division of b\cdcr Resow-c,s
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operator(s) as Back-up ORC(s). The ORC or their back-up shall visit the facilities in
accordance with 15A NCAC 08G .0200, and shall comply with all other conditions
specified in the previously sited rules. [15A NCAC 02T .0117]"
In addition, Title 15A NCAC 08G .0201 RESPONSIBILITY OF SYSTEM OWNERS TO
DESIGNATE CERTIFIED OPERATORS states, "Owners of classified water pollution
control systems shall designate operators certified by the Commission of the same type and
grade as the classification for the system and for each classification shall:
(1) designate one ORC who possesses a valid certificate of the type and grade at least
equivalent to the type and grade of the system;
(2) designate one or more Back-up ORC(s) 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 Back-up ORC is required for systems whose minimum visitation requirements are
twice per year; and
(3) submit a signed completed 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 ORC and the Back-up ORC:
(a) 60 days prior to wastewater or residuals being introduced into a new system;
(b) within 120 days following:
(i) notification of a change in the classification of the system requiring the
designation of a new ORC and Back-up ORC of the proper type and
grade; or
(ii) a vacancy in the position of ORC or Back-up ORC; or
(c) within seven days of vacancies in both ORC and Back-up ORC positions
replacing or designating one of the responsibilities. the Operator Designation Form
may be found on the Commission website . at:
https:Hdeq.ne.gov/about/divisions/water-resources/operator-
certification/wastewater-operatorcertification/wastewater-operator-certification-
downloads and shall include:
(i) the owner's name, contact information, and signature;
(ii) the system name, location, permit number, type, and classification;
(iii) the ORC name, contact information, the type and grade of the
certification, and signature; and
(iv) the Back-up ORC name(s), contact information, the type(s) and
grade(s) of the certification(s), and the signature(s)."
Division records indicate that no ®RC or Back-up ®RC has been designated or
currently employed by Linco Partnership.
2. Unpermitted Discharge of Wastewater
Your subject permit in Condition II. PERFORMANCE STANDARDS, Item 1. states, "The
subject non -discharge facilities shall be effectively maintained and operated at all times so
there is no discharge to surface waters, nor any contravention of groundwater or surface
water standards. In the event the facilities fail to perform satisfactorily, including the
creation of a nuisance condition due to improper operation and maintenance, the Permittee
shall take immediate corrective actions including Division required.actions as stipulated in
G.S. 143-215.1, 143-213.3(a)".

I
In addition, Condition I1I. OPERATION AND MAINTENANCE REQUIREMENTS,
Item 1. states, "The facilities shall be properly maintained and operated at all times. The
facilities shall be effectively maintained as a non -discharge system to prevent the discharge
of any wastewater resulting from the operation of this facility."
In addition, Conditions III. OPERATION AND MAINTENANCE REQUIREMENTS,
Item 11. states, "Diversion or bypassing of untreated or partially treated "wastewater from
the treatment facilities is prohibited. [15A NCAC 02T .0505(d)]"
Your response on May 19, 2020, indicated that wastewater was discharged from the
-system on or about April 13, 2020, as a result of heavy rains and a power outage.
3. Failure to report a discharge
Your subject permit in Condition IV. MONITORING AND REPORTING
REQUIREMENTS, Item 13. Noncompliance Notification states "The,.Permittee shall
report by telephone to the Mooresville Regional Office, telephone number [phone],
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. Treatment of wastes abnormal in quantity or characteristic, including the known
passage of a hazardous substance.
b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or
unknown reasons, rendering the facility incapable of adequate wastewater
treatment.
c. Any facility failure resulting in a by-pass directly to receiving surface waters.
d. Any time self -monitoring indicates the facility has gone out of compliance with its
permit limitations.
e. Ponding in or runoff from the irrigation sites.
Any emergency requiring immediate reporting (e.g., discharges to surface water, imminent
failure of a storage .structure, etc.) outside normal business hours shall be reported to the
Division's Emergency Response personnel at telephone number [phone], (800)
733-3300. Persons reporting such occurrences by telephone shall also file a written report
in letter form within five days following first knowledge of the occurrence. This report
shall outline the actions taken or proposed to be taken to ensure the problem does not recur.
[15A NCAC 02T .105(1), 02T .6108 (b)(1)]"
The Division has no record of any report from Linco Partnership regarding the
discharge(s) that occurred on or about April 13, 2020, as noted in your
correspondence dated May 19, 2020.
4. Failure to conduct monitoring as required
Your subject permit . in Condition IV. MONITORING AND REPORTING
REQUIREMENTS, Item 3 'states, "Flow through the treatment facility shall be
continuously monitored, anq daily flow values shall be reported on Form NDMR.

I
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Signature � Agent
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permits. D. Is delivery address d erent from item 17 No
or on the front if spaceIf YES, enter eiivery address below:1 i�
1. Article Addressed to: U L�
LINCO PARTNERSHIP
288 WHITEHOUSE DRIVE
LINCOLNTON NC 28093
ATTN: PERRY KEISTER �aP �MallExPre-O
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0
ROY COOPER
Governor
MICHAEL S. REGAN
S. DANIEL SMITH
Diri,ctnr
NORTH CAROLINA
Environmental Quality
May 7, 2020
Certified Mail # 7018 0360 0002 2099 8047
Return Receipt Requested
Perry Keister - Partner
Linco Partnership
288 Whitehouse Drive
Lincolnton, NC 28092
Certified Mail # 7018 0360 0002 2099 8054
Return Receipt Requested
Perry Keister — Partner
Linco Partnership
5200 Old Harding Road
Nashville, TN 37064
Dear Mr. Keister:
FILE
Subject: Status of Facility
Linco Partnership — Lincolnton WWTF
Permit No. WQ0003924
Wastewater Irrigation System
Lincoln County
The staff of the Mooresville Regional Office (MRO) has received documentation indicating the
Industrial User Pretreatment Permit, number 0028, issued by the City of Lincolnton to Celadon
Recycling Solutions was revoked by the City of Lincolnton effective April 27, 2020. This issue
requires Division of Water Resources (DWR) to ask how all wastewaters are being handled at the
site and who is operating the site.
Please respond in writing to the following items:
1. Describe and provide documentation of all domestic and industrial wastewater streams
and how both are being handled and disposed of.
2.- Specifically describe how any parts of the wastewater treatment system described in Non -
Discharge Permit #WQ0003924 are being utilized.
3. Provide information about the ownership and operation of the site including details of the
relationship between Linco Partnership and Celadon Recycling Solutions as it may relate
to wastewater at the site.
North Carolina Department of Environmental Quality 1 Division of Water Resources
Mooresville Regional Office 1 610 East Cenrer Avenue, Suite 301 I Mooresville, North Carolina 28115
timgeutr+uatw :�. :3au wi3xu�etr 7049663.1699

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._.288 WHITEHOUSE DRIVE
LINCOLK"TON NC 28092
A IT IN: PERRY KEISTER
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4. Provide a list of all parties that may be involved in: the Linco Partnership that may be
involved in the operation and maintenance of the site as it may relate to wastewater at the
site.
5. Provide a list of all other entities providing waste streams to the site that may contribute
to the wastewater streams.
6. Describe site activities related to the handling of rinsate from totes or any other vessels.
7. Describe site activities and number of occurrences that may have resulted in any spills of
wastewater and activities taken to clean up any spills.
8. Provide the name and license number of the currently designated Operator in Responsible
Charge of the permitted Non -Discharge system.
Please respond to the above noted items within 10 calendar days of receipt of this letter. Your
response will be used to determine if further action is necessary by the Division.
A review of our files indicates the subject Non -Discharge permit was issued on March 26, 2019,
as a result of Linco Partnership's written request to change ownership. Please be advised that
several conditions of the permit require written and verbal notification to DWR prior to operation
of the Non -Discharge wastewater treatment system. Also, please be advised that the subject permit
only allows for waste streams as described in your permit application.
Should you have any questions, feel free to contact our office by phone at 704-235-2198 or by
email at edward.watsongncdenr.gov.
Sincerely,
DocugSiignnedd Eby: o
A14 CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
CC: Brent Burch, DWM-Hazardous Waste Section (via email)
Sean Morris, DWM- Hazardous Waste Section (via email)
Jason Watkins, DWM- Soil Waste Section (via email)
Deb Aja, DWM-Solid Waste Section (via email)
Vivien Zong, PERCS, Unit-NCDWR (via email)
Donald Burkey, Lincolnton WWTP (via email)
Steve Reid, Operator Certification (via email)
EPA Region IV, Atlanta, Georgia

�ISM
fi
Water Resources
Environmental Quality
ROY COOPER
Govertim-
M.ICHAEL S. REGAN
Secretan,
S. JAY ZIMMERMAN
Director
May 17, 2017
National Fruit Products Company Holdings, LLC
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David C. Gum, III
Member/Manager NFP Holdings, LLC
Dear Mr. Gum:
Subject: Non -Discharge Permit Inspection
Permit #WQ0003924 - Wastewater Irrigation System
National Fruit— Lincolnton Plant
Lincoln County
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on May 5th, 2017.
The MRO would like to thank Glen Fredell (Facility Maintenance) and Lynn Aldridge (ORC) for their time
during the inspection.
This system has not been in operation since 2009. During the site visit, the lagoon was reviewed and an
assessment was made regarding the lagoon condition.
The lagoon liner is in disrepair and there is significant vegetation growing in the berm. The exposed liner
has also become compromised due to exposure to the sun and large areas of the liner material have
become threadbare due to this exposure. The unexposed liner appears to be water tight as the lagoon
water level can be maintained. However, due to the presence of vegetation in the berm and the fact
that the lagoon liner has been torn, this site is considered to not be in compliance with the permit.
The option of lagoon closure and permit rescission is currently being evaluated by NFP. During the site
visit, MRO staff was informed that the spray irrigation system will be able to effectively reduce the
water level of the lagoon up to a point. Closure will require evaluation of sludge thickness, as it is
currently unknown.
During the site visit, a hard copy of the Lagoon Closure procedures was present to Mr. Fredell.
The MRO has also included the website link, "Guidelines for the Closure of ... Lagoons". The Guidelines
for Closure-:. the document may be located on NCDEQ website at:
http://deq.nc.gov/a bout/divisions/water-resources/water-resources-perm its/wastewater-
branch/ground-water-protection/ground-water-policies.
State or North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

or
Should you have any questions regarding the report, please feel free to contact at 704-235-2198 or by
email at edward.watson . dcdner.ov.
CC: Lynn Aldrich (via email)
Non -discharge Compliance, CO Raleigh
Sincerely,
Ed6vard Watson, Hydrogeologist
Mooresville Regional Office .
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ

City of Lincolnton, North Carolina
PERMIT
Industrial User Pretreatment Permit (IUP)
To Discharge Wastewater Under the
Industrial Pretreatment Program
0028 N/A
IUP Number 40 CFR Category(if Applicable)
In compliance with the provisions of North Carolina General Statute 143-215.1, any applicable
federal categorical pretreatment regulations, all other lawful standards and regulations promulgated
and adopted by the North Carolina Environmental Management Commission, and the City of
Lincolnton Sewer Use Ordinance. The following Industry, hereafter referred to by name or as the
permittee:
Industry name, permittee:
Celadon Recycling Solutions
Facility Located at Street Address
244 Whitehouse Drive
Mailing Address (if different)
City, State, Zip
Lincolnton, NC 28092
is hereby authorized to discharge wastewater from the .facility located at the above listed address
into the sanitary sewer collection system and the wastewater treatment facility of the City of
Lincolnton listed below:
IUP Control Authority and/or Municipality WWTP name:
City of Lincolnton WWTP
NPDES Number:
NC0025496
W WTP Address:
550 Highway 150 West, Bypass
City, State, Zip:
Lincolnton, NC 28092
in accordance with effluent limitations, monitoring requirements, and all other conditions set forth
in Parts I, II, and III of this Industrial User Pretreatment Permit (IUP).
Effective date, this permit and the authorization to discharge shall become
effective at midnight on this dale:
March 13, 2018
Expiration date, this permit and the authorization to discharge shall expire at
midnight on this dale:
February 28, 2023
.51/ ZZ Z t
pr��
Date signed Water Resources Director
Date signed City Man 'e

LAGOON WATER LEVEL
INCHES TO GALLONS
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1632 365.37
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439,599.12
so
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133
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00
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492,063.47
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State of North Carolina
:� Department of Environmental Quality
w t� �:
Division of Water Resources
DI I NON -DISCHARGE SYSTEM RENEWAL,
Division of Water Resources FORM: NDSR 09-19
This Form is for renewal without mortification for all non -discharge system permits, except Residuals Management and Single -
Family Residence Wastewater Irrigation System permits.
For more information, visit the Water Quality, Permitting Section's Non -Discharge Branch Website.
t
RECEIVE®
E
1. PERMITTEE INFORMATION: 1
i
1. Permittee: North Carolina Division of Parks and Recreation By, Nathaniel Thvrriburg at 9`01 am,' Apr 18;=202C
2. Signature authority's name: Scott Avis per 15A NCAC 02T .0106(b) Title: Park. Superintendent
Primary Telephone number: [phone] Select Secondary number: (i} _- Select
Email Address: scott.avis@ncparks. gov
3. Permittee's mailing address: 759 State Park Rd
City: Troutman State: NC Zip: 28166
4. Billing address (if different from above):
City: State: Zip:
5. Contact person's name (if different from signature. authority): Title:
Primary Telephone number: Select Secondary number: (_ _) _- Select
Email Address:
11. PERMIT INFORMATION:
l.. Existing permit number: WQ0020881
2. Has the facility been constructed? ® Yes or ❑ No e1
If yes, has the facility been constructed in accordance with the permit and the Division -approved plans and specifications?
[ 1.SA NCAC; 02T .{} 1 10 ® Yes or ❑ No
If no, a formal permit modification request shalt be submitted to the Division.
3. Has any of the property ownership within the facility and/or disposal area changed from what is indicated in the current permit
(Attachment B — disposal field owner/lessee)? ❑ Yes or ® No
Has the Permittee had a name',change or has the permit changed ownership? ❑ Yes or ® No-
. J
If yes to either, a permit modification request shall be. submitted to the'Divisioti• �'[r5A'I1�CAC 02T ,01.05.1
4. is this facility a Privately-Ov .ed Public Utility? ❑ Yes or ® No
If yes, provide two copies of the Certificate of Public Convenience and Necessity from the North Carolina Utilities Commission
demonstrating the Applicant is authorized to hold the utility franchise. [15A NCAC 02T .01 1.5(a)(1)]
5. Is the Permittee a Home/Property Owners' Associations or Developers of lots to be sold? ,.;.❑ Yes or ® No
If yes, provide the following: t.
• For Home/Property Owners' Associations — Operational A regiment (FORM: TIC) and a copy of the proposed or
approved Articles of Incorporation, Declarations, and By-laws [15A NCAC 02T .fit 15(c)]
a For Developers of lots to be sold — Operational. Aereement (FORM: DEV) [ 15A NCAC 02T .01 15(b)]

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0003924)
Attn: (Erick Saunders) Facility name: National Fruit Spray Irrigation
County: Lincoln
From: (Edward Watson)
Mooresville Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 10/30/2018
b. Site visit conducted by: Edward Watson
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Perry Keister and their contact information: (828) 638 - 5032 ext.
e. Driving directions:
2. Discharge Point(s): N/A This is a spray irrigation permit and it should not discharge to surface waters.
Latitude:
Latitude:
Longitude:
Longitude:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Lynn Aldrich Certificate #:993778 Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: This facility has not actively operated since October of 2008. The last
application event was December of 2016. The facility has been up for sale for several years. The property was
recently sold to Linco Properties in October 2018.
Proposed flow: 60,000 GPD
Current permitted flow: 60,000 GPD
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) Since the sale, the irrigation system has been isolated form the storage tank so the liquid now in the tank is
not able to be transferred to the spray irrigation application fields.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? The system has not had a spray event since 2016
FORM: WQROSSR 04-14 Page 1 of 3

4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ® Yes or ❑ No
If yes, please explain: The new property owner has no plan to re -activate the spray irrigation system currently in
place. The new property owner has a pre-treatment permit to transfer wastewater to the Town of Lincolnton
WWTP.
5. Is the residuals management plan adequate? ❑ Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or X No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: The 300,000 gal tank has been repurposed for storage of other materials and has been
disconnected from the wastewater system. It should be removed from the permit description.
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
If no, please explain: The wells will need to be abandoned as part of the system closure activities.
11. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: This system has not operated since late 2016, MW-59s
are current and have shown no exceedances.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
13. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: N/A
16. Pretreatment Program (POTWs only): N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain:
2.. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
® Issue upon receipt of needed additional information
FORM: WQROSSR 04-14 Page 2 of 3

r
ROY COOPER NORTH CAROLINA,
Goc,:rm, 6nvlronmentalQaatttp
N11CRAEL S. REGA,
LDTDA CULPEPPER.
InterfanDimt-
Certified Mail # 7018 0360 0002 2099 0928
Return Receipt Requested
July 3, 2019
Perry Keister - Partner
LINCO PARTNERSHIP
5200 Old Harding Rd.
Nashville, TN 37064
SUBJECT: NOTICE OF VIOLATION
Tracking Numbers: See Chart Below
Permit No. WQ0003924
Linco Partnership
Lincoln County
Dear Mr. Keister:
A review of the May 2018 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Permit Condition Violations-:
Parameter
Date(s)
Type of Violation
NOV NUMBER
Reporting Violation
10/31/2018
Late/Missing NDAR-1 and NDMR
NOV-2019-PC-0493
Reporting Violation
11/30/2018
Late/Missing NDAR-1 and NDMR
NOV-2019-PC-0494
Reporting Violation
12/31/2018
Late/Missing NDAR-1 and NDMR
NOV-2019-PC-0495
Reporting Violation
01/31/2019
Late/Missing NDAR-1 and NDMR
NOV-2019-PC-0496
Reporting Violation
02/28/2019
Late/Missing NDAR-1 and NDMR
NOV-2019-PC-0497
A Notice of Violation is being issued for the noted violations of North Carolina General Statute (G.S.) 143-215.1
and the facility's NPDES WW Permit. 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.
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

v
If you wish to provide additional information regarding the noted violations, request technical assistance, or
discuss overall compliance please respond in writing within thirt ry (30) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Monitoring
Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no
response is received in this Office within the 30-day period, a civil penalty assessment may be
prepared.
Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. 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.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
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,
DocuSigned by:
A14CC681 AF27425...
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
North Carolina Department of Environmental Quality i Division of Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

Visitation to Celadon which led to the Expulsion of and co-worker and me
On April 27, 2020, at approximately 1100 hours, Ron Specht and l visited
Celadon to discuss a diagram of Celadon's tote washing area that Perry emailed
to me this morning. Perry wanted me to include this diagram in Celadon's permit
modification that is due to Raleigh today and has already been signed by the City
Manager and Water Resources Director.
Below is a summation of events which took place at Celadon:
Ron and I entered the facility through the front doors and went to the office where
Perry was sifting. 1 began to talk with Perry about his requested changes that he
wants to be included in Celadon's upcoming modified permit. I also mentioned
that prior to Celadon's receipt of their modified permit that the three hundred
thousand gallon equalization basin needs to be pumped out and, I needed to see
the documentation/chain of custody for receipt of the water by an outside
company. I also stated that after I finished talking with him that I was going to
look inside the equalization basin. Perry stated that there was only glue water in
the equalization basin and I responded that I still need to see what is in the tank.
The conversation continued on regarding the requested unit on his diagram. The
requested unit is a carbon filtration unit which helps with the Biological Oxygen
Demand Test. When I asked to see'this piece of equipment Perry, Ron, and I left
the office and began walking to and through the bay area's inside the facility.
When we entered the bay, where the loading dock is located, I noticed
approximately 8-12 full totes sitting on the floor of the bay. I asked Perry why
these totes were sitting inside the bay and he explained that these totes were just
placed there today and someone else will move them later today to the
solidification area. I then asked, since these totes were being moved by a forklift
if they could just move them from the tote washing bay straight to the
solidification building. Perry explained to me that at our meeting, on April 13th,
2020, the verbal agreement entered was to move the full totes out of the tote
washing room. I explained that what I agreed to was for the removal of all totes
out of the building. Perry went on to ask if what I am saying is that in the one and
only place where the loading dock is located that he cannot store totes that he
unloads in the bay or totes that are filled with wastewater in the tote cleaning bay

on a temporary basis. I replied, if he wants a modified permit all totes need to be
removed and I reminded him that any tote that is accepted by Celadon is not
supposed to contain more than three inches of residual wastewater. We
continued with our conversation and walked outside where the carbon filtration
unit is located. We talked a little about the unit and walked back into the bay area
passing the loading dock and entered the tote washing area. While showing me
where he plans to install the filtration unit, he abruptly changed the conversation
by saying the more I think about this I have had enough. He continued this
conversation by saying to Ron and me that we need to leave now and repeated
the words let's go several times. Perry also mentioned that he wanted to have a
meeting, did not want the permit modification to go forward to the State, and he
was going to disconnect from the City and send us a picture of the disconnection.
I tried to call Burkey, as Ron and I were being expelled from Celadon, to inform
him of the events that were taking place. As Ron and I were exiting the facility,
Perry held the door opened and stated he will get in touch with his attorney about
this permit problem/change. Ron and I did exit the facility as Perry watched us
get in the vehicle and drive off. I had planned to look at their equalization and
pump house basins but did not get the opportunity to do so.
Pursuant to the Sewer Use Ordinance, Section 8-64 - Right of Revision, "The
City reserves the right to establish limitations and requirements which are more
stringent than those required by either State or Federal regulation if deemed
necessary to comply with the objectives presented in Section 8.50 of this article
or the general and specific prohibitions in Section 8.60 of this article, as allowed
by 40 CFR 403.4".
This section of the sewer use ordinance was taken under consideration, when
modifying Celadon's permit, as a prevention tool to aid in the safety of the City's
sewer from unauthorized waters reaching the City's Wastewater Treatment Plant.
Since all of Celadon's drains are connected and flow to the pump house an
accidental puncture of a container or other releases could spill ending up into our
sewer system.
I am requesting to have Celadon's permit terminated since, at this time, I am no
longer able to monitor their compliance because I am banned from their
property.

xx-)
l -
Debra V Tunstall
Pretreatment Compliance Technician
Ronald N. Specht
Biological Operator

Watson, Edward M
From: Donald A. Burkey<[e-mail]>
Sent: Tuesday, April 28, 2020 4:46 PM
To: Watson, Edward M
Cc: Pitner, Andrew; Basinger, Corey
,Subject: [External] RE: NCDEQN Non -Discharge Permit for WQ0003942
Attachments: Debra Expulsion Letter.pdf
El
Sorry for the late response today concerning this matter. We have been in discussions most of the day concerning the
situation that occurred at Celadon on Monday. I have attached a letter from Debra Tunstall outlining the events that
occurred on Monday during her visit to Celadon.
The City of Lincolnton has decided to revoke the Industrial User Pretreatment Permit issued to Celadon Recycling
Solutions effective April 27, 2020 at the direction of the City Manager due to Debra being removed from their property
and at the written request of Mr. Perry Keister in an email directed to Debra and Richard Haynes, Asst. City Manager.
At the present time, Celadon Recycling Solutions has very limited storage capacity at their facility in their 300,000 gallons
storage tank/equalization basin and inside in their process units. We do know Celadon is still receiving shipments of IBC
totes for cleaning which are believed to contain paraquat. Celadon is also receiving other waters into the facility from
tankers.
With limited amount of room for storage or treatment and not an option to discharge into the city sewer, I believe they
will begin discharging these waters into the lagoon onsite.
I will e-mail a copy of the City's revocation letter to Celadon once I receive'it. I am currently sorting through some
pictures I have received showing a spill that happened and of the paraquat being present in their process water. I will
email them tomorrow.
Thank you for your help with this and let us know what we can do to help with this situation.
Donald A. Burkey, Jr., Superintendent
City of Lincolnton
Waste Water Treatment Plant
P.O. Box 617
608 W. Hwy 150 Bypass
Lincolnton, NC -28093
Phone: [phone]
Fax: [phone]
Lincolnton NC

From: Watson, Edward M [mailto:[e-mail]]
Sent: Monday, April 27, 2020 12:06 PM
To: Donald A. Burkey
Cc: Basinger, Corey; Pitner, Andrew
Subject: NCDEQN Non -Discharge Permit for WQ0003942
Don,
I have spoken with Debra Tunstall and I have attached a copy for the Non -Discharge permit for the same facility.
Once you have discussed the situation at this facility, please send me a report including what time Debra was asked to
leave the facility.
Also, send me information regarding the spill and any other photos that were taken.
Please copy Corey Basinger and Andrew Pitner in your response.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
[e-mail]
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

W,.,.l
I MIM,
;+ s
Visitation to Celadon which led to the Expulsion of my co-worker and me
On April 27, 2020, at approximately 1100 hours, Ron Specht and I visited
Celadon to discuss a diagram of Celadon's tote washing area that Perry emailed
to me this morning. Perry wanted me to include this diagram in Celadon's permit
modification that is due to Raleigh today and has already been signed by the City
Manager and Water Resources Director.
Below is a summation of events which took place at Celadon:
Ron and I entered the facility through the front doors and went to the office where
Perry was sitting. 1 began to talk with Perry about his requested changes that he
wants to be included in Celadon's upcoming modified permit. I also mentioned
that prior to Celadon's receipt of their modified permit that the three hundred
thousand gallon equalization basin needs to be pumped out and, I needed to see
the documentation/chain of custody for receipt of the water by an outside
company. I also stated that after I finished talking with him that I was going to
look inside the equalization basin. Perry stated that there was only glue water in
the equalization basin and I responded that I still need to see what is in the tank.
The conversation continued on regarding the requested unit on his diagram. The
requested unit is a carbon filtration unit which helps with the Biological Oxygen
Demand Test. When I asked to see this piece of equipment Perry, Ron, and I left
the office and began walking to and through the bay area's inside the facility.
When we entered the bay, where the loading dock is located, I noticed
approximately 8-12 full totes sitting on the floor of the bay. I asked Perry why
these totes were sifting inside the bay and he explained that these totes were just
placed there today and someone else will move them later today to the
solidification area. I then asked, since these totes were being moved by a forklift
if they could just move them from the tote washing bay straight to the
solidification building. Perry explained to me that at our meeting, on April 13th,
2020, the verbal agreement entered was to move the full totes out of the tote
washing room. I explained that what I agreed to was for the removal of all totes
out of the building. Perry went on to ask if what I am saying is that in the one and
only place where the loading dock is located that he cannot store totes that he
unloads in the bay or totes that are filled with wastewater in the tote cleaning bay

on a temporary basis. l replied, if he wants a modified permit all totes need to be
removed and I reminded him that any tote that is accepted by Celadon is not
supposed to contain more than three inches of residual wastewater. We
continued with our conversation and walked outside where the carbon filtration
unit is located. We talked a little about the unit and walked back into the bay area
passing the loading dock and entered the tote washing area. While showing me
where he plans to install the filtration unit, he abruptly changed the conversation
by saying the more 1 think about this I have had enough. He continued this
conversation by saying to Ron and me that we need to leave now and repeated
the words let's go several times. Perry also mentioned that he wanted to have a
meeting, did not want the permit modification to go forward to the State, and he
was going to disconnect from the City and send us a picture of the disconnection.
I tried to call Burkey, as Ron and I were being expelled from Celadon, to inform
him of the events that were taking place. As Ron and I were exiting the facility,
Perry held the door opened and stated he will get in touch with his attorney about
this permit problem/change. Ron and I did exit the facility as Perry watched us
get in the vehicle and drive off. I had planned to look at their equalization and
pump house basins but did not get the opportunity to do so.
Pursuant to the Sewer Use Ordinance, Section 8-64 - Right of Revision, "The
City reserves the right to establish limitations and requirements which are more
stringent than those required by either State or Federal regulation if deemed
necessary to comply with the objectives presented in Section 8.50 of this article
or the general and specific prohibitions in Section 8.60 of this article, as allowed
by 4&CFR 403.4".
This section of the sewer use ordinance was taken under consideration, when
modifying Celadon's permit, as a prevention tool to aid in the safety of the City's
sewer from unauthorized waters reaching the City's Wastewater Treatment Plant.
Since all of Celadon's drains are connected and flow to the pump house an
accidental puncture of a container or other releases could spill ending up into our
sewer system.
I am requesting to have Celadon's permit terminated since, at this time, I am no
longer able to monitor their compliance because I am banned from their
property.

Debra V Tunstall
Pretreatment Compliance Technician
Ronald N. Specht
Biological Operator

aw.
r-
ROB' COOPER
Cgoyernor
MICHAEL S. PEGA
3 aye rest=
L[ DA C LPEPPER.
Inr€dm Directur
Mr. Perry Keister (via email)
Linco Properties
5200 Old Harding Road
Nashville, Tennessee 37064
Dear Mr. Keister:
NORTH CAROLINA
E'rivi onmen(trf Quality
November 7, 2018
Subject: Surface Irrigation Inspection Report
Permit No. WQ0003924
Former National Fruit Spray Irrigation System
Lincolnton, Lincoln County
Thank you your time and assistance during the October 31 2018, inspection. Enclosed you will find the
report for the compliance inspection. National Fruit ceased operations at this location in October of 2008.
No residuals from the treatment and disposal system have been applied to the dedicated fields since
December 2016.
It is the understanding of the MRO that is permit is to eventually be rescinded. There are, however, a few
items that should be addressed to renew the permit for the period of time it will take to decommission the
system and eventually rescind the permit:
• It is important that the name change form be completed as soon as possible so a permit can be
issued under the new name.
• Please refer to the inspection report for the forms and links that will help you to complete the
system decommissioning activities as part of the permit rescission process.
The report should be self-explanatory. Should you have any questions regarding this report, feel free to
contact Edward Watson at edward.watsonCa)-ncdner.gov, or 704-235-2198.
Sincerely,
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources
Attachment: Compliance Inspection Report
North Carolina Deo ;rtrrent of Environmental Qua ity Division of water Resource;
Mooresville Regional Grf;ce i 61C cast Cen er Avenue, Suite 301 Mooresville, No-h Carolina 28115
704.663.1699

'' Filename: WO0003924 Former National Fruit Compliance Inspection Rpt
Directory: C:\Users\emwatson1 \Documents
Template: C:\Users\emwatson1 WppData\Roaming\Microsoft\Templates\Normal.dotm
Title: GROUNDWATER SECTION
Subject:
Author: susan_massengale
Keywords:
Comments:
Creation Date: 11/7/2018 11:48:00 AM
Change Number: 3
Last Saved On: 11 /7/2018 11:56:00 AM
Last Saved By: Watson, Edward M
Total Editing Time: 11 Minutes
Last Printed On: 4/28/2020 6:48:00 PM
As of Last Complete Printing
Number of Pages: 3
Number of Words: 241 (approx.)
Number of Characters: 1,378 (approx.)

Watson, Edward M
From: Watson, Edward M
Sent: Tuesday, October 23, 2018 2:22 PM
To: Saunders, Erickson G
Subject: National Fruit Permit renewal
Erik,
After having conversations with the representative of the new site owner, they will renew the permit pending the
completion of closure activities. Eventually, they plan to rescind the permit, has their operation does not have a need for
an irrigation system. I have a site visit scheduled for 10/30/2018 to review the system with the owner's consultant. The
consultant has already received the name change and Lagoon Closure information.
They wish to use the lagoon as a recycle pond, so I have requested information regarding their treatment
process. However, it appears the new owner has already received a POTW from the City of Lincolnton. I will have more
information after the meeting on the 30tn
If there is anything additional paperwork the new owner will need to.complete in order to complete system closure and
rescind the permit, please let me know, so I can get those documents to the new owner.
Regards,
Ed
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality
704 235 2198 Office
704 235 6040 Fax
edward.watson_@.ncdenr.gov
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Watson, Edward M
From: Watson, Edward M
Sent: Monday, October 22, 2018 12:13 PM
To: '[e-mail]'
Subject: Permit closure and current permit
Attachments: WWIS 11-13.docx; WQ0003924 Ntl Fruit Permit-070114.pdf
Perry,
Since the permit will expire before we are able to complete the required rescission activities; it is best to renew the
current permit until we are able to complete these activities. Having an active permit in place, will at least provide you
with coverage until closure activities can be completed. I have attached several links below which include an Ownership
Name Change form that will need to be completed. I have also attached a PDF copy of the current permit.
The attached Waste Water Irrigation form will need to be completed is part of the system closure.
As an option, I have attached a link for Pump and Haul in the event that you wish to address the lagoon water and
sludge using this method. However, I would appreciate it if you provide documentation regarding the method
treatment to be used to treat the lagoon water when we meet on the 29cn
The last link I have submitted is the Lagoon Closure document I spoke to you about in our phone conversation. If the
Lagoon is closed, we will need an engineer's certification regarding the sludge removal and sludge analytical testing
results.
httos://fifes.nc.gov/ncdecilWater%20Quality/Aquifer%20Protection/AFO[Reporting%20Forms/Combined%20irrigation%
20record%20form%20(1 RR-1%20&%201 RR-2)-08-03-2012.
https•//files nc gov/ncdeq/Water%20Quality/Surface%2OWater%2OProtection/PERCS/WCS/*20%28PNOCF/`29/PNOCF/o
2001-16%28CO%29.docx
https•//deg nc gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/`collection-
systems/pump-haul
https://files.nc,gov/ncdeq/Water%20Quality/Aquifer%20Protection/LAU/NDPONC%2006-16.docx
httos://files.nc.gov/ncdeq/Water%20QuaIity/Aquifer%20ProtectionJA_PPSl20Po1icies/LagoonClosureGuidelines-
20120622:pdf
I realize this is a lot of information. Once the documents have been received by our Central Office permitting group in
Raleigh, we can proceed with the permit rescission and the lagoon change over. I look forward to meeting with you on
Monday the 29tn
Best Regards,
Edward Watson
Hydrogeologist
Water Quality Regional Operations Section
Division of Water Resources
North Carolina Department of Environmental Quality

_ *r
704 235 2198 Office
704 235 6040 Fax
[e-mail]
610 E. Center Ave.
Suite 301
Mooresville, NC 28115
Email correspondence to and from this address is subject to the
North Carolina Public Records Caw and may be disclosed to third parties.

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LAGOON WATER LEVEL
INCHES TO GALLONS
Inches
Cubic Feet
Gallons
Inches
Cubic Peet
Gallons
Inches
Cubic Peet
Gallons
1
1,288.85
9,641.91
49
76,638.61
573,333.47
99
183,221.28
1,370,678.40
2
2,589.17
19,369.61
50
78,489.33
687,178.70
100
185,645.33
1,388,812.74
3
3,900.96
29,183.08
61
80,351.52
601,109.72
101
188,080.85
1,407,032.86
4
5,224.21
39,082.34
52
82,225.17
615,126.52
102
190,527.84
1,426,338.77
5 1
6,558.93
49,067.38
53
84,110.29
629,229.10
103
192,986.29
1,443,730.46
6
7,905.12
69,138.20
64
86,006.88
643,417.47
104
195,456.21
1,462,207.93
7
9,262.77
69,294.81
55
87,914.93
657,691.62
105
197,937.60
1,480,771.19
8
10,631.89
79,637.19
56
89.834.45
672,061.65
106
200,430.45
1,499,420.22
9
12,012.48
89,865.36
67
91,765.44
686,497.26
107
202,934.77
1,518,166.04
10
13,404.53
100,279.31
58
93,707.89
701,028.76
108
205,450.56
1,636,975.84
11
14,808.05
110,779.05
69
95,661.81
716,646.03
109
207,977.81
1,665,882.02
12 1
19,223.04
121,364.56
60
97,627.20
730,349.08
110
210.516.53
1,674,874.19
13
17,649.49
132,035.86
61
99,604.05
745,137.92
111
213.066.72
1,593,962.13
14
19,087.41
142,792'.94
fit
101,592.37
760,012.64
112
215,628.37
1,613,116.86
16
20,536.80
153,636.80
63
103,592.16
774,972.95
113
218,201.49
1,632,365.3T
16
17
21,997.65
23,469.97
164,664.44
176,678.87
64
66
105,603.41
107,626.13
790,019.14
806,151.10
114
116 '
220,786.08
223,382.13
1,661,700.66
1,671,121.74
18
24.953.76
186,679.08
66
109,660.32
820,368.85
116
225,989.65
1,690,628.60
19
26,449.01
197,866.07
67
111,705.97
835,672.39
117
228,608.64
1,710,221.24
20
27,955.73
209,136.84
68
113,763.09
861,061.70
118
231,239.09
1,729,899.66
21
29.473.92
220,494.40
69
115,831.68
866,536.80
119
233,881.01
1,749,663.86
22
31,003.57
231,937.73
70
117,911.73
882,097.68
120.
236,534.40
1,769,613.85
23
32,544.69
243,466.85
71
120,003.25
897,744.34
121 •
239,199.25
1,789,449.61
24
25
26
27
28
34,097.28
35,661.33
37,236.85
38,823.84
40,422.29
266,081.76
268 782.43
278,568.90
290,441.16
302,399.18
72
73
74
76
76
122,106.24
124,220.69
126,346.61
128,484.00
130,632.85
913,476.78
__929,295.01
946,199.0i
961,188.80
977,264.38
_
122•
123
IN
125
126
241,875.57
244,563.36
247,262.61
249,973.33
252,695.52
1,809,471.16
1,829,678.60
1,849,771.81
1,870,050.61
1,890,415.19
29
42,032.21
314,442.99
78
134,964.96
1,009,672.87
127
255,429.17
1,910,865.65
30
43,653.60
326,672.68
79
137,148.21
1,026,006.78
128
258,174.29
1,931,401.89
31
45,286.45
46,930.77
338,787.96
351,089.12
80
81
139,342.93
141,549.12
1,042,424.48
1,058,928.97
129
130
260,930.88
263,698.93
1,962,023.91
1,972,731.72
_32_
33
48,586.56
383,476.06
82
143.766.77
1,075,519.23
131
266,478.45
1,993,526.31
34
35
50,253.81
51,932.53
376,948.78
388,607.28
83
84
1 145,995.89
148,236.48
150,488.53
152,752.05
155,027.04
157.313.49
159,611.41
161,920.80
164,241.65
1,092,196.28
1,108,957.11
1,126,804.72
_
132
13_3
269,269.44
272,071.89
2,014,404.68
2,036,369.83
38
53,622.72
_
401,151.57
_
86
134
274.885.81
2,066,420.77
37
38
39
40
41
42
55,324.37
57,037:49
58,762.08
60,408.13
62,245.65
64,004.64
413,881.64
426,697.49
439,699.12
452,686.64
466,669.73
478,818.71
86
87
88
89
90
91
1,142,730.11
1,169,757.29
1,176,862.24
1,194,062.98
1,211,329.50
1,228,691.81
136
136
137
138
139
140
277,711.20
280,548.05
283,396.37
286,256.16
289,127.41
292,010.13
2,077,657.49
2,098,779.99
2,120,088.27
2,141,482.33
2,162,962.18
2,184,627.81
43
65,775.09
492,063.47
92
166,573.97
1,246,139.89
44
67,557.01
605,394.02
93
168,917.76
1,263,673.76
46
69,350.40
618,810.34
95
173.639.73
1,298,998.86
46
71,155.25
632,312.46
96
176,017.92
1,316,790.06
47
72,971.57
645,900.34
97
178,407.57
1,334,667.06
48
74 799.36
559 574.01
98
180,808.69
1,362,629.83
Page 1

19930 W Catawba Ave, Cornelius, NC 28031 to Whitehouse Dr - Google Maps Page 1 of 1
Directions to Whitehouse Dr
Goostemaps 28.2 mi — about 47 mins.
Save trees. Go green! a,_{
Download Google Maps on your r,
phone at google.com/gmm �vv�
19930 W Catawba Ave, Cornelius, NC 28031
1. Head west on W Catawba Ave toward Kunkleman Dr
About 6 mins
73 2. Turn right at N Carolina 73 W
About 28 mins
27 3. Turn right at N Carolina 27 W
About 4 mins
4. Turn right at Huss St CT ��
About 1 min
5. Slight left at Wilma Sigmon Rd
About 3 mins
6. Turn right at N Generals Blvd/State Rd 321 Bus
Continue to follow State Rd 321 Bus
About 2 mins
7. Continue onto Maiden Hwy
About 2 mins
8: -Turn left at Whitehouse -Dr
About 1 min
Whitehouse Dr
go 2.9 mi
total 2.9 mi
go 18.3 mi
total 21.2 mi
go 2.4 mi
total 23.6 mi
go 0.7 mi
total 24.4 mi
go 1.6 mi
total 25.9 mi
go 0.9 mi
total 26.8 mi
go 1.0 mi
total 27.8 mi
go 0.4 mi
total 28.2 mi
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause
conditions to differ from the map results, and you should plan your route accordingly. You must obey all signs or notices. regarding your
route.
Map data 02010 Google
Directions weren't right? Please find your route on maps.google.com and click "Report a problem" at the bottom left.
http://maps. google. com/maps?f=d&source=s_d&saddr=1993 0+West+Catawba+Avenue,+... 6/3 0/2010

Page 1 of 1
%D�-73S-..zs3 )
http://207.4.172.205/output/LCProperty2_LC_W W W2423420313.png 12/7/2004

AL,h
NCDENR FILE
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, III .
Governor Secretary
May 2, 2014
National Fruit Products Company Holdings, LLC
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David C. Gum, III
Member/Manager NFP Holdings, LLC.01690
RE: Surface Irrigation Inspection Report
Permit No. WQ0003924
National Fruit - Lincolnton Plant
Lincoln County, N.C.
Dear Mr. Gum:
The Mooresville Regional Office (MRO) conducted a compliance inspection, on March
17th, 2014,.in conjunction with your recent permit renewal. The MRO met with Glen Fredell
(Facility Maintenance) and Lynn Aldridge (ORC). Mr. Fredell noted the application fields
required maintenance and planned to mow, once weather and wet field conditions allowed.
The treatment and disposal system appeared to be properly maintained since the plant
shutdown.
The expiration date of your recent permit is February 28, 2019. A renewal application is
due at least 180 days prior to this date.
Per discussion with Mr. Fredell, at this time, National Fruit intends to keep the irrigation
system intact, while exploring future options for the facility. I have enclosed a copy of the
inspection report, an ownership change form, in the event the facility is sold; and, a copy of
the Lagoon Closure guidance document, should you decide to close-out the facility and
rescind this permit. This information is also available online at:
• http://portal.ncdenr.org/web/wq/aps/gwpro/policy Select "Guidelines for the Closure
of Permitted Wastewater Ponds and Lagoons".
.,_•---http://Portal.ncdenr-.srg/web/wglaps/lau/applications wastewater-jr-igatien
systems, then the Non -Discharge Name Change/Change of Ownership form.
Please contact me by phone [phone]) or email ([e-mail]), should
you have any questions about the attached documents.
Mooresville Regional Office, 610 East Center Avenue, Mooresville, North Carolina 28155
Phone: [phone] Internet: www.ncdenr.gov
An Equal Opportunity 1 Affirmative Acton Employer— Made in part by recycled paper

Sincerely,
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water. Quality Regional Operations Section
Division of Water Resources, NCDENR
Attachment(s): Inspection Report March.2014
Guidelines for Closure of Permitted Wastewater Ponds and Lagoons
Non -Discharge Name Change/Change of Ownership form
CC: James C. Zombro, Jr., Transition Manager (email)
Glen Fredell, National Fruit, P.O. Box 916, Lincolnton, NC 28093
Lynn Aldridge, ORC'(email)
David Goodrich, CO -Raleigh (email)

State of North Carolina
Department of Environment
and Natural Resources
Division of -Water Resources
Pat McCrory, Governor
John E. Skvarla, III, Secretary
e��
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: NFP Holdings, LLC
Permit # WQ0003924
IssuanceDate: 4/7/2014
Permittee Contact: David Gum
ORC Name: Lynn Aldridge Cert #S1993778
Email address: [e-mail]
B/U ORC Name: David Frame Cert#S126346
County: Lincoln
Project Name: National Fruit
Expiration Date: 2/28/2019
Telephone No.: 540-662-3401
Telephone No.: 704-431-5266 cell
Telephone No.: 704-636-8850
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary; (additional comments may be included on attached pages)
The wastewater treatment and disposal system has not operated since June 2009 but weekly ORC
visits have continued. The application fields are to be mowed as weather and field conditions
permit. The lagoon appears to be well maintained and in compliance. Records are currently
maintained in the Virginia office and locally by the ORC, since the production facility remains in
shutdown and the building is presently being rented.
is-a=follow-up=inspection-necessary-- - ___,,.yes
Inspector Name/Title: Maria Schulte, Environmental Specialist
Tel. No. 704-235-2184 Fax No. 704-663-6040
Date of Inspection: 3/17/14

Google Maps 7 ylap
Google
Directions from 610 E Center Ave to Whitehouse Dr.
O 610 E Center Ave
Mooresville, NC 28115
Take NC-150 W and E Maiden Rd to
Springs East Rd in Ironton
no
---- 26-mi-/34 min
1
41
1.
2.
Head west on E Center Ave toward E
Statesville Ave
_. __ -• -06 mi
Turn left onto S Main St
f
-
3.
-- 407 ft
Take the 1 st right onto W McLelland Ave
---------_ ----- —1 0 mi
41
4.
Turn left onto NC-150 W/E Plaza Dr
Continue to follow NC-150 W
— —.—_— 14.-7 mi
1'r
5.
Turn right onto E Maiden Rd
= — --54mi
"ll
6.
Slight left onto Buffalo Shoals Rd
mi
Turn right onto Springs East Rd
Page 1 of 2
Drive 27.9 mi, 41 min
https://www.Roogle.com/mal)s/dir/61 O+E+Center+Ave,+Mooresville,+NC+28115/Whiteh... 3/12/2014

Google Maps Page 2 of 2
1.7mi/3min
Turn left onto State Rd 155/US-
41 321 BUSS
Q Whitehouse Dr
Lincolnton, NC 28092
These directions are for planning purposes only. You may find that construction
projects, traffic, weather, or other events may cause conditions to differ from the
map results, and you should plan your route accordingly. You must obey all signs or
notices regarding your route.
Map data ©2014 Google
https://www.google.com/maps/dir/610+E+Center+Ave,+Mooresville,+NC+28115/Whiteh... 3/ 12/2014

j�.COPY
HCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Division of Water Quality Secretary
July 6, 2010
National Fruit Products Company
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David Gum, VP Mfg.
RE: Surface Irrigation. Inspection Report
Permit No. WQ0003924
Facility: Lincolnton Plant
Lincoln County, N.C.
Dear Mr. Gum:
Enclosed you will find the report for the annual compliance inspection that I conducted on July 1, 2010.
The treatment and disposal system appeared to be properly maintained during the plant shutdown. The
Aquifer Protection Section of the Mooresville Regional Office should be notified when plant operations
resume.
As a result of passage of Session Law 2009-406, the expiration date for this permit has been extended
to February 28, 2013. An application for renewal should be submitted to the division no later than six
months prior to that date.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
Cc: Tim Fredell, National Fruit Products Co., POB 916, Lincolnton 28093 w/enclosure
MAF/national fruit inspection rpt 7-1-10
One
NorthCarolil
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] oi, Car l ii
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org l/ V L lli

4-1
1 ;.J
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Colleen H. Sullins, Director
A10111VVA
11 0
44614
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: National Fruit Products Company
Permit # W00003924
Issuance Date: 3/9/05
Permittee Contact: David Gum
ORC Name: Tim Fredell Cert #S1994593
Email address: [e-mail]
Reason for Inspection
X ROUTINE COMPLAINT
County: Lincoln
Project Name: National Fruit
Expiration Date: 2/28/13
Telephone No.: 540/662-3401
Telephone No.: 704/735-2531
FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The plant is in temporary shutdown. The wastewater treatment and disposal system has not
operated since June 2009 but weekly ORC visits have continued. The application fields were
mowed just prior to this inspection. Samples have been collected for soil fertility analysis.
The lagoon appears to be well maintained and in compliance. Tim Fredell, operations mgr,
was recently certified and has assumed ORC responsibilities. Deficiencies related to
recordkeeping have been addressed.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist; Maria Schutte, Senior Env. Technician
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 7/1/10

r
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
AIK ;W'A
IT 0
41
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: National Fruit Products Company
Permit # WQ0003924
Issuance Date: 3/9/05
Permittee Contact: David Gum
ORC Name: Tim Fredell Cert #S1994593
Email address: [e-mail]
County: Lincoln
Project Name: National Fruit
Expiration Date: 2/28/13
Telephone No.: 540/662-3401
Telephone No.: 704/735-2531
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary: (additional comments may be included on attached pages)
The plant is in temporary shutdown. The wastewater treatment and disposal system has not
operated since June 2009 but weekly ORC visits have continued. The application fields were
mowed just prior to this inspection. Samples have been collected for soil fertility analysis.
The lagoon appears to be well maintained and in compliance. Tim Fredell, operations mgr,
was recently certified and has assumed ORC responsibilities. Deficiencies related to
recordkeeping have been addressed.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist; Maria Schutte, Senior Env. Technician
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 7/1/10

Via ',a Date S_ l V 2 9 2009
Division of Water Quality I " ffc
Land Application Unit-
1636 Mail Service Center
Raleigh, NC 27699-1636
Subject: Permitting Signature Authority
To Whom It May Concern:
As an appropriate signing official for I ` A4/Cq+ ! I" rit t f ` o' o d u c - CC' (city/town or
business name) as designated by 15A NCAC 2T .0106(c), I hereby delegate authority to sign and certify all
permit applications, reports or other permit related documents to the following staff for the following
permit types (sewer, spray, land application) and/or permit numbers:
Position
Person Currently in Position
Permit Type or Permit Number
If you have any questions, please contact me at the following:
PPT iftPP/Annlinnnt name tnlease nrintl'
Title: ' P— O V iA 1 t 't
Complete mailing address: ® , I
Ci A 7�"�✓i.� State: / Zip:
ty: i 1
Telephone number: (•? �G) �i� " =1" Q C Facsimile number: (r) 7
x
Sincerely,
signature

NC®ENR
North Carolina Department of Environment and
Beverly Eaves Perdue
Governor
National Fruit Products Company
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David Gum
Dear Mr. Gum:
Coleen H. Sullins
Division of Water Quality
(3Y
i
,,
[PY/ �
Natural Resources
Dee Freeman
Secretary
June 19, 2009
RE: Surface Irrigation Inspection Report
Permit No. WQ0003924
Facility: Lincolnton Plant
Lincoln County, N.C.
Enclosed you will find the report for the annual compliance inspection that I conducted on June 9, 2009.
The treatment system appears to be performing satisfactorily. Inspection of the disposal fields found
them significantly improved with regard to crop coverage.
However, deficiencies persist with regard to submission of compliance monitoring data. Please submit
the missing reports to this office within 15 days (see page 4 of report).
It should be noted that your permit will expire in February of 2010. An application for renewal should be
submitted to the Division no later than August 1, 2009.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
Cc: Cole Gamble, National Fruit Products Company, POB 2040, Winchester, VA 22604-2040
w/enclosure
Tim Fredell, National Fruit Products Co., 288 White House Rd., Lincolnton 28092 w/enclosure
MAF/national fruit inspection rpt 6-9-09
Nne
orthCarolh
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] a 1��ul,R//l
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org �/ Y [b

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Beverly Eaves Purdue, Governor
Dee Freeman, Secretary
Coleen H. Sullins, Director
11
k"
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
Owner: National Fruit Products Company County: Lincoln
Permit # WQ0003924 Project Name: National Fruit
Issuance Date: 3/9/05 'Expiration Date: 2/28/10 .
Permittee Contact: David Gum Telephone No.: 540/662-3401
ORC Name: Cole Gamble Cert #S1990720 Telephone No.: 540/662-3401
Email address:[e-mail]
Backup ORC Name: Phil Himebaugh Cert #987936 Telephone No.: 704/735-2531
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Summary; (additional comments may be included on attached pages)
The wastewater treatment system is operating satisfactorily. The application fields are in
excellent condition at this time. Tim Fredell, operations mgr, completed the spray operator's
school this past spring and is scheduled to take the certification exam in November.
Deficiencies persist with regard to submission of compliance monitoring.
The permit expires in February 2010.
Is a follow-up inspection necessary yes X no
Inspector Name/Title: Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 6/9/09

Surface Irrigation
Permit #WQ0003924
Type
Activated Sludge Spray, low rate
Activated Sludge Drip, low rate
_X_ Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Influent pump station
Y All pumps present, operational.
Bar screen, maintained
Bars evenly spaced
Back-up power
Flow Measurement — Influent
_Y_ Is flowmeter calibrated annually?
_Y_ Is flowmeter operating properly?
_Y_ Does flowmeter operate continuously?
Does flowmeter record flow?
_Y Does flowmeter appear to monitor accurately?
Bypass structure present
Free of excessive debris
Bars excessively corroded
Flow Measurement — Water -Use Records
_Y Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Page 2
Is the system working? Is the system properly maintained?
Tablets Gas Liquid _Y_ UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
_Y_ Is the flowmeter calibrated annually?
_ Y _ Is the flowmeter operating properly?
_Y _ Does the flowmeter monitor continuously?
Y Does the flowmeter appear to monitor accurately?

1
Surface Irrigation
Permit #WQ0003924
Effluent Storaae
Page 3
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Storage Lagoons
Check any/all that apply
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
_Y_ Vegetation (is there excessive vegetation on the lagoon bank
_Y_ Liner (if visible, is it intact)
_NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y_ Staff gauge (clearly marked)
_N_ Evidence of overflow (vegetation discolored or laying down/broken)
_N_ Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
N _Floating mats (sludge, plants, inorganics)
_N _ Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comments: Some vegetation is growing on the liner above the waterline. This needs
to be removed.
Residuals
storage/treatment
Comment:
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated this past year?
_N_ Are cover crops the type specified in permit?
_N_ Is cover crop in need of improvement?
_N_ Signs of runoff?
_N_ Signs of ponding?
_N_ Signs of drift?
Comments: The fescue cover crop is in excellent condition after liming, reseeding and,
much -needed rain.

Surface Irrigation Page 4
Permit #WQ0003924
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
_ Are restrictions for use of these areas specified?
Y Is permit being followed?
Y Is site access restricted in accordance with permit?
Recordkeeping
Y Is permit available upon request?
Y _ Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _ Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
_Y_ Are all samples analyzed for the required parameters?
NA_ Is field parameter certification required?
_N_ Are there any 2L GW quality violations?
* Are annual soil reports available?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: * Soil samples will be collected shortly after harvesting of crop.
Groundwater Monitoring
_Y_ Does the permit require monitoring wells? If so,
_Y_ . Are the monitoring wells properly installed according to the permit?
N Are the wells damaged?
Comments: The Division has not received the compliance monitoring reports (GW-59
forms) for April and October 2008.

?, a
Water -Resources
Environmental Quality
May 17, 2017
National Fruit Products Company Holdings, LLC
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David.C. Gum, III
Member/Manager NFP Holdings, LLC
Subject:
Dear Mr. Gum:
R u Y-YCOOPER
L Governor
MICHAEL S. REGAN
Secretary
S. JAY ZIMMERMAN
Director
Non -Discharge Permit Inspection
Permit #WQ0003924 - Wastewater Irrigation System
National Fruit —LincolntonPlant
Lincoln County
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on May Sth, 2017.
The MRO would like to thank Glen Fredell (Facility Maintenance) and Lynn Aldridge (ORC) for their time
during the inspection.
This system has not been in operation since 2009. During the site visit, the lagoon was reviewed and an
assessment was made regarding the lagoon condition.
The lagoon liner is in disrepair and there is significant vegetation growing in the berm. The exposed liner
has also become compromised due. to exposure to the sun and large areas of the liner material have
become threadbare due,to this exposure. The unexposed liner appears to.be water tight as the lagoon
water level can be maintained. However, due to the presence of vegetation in the berm and the fact
that the.lagoon liner.has-been torn, this site is considered W not be in compliance with the permit.
The option of lagoon closure and permit rescission is currently being evaluated by NFP. During the site
visit, MRO staff was informed that the spray irrigation system will be able to effectively reduce the
water level of the lagoon up to a point.' Closure will require evaluation of sludge thickness, as, it is
currently unknown.
During the site visit, a hard copy of the Lagoon Closure procedures was present to Mr. Fredell.
The.MRO has also included the website link,. "Guidelines for the Closure of ... Lagoons". The Guidelines
for Closure... the document may be located on NCDEQ website at:
http://deq. nc:goy/a bout/divisions/water-resources/water-resources-perm its/wastewater-
branch/ground-water-protection/ground-water-policies.
State of North Carolina I Environmental Quality. I Water Resources 1 Water Quality Regional Operations
Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704-663-1699

ro-
Should you have any questions regarding the report, please feel free to contact at 704-235-2198 or by
email at [e-mail].
Sincerely,
E ward Watson�olo ist
Y g g
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
CC: Lynn Aldrich (via email)
Non -discharge Compliance, CO Raleigh

T
Compliance Inspection Report
Permit: WQ0003924 Effective: 04/07/14 Expiration: 02/28/19 owner: Nfp Holdings LLC
SOC: Effective: Expiration: Facility: National Fruit Product Co Inc
County: Lincoln 288 White House Rd
Region: Mooresville PO Box 916
Lincolnton NC 28093
Contact Person: James C Zombro Title: Phone: [phone] Ext.259
Directions to Facility:
From Hwy 150 in Pumpkin Center, travel west for approx. two miles and turn right onto Shuford Rd. Travel approx. five miles to its
intersection with Old Hwy 321 (Maiden Rd). Turn left and travel approx. two miles to White House Rd on the right.
System Classifications: SI,
Primary ORC: A Lynn Aldridge Certification: 993778 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/08/2017
Primary Inspector: Edward Watson
Secondary Inspector(s):
Entry Time: 10:05AM
Maria Schutte
Reason for Inspection: Routine.
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Exit Time: 11:37AM
Phone:
Inspection Type: Compliance Evaluation
E Miscellaneous Questions E Treatment Lagoons
(See attachment summary)
Page: 1

Permit: WQ0003924 Owner - Facility: Nfp Holdings LLC
Inspection Date: 05/0812017 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary
This system has been inactive since 2009. The inspection is for the possibility of Lagoon Closure, eventually leading to
permit rescission. The Lagoon Closure Guidance was handed to Glen Fredell of NFP. Previuosly, this form has been
electronically submitted to NFP during the 2016 compliance inspection.
The Lagoon Liner has become severely compromised. The liner is torn and has become,covered by heavy vegetative growth
as a result of not maintaining the water level in the lagoon. The liner has also become damaged from sun exposure. Large
areas of the liner present evidence of becoming threadbare from over exposure to the sun. If the system is returned to
operation, liner repairs are necessary. The unexposed portion of the liner appears to be capable of retaining fliud. Treatment
through Chlorination is still being performed.
The irrigation system appears to be operational and capable of reducing fluid volume in the lagoon. However, lagoon closure
will require an evaluation of sludge thickness.
Page: 2

r'
Permit: WQ0003924
Inspection Date: 05108/2017
Type
Infiltration System
Reuse (Quality)
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Drip, LR
Activated Sludge Spray, HR
Single Family Drip
Recycle/Reuse
Lagoon Spray, LR
001 -
Treatment Lagoons
Lagoon Type
Primary/Secondary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on banks/berms)
Liner
Liner Type
Baffles/curtains
Freeboard Marker
Required freeboard
Actual freeboard
Owner - Facility: Nfp Holdings LLC
Inspection Type: Compliance Evaluation
Are increments clearly marked on gauge at adequate intervals?
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Acceptable color
Floating mats
Excessive solids buildup
Aerators/mixers
Reason for Visit: Routine
Yes No NA NE
Yes No NA NE
Aerated
Primary
❑ ❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑ ❑
Apron, synthetic
❑❑■❑
❑ ❑ ❑
2
Feet
10
Feet
❑ ❑ ❑
❑ ❑ ❑
❑■❑❑
❑ ❑ N ❑
i❑❑❑
■❑❑❑
❑■❑❑
Page: 3

Permit: WO0003924 Owner - Facility: Nfp Holdings LLC
Inspection Date: 05/08/2017 Inspection Type: Compliance Evaluation
Effluent structure
Lagoon cover
Reason for Visit: Routine
❑❑❑■
■❑❑❑
Page: 4

WQEerRe$ources
ENVIRONMENTAL QUALITY
March 29, 2016
National Fruit Products Company Holdings, LLC
Post Office Box 2040
Winchester, VA 22604-2040
Attention: David C. Gum, III
Member/Manager NFP Holdings, LLC
Dear Mr. Gum:
MCCRORY
fL
s
Gavenror
L��
DONALD R. VAN DER VAART
. Secretary
S. JAY ZIMMERMAN
Subject: Non -Discharge Permit Inspection
Permit #WQ0003924 - Wastewater. Irrigation System
National Fruit — Lincolnton Plant
Lincoln County, N.C.
Director
Staff of the Mooresville. Regional Office (MRO) conducted a compliance inspection on March 7ln
2016. The MRO would like to thank Glen Fredell (Facility Maintenance)' and Lynn Aldridge
(ORC) for their time during the inspection.
The lagoon liner is in need of repair(photos in inspection report). You have the option of
maintaining the lagoon and facility -or closing them and rescinding this permit. System .
maintenance is a requirement to remain compliant with permit conditions. Because this system
has been inactive since 2009, 1 included a "Guidelines for the Closure of... Lagoons" with the
last. inspection report. That. Guidelines for .Closure... document.may be located on the new
NCDEQ website at:
http://deg. n6.gov/about/divisions/water-resources/water-resources-permits/wastewater-
branch/ground-water-protection/ground-water-policies. Select "Guidelines for the
Closure.of Permitted Wastewater Ponds and Lagoons
Please contact me by phone [phone]) or email-(maria.schutte&ncdenr:gov), should you
have any questions. [.will be glad to further discuss this with Mr. Aldridge as well.
. . Sincer�ejly, . .
Maria Schutte, Environmental Specialist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources
Attachment: March 2016 Inspection Report
CC: James C.. Zombro; Jr., Transition Manager (email)
Glen Fredell, National Fruit, P.O. Box 916, Lincolnton, NC 28093
Lynn Aldridge, ORC (email) .
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Office) 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

State of North Carolina Department of Environmental Quality
Division of Water Resources
Pat McCrory, Governor
Donald R. van der Vaart, Secretary
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION .
Owner: NFP Holdings, LLC
Permit #: WQ0003924
Issuance Date: 04/07/2014
Permittee Contact: David Gum
ORC Contact: Lynn Aldridge Cert #SI993778
Email: rowanwastewaterna,gmail.com
Backup ORC_ Name: David Frame Cert #SI26346
County: Lincoln
Project Name: National Fruit - Lincolnton
Expiration Date: 02/28/2019
Telephone No.: 540-662-3401
Telephone No.: 704-431-5266 (cell)
Telephone No.: 704-636-8850
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP Facility Start-up
Inspection Date(s): March 7, 2016
Inspection Summary: (additional comments may be included on attached pares)
The wastewater treatment and disposal system has not operated since June 2009 but weekly ORC visits have
continued. Records.are maintained in the Virginia office and locally by the ORC, since the building is being rented. A
couple of issues noted during this year's inspection_ will need to be addressed to return to full compliance:
• The lagoon liner is in need of repair as noted in the cover letter and seen in the photos below:
• The MRO should.be informed of any changes to the contact information noted above. The operator
designation form can be found at the new DEQ web -link below: .
http J/deq.ne. gov/about/divisions/water-resources/wastewater-operator-certification/wastewater-operator-
certification/wastewater-operator-certification-downloads
Is. a follow-up inspection necessary ^yes. X. no: with submission of repair documentation.
Inspector Name/Title: Maria Schutte, Environmental Specialist
Telephone No.: 704-663-1699 Fax No. 704-663-6040
Date of Inspection: 03n12016

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NORTH CAROLINA ADMINISTRATIVE CODE
TITLE 15
DEPARTMENT OF ENVIRONMENT AND NATURAL RESO URCES
CHAPTER 2
ENVIRONMENTAL MANAGEMENT DIVISION
SUBCHAPTER 2H
PROCEDURES FOR PERMITS, APPROVALS
SECTION. 0800
LABORATORY CERTIFICATION
Current through August 1, 2002
ENVIRONMENTAL MANAGEMENT COMMISSION
RALEIGH, NORTH CAROLINA

SECTION .0800 - LABORATORY CERTIFICATION
15A NCAC 02H .0801 PURPOSE
The purpose of these Rules is to set out certification criteria for laboratory facilities performing any tests, analyses,
measurements, or monitoring required under G.S.143 Article 21 of or any Rules adopted thereunder, and to establish fees for
certification program support.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. February 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984; November 1, 1978;
Temporary Amendment Eff. October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0802 SCOPE
These Rules apply to laboratory facilities which perform and report analyses for persons subiect to G.S.143-215.1
143-215.63 et sea.; the Environmental Management Commission Rules for Surface Water Monitoring and
Revortine found in Subchapter 2B of this Chapter Section .0500 (Only facilities classified in accordance with
Classification of Water Pollution Control Systems Rules found in 15A NCAC 08G .0300 are subject to these Rules.);
Groundwater Rules found in 15A NCAC 02L .0100, .0200, and .0300; Waste Not DischarLyed to Surface Waters
Rules found in 15A NCAC 0211.0200; Point Source Discharees to the Surface Waters Rules found in 15A NCAC
02H .0100. These Rules also apply to all wastewater treatment plant laboratories for municipalities having Local
Pretreatment Proerams as regulated in 15A NCAC 02H .0900. Laboratory facilities performing and reportine
analyses for field parameters only, shall be considered for certification as specified in Rule .0805(a) of this Section.
History Note: Authority G.S. 143-215.3(a)(I); 143-215.3(a)(10);
Eff February 1, 1976;
Amended Eff. November 2, 1992; July 1, 1988; December 1, 1984;
Temporary Amendment Eff. October 1, 2001;
Amended Eff. August 1, 2062.
15A NCAC 02H .0803 DEFINITIONS
The following terms as used in this Section shall have the assigned meaning:
(1) "Analytical chemistry experience" means experience analyzing samples in a chemistry laboratory or
supervising a chemistry laboratory that analyzes"samples.
(2) "Certification" means a declaration by the state that the personnel, equipment, records, quality control
procedures, and methodology cited bythe applicant are accurate andthat the applicant's proficiencyhas
been considered and found to be acceptable pursuant to these Rules.
(3) "Certified Data" shall be defined as any analytical result, including the supporting documentation,
obtained through the use of a method or procedure which has been deemed acceptable by the State of
North Carolina for Laboratory Certification purposes pursuant to these Rules.
(4) "Commercial Laboratory" means any laboratory, including its agents or employees, which is seeking to
analyze or is analyzing samples, including Field Parameters, for others for a fee.
(5) 'Decertification" means loss of certification.
(6) "Falsified data or information" means data or information which has been made untrue by alteration,
fabrication, omission, substitution, or mischaracterization. The agency need not prove intent to defraud to
prove data is falsified.
(7) "Field Parameters", for the purpose of these Rules shall include Total Residual Chlorine,
Conductivity, Dissolved Oxyeen, pH, Settleable Residue, and Temperature.
(8) "Inaccurate data or other information" means data or information that is in any way incorrect, or mistaken.
(9) "Industrial Laboratory" means a laboratory, including its agents or employees, operated by an
industry to analyze samples, including Field Parameters, from its wastewater or wastewater from
its water treatment plant(s).

(10) "Municipal Laboratory" means a laboratory, including its agents or employees, operated by a
municipality or other local government to analyze samples, including Field Parameters, from its
wastewater or wastewater from its water treatment plant(s).
(11) "Other" laboratory means a facility that does not require laboratory certification as part of its
routine operation and does not analyze samples for a fee, or is doing business as a non-profit
facility.
(12) "Pretreatment Program" means a program of waste pretreatment requirements set up in accordance with
15A NCAC 02H .0900 and approved by the Division of Water Quality.
(13) "State" means the North Carolina Department of Environment and Natural Resources, or its successor.
(14) "State Laboratory" means the Laboratory Section ofthe North Carolina Division of Water Quality, or its
successor.
(15) "Unacceptable results" means those results on performance evaluation samples that exceed the specified
acceptable range as indicated by a US EPA accredited vendor.
(16), "Uncertified data" shall be defined as any analytical result, including the supporting documentation,
obtained using a method or procedure which is not acceptable to the State Laboratory pursuant to these
Rules.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. Februmy 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984; November 1, 1978;
Temporary Amendment Eff October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0804 PARAMETERS FOR WHICH CERTIFICATION MAY BE REQUESTED
(a) Commercial laboratories are required to obtain certification for parameters which will be reported bythe client to comply
with State surface water monitoring, groundwater, and pretreatment Rules. Municipal and Industrial Laboratories are
required to obtain certification for parameters which will be reported to the State to comply with State surface water
monitoring, groundwater, and pretreatment Rules. Commercial, Municipal, Industrial and Other facilities are required
to obtain certification for field parameters which will be reported by the client to comply with State surface water,
groundwater, and pretreatment Rules.
(b) A listing of
certifiable inorganic parameters follows:
(1)
Alkalinity
(2)
Aquatic Humic Substances
(3)
BOD
(4)
COD
(5)
Chloride
(6)
Chlorine, Total Residual
(7)
Chlorophyll
(8)
Coliform, Fecal
(9)
Coliform, Total
(10)
Color
(11)
Conductivity
(12)
Cyanide
(13)
Dissolved Oxygen
(14)
Fluoride
(15)
Hardness, Total
(16)
MBAS
(17)
Ammonia Nitrogen
(18)
Total Kjeldahl Nitrogen (TKN)
(19)
Nitrate plus Nitrite Nitrogen
(20)
Nitrate Nitrogen
(21)
Nitrite Nitrogen
(22)
Total Phosphorus
(23)
Orthophosphate

(24) Oil and Grease
(25) PH
(26) Phenols
(27) Residue, Settleable
(28) Residue, Total
(29) Residue, Total Dissolved 180°C
(30) Residue, Total Suspended
(31) Salmonella
(32) Sulfate
(33) Sulfide
(34) Sulfite
(35) Tem0erature
(36) Total Organic Carbon (TOC)
(37) Turbidity
(38) Leachate Procedures
(39) Vector. Attraction Reduction - All Options
(c) Metals: Each of the following will be considered a certifiable Metals analyte:
(1) Aluminum
(2) Antimony
(3) Arsenic
(4) Barium
(5) Beryllium
(6) Cadmium
(7) Calcium
(8) Chromium, Total
(9) Chromium, Hexavalent
(10) Cobalt
(11) Copper
(12) Iron
(13) Lead
(14) Magnesium
(15) Manganese
(16) Mercury
(17) Molybdenum
(18) Nickel
(19) Selenium
(20) Silver
(21) Thallium
(22) Tin
(23) Vanadium
(24) Zinc
(d) Each of the analytical categories listed in this Paragraph shall be considered a certifiable parameter. Analytical methods
shall be determined from the sources listed in Rule .0805(a)(1) of this Section. A listing of certifiable organic parameters
follows:
(1) Purgeable Halocarbons
(2) Purgeable Aromatics
(3) Acrolein, Acrylonitrile, Acetonitrile
(4) Phenols
(5) Benzidines
(6) Phthalate Esters
(7) Nitrosamines
(8) Organochlorine Pesticides
(9) Polychlorinated Biphenyls
(10) Nitroaromatics and Isophorone
(I1) Polynuclear Aromatic Hydrocarbons

(12) Haloethers
(13) Chlorinated Hydrocarbons
(14) Purgeable Organics
(15) Base/Neutral and Acid Organics
(16) Chlorinated Acid Herbicides
(17) Organophosphorus Pesticides
(18) Total Petroleum Hydrocarbons - (TPH) California GC Method - Diesel Range Organics
(19) Total Petroleum Hydrocarbons - (TPH) California GC Method - Gasoline Range Organics
(20) Nonhalogenated Volatile Organics
(21) N-Methylcarbamates
(22) 1,2, Dibromoethane (EDB)
(23) Extractable Petroleum Hydrocarbons
(24) Volatile Petroleum Hydrocarbons
(25) Chlorinated Phenolics
(26) Adsorbable Organic Halides
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. Februmy 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984;
Temporary Amendment Eff. October], 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0805 CERTIFICATION AND RENEWAL OF CERTIFICATION
(a) Prerequisites and requirements for Certification. The following requirements must be met prior to certification. Once
certified, failure to comply with any of the following items will be a violation of certification requirements. All "Field
Parameter" only facility requirements are located in ParaLyranh (e) of this Rule.
(1) Laboratory Procedures. Analytical methods, sample preservation, sample containers and sample holding
times shall conform to those requirements found in 40 CFR-136.3; Standard Methods for the Examination
of Water and Wastewater, 18th Edition; or Test Methods for Evaluating Solid Waste, SW 846, Third
Edition. These and subsequent amendments and editions are incorporated by reference. This material is
available for inspection at the State Laboratory, 4405 Reedy Creek Road, Raleigh, North Carolina,
27607. Copies of the Code of Federal Regulations, 40 CFR Part 136, may be obtained for a cost of forty-
two dollars ($42.00), from the Superintendent of Documents, U.S. Government Printing Office (GPO),
Superintendent of Public Documents, Washington, DC, 20402. The publication number is 869-042-
00148-6. Standard Methods for the Examination of Water and Waste, is available for purchase_ from the
American Water Works Association (AWWA), 6666 West Quincy Avenue, Denver, CO 80235. The
costs are as follows: 18th Edition -one hundred sixty dollars ($160.00),19th Edition - one hundred eighty
dollars ($180.00), 20th Edition - two hundred dollars ($200.00). Copies of Test Methods for Evaluating
Solid Waste, SW 846, Third Edition may be purchased for a cost of three hundred sixty seven dollars
($367.00) from the Superintendent ofDocuments, U.S. Government PrintingOffice (GPO), Washington,
DC 20402. Vector Attraction Reduction Options shall be Control of Pathogens and Vector Attraction in
Sewage Sludge; EPA/625/R-92/013, Chapter 8. The document is available from US EPA; Office of
Research and Development, Washington, NC 20460 at no cost. The method for Total Petroleum
Hydrocarbons shall be the California Gas Chromatograph Method, Eisenberg, D.M., and others, 1985,
Guidelines for Addressing Fuel Leaks: California Regional Quality Control Board San Francisco Bay
Region. The method for Total Petroleum Hydrocarbons is available from the State Laboratory at no cost.
The methods for Volatile Petroleum Hydrocarbons and Extractable Petroleum Hydrocarbons shall be
Massachusetts Department of Environmental Protection, Method for the Determination of Volatile
Petroleum Hydrocarbons (VPH) and Method for the Determination of Extractable Petroleum
Hydrocarbons (EPH); January, 1998. The Director may approve other analytical procedures that have
been demonstrated to produce verifiable and repeatable results and that have a widespread acceptance in
the scientific community.
(2) Performance Evaluations. Annually, each certified laboratory must demonstrate acceptable performance
on evaluation samples as required by these Rules.

(A) Municipal and Industrial laboratories must participate in the annual Environmental Protection
Agency Discharge Monitoring Report Quality Assurance (EPA/DMR/QA) Study by analyzing
performance evaluation samples obtained from an accredited vendor as unknowns, and
reporting data produced to the State. The laboratory is responsible for submitting acceptable
results for all parameters listed on their certificate.
(B) Commercial laboratories must participate annually in water pollution studies by analyzing
performance evaluation samples obtained from an accredited vendor as unknowns, and
reporting data produced to the State. The laboratory is responsible for submitting acceptable
results for all parameters listed on their certificate. When two samples for the same.parameter
are submitted and analyzed at the same time, an unacceptable result on one or both samples will
be considered the first unacceptable result for certification purposes and a rerun sample must be
submitted.
(C) Laboratories requesting initial certification must submit an acceptable performance sample
result for each parameter for which performance samples are available. Laboratories that
submit two unacceptable results for a particular parameter must then submit two consecutive
acceptable results for that parameter prior to initial certification.
(D) If performance samples are not available for a parameter, certification for that parameter will be
based on the proper use of the approved procedure, the on -site inspection, and adherence to the
other requirements in this Section. Analysis of split samples may also be required.
(3) Supervisory Requirements.
(A) The supervisor of a commercial laboratory must have a minimum of a B.S. or A.B.
degree in chemistry or closely related science curriculum from an accredited college or
university plus a minimum of two years laboratory experience in analytical chemistry, or
a two year associate degree from an accredited college, university, or technical institute in
chemistry technology, environmental sciences, or closely related science curriculum plus
a minimum of four years experience in analytical chemistry.
(B) The supervisor of a municipal or industrial waste water treatment plant laboratory must
have a minimum of a B.S. or A.B. degree in chemistry or closely related science
curriculum from an accredited college or university plus a minimum of six months
laboratory experience in analytical chemistry, or a two year associate degree from an
accredited college, university, or technical institute in chemistry technology,
environmental sciences, or closely related science curriculum plus a minimum of two
years experience in analytical chemistry. Non -degree supervisors must have at least six
Years laboratory experience in analytical chemistry.
(C) All laboratory supervisors are subject to review by the State Laboratory. One person may serve
as supervisor of no more than two laboratories. The supervisor shall provide personal and
direct supervision ofthe technical personnel and be held responsible for the proper performance
and reporting of all analyses made for these Rules. The supervisor must work in the laboratory
or visit the laboratory once each day of normal operations. If the supervisor is to be absent, the
supervisor shall arrange for a substitute capable of insuring the proper performance of all
laboratory procedures, however, the substitute supervisor cannot be in charge for more than six
consecutive weeks. Existing laboratory supervisors that do not meet the requirements of this
Rule may be accepted after review by the State Laboratory and meeting all other certification
requirements. Previous laboratory -related performance will be considered when reviewing the
qualifications of a potential laboratory supervisor.
.(4) Laboratory Manager. Each laboratory must designate a laboratory manager and include his name and title
on the application for certification. The laboratory manager shall be administratively above the laboratory
supervisor and will be in responsible charge in the event the laboratory supervisor ceases to be employed
by the laboratory and will be responsible for filling the laboratory supervisor position with a replacement
qualified pursuant to these Rules. At commercial laboratories, where the owner is the laboratory
supervisor, the laboratory manager and laboratory supervisor may be the same person if there is no one
administratively above the laboratory supervisor.
(5) Application. Each laboratory requesting initial state certification shall submit an application in duplicate,
accompanied by the application fee and the laboratory's Quality Assurance Manual to the State
Laboratory. Separate application and certification shall be required for all laboratories maintained on

(6)
(7)
separate premises even though operated under the same management; however, separate certification is
not required for separate buildings on the same or adjoining grounds. After receiving a completed
application and prior to issuing certification, a representative of the State Laboratory may visit each
laboratory to verify the information in the application and the adequacy of the laboratory.
Facilities and equipment. Each laboratory requesting certification must contain or be equipped with the
following:
(A) A minimum of 150 sq. ft. of laboratory space;
(B) A minimum of 12 linear feet of laboratory bench space;
(C) A sink with hot and cold water;
(D) An analytical balance capable of weighing 0.1 mg, mounted on a shock proof table;
(E) A refrigerator of adequate_ size to store all samples and maintain temperature of four degrees
Celsius;
(F) A copy of each approved analytical procedure being used in the laboratory;
(G) A source of distilled or deionized water that will meet the minimum criteria of the approved
methodologies;
(H) Glassware, chemicals, supplies, and equipment required to perform all analytical procedures
included in their certification.
Analytical Quality Control Program. Each laboratory shall develop and maintain a document outlining the
analytical quality control practices used for the parameters included in their certification. Supporting
records shall be maintained as evidence that these practices are being effectively carried out. The quality
control document shall be available for inspection by the State Laboratory. The following are
requirements for certification and must be included in each certified laboratory's quality control program:
(A) All analytical data pertinent to each certified analysis must be filed in an orderly manner so as to
be readily available for inspection upon request.
(B) Excluding Oil and Grease, all residue parameters, leachate extractions, residual chlorine, and
coliform, analyze one known standard in addition to calibration standards each day samples are
analyzed to document accuracy. Analyze one suspended residue, one dissolved residue, one
residual chlorine and one oil and grease standard quarterly. For residual chlorine, all calibration
standards required by the approved procedure in use and by EPA must be analyzed.
(C) Except for Oil and Grease (EPA Method 413.1), settleable solids or where otherwise specified
in an analytical method, analyze five percent of all samples in duplicate to document precision.
Laboratories analyzing less than 20 samples per month must analyze at least one duplicate each
month samples are analyzed.
(D) Any quality control procedures required by a particular approved method shall be considered as
required for certification for that analysis.
(E) All quality control requirements in these Rules as set forth by the State Laboratory.
(F) Any time quality control results indicate an analytical problem, the problem must be resolved
and any samples involved must be rerun if the holding time has not expired.
(G) All analytical records must be available for a period of five years. Records, which are stored
only on electronic media, must be maintained and supported in the laboratory by all hardware
and software necessary for immediate data retrieval and review.
(H) All laboratories must use printed laboratory bench worksheets that include a space to enter the
signature or initials of the analyst, date of analyses, sample identification, volume of sample
analyzed, value from the measurement system, factor and final value to be reported and each
item must be recorded each time samples are analyzed. The date and time BOD and coliform
samples are removed from the incubator must be included on the laboratory worksheet.
(I) For analytical procedures requiring analysis of a series of standards, the concentrations ofthese
standards must bracket the concentration of the samples analyzed. One of the standards must
have a concentration equal to the laboratory's lower reporting concentration for the parameter
involved. For metals by AA or ICP, a series of at least three standards must be analyzed along
with each group of samples. For colorimetric analyses, a series of five standards for a curve
prepared annually or three standards for curves established each day or standards as set forth in
the analytical procedure must be analyzed to establish a standard curve. The curve must be
updated as set forth in the standard procedures, each time the slope changes by more than 10

percent at mid -range, each time a new stock standard is prepared, or at least every twelve
months. Each analyst performing the analytical procedure must produce a standard curve.
(J) Each day an incubator, oven, waterbath or refrigerator is used, the temperature must be checked,
recorded, and initialed. During each use, the autoclave maximum temperature and pressure
must be checked, recorded, and initialed.
(K) The analytical balance must be checked with one class S, or equivalent, standard weight each
day used and at least three standard weights quarterly. The values obtained must be recorded in
a log and initialed by the analyst.
(L) Chemicals must be dated when received and when opened. Reagents must be dated and
initialed when prepared.
(M) A record of date collected, time collected, sample collector, and use of proper preservatives
must be maintained. Each sample must clearly indicate the State of North Carolina collection
site on all record transcriptions.
(N) At anytime a laboratory receives samples which do not meet sample collection, holdingtime, or
preservation requirements, the laboratory must notify the sample collector or client and secure
another sample if possible. If another sample cannot be secured, the original sample may be
analyzed but the results reported must be qualified with the nature of the infraction(s) and the
laboratory must notify the State Laboratory about the infraction(s). The notification must
include a statement indicating corrective actions taken to prevent the problem for future
samples.
(0) All thermometers must meet National Institute of Standards and Technology (NIST)
specifications for accuracy or be checked, at a minimum annually, against a NIST traceable
thermometer and proper corrections made.
(8) Decertification Requirements. Municipal and industrial laboratories that cannot meet initial certification
requirements must comply with the Decertification Requirements as set forth in Rule .0807(e) of this
Section.
(b) Issuance of Certification.
(1) Upon compliance with these Rules, certification shall be issued by the Director, Division of Water
Quality, Department of Environment and Natural Resources or his delegate, for each of the applicable
parameters requested within 30 days.
(2) Initial certifications shall be issued for prorated time periods to schedule all certification renewals on the
first day of January and shall be valid for one year.
(c) Maintenance of Certification.
(1) To maintain certification for each parameter, a certified laboratory must analyze up to four performance
evaluation samples per parameter per year submitted by an accredited vendor as an unknown.
Laboratories submitting unacceptable results on a performance evaluation sample may be required to
analyze more than four samples per year.
(2) In addition, the State Laboratory may request that samples be split into two equal representative portions,
one part going to the State and the other to the certified laboratory for analysis.
(3) The State laboratory may submit or require clients to submit blind performance samples or split samples
under direction of State Laboratory personnel.
(4) A certified laboratory shall be subject to periodic announced or unannounced inspections during the
certification period and shall make time and records available for inspections and must supply copies of
records for any investigation upon written request by the State Laboratory.
(5) A certified laboratory must provide the State Laboratory with written notice of laboratory supervisor or
laboratory manager changes within 30 days of such changes.
(6) A certified laboratory must submit written notice of any changes of location, ownership, address, name or
telephone number within 30 days of such changes.
(7) A certified laboratory must submit a written amendment to the certification application each time that
changes occur in methodology, reporting limits, and major equipment. The amendment must be received
within 30 days of such changes.
(d) Certification Renewals
(1) Certification renewals of laboratories shall be issued for one year.
(e) Data reporting.

(1) Certified commercial laboratories must make data reports to their clients that are signed bythe laboratory
supervisor. This duty may be delegated in writing; however, the responsibility shall remain with the
supervisor.
(2) Whenever a certified commercial laboratory refers or subcontracts samples to another certified laboratory
for analyses, the referring laboratory must supply the date and time samples were collected to insure
holding times are met. Subcontracted samples must clearly indicate the State of North Carolina as the
collection site on all record transcriptions. Laboratories may subcontract sample fractions, extracts,
leachates and other sample preparation products provided that all Rules and requirements of 15ANCAC
02H .0800 are documented. The initial client requesting the analyses must receive the original or a copy
of the report made by the laboratory that performs the analyses.
(3) All uncertified data must be clearly documented as such on the benchsheet and on the final report.
(f) Discontinuation of Certification.
(1) A laboratory may discontinue certification for any or all parameters by making a written request to the
State Laboratory.
(2) After discontinuation of certification, a laboratory may be recertified by meeting the requirements for
initial certification; however, laboratories that discontinue certification during any investigation shall be
- subject to Rule .0808 of this Section.
(0 Prerequisites and requirements for Field Parameter Certification. Only the following requirements must be met
prior to certification for Field Parameter Laboratories. Once certified, failure to comply with any of the following
items will be a violation of certification requirements.
(1) Data pertinent to each analysis must be maintained for five years. Certified Data must consist of
date collected, time collected, sample site, sample collector, and sample analysis time. The field
benchsheets must provide a space for the signature or initials of the analyst, and proper units of
measure for all analyses.
(2) A record of instrument calibration where applicable, must be filed in an orderly manner so as to
be readily available for inspection upon request.
(3) A copy of each approved analytical procedure must be available to each analyst.
(4) Each facility must have glassware, chemicals, supplies, equipment, and a source of distilled or
deionized water that will meet the minimum criteria of the approved methodologies.
(5) Supervisors of laboratories certified for Field Parameters only must meet the requirements of
Subparagraph (a)(3)(A) or (a)(3)(B) of this Section, or possess a chemistry or related degree with
two years of related environmental experience, or hold any Biological Water Pollution Control
System Operator's Certification as defined by 15A NCAC 08G.
(6) Application: Each Field Parameter Laboratory shall submit an application in duplicate.
(7) Performance Evaluations. Each Field Parameter Laboratory must participate in an annual
quality assurance study by analyzing performance evaluation samples obtained from an
accredited vendor as unknowns. If performance evaluations are not available for a parameter,
certification for that parameter may be based on the proper use of the approved procedure as
determined by an announced or unannounced on -site inspection.
(8) Decertification and Civil Penalties. A laboratory facility can be decertified for infractions as
outlined in Rule .0807 of this Section.
(9) Recertification. A laboratory facility can be recertified in accordance with Rule .0808 of this
Section.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. February 1, 1976;
Amended Eff. July 1, 1988; July 1, 1985; December 1, 1984; November 1, 1978;
RRC Objection Eff October 15, 1992 due to lack of statutory authority;
Amended Eff. December 21, 1992;
RRC Objection Removed Eff. December 16, 1993;
Temporary Amendment Eff. October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0806 FEES ASSOCIATED WITH CERTIFICATION PROGRAM

(a) An applicant for laboratory certification, excluding those laboratories seeking Field Parameter Certification only,
must submit to the Department of Environment and Natural Resources, Laboratory Section, a non-refundable fee of three
hundred dollars ($300.00) for the evaluation and processing of each application.
(b) Municipal, Industrial and Other laboratories must pay an annual fee of fifty. dollars ($50.00) for each inorganic parameter
plus one hundred dollars ($100.00) for each organic parameter and metals analyte; however, the minimum fee will be one
thousand three hundred fifty dollars ($1,350.00) per year.
(c) Commercial laboratories must pay an annual fee of fifty dollars ($50.00) for each inorganic parameter plus one hundred
dollars ($100.00) for each organic parameter and metals analyte; however, the minimum fee will be two thousand seven
hundred dollars ($2,700.00) per year.
(d) Prior to receiving initial certification, a laboratory must pay the required fee as specified in Paragraph (b) or (c) of this
Rule. Initial certification fee will be prorated on a semi-annual basis to make all certification renewals due on the first day of
January.
(e) Once certified, a laboratory must pay the full annual parameter fee for each parameter added to their certificate.
(f) A laboratory decertified for all parameters must pay initial certification fees prior to recertification.
(g) A laboratory decertified for one or more parameters must pay a fee of two hundred dollars ($200.00) for each parameter
for which it was decertified prior to recertification.
(h) Out-of-state laboratories shall reimburse the state for actual travel and subsistence costs incurred in certification and
maintenance of certification.
(i) Annual certification fees are due 60 days after receipt of invoice.
0) A two hundred fifty dollar ($250.00) late payment fee must be paid when annual certification fees are notpaid bythe date
due.
(k) Commercial facilities analyzing samples for field parameters only must pay an annual fee of two hundred
dollars ($200.00) per year.
(1) Municipal and Industrial facilities analyzing samples for field parameters only must pay an annual fee of one
hundred dollars ($100.00) per year.
History Note: AuthorityG.S 143-215.3(a)(1); 143-215.3(a)(10);
Eff. February 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984;
Temporary Amendment Eff. October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0807 DECERTIFICATION AND CIVIL PENALTIES
(a) Laboratory Decertification. A Laboratory may be decertified, for anv or all parameters, for up to one vear for
any of the following infractions:
(1) Failing to maintain the facilities, or records, or personnel, or equipment, or quality control
program as set forth in the application, and these Rules; or
(2) Submitting inaccurate data or other information; or
(3) Failing to pay required fees by the date due; or
(4) Failing to discontinue supplying data for clients or programs described in Rule .0802 of this
Section during periods when a decertification is in effect; or
(5) Failing to submit a split sample to the State Laboratory as requested; or
(6) Failing to use approved methods of analysis; or
(7) Failing to report laboratory supervisor or equipment changes within 30 days of such changes; or
(8) Failing to report analysis of required annual performance evaluation samples submitted by an
EPA approved vendor within the specified time limit; or
(9) Failing to allow an inspection by an authorized representative -of the State Laboratory, or
(10) Failing to supply analytical data requested by the State Laboratory; or
(11) Failing to submit a written amendment to the certification application within 30 days of applicable
changes; or
(12) Failing to meet required sample holding times; or
(13) Failing to respond to requests for information by the date due; or
(14) Failing to comply with any other terms, conditions, or requirements of this Section or of a
laboratory certification.

b) Parameter Decertification. A laboratory may receive a parameter decertification for failing to:
(1) Obtain acceptable results on two consecutive blind or announced performance evaluation samples
submitted by an EPA accredited vendor or the State Laboratory; or
(2) Obtain acceptable results on two consecutive blind or announced split samples that have also been
analyzed by the State Laboratory.
(c) Falsified Data. A laboratory that submits falsified data or other information may be decertified for all
parameters for up to two years.
(d) Decertification Factors. In determining a period of decertification, the Director shall recognize that any harm
to the natural resources of the State arisinLy from violations of these Rules in this Section may not be immediately
observed and may be incremental or cumulative with no damage that can be immediately observed or documented.
Decertification for periods up to the maximum may be based on any and or a combination of the following factors
to be considered:
(1) The deLyree and extent of harm, or potential harm, to the natural resources of the State or to the
public health, or to private property resulting from the violation;
(2) The duration, and gravity of the violation;
(3) The effect, or potential effect, on ground or surface water quantity or quality or on air quality;
(4) Cost of rectifying any damaLye;
(5) The amount of money saved by noncompliance;
(6) As to violations other than submission of falsified data or other information, whether the violation
was committed willfully or intentionally,
(7) The prior record of the laboratory in complying or failine to comply with any State and Federal
laboratory Rules and regulations;
(8) The cost to the State of investieation and enforcement procedures;
(9) Cooperation of the laboratory in discoverine, identifying, or reportine the violation;
(10) Measures the laboratory implemented to correct the violation or abate the effect of the violation,
including notifying any affected clients;
(11) Measures the laboratory implemented to correct the cause of the violation;
(12) Any other relevant facts.
(e) Decertification Requirements.
(1) A decertified laboratory is not to analyze samples for the decertified parameters for programs
described in Rule .0802 of this Section or clients reporting to these programs.
(2) A decertified commercial laboratory must supply written notification of the decertification to
clients with Division of Water Ouality reporting requirements. Within 30 days, the decertified
laboratory must supply the State Laboratory with a list of clients involved and copies of the
notices sent to each.
(3) A commercial laboratory that has received a parameter decertification may make arraneements
to supply analysis throueh another certified laboratory durine any decertification periods. The
decertified laboratory must supply the State Laboratory, by written notice, the name of the
laboratory to be used.
(4) A commercial laboratory decertified for all parameters cannot subcontract samples for analyses
to other certified laboratories during the decertification period.
(5) A decertified municipal or industrial laboratory must have its samples analyzed by another
certified laboratory during any decertification period and supply the State Laboratory, by written
notice, the name of the certified laboratory to be used.
(f) Civil Penalties. Civil penalties may be assessed against a laboratory which violates or fails to act in accordance
with any of the terms, conditions, or requirements of the Rules in this Section or of a laboratory certification. A
laboratory is subiect to both civil penalties and decertification.
History Note: AuthorityG.S 143-215.3(a)(1); 143-215.3(a)(10); 143-215.6A;
Eff. Februmy 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984;
Temporary Amendment Eff October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0808 RECERTIFICATION

(a) A laboratory decertified in accordance with Paragraph (a) of Rule .0807 of this Section may be recertified at the
end of the decertification period by showing to the satisfaction of the State Laboratory that it has corrected the
deficiency(ies).
(b) A laboratory decertified for a parameter due to unacceptable results on two consecutive performance
evaluation samples submitted by an EPA accredited vendor, or on two consecutive split samples may be recertified
after 60 days by reporting acceptable results on two consecutive performance evaluation samples submitted by an
EPA accredited vendor. Recertification samples may be requested from an EPA accredited vendor at any time,
however, recertification must be requested in writing at the end of the 60 day period immediately following the date
of decertification.
(c) A laboratory decertified for submitting falsified data or other information may be recertified at the end of the
decertification period by demonstrating compliance with all requirements of this Section.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. February 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984;
Temporary Amendment Eff October 1, 2001;
Amended Eff. August 1, 2002.
15A NCAC 02H .0809 RECIPROCITY
(a) Laboratories certified under other state certification programs may be given reciprocity certification where such
programs meet the requirements of this Section. In requesting reciprocity certification, laboratories shall include with the
application required by Rule .0805(a) ofthis Section a copy oftheir certification and Regulation from the certifying agency.
(b) Laboratories certified by reciprocity shall pay the fees required by Rule .0806 of this Section.
(c) Any time that a laboratory has its certification with the reciprocal program discontinued for any reason, certification
under this Section shall be terminated at the same time.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. February 1, 1976;
Amended Eff. November 2, 1992; December 1, 1984.
15A NCAC 02H .0810 ADMINISTRATION
(a) The Director of the Division of Water Quality, Department of Environment and Natural Resources, or his delegate, is
authorized to issue certification, to. reject applications for certification, to renew certification, to issue recertification, to issue
decertification, and to issue reciprocity certification.
(b) Appeals. In any case where the Director of the Division of Water Quality, Department of Environment and Natural
Resources or his delegate denies certification, or decertifies a laboratory, the laboratory may appeal to the N.C. Office of
Administrative Hearings in accordance with Chapter 150B of the General Statutes.
(c) The State Laboratory will maintain a current list of certified commercial laboratories.
(d) Implementation of the October 1, 2001 changes to this Section.
(1) All requirements of the Rules in this Section are effective on the effective date of the amendments.
(2) Requests for the new parameters may be made by submitting a properly completed amendment form.
(3) Laboratories subject to the amended requirements ofthese Rules must submit a completed application, or
amendment form, within three months of the effective date ofthe amendments. Laboratories submitting
an application or amendment form for any of the newly certifiable parameters may analyze samples for
these new parameters until the State Laboratory has issued or denied certification. Fees for parameter
additions requested during the initial three month period will be calculated as initial certification fees.
(4) Laboratory facilities, not currently certified, that are performing analyses for Field Parameters
only must submit an application within three months of the effective date of the amendments.
After submitting an application, these laboratories may continue to analyze samples until the State
Laboratory has issued or denied certification.
History Note: Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10); 150B-23;
Eff. Februmy 1, 1976,-
Amended Eff. November 2, 1992; July 1, 1988; December 1, 1984; November 1,1978;

Temporary Amendment Eff. October], 2001;
Amended Eff. August 1, 2002.
15A NCAC 0211.0811 IMPLEMENTATION
History Note:. Authority G.S. 143-215.3(a)(1); 143-215.3(a)(10);
Eff. December 1, 1984;
Repealed Eff. July 1, 1988.

\IATF Micnaei i-. =asiey, uovernor
r� R ,f �) `J William G. Ross Jr., Secretary
\O� QG I L � \� North Carolina Department of Environment and Natural Resources
y Alan W. Klimek, P.E. Director
r Division of Water Quality
>_ —{
O '<
AQUIFER PROTECTION SECTION
June 27, 2008
National Fruit Products Company
PO Box 2040
Winchester, VA 22604-1240
Attention: David Gum, VP Mfg.
RE: Surface Irrigation Inspection Report
Permit No. WQ0003924
White House Road Facility
Lincoln County, N.C.
Dear Mr. Gum:
Enclosed you will find the report for the annual compliance inspection that I conducted at the Lincointon
Plant on June19, 2008. The report should be self-explanatory but certain items deserve emphasis.
The condition of the application fields at the west end has improved but still require attention. Based on
the soil fertility analysis and the weather in the fall, additional lime and reseeding may be appropriate.
On -site recordkeeping was generally satisfactory but compliance monitoring forms (NDMR, NDAR, GW-
59) submitted to the Division have not contained the required sampling information. Therefore, please
conduct effluent sampling in accordance with Condition 111.3. of your permit and submit the results on
Form NDMR to this office within 60 days.
Should you have any questions, feel free to call me at 704/235-2183.
Sincerely,
Pegj inley
Environmental Specialist
Enclosure: Inspection Report
Cc: Cole Gamble, Plant Mgr., National Fruit Products, PO Box 916, Lincolnton 28093 w/ enclosure
MAF/national fruit inspection rpt 6-19-08
NorthCaro
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] �atura�
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org

Permit #WQ0003924
Effluent Storaqe
Page 3
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Lagoon
(Check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N_ Vegetation (is there excessive vegetation on the lagoon bank
Y_ Liner (if visible, is it intact)
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge (clearly marked)
_N Evidence of overflow (vegetation discolored or laying down/broken)
N Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
N Floating mats (sludge, plants, inorganics)
N Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated annually?
Y _ Are cover.crops the type specified in permit?
Y*_ Is cover crop in need of improvement?
_N_ Signs of runoff or drift?
_Y*_ Signs of ponding?
Comments: *The status of the cover crop has improved over the last year but
continues to need attention.
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?.
N Are restrictions for use of these areas specified?
Y Is permit being followed?
Y Is site access restricted in accordance with permit?

5
Permit #WQ0003924
Recordkeeping
Page 4
Y Is permit available upon request?
_Y_ Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y Complete?
Y Are lab sheets available for review?
N Do lab sheets support data represented on NDMR or NDAR?
_N_ Are all samples analyzed for the required parameters?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
_Y_ Did the last report indicate a need for lime? _Y_ Was it applied?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: A review of the facility's operational records found them to be complete
and up-to-date. However, groundwater and effluent monitoring sampling data was
incomplete. In addition, the MRO has not been receiving the, required groundwater
monitoring reports.
Groundwater Monitorinq
Y Does the permit require monitoring wells? If so,
_Y_ are the monitoring wells properly installed according to the permit?
_N_ are the wells properly identified?
_N_ are the wells damaged?

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F \,N A
\O�(; 'QQG Michael F. Easley, Governor
William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
[D
> �� Coleen H. Sullins, Director
O 1..� I Division of Water Quality
AQUIFER PROTECTION SECTION
July 30, 2007
National Fruit Products Company
PO Box 2040
Winchester, VA 22604-1240
Attention: David C. Gum, CEO
RE: Compliance Monitoring
Permit No. WQ0003924
National Fruit Products — Lincolnton Plant
Wastewater Surface Irrigation
Lincoln County
Dear Mr. Gum:
On May 16, 2007, 1 conducted my annual inspection of the waste treatment facility at the Lincolnton plant. The
inspection report is included for reference. As you will note, I expressed a concern about the condition of some of
the spray fields in the report. Because of this concern, a more in-depth review of the wastewater effluent
monitoring was conducted. This review generated additional concern about the status of the spray irrigation fields
as a whole.
Your permit requires that a sodium absorption ratio (SAR) be calculated based on the concentrations of sodium,
calcium and magnesium in the effluent (see Attachment A). It does not appear that the SAR is being calculated.
This calculation is important because the results are an'indicator of the impact that salts in the wastewater may be
having on the soil. Damage to the structure impairs the ability of the soil to properly assimilate the wastewater. A
SAR value of 5 serves as a "red flag" while an SAR of 10 is generally considered an upper limit of safe operation.
My calculations of SAR based on your reported effluent concentrations indicate that action must be taken to avert
future problems that may make the fields unsuitable for surface irrigation (see Attachment B).
The first action should be to determine whether the sodium concentration of the waste stream can be reduced.
Otherwise, the treatment system must be re-evaluated with regard to improving sodium removal. You may wish to
contact Mark Stokes with the DWQ Technical Assistance Unit for consultation on this matter. He can be reached
through the DENR Winston-Salem Regional Office at 336/771-4952. You may also wish to seek assistance from
the Lincoln Co. Agricultural Extension agent regarding management of the cover crop on the application fields.
Please be advised that any change to the treatment system will require a permit modification.
Within 60 days, please provide a status report on the efforts you have taken to address this matter. Should you
have any questions, do not hesitate to call me at 704/235-2183.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: 2007 Inspection Report
Attachment A — SAR Equation
Attachment B — Lincolnton Plant SAR calculations
Cc: L.D. Shockley, 288 White House Rd., Lincolnton 28092 w/enclosures
Cole Gamble, 288 White house Rd., Lincolnton 28092 w/enclosures
MAF/national fruit Itr 7-30-07
One
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] D o6#hCarolina
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwatergualitv.org Aaturldff

Michael F. Easley, Governor
William G. Ross Jr., ?ecretarr,
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
May 21, 2007
National Fruit Products Company
PO Box 916
Lincolnton, North Carolina 28093
Attention: Cole Gamble
RE: Surface Irrigation Inspection Report
Permit No. W00003924
White House Road Facility
Lincoln County, N.C.
Dear Mr. Gamble:
Enclosed you will find the report for the annual compliance inspection that I conducted on March 16,
2007. The report should be self-explanatory but certain items deserve emphasis.
The condition of the disposal fields were of concern. The area around spray head #1, with its ruts .and
bare areas, appeared the same as during my 2006 visit. Sparse and dead vegetation was observed
around other spray heads in Areas 1 and 2. Irrigation of these fields must cease until they are repaired
and reseeded.
Recordkeeping was generally satisfactory but the results of the semi-annual effluent monitoring must be
recorded on the Non -discharge Monitoring Forms (NDMR) when they are submitted for April and October
of each year.
Should you have any questions, feel free to call me at 704/235-2183.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/national fruit inspection rpt 5-21-07
One
NorthCaroli�
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] oft hCar / l
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.ncwaterquality.org (/ V lll

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
A IT 00
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
City/Town/Owner: National Fruit Products Co.
Permit # WQ0003924
Issuance Date: 3/9/05
Permittee Contact: Cole Gamble, QA Mgr.
ORC Name: Larry Reep Cert #15647
Backup ORC Name: Philip Himebaugh Cert #987936
County: Lincoln
Project Name: Lincolnton Plant
Expiration Date: 2/28/10
Telephone No.: 704/735-2531
Telephone No.: 704/735-2531
Telephone No.: 704/735-2531
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Inspection Summary. (additional comments may be included on attached pages)
The treatment system appears to be operating properly. There has been no significant
change in the volume of the wastewater generated this past year. A small leak has
been identified in the piping from the lagoon to the disposal area. It is in the same
general location of the leak last year and awaits repair. Several areas in the
application fields are in poor condition and the area around spray head #1 has still not
been adequately repaired. Mr. Gamble was advised that this matter needs prompt
attention.
Mr. Reep is retiring this month. Mr. Gamble has completed the spray irrigation course
and will take the exam in June. Once he is certified, he will assume the duties of the
ORC.
Is a follow-up inspection necessary _?(.yes no
Inspector Name/Title Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 5/16/07

Permit #WQ0003924
Type
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Influent pump station
Y all pumps present, operational
Bar screen, maintained
Bars evenly spaced
Back-up power
Flow Measurement — Influent
Y Is flowmeter calibrated annually?
_Y_ Is flowmeter operating properly?
Does flowmeter operate continuously?
N Does flowmeter record flow?
Y Does flowmeter appear to monitor accurately?
Bypass structure present
Free of excessive debris
Bars excessively corroded
Flow Measurement — Water -Use Records
Y_ Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Page 2
Is the system working? _Y_ Is the system properly maintained?
Tablets Gas _Y_ Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/liquid, does cylinder/tank storage seem safe?.
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y* Is the flowmeter calibrated annually?
Is the flowmeter operating properly?
_N Does the flowmeter monitor continuously?
Does the flowmeter appear to monitor accurately?
Comments: A new effluent flow meter was just installed and will be calibrated shortly.

Permit #WQ0003924
Effluent Storaae
Page 3
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Lagoon
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N_ Vegetation (is there excessive vegetation on the lagoon bank
Y_* Liner (if visible, is it intact)
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
—Y—Staff gauge ( clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
—N—Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
N Floating mats (sludge, plants, inorganics)
_N Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Vegetation on -liner needs to be removed and the integrity of the liner
verified.
Disposal (final end use)
Y Is the application equipment present and operational?
_N Is application equipment in need repair?
_N_ Spray heads calibrated annually?
_Y _ Are cover crops the type specified in permit?
Y*_ Is cover crop in need of improvement?
_N_ Signs of runoff or drift?
Y*_ Signs of ponding?
Comments: * The disturbed area that was observed last year in the vicinity of spray
head #1 has not been adequately repaired. Ruts remain and vegetation is sparse.
Vegetation.is sparse or dead around some spray heads in application areas #2 and 3..
The spray heads should be calibrated annually.
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
N Are restrictions for use of these areas specified?
N Is permit being followed? .
Y Is site access restricted in accordance with permit?

Permit #WQ0003924
Recordkeepinq
Page 4
Y Is permit available upon request?
Y Are flow rates less than permitted flow?
Y* Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
_N+_ Are all samples analyzed for the required parameters?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
_N_ Did the last report indicate a need for lime? Was it applied?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: * Bi-annual effluent monitoring has not been transferred from lab sheets to
NDMRs.
+ Coliform analysis has been for fecal instead of total coliform.
Groundwater Monitoring
_Y_ Does the permit require monitoring wells? If so',
_Y_ are the monitoring wells properly installed according to the permit?
_Y_ are the wells properly identified?
_ _ are the wells damaged?

,r
In terms of the soil, the nature of the various salts, their proportionate amounts,
their total concentration, and their distribution in the soil profile must be considered.
The structure of the soil and its drainage and aeration are important as well.
Prevention of the problem is very important. Once sodium and salt damage occurs
to the soil, it is a slow and tedious procedure to restore the soil to its original condition.
To prevent such damage, an operator must know the sodium concentration in the
irrigated wastewater. As discussed in Chapters 1 and 3, a ratio of the sodium
concentration to the concentrations of calcium and magnesium in the wastewater is
called the sodium adsorption ratio (SAR) and is a good indicator of potential soil
problems.
Calculations for SAR utilize the liquid concentrations (in mg/L) of sodium, calcium,
and magnesium in the wastewater. The formula for Sodium Adsorption Ratio is as
follows, with all concentrations expressed in milliequivalents:
SAR = Na
0.5 x (Ca + Mg)
The milliequivalents of a given element or ion can be calculated by dividing the
concentration, in milligrams per liter (mg/L), by the equivalent weight of the ion. The
equivalent weights of sodium, calcium, and magnesium are, respectively, 23, 20, and
12.
Example: What is the SAR for a wastewater that has the following ion
concentrations:
Sodium (Na`)= 54 mg/L
Calcium (Ca'Z) = 36 mg/L
Magnesium (Mg") = 8 mg/L
S'�i ``� � (_ 1' 1 �,�,►Sl -� ►� � ✓� 5 �� �..Y,-, �� �:�!` � �1(� C-aj v� 1 ✓� CJ 1 �' l �.- I-, ),y
5-82

Step 1) Change concentrations into milliequivalents (meq) using the conversions:
54 mg/L
Na meq = = 2.34
23
36 mg/L
Ca meq = = 1.8
20
8 mg/L
Mg meq = = 0.67
12
Step 2) Use formula to calculate SAR:
SAR = 2.34
0.5 x (1.8 + 0.67)
SAR = 2.34 = 2.10
1 .235
Sodium adsorption ratios in wastewater range from very low (less than 1) to several
hundred. Facilities that are especially prone to having SAR problems are the food
processing industry, industries that use sodium hydroxide as a wash or disinfectant, or
other operations using a form of sodium. A SAR of 10 is generally considered an upper
level for safe operation. There are, however, many variables that go along with the SAR
that will determine if problems will be expressed in the soil.
A SAR of 5 in a wastewater should be a "red flag" to an operator. At this level, there
should be some attention to the sodium issue to ensure that future problems can be
minimized. If the SAR exceeds 5, an operator should determine if excess sodium in the
5-83

wastestream can be reduced. Soil samples should also be analyzed and handled as a
problem sample to help determine if the soil sodium activity level is approaching a
problem level. Individuals with technical expertise should be contacted if the operator is
not experienced with these issues.
While SAR evaluates the sodium status of wastewater, exchangeable sodium
percentage (ESP) is an evaluation that can � be used to determine possible excess
sodium concentration in the soil itself. The ESP is the percentage of the soil's cation
exchange capacity (CEC) that is occupied by the sodium cations. This determination
can be made from a typical soil fertility evaluation.
Example:
The CEC of a soil is 8.9 meq/100 cm3 and the Na is 0.2 meq/100 cm'. What is the
exchangeable sodium percentage?
ESP =
Na concentration
CEC
X (100%) .
0.2
ESP .= X 100% = 2.25%
8.9
An ESP level of 15 percent or higher is typically used to denote a level of concern
where salt damage may occur both to the crop and to the soil structure. Levels from 10
to 15 percent should cause the operator some concern, and should justify the need to
take remedial action (described above) before long range problems occur. The ESP
ratio evaluation should be used in conjunction with calculating the SAR of the
wastewater to ensure that salt buildup does not limit or restrict the long-range use of the
site.
5-84

Item 1
National Fruit Products Effluent Monitoring
Date
Mg Meq
Na Meq
Ca Meq
Cl
TDS
BOD5
TSS
2/24/2003
0.30833
40.00000
0.65000
200.00000
1600.00000
3300.00000
23.00000
10/27/2003
0.33333
6.08696
0.70000
160.00000
600.00000
1900.00000
45.00000
2/24/2004
0.27500
5.21739
0.65000
120.00000
1600.00000
4200.00000
13.00000
6/28/2004
0.25000
3.95652
0.65000
92.00000
480.00000
2800.00000
58.00000
10/25/2004
0.25833
4.00000
0.65000
81.00000
480.00000
3500.00000
87.00000
2/23/2005
0.23333
6.08696
0.55000
190.00000
840.00000
4700.00000
17.00000
6/30/2005
0.25000
6.52174
0.70000
150.00000
590.00000
4300.00000
43.00000
10/27/2005
0.24167
7.39130
0.65000
140.00000
580.00000
3400.00000
81.00000
2/24/2006
0.27500
3.95652
0.65000
67.00000
4/1/2007
1.08000
6.90000
1.70000
166.00000
90.00000
Mg & Ca Meq Multiplier SAR
0.95833 57.79 57.78521
1.03333
8.47
8.46828
0.92500
7.67
7.67180
0.90000
5.90
5.89803
0.90833
5.94
5.93543
0.78333
9.73
9.72617
0.95000
9.46
9.46273
0.89167
11.07
11.06967
0.92500
5.82
5.81779
2.78000 5.85 5.85250
i

P6,n31 z�/
Item 1
Date
Mg Meq
Na Meq
Ca Meq
Cl
TDS
BOD5
NH3
2/24/2003
0.30833
40.00000
0.65000
200.00000
1600.00000
3300.00000
BRL
<2
10/27/2003
0.33333
6.08696
0.70000
160.00000
600.00000
1900.00000
BRL
<2
2/24/2004
0.27500
5.21739
0.65000
120.00000
1600.00000
4200.00000
BRL
<2
6/28/2004
0.25000
3.95652
0.65000
92.00000
480.00000
2800.00000
BRL
<2
10/25/2004
0.25833
4.00000
0.65000
81.00000
480.00000
3500.00000
BRL
<2
2/23/2005
0.23333
6.08696
0.55000
190.00000
840.00000
4700.00000
BRL
<2
6/30/2005
0.25000
6.52174
0.70000
150.00000
590.00000
4300.00000
BRL
<2
10/27/2005
0.24167
7.39130
0.65000
140.00000
580.00000
3400.00000
0.31000
<2
2/24/2006
0.27500
3.95652
0.65000
BRL
Item 2
Fecal TSS Mg
& Ca Meq
Multiplier
SAR
23.00000
0.95833
57.79
57.78521
45.00000
1.03333
8.47
8.46828
13.00000
0.92500
7.67
7.67180
58.00000
0.90000
5.90
5.89803
87.00000
0.90833
5.94
5.93543
17.00000
0.78333
9.73
9.72617
43.00000
0.95000
9.46
9.46273
81.00000
0.89167
11.07
11.06967
67.00000
0.92500
5.82
5.81779

-'ynG vviniam Ci. Koss Jr., secretary
O
VV�� �\ North Carolina Department of Environment and Natural Resources
Alan W. Klimek; P.E. Director
r
> Division of Water Quality
o <
AQUIFER PROTECTION SECTION
May 21, 2007
National Fruit Products Company
PO Box 916
Lincolnton, North Carolina 28093
Attention: Cole Gamble
RE: Surface Irrigation Inspection Report
Permit No. WQ0003924
White House Road Facility
Lincoln County, N.C.
Dear Mr. Gamble:
Enclosed you will find the report for the annual compliance inspection that I conducted on Malsk16,
2007. The report should be self-explanatory but certain items deserve emphasis.
The condition of the disposal fields were of concern. The area around spray head #1, with its ruts and
bare areas, appeared the same as during my 2006 visit. Sparse and dead vegetation was observed
around other spray heads in Areas 1 and 2. Irrigation of these fields must cease until they are repaired
and reseeded.
Recordkeeping was generally satisfactory but the results of the semi-annual effluent monitoring must be
recorded on the Non -discharge Monitoring Forms (NDMR) when they are submitted for April and October
of each year.
Should you have any questions, feel free to call me at 704/235-2183.
Sincerely,
Peggy Finley
Environmental Specialist
Enclosure: Inspection Report
MAF/national fruit inspection rpt 5-21-07
One
NorthCarolit
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office Phone: [phone] Fax: [phone] bft Caro it
610 East Center Avenue, Suite 301, Mooresville, NC 28115 Customer Service 1-877-623-6748 Internet: www.newaterquality.org

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
SURFACE IRRIGATION
GENERAL INFORMATION
City/Town/Owner: National Fruit Products Co.
Permit # WQ0003924
Issuance, Date: 3/9/05
Permittee Contact: Cole Gamble, QA Mgr.
ORC Name: Larry Reep Cert #15647
Backup ORC Name: Philip Himebaugh Cert #987936
County: Lincoln
Project Name: Lincolnton Plant
Expiration Date:. 2/28/10
Telephone No.: 704/735-2531
Telephone No.: 704/735-2531
Telephone No.: 704/735-2531
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Inspection Summary: (additional comments may be included on attached pages)
The treatment system appears to be operating properly. There has been no significant
change in the volume of the wastewater generated this past year. A small leak has
been identified in the piping from the lagoon to the disposal area. It is in the same
general location of the leak last year and awaits repair. Several areas in the
application fields are in poor condition and the area around spray head #1 has still not
been adequately repaired. Mr. Gamble was advised that this matter needs prompt
attention.
Mr. Reep is retiring this month. Mr. Gamble has completed the spray irrigation course
and will take the exam in June. Once he is certified, he will assume the duties of the
ORC.
Is a follow-up inspection necessary _X�yes no
Inspector Name/Title Peggy Finley, Environmental Specialist
Tel. No. 704/235-2183 Fax No. 704/663-6040
Date of Inspection: 5/16/07

Permit #WQ0003924
Type
X Lagoon Spray, Low Rate
Lagoon Drip, Low Rate
Treatment
Y Are treatment facilities consistent with those outlined in the current permit.
Y Do all treatment units appear to be operational. If no, note below.
Influent pump station
Y all pumps present, operational
Bar screen, maintained
Bars evenly spaced
Back-up power
Flow Measurement — Influent
_Y_ Is flowmeter calibrated annually?
_Y_ Is flowmeter operating properly?
Does flowmeter operate continuously?
N Does flowmeter record flow?
Y Does flowmeter appear to monitor accurately?
Bypass structure present
Free of excessive debris
Bars excessively corroded
Flow Measurement — Water -Use Records
Y Is water use metered?
Y Are the daily average values properly calculated?
Disinfection NA
Page 2
Is the system working? _Y_ Is the system properly maintained?
Tablets Gas _Y_ Liquid UV
If tablets, proper size? Present in Cylinder(s)?
If gas/Liquid; does cylinder/tank storage seem safe?
If bulbs, are replacement bulbs on hand?
Is contact chamber free of sludge, solids and growth?
Flow Measurement — Effluent
Y* Is the flowmeter calibrated annually?
Is the flowmeter operating properly?
_N Does the flowmeter monitor continuously?
Does the flowmeter appear to monitor accurately?
Comments: A new effluent flow meter was just installed and will be calibrated shortly.

a
Permit #WQ0003924
Page 3
Effluent Storaae
X LAGOON SEPTIC TANK(s) ABOVE GROUND TANK OTHER
Number of months storage Spill control plan on site
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Lagoon
Primary (check any/all that apply)
Y Influent structure (free of obstructions)
N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N_ Vegetation (is there excessive vegetation on the lagoon bank
Y_* Liner (if visible, is it intact)
NA Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
—Y—Staff gauge ( clearly marked)
N Evidence of overflow (vegetation discolored or laying down/broken)
—N—Unusual color (very black, textile colors)
N Foam (are antifoam agents used)
_N Floating mats (sludge, plants, inorganics)
_N Excessive solids buildup (from bottom)
NA Aerators/mixers operational (if present)
Y Effluent structure (free of obstructions, easily accessible)
Comment: Vegetation on liner needs to be removed and the integrity of the liner
verified.
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Spray heads calibrated annually?
Y _ Are cover crops the type specified in permit?
Y*_ Is cover crop in need of improvement?
_N_ Signs of runoff or drift?
Y*_ Signs of ponding?
Comments: * The disturbed area that was observed last year in the vicinity of spray
head #1 has not been adequately repaired. Ruts remain and vegetation is sparse.
Vegetation is sparse or dead around some spray heads in application areas #2 and 3.
The spray heads should be calibrated annually.
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?
N Are restrictions for use of these areas specified?
N Is permit being followed?
Y Is site access restricted in accordance with permit?

Permit #W00003924
Page 4
Recordkeeping
Y Is permit available upon request?
Y Are flow rates less than permitted flow?
Y* Are monitoring reports present: NDMR _ NDAR
Y Are operational logs present? _Y Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
_N+_ Are all samples analyzed for the required parameters?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
_N_ Did the last report indicate a need for lime? Was it applied?
Y Is the operation and maintenance manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment: * Bi-annual effluent monitoring has not been transferred from lab sheets to
NDMRs.
+ Coliform analysis has been for fecal instead of total coliform.
Groundwater Monitoring
Y Does the permit require monitoring wells? If so,
Y are the monitoring wells properly installed according to the permit?
_Y_ are the wells properly identified?
_ _ are the wells damaged?

•, / O� W ATF9 r Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
rAlan W. Klimek, P.E. Director
> Division of Water Quality
AQUIFER PROTECTION SECTION
March 24, 2006
National Fruit Product Company
288 White House Road
Lincolnton, North Carolina 28093
Attention: L.D. Shockley, Plant Manager
RE: Spray Irrigation Inspection Report
Permit No. W00003924
Lincoln County, N.C.
Dear Mr. Shockley:
Enclosed you will find the report for the inspection that I conducted on March 15, 2006. The facility is
generally in compliance. The report should be self-explanatory but please call me at 704/235-2183 if you
have any questions.
Sincerely,
Peg irzy
Hydrogeological Technician
Enclosure: Inspection Report
MAF/inspections/national fruit 3-15-06
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Phone:
NorthCaroli
[phone] Fax: [phone] ��tura!!
Internet: www.ncwaterquality.org

Spray Irrigation
Permit #WQ 0003924
Influent pump station
Y all pumps present, operational
Y Bar screen, maintained
—Y—Bars evenly spaced
—Y—Back-up power
Bypass structure present
—Y—Free of excessive debris
_N_Bars excessively corroded
Aeration Basin NA
aeration pattern even across surface of unit
easily accessed
Clarifiers N/A
weirs level scum rack operational easily accessible
Filters N/A
media present air scour operational clear well free of solids
Residuals N/A
storage/treatment
Disinfection NA
Page 3
Is the system working? Is the system properly maintained?
Tablets Gas Liquid . UV
Effluent Storage
X LAGOON SEPTIC TANK(s)_X ABOVE GROUND TANK OTHER
Number of months storage-4 Spill control plan on site Y
Above ground tank Aerated Mixed
In ground tank Aerated Mixed
Drying beds Concrete storage pad
Comment:
Disposal (final end use)
Y Is the application equipment present and operational?
_N_ Is application equipment in need repair?
_N_ Are cover crops the type specified in permit?
_Y _ Is cover crop in need of improvement?
_N_ Signs of runoff?
Y Signs of ponding?
Comments: The condition of the drainage area between the two application fields looked
improved. The soil around one of the spray heads on line 1 was substantially disturbed by
heavy equipment. This has resulted in lack of cover crop, rutting and ponding: This area
needs to be repaired as soon as possible.

r
Spray Irrigation Page 4
Permit #WQ003924 .
Y Are buffers adequate?
Y Is the acreage specified in the permit being utilized?
N Are there any limiting slopes in disposal fields?'
NA Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Is site access restricted in accordance with permit?
Recordkeeping
Y Is permit available upon request?
Are flow rates less than permitted flow?
Y Are monitoring reports present: NDMR _ NDAR
N Are operational logs present? _ Complete?
Y Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
Y Are all samples analyzed for the required.parameters?
_N_ Are there any 2L GW quality violations?
Y Are annual soil reports available?
_NE Did the last report indicate a need for lime? Was it applied?
Is the operation and maintenance- manual present? Complete?
N Has DWQ received any complaints regarding the facility in the last 12 months?
Comment:
Groundwater Monitoring
Y_ Does the permit require monitoring wells? If so,
Y are the monitoring wells properly installed according to the permit?
Y are the wells properly secured?
_N_ are the wells damaged?
Comments: Wells are now secured with locks.

Michael F. Easley, Governor
William G. Ross Jr., Secretary
(v" � North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
AQUIFER PROTECTION SECTION
March 18, 2005
National Fruit Product Company, Inc.
Post Office Box 916
Lincolnton, North Carolina 28092
Attention: L.D. Shockley, Plant Manager
RE: Facility Inspection Follow-up
Permit No. WQ0003924
Wastewater Spray Irrigation System
Lincoln County, NC
Dear Mr. Schockley:
Thank you for taking the time to accompany Mr. Reep and me on my recent inspection of the
facility's spray irrigation system. Enclosed you will find a copy of my inspection checklist.
I have searched the Aquifer Protection Section's (APS) permit file and have not found well
construction records for any of the monitoring wells. I would appreciate it if you would check your
records for this information. Enclosed you will also find an excerpt from the NC Well Construction
rules about maintenance of monitoring wells and information about the APS groundwater sampling
video. This video reinforces some of the points covered during the inspection.
Should you have any questions, please call me at [phone] or contact me by email at
peggy. finleyQncmail. net.
Sincerely,
Peggy Finley
Hydrogeological Technician
MAF/letters/national fruit 3-18-05
Division of Water Quality / Aquifer Protection Section / Mooresville Regional Office
610 East Center Street, Suite 301, Mooresville, NC 28115
Phone:
[phone] Fax: [phone] NofthCarolh
Internet: hftPA/qw.ehnr.state.nc.us )III&M I,

S
v State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Secretary
Alan W. Klemek, P.E. Director
NCDENR
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
City/Town/Owner National Fruit Product Co
Permit # WQ 0003924 _
Issuance Date _July 7, 2000
If applicable SOC Issuance Date NA
County Lincoln
NPDES # NA
Expiration Date 6-30-05
Expiration Date
Permittee Contact LD Shockley, Plant Mgr Telephone No _704/735=2531
ORC Name _Larry Reep_ M15647 Telephone No.
24hr Contact Name Telephone No.
Reason for Inspection
X ROUTINE COMPLAINT FOLLOW-UP OTHER
Type of inspection
Collection System X Spray Irrigation Sludge
Date of Inspections 02/25/_05
Other
Inspection Summary: (additional comments may be included on attached pages)
Facility manufactures Gatorade and some vinegar. There have been no changes to the production
process since at least the last permit renewal. The treatment plant is operating as permitted.
Monitoring reports (GW-59s, NDARs, NDMRs) are in compliance.
Is a follow-up inspection necessary _yes —X—no
Inspector(s) Name(s)/Title(s) Peggy Finley HT II, Ellen Huffinan ESp II
Telephone No. 704/663-1699 Fax No. 704/663-6040
Date of Inspection 2/25/05

Spray Irrigation Inspection
Permit #WQ0003924
Type
Activated Sludge Spray, low rate
Activated Sludge Spray, high rate
Activated Sludge Drip, low rate
X Lagoon Spray, low.rate
Reuse (Golf Courses).
Recycle /Reuse -
Single Family Spray, low rate
Single Family Drip
Infiltration System
Other
Pg 2
Treatment
Yes Are treatment facilities consistent with those outlined in the current permit.
Yes Do all treatment units appear to be operational. If no, note below.
List any action items necessary for each unit.
Comments:
Lagoon
Primary(check any/all that apply)
Y_ Influent structure (free of obstructions)
_N Banks/berms (are there signs of seepage, overtopping, down cutting or erosion)
N_ Vegetation (is there excessive vegetation on the lagoon bank
Y_ Liner (if visible, is it intact)
N Baffles/curtains (in need of repair)
Y Freeboard (>2 feet from overtopping)
_Y Staff gauge (clearly marked)
N_ Evidence of overflow (vegetation discolored or laying down/broken)
N_ Unusual color (very black, textile colors)
N_ Foam (are antifoam agents used)
N_ Floating mats (sludge, plants, inorganics)
N_ Excessive solids buildup (from bottom)
_Y_ aerators/mixers operational (if present)
_Y Effluent structure (free of obstructions, easily accessible)
Comments:

In
Spray Irrigation Inspection pg 3
Permit #0003924
Secondary Lagoon NA
_ Is the influent structure free of obstructions?
Are there signs of seepage or erosion on the banks/berms?
Is there excessive vegetation on the lagoon bank?
_ Is the liner visible and is it intact?
Are baffles/curtains in need of repair?
Is there >2 feet of freeboard available?
Is there evidence of overflow? Is vegetation discolored or laying downibroken?
Is the lagoon an unusual color (very black, textile colors)?
Is foam visible? Are antifoam agents used?
Are floating mats (sludge, plants) visible?
Are aerators/mixers operational (if present)?
Is the effluent structure free of obstructions, easily accessible?
Influent pump station
X all pumps present, operational
X Bar screen, maintained
Y Bars evenly spaced
Y Back-up power
Y Bypass structure present
Y Free of excessive debris
N Bars excessively corroded
Aeration Basin N/A
aeration pattern even across surface of unit
easily accessed
Comments:
Clarifiers N/A
weirs level scum rack operational
Comments:
Return Pumps N/A
in place operational
easily accessible

1J
Spray Irrigation Inspection
Permit #WQ0003924
Filters N/A
media present
Residuals NA
—storage/treatment
Comments:
Disinfection N/A
If gas, is storage safe?
Is it dual feed system?
air scour operational
How do you know it is working?
If tablets - are tablets present?
clear well free of solids
Effluent Storage
X LAGOON(s) SEPTIC TANK(s) X ABOVE GROUND TANK OTHER
Number of months storage Spill control plan on site _Y
Lagoon Is lagoon lined? YES
Above ground tank Aerated Mixed _X_
In ground tank _NA Aerated Mixed
Drying beds NA Concrete storage pad NA
Disposal (final end use)
Is application equipment in need of repair? No Are buffers adequate? Yes .
Are cover crops the type specified in permit? Yes In need of improvement? No .
Signs of runoff? No . Signs of ponding? Yes.
Comments: —Substantial rainfall had occurred recently. ORC reported that spraying hadn't taken
place for 8 days. Permittee instructed to improve drainage in the area between the two sections of
fields when weather allows.
Y Is the acreage specified in the permit being utilized?
Y Is the application equipment present and operational?
N Are there any limiting slopes in disposal fields?
N Are restrictions for use of these areas specified?
Y Is permit being followed?
N Is there evidence of runoff or drift?
Y Is site access restricted in accordance with permit? If so, how?
Remoteness of application areas; forest buffers

Spray Irrigation Inspection
Permit #WQ0003924
Y Is permit available upon request?
Y Are monitoring reports present: NDMR X NDAR X
Y Are monitoring wells required by the permit present?
Y Are operational logs present?
Y - Are lab sheets available for review?
Y Do lab sheets support data represented on NDMR or NDAR?
N/A Are annual soil reports available?
Y Are operation and maintenance records present?
No Has permittee received any public complaints in the last 12 months?
Comments:
pg 5

� ��� ��
_o�

!.-
Q0
Spray Irritation Inspection check list
Type
Reuse (Golf Courses)
,,Recycle /Reuse
V Lagoon Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Single Family Spray, LR
Single Family Drip
Infiltration System
Other
Treatment
Are treatment facilities consistent with those outlined in the current permit.
Do all treatment units appear to be operational. If no, note below.
List any action items necessary per unit.
Comments
Lagoons
Primary (check any/all that apply)
�.. Influent structure (free of obstructions)
e' anks/berms (are there signs of seepage or erosion)
M Vegetation (is there excessive vegetation on the lagoon bank that makes inspection
difficult)
Liner (visible, is it intact)
_ Baffles/curtains (in need of repair)
Freeboard (>2 feet from overtopping)
Y Evidence of overflow (vegetation discolored or laying down/broken)
Unusual color (very black, textile colors)
AI%4 _ Foam (are antifoam agents used)
nnA Floating mats (sludge, plants)
_ Excessive solids buildup (from bottom)
aerators/mixers operational (if present)
Effluent Structure (free of obstructions, easily accessible)
Secondary
Influent structure (free of obstructions)
Banks/berms (signs of seepage or erosion)
Vegetation (excessive vegetation on the lagoon bank that makes Inspection difficult)
Liner (visible, is it intact)
O

r r
1AU,
bl�
AA/ S'
Y) � ,,
1 i'

Secondary cont.
fj
p
Commes '
Spray pg 2
Baffles/curtains (in need of repair)
Freeboard (>2 feet from overtopping)
Evidence of overflow (vegetation discolored or laying downibroken)
Unusual color (very black, textile colors)
Foam (are antifoam agents used)
Floating mats (sludge, plants)
are aerators/mixers operational (if present)
Effluent Structure (free of obstructions, easily accessible.
Influent pump station
small pumps present
��iar screen, maintained
V�Bars evenly spaced
Bypass structure present
v e Free of excessive debris
Bars excessively corroded
Aeration Basin �17.�
aeration pattern even across surface of unit
easily accessed
Clarifiers �
weirs level
Return Pumps W �G
in place
Filters 0�4�
media present
Sludge
storage/treatment.
Comments
Scum rack operational
Operational
air scour operational
Easily accessable
clear well free of solids

Disinfection
If gas, is storage safe?
Is it dual feed system?
How do you know it is working?
If tablets - are tablets present? _
Spray pg 3
Storage 206; D Gl a
LAGOON(s) SEPTIC TANK(s) �`ABOVE GROUND TANK OTHER ,�"
Number of � moii the storage Spill control plan on site ,2 J, OLD
Lagoon �/ . Is lagoon lined a%
Above ground tank Z_ Aerate j" Mixe
In ground tank Aerated Mixed
Drying beds Concrete storage pad
' c--
Comments S�,v,ke_ /�� �,�--: `Svc � 4� U7JS—
Disposal (final end use)
Is application equipment in need repair? Are buffers adequate?
Are cover crops the type specified in permit? In need of improvement?
Signs of runoff? Signs of ponding?
Comments
Is the acreage specified in the permit being utilized?
Is the application equipment present and operational?
Are there any limiting slopes in disposal fields?
Are restrictions for use of these areas specified?
Is permit being followed?
Is there evidence of runoff or drift?
Are monitoring wells called for in permit present?
Is site access restricted in accordance with permit?
How

Spray pg 4
—�Os permit available upon request?
Are monitoring reports present: NDMR NDAR
r/ Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data represented on NDMR or NDAR? -40
Are annual soil reports available? ��y� 1 15 A��
PtOperation and Maintenance records present? Complete
permittee received any public complaints in the last 12 months?
Comments
,J3,��
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3
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P -dljoNllqq �-)Ivvl7dwoD

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
DAVID GUM
NATIONAL FRUIT PRODUCT CO-WWT
PO BOX 2040
WINCHESTER, VA 22604
Dear Permittee:
IN
February 28, 2000
E N R
tv.(. OEF1'. tup
FIN IRONMENT, HEALTI#9t,
v NATURAL RF-SOURCES
P44R 8 2000
RIVISM] OF E.°1Vf;if KMENTAL KANAGEI,Ep1
UOORESVILLE REGIONAL 9Fltgi
Subject: PERMIT NO. WQ0003924
NATIONAL FRUIT PRODUCT CO-WWT
LINCOLN COUNTY
Our files indicate that the subject permit issued on 1/17/96 expires on 9/30/00. We have not received a
request for renewal from you as of this date.
A renewal request shall consist of a letter asking for permit renewal and four (4) copies of a completed
application. For permitted facilities with treatment works, a narrative description of the residuals management
plan, which is in effect at the permitted facility, must also be submitted with the renewal application.
Applications may be returned to the applicant if incomplete.
The General Assembly passed legislation incorporating renewal fees into the annual fee.
Please be advised that this permit must not be allowed to expire. You must submit the renewal request at
least 180 days prior to the permit's expiration date, as required by the 15 NCAC 2H .0211. Failure to request a
renewal at least 180 days prior to the permit expiration date and/or operation of a facility without a valid permit
may result in the assessment of civil penalties. NCGS 143-215.6A allows for the assessment of Civil penalties
up to $10,000 per violation per day.
The letter requesting renewal, along with the'completed Non -Discharge Permit Application must be sent
to:
N.C. DIVISION OF WATER QUALITY
NON DISCHARGE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If you have any questions concerning this matter, please contact Ms. Kimberly Young at
919 733-5083 extension 574.
Sincerely,
Kim H. Colson, P.E., Supervisor
Non -Discharge Permitting Unit
cc: Mooresville Regional Office
Central Files

JAMES B.-HUNT J
" L E,
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
MOORESVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
March 22, 1999
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, Virginia 22604-1240
Attention: James C. Zombro, Jr.
RE: Groundwater Compliance Monitoring
National Fruit Product Company
Lincolnton, NC Plant
Permit No. WQ0003924
Wastewater Spray Irrigation
Dear Mr. Zombro:
A review of the October 1998 compliance monitoring revealed elevated
concentrations of total organic carbon (TOC). Further review of previous TOC
sampling indicates that concentrations in some of the monitroing wells have been above
10 milligrams per liter (mg/L) over the last few sampling events. Permit condition IV.
1. requires additional sampling and analysis when any downgradient well shows TOC
concentrations above 10 mg/L.
For each downgradient well that shows TOC levels above 10 mg/L at the June
sampling event, you are instructed to collect and analyze a sample for semivolatile
organic compounds using Method 625. Please submit copies of the laboratory results
along with the compliance monitoring reports (GW-59). ,
Should you have any questions, please call me at 704/663-1699, ext. 238.
Sincerely,
r� _14�a"
Margaret A. Finley
Hydrogeological Technician
MAF/national fruit.ltr
919 NORTH MAIN STREET, MOORESVILLE, NORTH CAROLINA 28115
PHONE [phone] FAX [phone]
AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER- 50% RECYCLED/10% POST -CONSUMER PAPER

State,of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
2/5/98
Verlis E. Miller
National Fruit Product Co, Inc. - Lincolnton
P.O. Box 2040
Winchester, VA 22604-1240
Lincolnton
Dear Verlis E. Miller,
FEB & 1990
cats t$;r,r:^:^•r sr z,;•.t,_
Subject: Monitoring'Data Accuracy
Permit Number: WQ0003924
National Fruit Product Co, Inc. -
Lincoln County
The purpose of this letter is to address reporting deficiencies with your monthly spray
irrigation report. Currently the State utilizes two (2) forms that have been developed to compile
all your required reporting information. These forms are the NDAR and NDMR. It is important
to use these forms properly and please remember that both forms must be submitted each month.
Regarding the NDMR, the first four columns; "Operator Arrival Time"," Operator Time
on Site","ORC on Site" and "Daily Rate (Flow) into Treatment System" must be reported
monthly. If you do not report flow on the NDMR form, your monthly average calculated for the
year will be inaccurately inflated. Required reporting parameters listed in the subject permit must
be submitted, three times a year, as -regulated by the permit. This figure must also be measured
correctly; your system must have flow meters or some measurement device that allows you to
read the flow of wastewater into your treatment system. This is before diluting, processing,
aerating, etc... Also Daily Rate must be reported in the units of measurements stated on the
monitoring form. All parameters not preprinted on the NDMR form must be filled in by the
permittee and must be reported in the units stated in the subject permit.
Regarding NDAR forms, fields must be consistently identified and cover crops listed
when reports are submitted each month. Each field must also be identified with acreage and
cover crop listed each time you submit reports with completed data. Please record 0.0 inches
Monthly Loading if there is no activity.
Nothing in this letter should be taken as absolving you of your responsibility to abide by
all relevant NC Statutes and Regulations.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

State of North Carolina
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
Verlis E. Miller
National Fruit Product Co, Inc.
P.O. Box 2040
Winchester, VA 22601
October 14, 1994'
AVIF
T4
IL
1�EHNR
N.C. DEPT. OF
ENVIRONMENT, HEALTH,
& NATURAL RESOURCES
OCT 17 199A
DIVISION OF ENVIRONME[ITAL L'RMAKI<tEM
RQORESVILLE REGIONAL OFFICE
Subject: Non Discharge Wastewater Monitoring Report
Forms (NDMR-1) and (NDMR-1.1)
Non Discharge Application Rate Form (NDAR-1)
National Fruit Product Co, Inc.
Permit No. WQ0003924
Lincoln. C-ounty
The purpose of this letter is to distribute pre-printed reporting forms to you as a spray irrigation
permit holder. Enclosed are two (2) pads. Each pad contains fifty (50) copies of one of the two (2)
forms which must be used when submitting data required by your permit. The forms have been
modified since February 28, 1994, when the first versions of the forms were distributed. The
enclosed pads of forms replace the forms currently used for reporting.
The Non Discharge Wastewater Monitoring Report Forms (NDMRs) are to be used to report the
results of the wastewater parameters monitored during a month. Your permit specifies the months to
monitor, the parameters to be monitored, and the frequency results must be submitted. The form
NDMR-1 has the six (6) most common parameters already entered with space for five (5) additional
parameters which may be required by your permit. These forms are similar to the Division of
Environmental Management's (DEM's) pre-printed "EFFLUENT" forms already in circulation for
use by the NPDES permitted facilities. However, please note the NPDES forms must not be
substituted for the Non Discharge forms since it will lead to confusion when the form is received by
DEM.
The form NDMR-1.1 has eleven (11) blank spaces and can be used instead of form NDMR-1 if it
better suits your monitoring requirements. This form is not enclosed, but you may obtain a pad by
contacting Lou Polletta of our staff at 91gn33-5083, ext. 536.
Since February 28, 1994, the NDMR-1 and NDMR-1.1 forms have been modified to specify that
the "Daily Rate Flow into the Treatment System" be reported and the sample be taken "at the point
prior to irrigation." The effluent from the treatment system is not requested on the NDMR forms.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Non Discharge Forms
WQ0003924
Page 2
The Non Discharge Application Report Form (NDAR-1) is to be used to report the amount of
wastewater sprayed during a month. The form has space for daily information for two (2) separate
fields. If a facility has more than two fields, you must submit more than one form. The
information requested on the form is information already required to be tracked as a condition of the
permit.
The NDAR-1 form has also been modified to include formulas which should provide all the
information required to be completed. Please note on the NDAR-1 form that daily loadings from
one month are no longer required to be carried over to the next month since an "Average Weekly
Loading" formula is provided which is calculated from one month's "Monthly Loading." Also the
"Year -To -Date Loading" has been replaced by a "12 Month Floating Total" for which a formula has
been provided.
These forms must be used starting in November 1994 when spray irrigation data is submitted to
DEM. Please note the forms have information on both sides and must be signed by both the
permittee and the operator in responsible charge. An original and two copies must be sent to the
address in the lower left-hand corner of these forms. This address should be the same as the one
listed in your permit, but may have changed since your permit was issued.
Some facilities have developed and are using their own self monitoring forms. If your facility
wishes to request approval to continue using its own forms, this request may be made when you
submit your next monitoring report. Before requesting approval, please make sure your forms
contain all the information required on DEM's forms and have the same headings and signatures as
DEM's forms. Depending on the number of requests received, DEM will attempt to respond within
thirty (30) calendar days.
If there is a need for any additional information or clarification on these reporting forms, please
do not hesitate to contact Lou Polletta of our staff at 91gn33-5083, ext. 536.
Sincerely,
. vC�
Dennis R. Ramsey
Assistant Chief for Operations
cc: Mooresville Regional Office - Water Quality
Facilities Assessment Unit
Central Files
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

From: f&
Division:�-
Section: W a
/ WAj
0 •
0A!
SL
Fm
NCDENR
North Carolina Department of
Environment and Natural Resources
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Phone; 704/663-1699
Fax; 704/663-6040
Date: D o
To: L Q
UU
Fax Number:j'7 I_g- Number of pages (including cover):
Message:
For more information, visit the DENR web page at www.ehnr.state.nc.us/EHNR/

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NC
Bill Holman, Secretary
Kerr T. Stevens, Director
DAVID COCO
NATIONAL FRUIT PRODUCT CO -A S
PO BOX 2040
WINCHESTER VA 22604
Subject: Rescission of State Permit
Permit No. WQ0012567
NATIONAL FRUIT PRODUCT CO -A S
LINCOLN County
Dear DAVID COCO:
April 11, 2000
1
� •
NORTH CAROL DEPARTMENT OF
ENVIRONMENT AN
D NATURAL RESOURCES
Reference is made to your request for rescission of the subject State Permit. Staff of the Mooresville Regional
Office have confirmed that this Permit is no longer required. Therefore, in accordance with your request, State
Permit No. WQ0012567 is rescinded, effective immediately.
If in the future you wish to again operate a nondischarge wastewater treatment sytem, you must first apply for
and receive a new State Permit. Operating a wastewater facility without a valid State Permit will subject the
responsible party to a civil penalty of up to $10,000 per day.
If it would be helpful to discuss this matter further, I would suggest that you contact Rex Gleason - Water
Quality Regional Supervisor, Mooresville Regional Office at [phone].
Sincerely,
fi't/� r/44�
Kerr T. Stevens
cc: LINCOLN County Health Department t�l oresvil e - at ity R�gional.S.up��i�sor wattarclrmtents
�on Discharge Branch -Kim Colson
Operator Training and Certification
Non Discharge Compliance/Enforcement Unit- w/attachments
Central Files - w/attachments
Fran McPherson, DWQ Budget Office
Mailing Address: Telephone (9I9) 733-5083
DENR
1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 State Courier #52-01-01
An Equal Opportunity /Affirmative Action Employer
50% recycled / 10%post-consumer paper
http://h20. enr.state.nc. us
Location:
512 N. Salisbury St.
Raleigh, NC 27699-1617

State of North Carolina
Department of Environment,
Health and Natural Resources
Water Pollution Control System Operators
Certification Commission
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Steve W. Tedder, Chairman
June 13, 1996
National Fruit Product Co, Inc. - Lincolnton
Verlis E. Miller
P.O. Box 2040
Winchester, NC VA 22604-1240
Dear Mr. Miller:
F.M?FA
00
4ia.
�EHNR
TD—T-IFT. O
JUM R t"' 1;;"16
"��•'s' � ;;tu;iln� 'U�jl�
Subject: Classification of Spray Irrigation Systems
National Fruit Product Co, Inc. - Lincolnton
Permit # WQ0003924
Lincoln County
The Water Pollution Control System Operators Certification Commission adopted Rule
15A NCAC 8C .0800, Classification of Spray Irrigation Systems, effective July 1, 1993. In order
to ensure the proper operation and maintenance of these systems, this Rule requires that all facilities
permitted for the spray irrigation of wastewater be classified as spray irrigation systems. As required
by Rule 15A NCAC .0202(b) and the subject permit, a certified operator and back-up operator of the
appropriate type and grade must be designated for each classified facility.
You are hereby notified by copy of this letter that the Water Pollution Control System
Operators Certification Commission has classified the subject facility as a Spray Irrigation System
effective August 31, 1996. Please complete and return the enclosed designation form to this office
by September 30, 1996. Failure to designate a certified operator of spray irrigation systems and
back-up operator is a violation of the permit issued for this facility. In addition, if the subject spray
irrigation system includes an activated sludge process, you are also required to designate a Grade Il
or higher Wastewater Treatment Plant Operator for this component of your system.
Thank you for your cooperation. If you need assistance or have any questions concerning
this requirement please call Ron Ferrell at 919-733-0026. Questions concerning application for
certification as a Spray Irrigation Operator and training opportunities should be referred to Dan
Cathey at this same number.
Sincerely,
Pflgina�l. Signed Rs
.4 TF'VE W. TEMI �i' P
Steve W. Tedder
Enclosure
cc: Mooresville Regional Office
Central Files
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

PF'. i.
h ►e/
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 24, 1996
Mr. Verlis E. Miller, V.P.-Manufacturing
National Fruit Product Company, Inc.
P.O. Box 2040
Winchester, VA 2260471240
Subject: Permit No. WQ0003924
National Fruit Product Co.
Lincoln County, NC
Dear Mr. Miller:
Our records show that Permit No. WQ0003924 was issued on
January 17, 1996 for your non -discharge wastewater treatment
facility. The purpose of this letter is to advise you of the
importance of the Permit and the 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 requested that you and
other appropriate persons thoroughly read the Permit.
The Permit sets forth specific performance standards,
operation and maintenance requirements, monitoring requirements,
plus general conditions applicable to non -discharge permits.
Failure to comply with the terms and conditions of the Permit
subjects the Permittee to enforcement action pursuant to Section
143-215.6 of the North Carolina General Statutes in the form of
civil or criminal penalties. -
Please note that the subject Permit expires on September
30, 2000. Part VI, No. 8 of the Permit requires that a renewal
request be submitted at least six (6) months prior to
expiration. Also the Permit is non -transferable, until such time
that the Permittee has requested a name change to'the new
Permittee.
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 5010 recycled/ 10% post -consumer paper

As mentioned previously; the purpose of this letter is to
advise you of the importance of your Permit. Please read the
Permit and contact this office at 704/663-1699 in Mooresville if
you have any questions or need clarification. We look forward
to providing any assistance.
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor
MLP

State of North Carolina
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
OF
G � r' ��,!��Txbruary 28, 1994
s. % ti.
Verlis E. Miller 61
National Fruit Product Coic:' t,Ed
P.O. Box 2040
Winchester, VA 22601
Subject:
Dear Mr. Miller:
00
EDEHNR
Non Discharge Wastewater Monitoring Report
Forms (NDMR-1) and (NDMR-1.1)
Non Discharge Application Rate Form (NDAR-1)
National Fruit Product Co, Inc.
Permit No. WQ0003924
Lincoln _ County_ =
The purpose of this letter is to notify all spray irrigation permit holders the Division of
Environmental Management (DEM) has developed three (3) forms which are to bei used when
submitting data required by your permit. Previously, DEM has been accepting a variety of
reporting forms, but now these forms have been developed in an attempt to standardize the format
of reporting results. The enclosed forms replace the forms currently used for reporting.
The Non Discharge Wastewater Monitoring Report Forms are to be used to report the results of
the wastewater parameters monitored during a month. Your permit specifies the months to monitor,
the parameters to be monitored, and the frequency results must be submitted. - The =form NDMR-1
has the six (6) most common parameters already entered with space for five (5) more parameters which
may be required by your permit. The form NDMR-1.1 has eleven (11) blank spaces and can be used
if it better suits your monitoring requirements. These forms are similar to DEM's pre-printed
"EFFLUENT' forms already in circulation for use by the NPDES permitted facilities. However,
please note the NPDES forms may not be substituted for the Non Discharge fo=, - since it will lead
to confusion when the form is received by DEM.
The Non Discharge Application Rate Form NDAR-1 is to be used to report. the amount of
wastewater sprayed during a month. The form has space for daily information for1-two(2) separate
fields. If a facility has more than two fields, you must submit mom. than one. form; The information
requested on the form is information already required to be tracked as_ a condition of the permit.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 T61,9phone 919;!733-7015 -. FAX9�1;9-7332496
An Equal Opportunity Affirmative Action Employer 50% recycledX`l G% post-consumer_papers._

_ II -
Non Discharge Forms -
WQ0003924 t
Page 2
Enclosed are three (3) copies of each form. Example forms are included for your guidance.
These forms should start being used immediately when spray irrigation data is submitted to DEM.
Please note the forms have information on both sides and must be signed by both the permittee and
the operator in responsible charge. An original and two copies must be sent to the address in the
lower left-hand corner of these forms. This address should be the same as the one listed in your
permit, but may have changed since your permit was issued.
Within the next sixty (60) to ninety (90) calendar days, pads of pre-printed forms will be sent to
all spray irrigation permittees. These forms are being printed now, so please maintain a blank copy
of each form on site until pads are received. _
Some facilities have developed and are using their own self monitoring forms. If your facility
wishes to request approval to continue using its own forms, this request may be made when you
submit your next monitoring report. Before requesting approval, please make sure your forms -
contain all the information required on DEM's forms and have the same headings and signatures as
DEM's forms. Depending on the number of requests received, DEM will attempt to respond within
thirty (30) calendar days.
If there is a need for any additional information or clarification on these reporting forms, please
do not hesitate to contact Lou Polletta at 91gn33-5083, ext. 536.
Sinc/e%rely,
Steve W. Tedder, Chief
Water Quaity Section
cc: Mooresville Regional Office -Water Quality
Facilities Assessment Unit
Central Files
0:

t MEMORANDUM
TO: Samar Bou-Ghazale
FROM: Rick Leonhardt
Bill Dembicki
SUBJECT: Waste Water
r,INViRONFIVInlN`P, HRAT,.T,
CAA NATURAI. T 1,+,'e-•;... ; DATE: 2-17-94
On Friday, February 11, 1994, our waste water tank had approximately
240,000 gallons and we started to divert plant water to the lagoon. On
Saturday, February 12, 1994, we sprayed approximately 60,000 gallons to
the irrigation field leaving a balance of 180,000 gallons.
Monday, at 8:00 A.M., we discovered we had approximately 80,000 gallons
remaining. Between Saturday evening and Monday morning we lost approximately
100,000 gallons of water. Investigations found that Larry Reep, the operator
for Saturday, February 12th.,had forgotten to shut off the irrigation' valves
to the field causing lines to syphon after pumps shut off for approximately
41 hours at a rate of approximately 2,450 gallons per hour or 41 gallons
per minute.
Appropriate disciplinary actions will be taken.
C.C.: Greg Hofe
Jim Zombro

i
LaD
�ptiESViILE wvl is #lfr1�E
NATIONAL FRUIT PRODUCT COMPANY, INC. P.O. BOX 2040 WINCHESTER, VIRGINIA 22601 TEL[phone]
ADDRESS REPLY TO TELEPHONE
P. O. Box 916 AREA CODE 704
LINCOLNTON, N.C. 28092 735-2531
Samar Bou-Ghazale
Environmental Engineer 1
D.E.H. Water Quality Section
Mr. Bou-Ghazale
Attached is an explanation of what happened on the morning of February 14,
1994. The attached explanation wasmalso forwarded to our corporate office
in Winchester, Va.
If you have any questions reguarding this matter do not hesitate to
call. My number is 704-735-2531 Ext. 15.
Thank You
O.R.C.

" NATIONAL FRUIT PRODUCT COMPANY INC.
P.O. Box 2040, Winchester, Virginia 22604-1240
703-662-3401 FAX [phone]
Mr, Shamar Bou-Ghazale
Environmental Engineer I
Division of Environmental Management
Water Quality Section
Mooresville, NC 28115
Dear Mr. Bou-Ghazale:
February 8, 1994 i\ pFP T . Or
EI�1VII�. ?'• i; .i`i'i' iTAT TII ,
Fe
C1TJ� �15
FL-3 1 4 i994
hip"�jxGLr4 H
Ei-L i;,-unit.
We have enclosed the information that you requested concerning the operation of our Lincolnton, North
Carolina spray irrigation wastewater facility. Enclosed are report forms showing the gallons of
wastewater produced by the plant operation, the gallons of wastewater irrigated, and other operational
data; we will continue to send these on a monthly basis.
The wastewater flow meter recalibration was performed on December 7, 1993 by Control Elements
Company of Charlotte, North Carolina.
There has been significant reduction of the volumes of wastewater generated by the plant processing
operations during the past several months and there will be additional reductions as our water
conservation and wastewater reduction program continues.
If you have any questions or need any additional information, please contact us.
Sincerely,
James C. Zombro, Jr.
Manager - Environmental Affairs
NATIONAL FRUIT PRODUCT COMPANY, INC.
cc: V. E. Miller
Greg Hofe
Jack Ross

NATIONAL FRUIT PRODUCT COMPANY, INC. - LINCOLNTON, NC PLANT
SPRAY IRRIGATION REPORT - PERMIT NO. WQ0003924
MONTH: December YEAR: 1993 OPERATOR: R. Leonhardt
DAY
GALLONS
PRODUCED
GALLONS
IRRIGATED
FIELD NO.
HOURS
WEATHER
COND.
FIELD MAINT.&
COMMENTS
1
71,181
59,811
6
6
Clear
2
102,691
59,367
1
6
P. cloudy
3
65,234
59,704
2
6
Clear
4
51,233
Rain 0.7"
5
48,931
59,596
3
6
Clear
6
61,480
59,983
4
6
Clear
7
71,645
59,733
5
6
Clear
8
66,777
59,873
6
6
Clear
9
77,630
59,917
1
6
Clear
10
83,984
Rain 0.2"
11
56,064
59,942
2
6
Clear
12
56,064
Clear
13
61,587
59,907
3
6
Clear
14
18,325
34,946
4
3.5
Cloudy
15
15,684
Rain 0.7"
16
24,912
19,969
5
2
Cloudy
17
17,569
59,977
6
6
Clear
18
10,258
59,812
1
6
Cloudy
19
8,678
59,417
2
6
Clear
20
47,621
59,837
3
6
Cloudy
21
76,896
59,856
4
6
Cloudy
22
22,315
59,642
5
6
Cloudy
23
28,418
Snow 2"
24
0
59,798
6
6
Clear
25
0
59,731
1
6
Clear
26
0
Clear
27
46,603
59,532
2
6
Clear
28
46,823
39,821
3
4
Cloudy
29
51,230
Rain 0.7"
30
36,587
59,634
4
6
Clear
31
32,769
59,967
5
6
Foggy
TOTAL
1,359,189
1,349,772
135.5
Rain 2.3"

NATIONAL FRUIT PRODUCT COMPANY, INC. - LINCOLNTON, NC PLANT
SPRAY IRRIGATION REPORT - PERMIT NO. WQ0003924
MONTH:-JanuaryYEAR:_1994 OPERATOR: R Leonhardt
DAY
GALLONS
PRODUCED
GALLONS
IRRIGATED
FIELD NO.
HOURS
WEATHER
COND.
FIELD MAINT.&
COMMENTS
1
0
Rain 0.3"
2
0
Cloudy
3
19,459
Rain 0.2"
4
43,145
Snow,rain,
sleet 0.6"
5
47,842
59,904
6
6
Clear
6
15,580
59,542
1
6
Cloudy
7
39,400
59,823
2
6
Cloudy
8
39,400
Cloudy
9
0
Clear
10
50,357
59,877
3
6
Clear
11
51,414
19,959
4
2
Cloudy
12
72,713
Rain 0.4"
Cleaned apple pit
13
50,828
59,994
5
6
Clear
14
42,910
59,831
6
6
Clear
Cleaned cooler pit
15
42,910
59,696
1
6
Clear
16
0
Cloudy
17
41,222
Sleet,rain
0.2" ,
18
16,701
49,747
2
5
Clear
19
17,673
Clear
Ground frozen
20
54,408
59,793
3
6
Clear
Cleaned cooler pit
21
19,625
Clear
22
19,625
Clear
23
0
Clear
24
43,323
59,854
4
6
Clear
25
62,065
59,797
5
6
Clear
Cleaned apple pit
26
56,931
59,933
6
6
Cloudy
27
56,582
Rain 0.7"
28
37,120
59,806
1
6
Cloudy
29
37,120
59,911
2
6
Cloudy
30
0
Cloudy
31
83,900
59,598
3
6
Cloudy
Cleaned cooler pit
TOTAL
1,062,253
907,065
91
3.4" Preci .
Excess storage
capacity available

703-662-3401 FAX [phone]
January 12, 1994
Mr. Samar Bou-Ghazale
Environmental Engineer I
Division of Environmental Management
Water Quality Section
Mooresville, NC 28115
Dear Mr. Bou-Ghazale:
N.C. DEPT. OF
RNVIRO'VVENT, HEALTH ,
,&NATIi12AL RESOURCES
MUN OF
pwRE'ME 6.EGIM OFFICE
We are writing per our phone conversation of January 3, 1994 concerning the wastewater operations at
our Lincolnton, North Carolina plant, and plans to insure compliance with Permit No. WQ 000 3924.
We have taken the following steps to reduce the volume of wastewater generated by the apple processing
operations in the plant:
Removal of all regular water hoses in the plant and only allow use of the high pressure -low
volume clean-up system.
2. Repaired two heat exchangers that were leaking water to the condensate return system causing
the Boiler Room condensate tank to overflow into the plant wastewater system.
3. Adjusted level controls in two cooling towers to prevent overflow of water into the plant
wastewater system.
4. Keep as much product off floor as possible -spillage from fillers, sauce finisher, peelers, etc., this
will reduce the need to wash floors as often.
5. Instead of washing solid material such as apple sauce apple waste under peelers, etc., down the
drain, sweep and shovel up this material to be hauled out as solid waste.
6. Repair and eliminate all leaks in water lines, product lines, product coolers, condensate lines, etc.
7. Take wastewater meter readings at end of first, second, and third shifts daily to pinpoint
wastewater generated on each shift and to determine high usage periods.
8. Reduced water volumes used on glass washers.
The following items will be implemented by August, 1994:
1. Upgrade the CEP tank cleaning system; water used for tank cleaning will be reduced by 50 to
60%.
2. Develop a system for reuse of apple juice concentrator condensate water; may be used in the
apple pressing operation, raw apple washing, and plant clean-up.

.{
The target for wastewater generation is 50,000 gpd for peak operation of the plant. The wastewater
generated during the first week in January, 1994 averaged 34, 137 gpd with vinegar and apple juice
production operating. Apple sauce production will operate during the month of February and should
generate no more than an additional 15,000 gpd of wastewater.
We believe that water conservation and wastewater reduction will enable us to comply with the terms of
Permit No. WQ 000 3924 and not require expansion of the spray irrigation facility at this time.
If you have any questions or need any additional information, please do not hesitate to contact us.
VEM:bfh
file: winword\zombro\wastewtr.lin
Sincerely,
Z�s�Eiller
Vice President -Manufacturing
NATIONAL FRUIT PRODUCT CO., INC.

I GL l'tLJ
lie
L
NATIONAL FRUIT PRODUCT COMPANY, INC. P.U. BOX 2M WINC RESTER, VIRUINIA 22601 'I ELU031fM" '?
Adonmas RLPLY To TCLEPHONC
p. O. Box 916 AnCA Coca 704
LimcoLwoN, N.G. 26002 y36•Z531
A'i"1'N:0.
F'Iium :
PAGES TO FOLLOW: _
Does not include cover shoet)
If you have any/ problems r•ecc iv I rrr' t.t, i r, l.raLnsltri r:r:i Orr,
voice request to FAX 1—"tUli—'f i�-.i'f'ly c�: l+lrc rcr l.1rc► ol'!'Ic�r� rrl, .I.—'t()tr—'t i`���'�.�1
extension #13.

WHITE
HousE
NATIONAL FRUIT PRODUCT COMPANY, INC. P.O. SOX 2040 WINCHESTER, VIRGINIA 22601 TEL[phone]
TELEPHONE
ADOnng REPLY io Anr-A CODE 704
P. 0. Bvx 016 733.2531
LINCOLHTON, N.C:. 28002
Samar Bou-Ghazale 11/19/93
Environmental Engineer I
DEM, Water Quality Section
Mooresville, NC 28115
Mr. Bou-Ghazale;
On Friday, November 5, 1993 we. experienced inclement weather in the A.M.
hours. Not allowing us to utilize the waste irrigation system, however
the plant was scheduled for a, full three shif•i., operation. The third
shift being scheduled for an ext,erlsive sanitary cleaning
causing
avoid the
abundance oi' waste water that evening. spray
storage tank from overflowing into Carpenter's Creek. We sprayed approx-
imately 60,000 gallons. The following day Saturday, November 61 1993 we
found ourselves in a similar situation and decided to spray again to avoid
a spill to the creek. We sprayed 59,772 gallons on zone 3 in 6 hours, and
then 30,000 gallons additional on zone 3 and 30,000 gallons on zone 4
during the next 6 hours. According to our calculations, the total volume
applied to zone 3 for the week was 89,772 gallons or 0.83 inches per acre;
the total volume applied to zone 4 for the week wtis 89,768 gallons or 0,87
inches per acre. This is within the maximum application rate of 0.87
Inches per acre per week as stated in our permit.
Exactly how we arrived at this com dition is unknown at this time. However,
there had been irrigation field attendant problems in the past and
discipline was imposed. The responsibility has since been removed from
the irrigation field attendant and assigned to the o.E.C. Also, we
experienced electrical failure to the system caused by a Faulty 250 AMP
inch
breaker which has been repaired. and a pump motor failor.due t have since
water line break causing water to short out a pump mo
been repaired. As stated above corrective action hRis been taken in hopes
to eliminate any future problems.
It is not the company's intention to disregard or violate our permit,
howevery we felt at the time it was imperative to take the measures we did
a5 not to create any 5p311 that would reach Carpenter's Creek.

Enclosed you will find copies of all records pertaining to the time and
days of the occurance along; with the operators discipline records. At the
time of the incident we did record all spraying s.ctivities in our Monthly
Journal to submit as ususal at the months end.
We did believe that we were in compliance with our permit since the application
rates did not exceed the limit of 0.87 inches per acre per week. We were
prepared to submit this information in our monthly report. We apoligize for
any inconvenience or violation of our permit and can assure you that if in
the future there are any deviations from the permit you will be notified
immediately. Any further information needed please advise.
Sincerely,
R. D. Leonhardt
National Fruit Product Co., Inc.
Lincolnton, NC 28092

PLANT
NATIONAL FRUIT PRODUCT CO., INC.
DISCIPLINARY ACTION
DATE j o l 19.�J
NAME.
DEPARTMENT ._tis�.v3�U.--_—�`__-
WARNING!
YOU ARE 1-IEREWITH WARNED IN THE FOLLOWING PARTICULARS, AND IF IMPROVEMENT
IS NOT SHOWN- SUSPENSION OR DISCHARGE MAY FOLLOW.
FOREMAN
r
323

PLANT
NATIONAL FRUIT PRODUCT CO., INC.
DISCIPLINARY ACTION
D AT E
z 19g3
NAME _ t DEPARTMENT � _ �t
i ENT _..i'�}H�a+��.�. ..�t—tip �-- NUMBER--2 �
WARNING!
H WARNED 1N THE FOLLOWING PARTICULARS. AND IF IMPROVEMENT
r YOU ARE HERfiWIT
a IS NOT SHOWN. SUSPENSION OR DISCHARGE MAY FOLLOW.
D _`- • C
n - -
o _ _...
3�3

PRAY IRRIGATION REPORT - PEnMi,r ii4. WQ0003924 •.; - -
YEAR: T OPERATOR:
DAY GALLONS FIELD HOURS WEATHER COVER COMMENTS
IRRIGATED AREA IRRIGATED CONDITIONS CROP
NO. MAINT.
4 -• ..
5 4 U)
17,4
1 1V
1:3 O a �`
r17
]. 9
21
22
23 24 - ..._
27 ---•-
28 -
2 9
r.
30 �--
EEAt _ = =.... .

MEMO
DATE-
SUBJECT:
From:
North Carolina Department of Environment,
Health, and Natural Resources eo printed on Recycled Paper

State of North Carolina
Department of Environment, Health, and Natural Resources
- Mooresville Regional Office
James , B . Hunt, Jr . , Governor Albert F. Hilton, Regional Manager
Jonathan B. Howes, Secretary
DIVISION OF ENVIRONMENTAL MANAGEMENT
January 15, 1993
Mr. James C. Zombro, Jr.
National Fruit Product Co., Inc.
Post Office Box 2040
Winchester, Virginia 22601-1240
Subject: Well Sampling Results
National Fruit Product Co., Inc.
Permit No. WQ0003924
Lincoln County, N.C.
Dear Mr. Zombro:
On December 29, 1992 the Groundwater Section of the Division
of Environmental Management reviewed the monitor well sampling
results from the October sampling of the monitor wells at the
subject site. The sampling results indicate that a number of
constituents exceeded established limits.
In your cover letter you indicated that proper sampling .
techniques were not utilized and that the wells were going to be
resampled. To date, this Office has not received the results of
the re -sampling. Please submit.the results of the re -sampling,
including VOC analysis, by February 5, 1993.
Should you have any questions, please contact me at (704)
663-1699.
;S,E : s c
Sincerely,
X
David Eudy
Hydrogeological Technician
P.O Box 950, 919 North Main Street, Mooresville, N.C. 28115-0950 • Telephone [phone] • FAX 704b63-6m
An Equal Opportunity Affirmative Action Employer

0
3 .swc N. C. DEPT. 07 NATiTI2AI,
._
<..D
_
f E 0, 1 1 1991
State of North Carolina
Department of Environment, Health, and Natural ResdUj bces E.::::.:: ' ;;srL I.'",il,1GD'1EPlT
Division of Environmental Management
14L0ESSIU E K-41a :IAL OFFICE
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
Wiliam W. Cobey, Jr., secretary
February 7, 1991
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, VA 22601
Attn.: Mr. Verlis E. Miller
Vice President-ManufactVring
SUBJECT: Permit No. WQ0003924
Lincolnton, NC Plant
Wastewater Spray Irrigation Facility
Lincoln County:
Dear Mr. Miller:
George T. Everett, Ph.D.
Director
In accordance with the policy of the Division of
Environmental Management to ensure the good quality of
North Carolina's groundwater, the referenced Permit
requires several activities related to groundwater
monitoring. The following guidelines are presented to
assist you in complying with those requirements. If you
have any questions concerning these matters, you should
contact Barbara Christian at the address shown below to
discuss the requirements relevant to your specific facility:
MOORESVILLE REGIONAL OFFICE
919 N. Main Street
Mooresville, NC 28115
[phone]
Condition No. IV-1: The installation of monitor wells
as approved by the Department's Mooresville Regional
Office.
THE MONITOR WELLS MUST BE DEVELOPED TO A TOTAL
SUSPENDED SOLIDS LEVEL NOT EXCEEDING 5 mg/L.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]

I
Prior to accepting a new well you should verify that
the driller has developed the well to an acceptable
level as stated above. Failure to do so may result in
samples containing excessive amounts of suspended
solids, due to improper well development, which could
lead to analysis and compliance problems. The North
Carolina Well Construction Standards 15A NCAC 2C .0105
require that a Permit be issued prior to construction
of any monitoring well, and therefore permit
application forms are attached for your convenience.
To facilitate the permitting process, you should
contact the appropriate Regional Office personnel as
described above, to discuss the location and
construction requirements relevant to your specific
facility.
NOTE: Please disregard the above if installation of
approved monitoring wells has already been
completed.
Condition No. IV-2: Sampling of the referenced wells
on the schedule and for the constituents listed
below:
SCHEDULE: The monitor wells must be sampled
initially after construction and
thereafter every February, June and October.
CONSTITUENTS:
NO (10.0) Total Coliforms (1/100ml)
Chloride (250.0) TDS (500.)
Ammonia Nitrogen TOC
Water Level Conductivity
Total Suspended Solids
pH (6.5-8.5 standard units)
Volatile Organic Compounds (in October Only
by Method 1 or 2 below)
Method 1: Method 6230D (Capillary - Column),
"Standard Methods For The
Examination of Water and
Wastewater", 17th ed., 1989
Method 2: Method 502.2 "Methods For The
Determination Of Organic Compounds In
Drinking Water", U.S. EPA - 600/4-88/039
The measurement of water levels must be made prior to
sampling for the remaining parameters.

s
The numbers in parentheses represent the maximum
allowable concentrations in groundwater for the
various analytical parameters, as specified in 15A
NCAC 2L [Groundwater Classifications and Standards].
Unless otherwise specified, the units for these
concentrations are expressed as milligrams per liter.
If any volatile organic compounds are detected by
method 6230D, or the equivalent method 502.2, then EPA
methods 604 and 611 must also be run to detect other
organic.compounds which may be present. The results of
all analyses specified in the monitoring requirements,
including 604 and 611 if required, must be submitted
simultaneously.
If TOC concentrations greater than 10 mg/l are
detected in any downgradient monitoring well,
additional sampling and analysis must be conducted
to identify the individual constituents comprising this
TOC concentration. If the TOC concentration as
measured in the background monitor well exceeds 10
mg/l, this concentration will be taken to represent the
naturally occuring TOC concentration. Any exceedances
of this naturally occuring TOC concentration in the
downgradient wells shall be subject to the additional
sampling and analysis as described above.
A supply of forms (GW-59) on which the analytical
results must be reported are attached. Instructions are
provided on the reverse of the white copy of each 4-part
form. The analytical results should be sent to the address
shown at the top of the form and are due in our office no
later than the last working day of the month following
sample collection.
Additional forms will be provided upon receipt of the
attached form GW-59 RO.
FOR ANY ADDITIONAL INFORMATION RELATED TO REQUIREMENTS
FOR GROUNDWATER QUALITY PROTECTION, PLEASE REFER TO
YOUR PERMIT.

A
If you have any questions, please do not hesitate to
contact me at [phone].
Attachments
cc:.
Bzar„karGx�ri s t i an
7Ce tral Files
Compliance Monitoring Files
CBW:hl:Miller
Sincerely,
C. Brian Wootton
Hydrogeology Technician
Permits and Compliance
Groundwater Section

State of North Carolina
Department of Environment, Health, and Natural Resources
Mooresville Regional Office
James G. Martin, Governor Albert F. Hilton, Regional Manager
William W. Cobey, Jr., Secretary DIVISION OF ENVIRONMENTAL MANAGEMENT
January 3, 1991
Mr. Verlis E. Miller
Vice President - Manufacturing
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, Virginia 22601
Subject: Permit No. WQ0003924
(Renewal of Permit No. 3917R2)
National Fruit Product Co., Inc.
Lincolnton, NC Plant
Wastewater Spray Irrigation Facility
Lincoln County, NC
Dear Mr. Miller:
Our records show that Permit No. WQ0003924 was issued on
December 31, 1990 for your non -discharge -wastewater treatment
facility. The purpose of this letter is to advise you of the
importance of the Permit and the 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 requested that you and
other appropriate employees thoroughly read the Permit.
The Permit sets forth specific performance standards,
operation and maintenance requirements, monitoring requirements,
plus general conditions applicable to non -discharge permits.
Failure to comply with the terms and conditions of the Permit
subjects the Permittee to enforcement action pursuant to Section
143-215.6 of the North Carolina General Statutes in the form of
civil or criminal penalties.
Please note that the subject Permit expires on December 31,
1995. Part VI. 9. of the Permit requires that a renewal request
be submitted at least six (6) months prior to expiration. Also
the Permit is non -transferable until such time that the
Permittee has requested a name change to the new Permittee.
919 North Main Street, Mooresville, N.C. 28115 • Telephone [phone] • FAX [phone]C40
An Equal Opportunity Affirmative Action Employer

-1,AW,
P
Mr. Verlis E. Miller
Page Two
January .3 , 1991
As mentioned previously, the purpose of this letter is to
advise you of the importance of your Permit. Please read the
Permit and contact this Office at 704/663-1699 in Mooresville if
you have any questions or need clarification. We look forward
to providing any assistance.
Sincerely,
D. Rex Gleason, P. E.
Water Quality Regional Supervisor

State of North Carolina
Department of Environment,
Health and Natural Resources • ,
Mooresville Regional Office
James B. Hunt, Jr., Governor � E H N R
Wayne McDevitt, Secretary
DIVISION OF WATER QUALITY
October 8, 1997
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, Virginia 22604-1240
Attention: Mr. James C. Zombro, Jr.
RE: Notice of Violation of Permit Conditions
Permit N4 WQ0003924 GW90266
Lincoln County, N.C.
Dear Mr. Zombro:
The Groundwater Section has received your September 19, 1997 letter addressing the Notice of
Violation of Permit Conditions received by you on September 19, 1997. Thank you for bringing to our
attention the modification of Permit No. WQ0003924. The Groundwater Section's file at the
Mooresville Regional Office did not contain a copy of this permit modification. As such, the NOV was
issued in accordance with the older permit conditions. A copy of the modified permit conditions has
been reviewed and filed. Based on the review of the modified Permit No. WQ0003924, the
requirements outlined in the NOV, received by you on September 19, 1997, are rescinded. Should you
have any questions please contact Chuck Pippin at 704-663-1699.
Sincerely,
Barbara S. Christian, P.G.
Acting Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
cgp/natfruit.rec
919 North Main Street, �y� FAX [phone]
Mooresville, North Carolina 28115 An Equal FAX
Action Employer
Voice 704-663-1699 50% recycled/10°1. post -consumer paper

; SENDER:
I also wish to receive the
v_ UComplete items t and/or 2 for additional services.
following services (for an
w ■Complete items 3, 4a, and 4b.
d ■ Print your name and address on the reverse of this form so that we can return this
extra fee):
y
card to you.
■Attach this form to the front of the mail piece, or on the back if space does not
1. ❑ Addressee's Address
permit.
■ Write'Return Receipt Requested' on the mailpiece below the article number.
2. ❑Restricted Delivery
co
a■The Return Receipt will show to whom the article was delivered and the date
Consult postmaster for fee.
°•
delivered.
0
2
0
•0 3. Article Addressed to:
4a. Article Number
.21 NATIONAL FRUIT PRODUCT CO INC
Z 335 770 415
ATTN: JAMES C ZOMBRO JR
4b. Service Type
d
0 PO BOX 2040
❑ Registered �1 Certified
�
WINCHESTER VA 22604-1240
❑ Express Mail ❑ Insured
c
In
¢
NOV OF PERMIT CONDITIONS
❑ Retum Receipt for Merchandise ❑ COD
C
®
PERMIT NO . WQ0003924 GW90�66
7. Date of Delivery
w
0
0
Z.
5. Received By: (Print Name)
8. Addressee's Address (Only if requested
�
C
tu
�.
and fee is paid)
W
cc
6. Signature: (Addressee t)
0
PS Form'3.8.11, December 19
102595-97-B-0179 Domestic Return Receipt
- - - Z 33-5 770 415
us Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail See reverse
Sent to
NATIONAL FRUIT PRODUCT CO NC
?F(p t i rgbe�040
YVpo�p(rjce�SIP_C�Ae 22604-1240
W1LV(NAMEVS ZOMBRO JR
ostage • J

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
lkr� WA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
3/31 /99
VERLIS E. MILLER
NATIONAL FRUIT PRODUCT CO-WWT
PO BOX 2040
WINCHESTER VA 22604
SUBJECT: NOTICE OF VIOLATION AND REVOCATION FOR NON PAYMENT
PERMIT NUMBER W00003924
NATIONAL FRUIT PRODUCT CO-WWT
LINCOLN COUNTY
Dear Permittee:
f!IitR, 0 z
Payment of the required annual administering and compliance monitoring fee of $600.00 for this year has not
been received for the subject permit. This fee is required by Title 15 North Carolina Administrative Code 2H.0105, under
the authority of North Carolina General Statutes 143-215.3(a)(1), (1 a) and (1 b). Because this fee was not fully paid within
30 days after being billed, this letter initiates action to revoke the subject permit, pursuant to 15 ncac 2H.0105(b) (2) (k)
(4), and G.S. 143-215.1 (b) (3).
Effective 60 days from receipt of this notice, subject permit is hereby revoked unless the required Annual
Administering and Compliance Monitoring Fee is received within that time. Discharges without a permit are subject to the
enforcement authority of the Division of Water Quality. Your payment should be sent to:
N.C. Department of Environment and Natural Resources
Division of Water Quality
Budget Office
P.O. Box 29535
Raleigh, NC 27626-0535
If you are dissatisfied with this decision, you have the right to request an administrative hearing within Thirty (30)
days following recipt of this notice, identifying the specific issues to be contended. This request must be in the form of a
written petition conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, Post Office Drawer 27447, Raleigh, North Carolina, 27611-7447. Unless such request for hearing is made or
payments received, revocation shall be final and binding. If you have any questions, please contact:
M_r. Rex Gleason, Mooresville Water Quality Regional Supervisor, [phone].
Sincerely,
err T. Stevens
cc: Supevisor, Water Quality Permits and Engineering Unit
Mooresville Regional Office
County Health Department
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
VERLIS E. MILLER
NATIONAL FRUIT PRODUCT CO-WWT
PO BOX 2040
WINCHESTER, VA 22604
Dear Mr. MILLER,
NCDENR-
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 24, 1998
Subject: NOTICE OF VIOLATION
Failure to Submit Monthly Reporting
NATIONAL FRUIT PRODUCT CO-WWT
Permit Number: WQ0003924
LINCOLN County
G'iJ'diai• i.S..��=�' Q
DEC 2 1998
+r:v.rf-3�s�t' y,T�rc ;Pr,i Fed
This is to inform you that your monthly monitoring report for August, 1998, has not been received by the Division
of Water Quality. This is in violation of the terms in your Non -Discharge permit, which requires submittal of your
monthly spray irrigation activities on or before the last day of the following month. Failure to submit reports as required
by the state issued permit will subject the violator to the assessment of civil penalties of up to $10,000.00 per violation.
To prevent further action, please submit this report to the letterhead address within 15 days or notify this office as
to any problem preventing its timely receipt. You will be considered non -compliant with the self -monitoring
requirements of you non -discharge permit until this report has been submitted.
If within the next twelve (12) months, future reports are not received within the required time frame, you will be
assessed $500.00. Additional violations within a twelve (12) month period will double the penalty for each violation.
The Division must take these steps because timely submittal of non -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 non -discharge monitoring reports, please contact'Kevin Barnett of our central office staff
at 919-733-5083 ext. 529.
Nothing in this letter should be taken as removing from you the responsibility or liability for failure to comply with all
applicable state laws and regulations.
Sincerely,
A. Preston Howard, Jr., P.E.
cc: Non -Discharge Compliance / Enforcement Unit
Non -Discharge Permitting Unit
Mooresville -Regional -Supervisor.
Central Files _ `�—
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

,WELL CONgRUCTION RECORD 1"m Imintll u5c ONI.Y:
IN3 rbyrnwi tv qtwd CPT singiz w, mminjac itcus
i. Well Cont ructior Information: 1 44041
[I �_WAIVWZUR
Brian Ewing 4 FROM I TV) nFrCAirTtnv
%V01 euromom
�L240-33
NC wel? C05ftokir Cca ir" Or. Naube? il IS. 011TERVASWC. (fdr mullka4d t, os URM fif awwat M
Fitom M
otAtw.,rr,,rRq9 TMEIRNMI's
SAEDACCO Inc
Vdlr4mx% Naffw i,16,1NNM CASI,� %, Cff M �K —1-
2. Well touttruction Permit j
ljjr,X,11744 Lh1V
ft.
J. Well f;bcck neli OW),
IjAgkiniltural
Dlrsieafiun
Non -Water Smaph- Well:
Mijuilfcr Rccharge
DA:tjoirer Steng
TechnArgy
0(kottwmat (Clused Loop)
1'.111C.M41clinal Water Suppky tsing1c)
I' Aesi&nfial W�jwr Stimliv iskirells
QGrourdwater Rentedixion
ristoanwater Dminage
05absiftwe CoMml
01'rdw
4. Date Wellb)Cumplefed:. 11-4-16 Wtqj lD,# SB-4
.;a. %VCll Uwation."
9 (11- 1 15 R. 8 1 hL j .010 Q galvanizee
ft. ft; a.
0
288.Whitehouse Drive Lincolnton, NC 28092 Lincoln
Pin 0m1A.Jdrr.5, (`it%. and zip
I It. Itrtj
Ftook
RinwildowficalipriNu. 1PIM
3 after
Sh. I-Atitude and 1,ongitvide in dearre0minuIvUsecondr- or decimal degrees:
6. Is (Aru) The well(si: 0permAne"t or Vrempoora*
7. b� this a repAir to an mistinguelft 01ves tor MNS)
N.Numberof %telk wastruLted:
ro"Sinitiph. Ad"*0!1.44,r wv.i-wdi& opp)i weih 0MY aw, r1jr
xa(jjur wir
9, Total twit depilt behm land surfacir.
I If. Static o ater levO below top of casitl;p MJ
ILBorclutlediatuder:2.25
12. Well wostmetion minhad: DRIVEN
i-"U�Cr. dbra-1 Ptod" =.I
FOR WATERSVPPLY WELLS ONLY:
13a, Vield -Method of test:.
13b. Disinfection n it 5.Antount:
r _%14TEk1%L
9SILL:W]r�UENT
S TO
IL is (C PORTLAND CHOUMED
ft.
ft,
ft. it.
iii-em-XVIE—PA, _CK 'tir—m—
I To
ft. ft.
--TT5
n. I ft.
tL ft.
A. M
Z_
fL
ft.
ft, DV']Q/BOG
SP-30
22. Certification: VVQROS
OppIC,
Brian Ewing .1.1/14/2.Oi6
Sipulum of Cenifud Vkll Con"wor Wit
- te—,m,
wuh 15,1 VCA( I o.-C, .010", -V I iA VC , .4c OX *t,'Ml IVI'll C'1h0fV4;61Jt SCIV4�4fle.1 ?fJtd d.11 el
23. Site diagram or additional wdl.detaits;
YOU MY USC tat' balk Of this Page to piolvide additional wdl site &1aih or well
44011siniction iktfils- You may abw affach Bklitional jKtg:s if nEccssam.
214a. For All 'We BI- 'Subnlli this fomn i6ithin u ttivs of coanplotion of %%ell
Constniction'to the foliming-.
Dit-pion of Water Resources, tnfurtuatitin Pruces-Aing Chit,
1617 MA Semkc ('enter. Raleigh. N(7276"-1617
241). UM ON U, In addition to Sending the form to iltz address in
24aubbve, also submit a opy of titi folto kii.ildil lo dais of of avil
Itivisiou orwater, kremourcks. Undergrtmod Itokillott Control Progmin,
1636 IMAK Smice (enter. Ralel* NC 27699.16A
24c. For Water Suaith & Inimbon Wells- I
Alw Submit ow 41� of 110S form withill 30 daysof 610plelloin of
weticom-intefion to the county kattli depannrxit of itte couaw Isiv.-M
Cominigicl
Fo Tai. GW- I N01111 Cakilula mTanmcm. of EatltryrurAlis ud,%41=4 Rc.wlu*CS - M iwmbef Watel Clmmcm

WELL CONSTRUCTION RECORD
° Ttis farm o;l M owd rn sinttk o. mtdtip7; w'c11s
1. Well Cimtractor Infurtnatiou:
Brian Ewing
WOW ('PtKt-.,&4tf N;ttmc
4240-B
NC Wcll C•:liinacicir Cerlif Nitiori Narriier
SAEDACCO Inc
Colt-pttn )•);brie
2. Well Construction Permit #: _
dra��i: ear ld, Aylt• nr:d l!.<n:tiP� tt.,rr. r:r!wnr:..St�7r. l tri.:fue. lgac6m rtr.d
I.Well Use f.ell0knell rise):
L':1!1ttt�ytltutal CIAf;+;lniciprd:l'ilblh;
t;1{�i Cltlt i1t111 Meatine;%cros in • atipnh-f r Residenli:d Water Supple (iinglel
Lllndustriit+Contmctnitl 17ResidwiiatWat+:rSttpptt•isteur)
t7;ltluiter RcctiartT,
M Attltifc r Stan gc ;grid Ret;ntcn'
O •Aquitcr T cst
C11".rlx n;ncntnl TLvhliolog+•
Ockothsnis111Citr, d.Lowl+t
Monridnilcr Rcnisdi:trictr
f]Ssomns'ater 13rttiitagc
O S)1h5itl211CC i; 'ardtnl
D7racer
00thel (esotain allder #_p I I
4.Date WORM Cumplefed: 11-4-16 well IDASB-I
Sa. We41 Li►catian:
F:C110y:01%rier Meow
F,tcelrtl 19ri iif nrfic,thlcp
288 Whitehouse Drive Lincolnton, NC 28092 Lincoln , , ,
PIn meal ;Aldr,eK OK.. 0514 Zip
<<3 73
F•sr ttxe"ant ttsc L?NL.i': 440416
fl. PI.
ft, l fl.
i t.l PI.1 in.I I i
fr. ry.j �.
{ 16 f1. 20 ft. 1 irt, .010 a galvanized
t ,
0 R. 1 20 ft. PORTLAND CEMMMED
ft, g h
(t. d
a gl1ij% - l:tr O Mitit11<aunn Na ONO after
11
1 DixrF.RIAl.
hVPlAt
ft. F
ft.
ti.
1 UNG I>l,1G
larlAch additional Owls it treccsQ nl
Y y TQ
nf'.tiCRnjTtn� i>4dsn Lartttwc.. x11w
ft.
A.
i
it.
ft
t 6,r _ NY .
Information
water sample w/SP-30 sampler abandc
V1/QR04
SN. Latitude and 1.ungitnde in degrees.'minuteiAwouds Rr rlcciuml dear-rs: Z2.tifrcatinn: P.f 0 7(� � �`JI LLB � EulOi �A.L 0 F
ti: nelt &M, law to l lotaris, slufi;K>1! i
t� _ __._ Brian Ewing 11/14/2016
Sipnuler, orCsnifi:d Well Confoaar Ewe
6. b fart) the %selll'rlt: ?7Pernranent or XTelnlNtraq M n ru.�,r tK, ::.rrrt, t nerr!•r rriit • oSi f tlsr nclM,n! mitt fi:[arj iwer,Iintr!ra ir, xzrerld.ge, r
irudr I53 ;4'C AC 0.1c' ,;F,irf: 1tr OA RtC,OZ(11 Weli ( wie f f for Srcua4u)"h ;eiJ rharl.t
�. h this a repair to an eabting Well: ::!Ves or NNO t r je'i C!f rki rev'r+red 1:fa 1teew w Mr aW,' tnmer
If An" •iel/[X!'ti!:F,Ir"Or AfluRJt t.'effd+iAi;1.111 riewfnflViA(ar::ni ain4 •`,gjjb l 014, nttrtAw 0 r110
rrrtttir cooler a31 !rn+urfs ,sea:: tear .:run rlar 1'::e•.$ ,rt erg a.lnr!x. 2.4. Site ditcgr'am ur additiaual wdl details:
YLNJ tm IM tlk. bkk of t11is Ogg it) plo'.ide additional well Site dvaf1S Ot t ell
N. Number of nelb construLled: 1 _ l;011S1M0i6niM3i6-. You nta�' aLsu auaelt additiiittaE pCtks if tiite5 are.
.Fee+.;t1!i1�tr +r>t?i!eJrR.:r Hf41-W'!li'e'P sJtyrttt. k'Nll• L�:\'1.1' n�tth rhr'. titArat' Cer1'tart'uCNtlnl t.:a1 <mra
Azai mlir<n1r Tina_ SUBMITTAL -MONS
9. Total dell depth Irelrnt land,urfaee: �lCt.P 24a. For All WOM Subn6t lib's faun uilhin 711 daes of cosprietion of Hell
T", n.,f1liple 11 Yrfh lijllidl rlt -0i A, JC e'rd•Jik 1t'.Z:uN!tdt• aa4!',:¢!?� t n; :. "a9'. FF,Il'h constnfction to tltt f4Un ing; .
we
1p. Static n'ater lesel below flip of rasing. (1t.b Bnision of Water Resources, inforwa iou Pmccssing l;oit.
ll nst.r: b tr: ;s u1k ce t a!ir!a. et „+ 1617 1►fa11 Sm iee (:enter. Raleigh. M.' 276"-t617
11. Barebelediameter..2.25 (in.t tab. En' i 1gM_3AM4 ONtV: to addition to'sending Ike farm to fix, ad lm"s in
2saallova. also 311btuil a copy of this forin %ittiiti to guts i)f i:itmplc,4lu I of tttiil
12. Well cmnstructian metliod: DRIVEN Ironstnretioa Its tltx fioiiowirig.
;i.c..�u�;r; r�an.;able, din.ci �r61+ ctt.i
AivW!;it of Water Re -mums, Undergrunnd l"ieetion CoatrldPnigraul,
FOR \}'ATER SVPPLN AVE LLS ONLY: ifi l6 Mail Service Center, Rulelglt, :>3C 274".I63o.
24c. For Water Suppis & faimttlin Wells:
13a 1"icld 1�;pm9 VtetlrnA of tact: XISO.subillit 01W Copy of this forin MItern 30 ilao'SC1f ltirnpl;�lcllr tDf
well Construction to the cmunf}• health dcrranment of the cttttcttr• wkrr
Consinictrd.
FetratCal`-t W�uhCantatutCicsrsr&nsofErnirt•niian trod*antrJbPcS+�tut:t5-Ueiwk[ctWslcrRettitrc� Rev G,:d.sLCW.Nsi:3

_V' AL
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
April 30, 2010
CERTIFIED MAIL # 7009 0820 0001 0529 8551
RETURN RECEIPT REQUESTED
David Coco
National Fruit Product Company, Inc.
288 White House Road
Lincolnton, NC 28093
Subject: Notice of Violation NOV-2010-PC-0476
National Fruit Product Company, Inc.
Permit Number WQ0003924
Lincoln County
Dear Mr. Coco,
Dee Freeman
Secretary
MAY - 4 2010
Nis DERaR (viRO
DWQ -A t.tifer Protection
As of this date, our records indicate that the above -referenced permit, which was issued on March
9, 2005 and expires on February 28, 2013, has overdue fees. It is both a condition of your permit and
required by Rule 15A NCAC 2T .0105(e)(2) to pay the annual administering and compliance fee within
thirty (30) days of being billed by the Division.
Failure to pay the fee accordingly may result in the Division initiating enforcement actions, to
include the assessment of civil penalties. Failure to comply with conditions in a permit may result in a
recommendation of enforcement action, to the Director of the Division of Water Quality who may issue a
civil penalty assessment of not more that twenty-five thousand ($25,000) dollars against any "person"
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit under
authority of G.S. 143-215.6A. Therefore, it is imperative that you submit the appropriate fee as requested
within thirty (30) days of this Notice of Violation (NOV). The following invoices are outstanding:
Invoice Number
Invoice Date
Due Date
Outstanding Fee
2009PRO01122
1 /23/2009
2/22/2009
$1,310.00
Please remit payment, made payable to the North Carolina Department of Environment and
Natural Resources (NCDENR) in the amount of $1,310.00. Please mail this payment to:
Division of Water Quality — Budget Office
Attn: Fran McPherson
1617 Mail Service Center
Raleigh, NC 27699-1617
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] \ FAX 1: 919-715-0588; FAX 2: 919-715-60481 Customer Service: 1-877-623-6748
Internet: www.ncwaterouality.org
Gne.
��1Ote11"CilIc1
An Equal Opportunity \ Affirmative Action Employer

If you have any questions concerning this Notice, please contact Ed Hardee at [phone] or
at [e-mail].
Sincerely, I
Jon-Ris aard, Supervisor
Land Application Unit
cc: Tyloore�vzlle`Re io�i la Office; wifR Eof�ection�Secl on.
Permit File WQ0003924
2

NATIONAL FRUIT PRODUCT COMPANY, INC. P.O. BOX 916 LINCOLNTON, NC 28092 TEL [phone]
"� ;v ;.:.x+.•t.�',a ^,Q?J�'rIP�; .fir
June 19, 2000 ,
Mr. Kerr T. Stevens j.�� `
North Carolina Department of Environment & Natural Resources L a
1617 Mail Service Center --
Raleigh, NC 27699-1617.
Dear Mr. Stevens
With regards to your NOTICE OF VIOLATION, dated May 31, 2000, National Fruit Product
Company (NPDES permit number NC0023761) has indeed submitted monthly monitoring
reports for March 2000. For your convenience, I have enclosed additional photocopies of the
reports, along with a copy of the USPS Return Receipt, indicating that the reports were
received by Marvin Wilson on May 02, 2000.
I would also like to point out that when Ellen Huffman, Environmental Technician at the
Mooresville Regional Office, visited the Lincolnton plant in April of this year, she indicated
that the Division of Water Quality had not received our February reports. I made a copy of
the USPS Return Receipt, indicating that the reports were received by Marvin Wilson on April
03, 2000. Again, for your convenience, I have enclosed a copy of this USPS Return Receipt.
To avoid confusion regarding monthly monitoring reports for April 2000 and also for your
convenience, I have enclosed additional photocopies of the April reports, along with a copy of
the USPS Return Receipt, indicating that the reports were received by Marvin Wilson on June
O1, 2000.
I have also enclosed monthly monitoring reports for May, 2000.
z�.5 L---'
L.D. Shockley
Plant Manager (Permittee)
cc: David Gum — NFP Co. - Winchester
Ellen Huffman — NCDENR - Mooresville

NATIONAL FRUIT PRODUCT COMPANY, INC. '�-
P.O. Box 2040, Winchester, Virginia 22604-1240 ^� `� V d)
703-G62-3401 FAX [phone] V
September 19, 1997 � L�
U �
Barbara S. Christian, P.G.
Acting Regional Supervisor
North Carolina DEHNR
Division of Water. Quality
919 North Main Street
Mooresville, NC 28115
Dear Ms. Christian:
i
i1.C. DEPT. of
ENVIRONMENT, T7E?. ,T TH ,
'7
J';i_L uCC,t`'
We are writing in reference to your letter of September 16, 1997 concerning violation
of groundwater monitoring permit conditions of Permit No. WQ0003924 for National Fruit's
Lincolnton, North Carolina plant spray irrigation wastewater facility.
The letter states that analyses for NO3 and VOCs for monitoring wells MW-1, MW-
2, and MW-3 have not been received for five sampling reports from February 14, 1996 to
June 16, 1997. According to the current Permit No. WQ0003924, a copy of which is
.attached, groundwater monitoring wells MW-1, MW-2, MW-3, and MW-4 are not required
_ to. be analyzed for NO3 and VOCs. Also attached is a copy of a letter from Cynthia Boyles of
the DEHNR Division of Environmental Management confirming the current groundwater
monitoring schedule.
We request that you rescind the Notice of Violation of Permit Conditions and notify
National Fruit Product Company, Rex Gleason, and Bob Cheek of such action.
If you have any questions concerning this matter, please contact the writer at (540)
662-3401.
Sincerely,
NATIONAL FRUIT PRODUCT COMPANY, INC.
ames C. Zombro, r.
Director of Quality Assurance and Environmental Affairs
cc: David Coco
Joel Thinnes
Clarke Crenshaw

State of North Carolina
"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. Verlis E. Miller, V.P.-Manufacturing
National Fruit Product Company, Inc.
P.O. Box 2040
Winchester, VA 22604-1240
Dear Mr. Miller:
January 17, 1996
LTWMA,
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_s''221997
DIVISIOe! OF E{"li
Ni00-nulm F�a,u OEi R
Subject: Permit No. WQ0003924-Modification
National Fruit Product Co., Inc.
Lincolnton, NC Plant
Wastewater Spray Irrigation
Lincoln County
In accordance with your application received October 4, 1995, we are forwarding herewith Permit
No. WQ0003924, dated January 17, 1996, to National Fruit Product Company, Inc. for the continued
operation of the subject wastewater treatment and spray irrigation facilities and construction of the
additional capacity in the storage lagoon. This permit modification is for the approval for construction to
increase the lagoon capacity to 2.0 million gallons. Please note, this facility has been approved by the
Division of Solid Waste for disposal of the residuals from this lagoon. This is an action that requires a
permit from DEM and not Solid Waste. Condition VI.9 of this permit requires National Fruit Product
Co., Inc. within 90 days from issuance of this permit to submit for approval an application for the disposal
of residuals from this facility and wastewater treatment and storage lagoon.
This permit shall be effective from the date of issuance until September 30, 2000, shall void Permit
No. WQ0003924, issued October 6, 1995, and shall be subject to the conditions and limitations as
specified therein. Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will result
in future compliance problems.
If any parts, requirements, or limitations contained in this pennit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, P.O. Drawer
27447, Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
One set of plans and specifications are being forwarded to you. If you need additional information
concerning this matter, please contact Mr. Randy Kepler at [phone] ext. 544.
Sincerely,
�0.���
A. Prest Howard, Jr., P.E.
cc: Lincoln County Health Department
Mooresville Regional Office, Water Quality Section
Mooresville Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Training and Certification Unit, No change in rating
Facilities Assessment Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SPRAY IRRIGATION SYSTEM PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
National Fruit Product Company, Inc.
Lincoln County
FOR THE
construction of additional storage in the storage lagoon for a total volume of 2.0 million gallons; and
continued operation of a 60,000 GPD spray irrigation treatment and disposal facility consisting of a
12,500 gallon capacity surge tank, a 300,000 gallon capacity storage tank, a 2,000,000 gallon storage
capacity lagoon, dual 585 GPM irrigation pumps, a six zone 21.5 acre irrigation disposal area, manual
controller, and all associated valves, piping, and appurtenances to serve National Fruit Product Company,
Inc., with no discharge of wastes to the surface waters, pursuant to the application received October 4,
1995, and in conformity with the project plan, specifications, and other supporting data subsequently filed
and approved by the Department of Environment, Health and Natural Resources and considered a part of
this permit.
This permit shall be effective from the date of issuance until September 30, 2000, shall void Permit
No. WQ0003924 issued October 6, 1995, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. Upon completion of construction and prior to operation of this permitted lagoon facility, a
certification must be received from a professional engineer certifying that the permitted
facility has been installed in accordance with this permit, the approved plans and
specifications, and other supporting materials. Mail the Certification to the Water Quality
Permits and Engineering Unit, P.O. Box 29535, Raleigh, NC 27626-0535.
2. The Mooresville Regional Office, telephone number 704-663-1699, shall be notified at
least forty-eight (48) hours in advance of operation of the installed facilities so that an in -
place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.

3. The spray irrigation facilities shall be effectively maintained and operated at all times so that
there is no discharge to the surface waters, nor any contamination of ground waters which
will render them unsatisfactory for normal use. In the event that the facilities fail to
perform satisfactorily, including the creation of nuisance conditions or failure of the
irrigation area to adequately assimilate the wastewater, the Permittee shall take immediate
corrective actions including those actions that may be required by the Division of
Environmental Management, such as the construction of additional or replacement
wastewater treatment and disposal facilities.
2. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.
3. The residuals generated from these treatment facilities must be disposed in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
4. Diversion or bypassing of the untreated wastewater from the treatment facilities is
prohibited.
5. The following buffers shall be maintained:
a) 400 feet between wetted area and any residence or places of public assembly under
separate ownership,
b) 150 feet between wetted area and property lines,
c) 100 feet_ between wetted area and wells,
d) 100 feet between wetted area and drainageways or surface water bodies,
e) 50 feet between wetted area and public right of ways,
f) 100 feet between wastewater treatment units and wells, and
g) 50 feet between wastewater treatment units and property lines.
Some of the buffers specified above may not have been included in previous permits for
this waste treatment and disposal system. These buffers are not intended to prohibit or
prevent modifications, which are required by the Division, to improve performance of the
existing treatment facility. These buffers do, however, apply to modifications of the
treatment and disposal facilities which are for the purpose of increasing the flow that is
tributary to the facility. These buffers do apply to any expansion or modification of the
spray irrigation areas and apply in instances in which the sale of property would cause any
of the buffers now complied with, for the treatment and disposal facilities, to be violated.
The applicant is advised that any modifications to the existing facilities will require a permit
modification.
6. The lagoon shall have a liner of natural material at least one foot in thickness, compacted to
95% proctor standard dry density and installed and compacted in layers no thicker than six
inches, with a hydraulic conductivity of no greater than 1 x 10-6 cm/sec. The existing
lagoon shall be inspected after removal of the residuals. If any damage has occurred from
the removal, repair shall be conducted and should meet the above requirement. Verification
of the liner's compliance with hydraulic conductivity and thickness specifications in the
new section and in any damaged areas must be provided to the Division of Environmental
Management, Water Quality Section, Permits and Engineering Unit and can be submitted
with the engineer's certification. Copies should also be sent to the Mooresville Regional
Office's Water Quality and Groundwater Sections at 919 North Main Street, Mooresville,
NC 28115.
2

II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class II, III, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202.
3. A suitable vegetative cover shall be maintained over the spray fields at all times.
4. Irrigation shall not be performed during inclement weather or when the ground is in a
condition that will cause runoff.
5. Adequate measures shall be taken to prevent wastewater runoff from the spray field.
6. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
7. The application rate shall not exceed a cumulative loading of 45.5 inches over any twelve
(12) month period at an instantaneous application rate not to exceed 0.5 inches per hour.
8. No type of wastewater other than that from National Fruit Product Company, Inc.'s
Lincolnton facility shall be sprayed onto the irrigation area.
9. No traffic or equipment shall be allowed on the disposal area except while installation
occurs or while normal maintenance is being performed.
10. Public access to the land application sites shall be controlled during active site use. Such
controls may include the posting of signs showing the activities being conducted at each
site.
11. Freeboard in the lagoon shall not be less than two feet at any time.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, soil or plant tissue analyses)
deemed necessary by, the Division of Environmental Management to insure surface and
ground water protection will be established and an acceptable sampling reporting schedule
shall be followed.

2. Adequate records shall be maintained by the Permittee tracking the amount of wastewater
disposed. These records shall include; but are not necessarily limited to, the following
information:
a. date of irrigation,
b . volume of wastewater irrigated,
c. field irrigated,
d. length of time field is irrigated,
e. continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for each
field,
f. weather conditions, and
g . maintenance of cover crops.
3. The effluent from the subject facilities shall be monitored by the Permittee at the point prior
to irrigation every February, June and October for the following parameters:
BODE ' TSS
Fecal Coliform pH
NH3 as N Sodium
Magnesium Calcium
Sodium Adsorption Ratio by Calculation
4. Due to the close proximity of surface waters and the level of groundwater under the lagoon,
DEM has concerns regarding protection of the water quality in the surface waters
downgradient of the lagoon. Periodic inspection and possible testing should be included in
the operation plan of this facility to insure protection of the surface water quality. When
any actions are taken, please submit the information received in with the monthly
monitoring report submitted in accordance with Condition III.5 of this Permit.
5. Three (3) copies of all operation and disposal records (as specified in condition III 2) on
Form NDAR-1 shall be submitted on or before the last day of the following month. Three
(3) copies of all effluent monitoring data (as specified in condition III 3) on Form NDMR-1
shall be submitted on or before the last day of March, July and November. All -information
shall be submitted to the following address:
NC Division of Environmental Management
Water Quality Section
Facility Assessment Unit
PO Box 29535
Raleigh, NC 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the Mooresville Regional Office, telephone
number 704-663-1699, 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 wastewater treatment facility which results in the treatment 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 renders the facility
incapable of adequate wastewater treatment, such as mechanical or electrical failures of
pumps, aerators, compressors, etc.;
4

c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to
such station or facility; or
d. Any time that self -monitoring information indicates that the facility has gone out of
compliance with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 5 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
1. Monitor wells MW-1, MW-2, MW-3 and MW-4 shall be sampled every February, June
and October for the following parameters:
Ammonia Nitrogen TDS pH
Chloride TOC Water Levels
The measurement of water levels must be made prior to sampling for the remaining.
parameters. The depth to water in each well shall be measured from the surveyed point on
the top of the casing.
The measuring points (top of well casing) of all monitoring wells shall be surveyed to
provide the relative elevation of the measuring point for each monitoring well.
If TOC concentrations greater than 10 mg/1 are detected in any downgradient monitoring
well, additional sampling and analysis must be conducted to identify the individual
constituents comprising this TOC concentration. If the TOC concentration as measured in
the background monitor well exceeds 10 mg/l, this concentration will be taken to represent
the naturally occurring TOC concentration. Any exceedances of this naturally occurring
TOC concentration in the downgradient wells shall be subject to the additional sampling
and analysis as described above.
The results of the sampling and analysis shall be sent to the Groundwater Section, Permits
and Compliance Unit, P.O. Box 29535 Raleigh, N.C. 27626-0535 on Form GW-59
[Compliance Monitoring Report Form] every March, July and November.
2. Any additional groundwater quality monitoring, as deemed necessary by the Division, shall
be provided.
3. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983 is established at either (1) 250
feet from the waste disposal area, or (2) 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or
beyond the Compliance Boundary is subject to immediate remediation action in addition to
the penalty provisions applicable under General Statute 143-215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.

V . INSPECTIONS
1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to
insure proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the wastewater treatment and disposal facilities
to prevent malfunctions and deterioration, operator errors and discharges which may cause
or lead to the release of wastes to the environment, a threat to human health, or a nuisance.
The Permittee shall keep an inspection log or summary including at least the date and time
of inspection, observations made, and any maintenance, repairs, or corrective actions taken
by the Permittee. This log of inspections shall be maintained by the Permittee for a period
of three years from the date of the inspection and shall be made available upon request to
the Division of Environmental Management or other permitting authority.
3. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the disposal site or facility at any reasonable time for the
purpose of determining compliance with this permit, may inspect or copy any records that
must be maintained under the terms and conditions of this permit, and may obtain samples
of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans and specifications, and other supporting
data.
2. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6(a) to 143-215.6(c).
5. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
6. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of the project.
7. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205
(c)(4).
8. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
6

9. This facility received an approval for disposal of the residuals (solid waste) in the treatment
and storage lagoon from the Division of Solid Waste Management on October 26, 1995.
Any disposal or application of any residual from a wastewater treatment facility permitted
through DEM must have a permit from this Division prior to any action taken for disposal.
Within 90 days from the issue date of this permit, National Fruit Product Co. Inc. must
submit an application for the disposal and or application of the residuals from the
wastewater treatment and storage lagoon.
Permit issued this the Seventeenth day of January, 1996
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A. Preston 40ward, Jr., P.P., Director / Y Division of vironmental Management
By Authority of the Environmental Management Commission
Permit Number WQ0003924
7

State of North Carolina
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
January 31, 1996
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, VA 22604-1240
Attn: Mr. Verlis E. Miller
Vice President, Manufacturing
SUBJECT: Permit No. WQ0003924/GW95224
National Fruit Product Company, Inc.
Wastewater Spray Irrigation
Lincoln County
Dear Mr. Miller:
EDEHNR
In accordance with the policy of the Division of Environmental Management to ensure the
good quality of North Carolina's groundwater, the referenced Permit requires several activities related
to groundwater monitoring. The following guidelines and forms are presented to assist you in
complying with those requirements. If you have any questions concerning these matters, you should
contact Barbara Christian at the address shown below to discuss the requirements relevant to your
specific facility:
Mooresville Regional Office
919 North Main Street
Mooresville, NC 28115
[phone]
Groundwater Condition No. IV.1.: Sampling of the referenced wells on the schedule and
for the constituents listed below:
SCHEDULE: Monitor wells MW-1, MW-2, MW-3, and MW-4 shall be sampled every
February, June, and October.
CONSTITUENTS: Ammonia Nitrogen TDS
Chloride TOC
pH Water Levels
The measurement of water levels must be made prior to sampling for the remaining parameters.
Groundwater Section �4% Voice 919-733-3221 FAX [phone]
P.O. Box 29578, Raleigh, North Carolina 27626-0578 N� A C An Equal Opportunity Affirmative Action Employer
2728 Capital Blvd., Raleigh, North Carolina 27604 50% recycled/10% post -consumer paper

Mr. Miller
January 31, 1996
Page 2
The results of all analyses specified in the monitoring requirements must be submitted
simultaneously.
If TOC concentrations greater than 10 mg/l are detected in any downgradient monitoring well,
additional sampling and analysis must be conducted to identify the individual constituents comprising
this TOC concentration. If the TOC concentration as measured in the background monitor well
exceeds 10 mg/l, this concentration will be taken to represent the naturally occurring TOC
concentration. Any exceedances of this naturally occurring TOC concentration in the downgradient
wells shall be subject to the additional sampling and analysis as described above.
* A supply of forms (GW-59) on which the analytical results must be reported is
attached. Instructions are provided on the reverse of the white copy of each four-part form. The
analytical results should be sent the address shown at the top of the form and is due in our office no
later than the last working day of the month following sample collection.
* FOR ANY ADDITIONAL INFORMATION RELATED TO REQUIREMENTS FOR
GROUNDWATER QUALITY PROTECTION, PLEASE REFER TO YOUR PERMIT. A
copy of the Groundwater Requirements for Permit No. WQ0003924 is attached for your reference.
If you have any questions, please do not hesitate to contact me at [phone].
Sincerely,
Cynthia A. Boyles
Hydrogeological Technician II
Permits and Compliance
Groundwater Section
Attachments
cc: Barbara Christian
Compliance Monitoring Files

I
State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
�EHNR
DIVISION OF WATER QUALITY
September 16, 1997
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, Virginia 22604-1240
Attention: Mr. James C. Zombro, Jr.
RE: Notice of Violation of Permit Conditions
Permit N4 WQ0003924 GW90266
Lincoln County, N.C.
Dear Mr. Zombro:
A review of the subject permit and your compliance monitoring data indicates that you
are in violation of the following permit condition:
Permit Condition Ns IV. Groundwater Requirements
1. Monitor Wells MW-1, MW-2 and MW-3 shall be sampled every February, June and
October for the following parameters:
NO3 Ammonia Nitrogen
TDS TOC
COD SO4
pH Water Level
Chloride Total Coliform
Total Suspended Solids Conductivity
Volatile Organic Compounds (VOC)
To date, we have not received any analyses for NO3 and VOCs for the last five sampling
reports. You are requested to submit the NO3 and VOC analyses for monitoring wells MW-1,
MW-2 and MW-3 for the following sample dates: February 14, 1996, June 26, 1996, October 28,
919 North Main Street, Nil
FAX [phone]
Mooresville, North Carolina 28115 CAn Equal Opportunity/Affirmative Action Employer
Voice 704-663-1699 500% recycled!100% post-ccnsumer paper

d SENDER: .
,C ■Complete items 1 and/or 2 for additional services.
I also wish to receive the
following services (for an
N ■Complete items 3, 4a, and 4b.
d ■ Print your name and address on the reverse of this form so that we can return this
extra fee):
dcard to you.
■Attach this form to the front of the mailpiece, or on the back if space does not
1. ❑Addressee's Address
v
permit.
■Write°Return Receipt Requested' on the mailpiece below the article number.
2. ❑ Restricted Delivery
a)
fn
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Consult postmaster for fee.
a
c delivered.
F)
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3. Article Addressed to:
4a. Article Number
d
Z 335 770 393
c
o NATIONAL FRUIT PRODUCT CO INC
4b. Service Type
o ATTN: JAMES C ZOMBRO JR
❑ Registered EX Certified
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❑ Express Mail ❑Insured
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WINCHESTER VA 22604=1240
❑ Return Receipt for Merchandise ❑ COD
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NOV OF PERMIT CONDITIONS
7. Date of Deliv_e,
1997 1 9
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5. Received By: (Print Name)
8. Addressee's Address (Only if requested
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and fee is paid)
6. Signature: d ressee o t) '
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PS Forrii3811 December . 4 ; ; i i ; t 102595-97-8-0179 Domestic Return Receipt
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US Postal Service
for Certified Mail
Receipt
No Insurance Coverage Provided.
ot use for Intemational Mail See reverse
Ltto�T:ONAFRUIT PRODUCT CON
b_ 40
22604-1240
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1 National Fruit Products Company, Inc.
September 16, 1997
Page Two
1996, February 28, 1997 and June 16, 1997. These analyses must be received within 30 days of
your receipt of this letter or an explanation of why you cannot comply. It should be noted that
the violations cited above and any additional documented violations could result in the initiation
of an enforcement action by this Office in accordance with General Statute 143-215.6A, which
provides for a $10,000 assessment of civil penalties for each violation. Each day that the
violations continue may be considered a separate violation.
Should you have any questions concerning this Notice, contact Chuck Pippin at (704)
663-1699, ext. 268.
Sincerely,
Barbara S. Christian, P.G.
Acting Regional Supervisor
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
cgp/natfruit.nov

State of North Carolina
Department of Environment,
`. Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
e��
[DEHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
September 14, 1995
National Fruit Product Company, Incorporated
Post Office Box 2040
Winchester, Virginia 22604-1240
Attention: Mr. James C. Zombro, Jr.
Subject:
Dear Mr. Zombro:
NDpermit WQ0003924
Lincoln County, N.C.
The Groundwater Section of the Mooresville Regional Office
received the information requested in the Notice of Violation,
which you received on August 25, 1995. The information bas been
reviewed and will remain on file in this office. Please remember
that the chlorination procedures enclosed with the Notice should
be implemented for MW1-MW4. In addition, the sampling schedule
set in the subject permit shall be followed and results for total
coliform reportedfas counts of colonies per 100 ml.
I would also like to apologize if there was any confusion
concerning the last three sets of VOC results and the timing of
the required June, 1995 sampling event. The submitted results
for samples collected on April 18, 1995 are acceptable in lieu of
a June, 1995 sampling event. All future sampling, however,
should occur as required in the subject permit.
Should you have any questions, please call me at -(704) 663-
1699,-ext. 241.
Sincerely,
,�tm a
Steven Bograd
Hydrogeological Technician
SEB/sc
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh
919 North Moro Street, Mooresntle. North Carolina 28115 Telephone [phone] FAX [phone]
An Equol opportunity Affirmative Action Employer 50% recycled/ 10% Pest -consumer paPer

State of North Carolina
Department of Environment,
Health and Natural Resources. ` •
Mooresville Regional Office �r
1
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary [DaHNF-7Z
Linda Diane Long, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 21, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
National Fruit Product Company, Incorporated
Post Office Box 2040
Winchester, Virginia 22601
Attention: Mr. Verlis E. Miller
RE: Notice Pf Violation of Permit Conditions
Permit WQ0003924/GW90266
Lincoln County, N.C.
Dear'Mr. Miller:
A review of the subject permit and your compliance
monitoring data indicates that you are in violation.of the
following permit condition:
Permit Condition IV(2): The monitor wells shall be sampled
every February, June and October; the results of the
sampling and analysis shall be sent to the N.C. Division of
Environmental Management on Form GW-59 every March, July and
November. Submitted monitor reports indicate National Fruit
Products, Inc. is not following the required schedule. In
particular, the last sampling event occurred on.April 18,
1995 and the results were not received until August 4, 1995.
In addition, results for VOC analyses have not been
submitted since June 17, 1994.
The submitted monitoring reports also indicate MW-1, MW-2,
MW-3 and MW-4 have levels of coliform exceeding the standards
outlined in Commission Rule 15A NCAC 2L .0202(g)(19). To ensure
accurate results, you should chlorinate the monitoring wells
(please see enclosed chlorination guidelines) and check your
QA/QC procedures. In addition, actual numerical results of
coliform analysis must be reported on the GW-59 form instead of
indicating "0" or "fail".
919 North Main. Street, Mooresville. North Carolina 28115
An Equal OpportuNty Atfimx tive Action Employer
Telephone [phone] FAX [phone]
50% recycled/ 10% post -consumer paper

of
National Fruit Product Company, Inc.
August 21, 1995
Page Two
You are requested to submit analytical results for VOCs and
coliform for the October 17, 1994, March 7, 1995 and April 18,
1995 sampling events within 14 days of receipt of this letter or
an explanation of why you cannot comply. It should be noted that
the violations cited above and any additional documented
violations could result in the initiation of an enforcement
action by this Office in accordance with General Statute 143-
215.6A, which provides for a $10,000 assessment of civil
penalties for each violation. Each day that the violations
continue may be considered a separate violation.
Should you have any questions concerning this Notice,
contact Steven Bograd at [phone], ext. 241.
Sincerely,
F
th Overcash, P.E.
al Supervisor
SEB
Enclosures: Chlorination Guidelines
cc: Ey e9 - Maorx;�z�ll�e ateG�ualit ct=ion
Bob Cheek - Permits arid` Compliance"Unit, Raleigh

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
e��
DEHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 3, 1995
Mr. Verlis E. Miller
Vice President -Manufacturing
National Fruit Product Company, Inc.
P.O. Box 2040
Winchester, Virginia 22604-1240
Subject: Notice of Violation and
Recommendation for Enforcement
Dated July 6, 1995.
NCGS 143-215.1- Control of
Sources of Water Pollution;
Permits Required.
National Fruit Product Plant
Lincoln County, N.C.
Dear Mr. Miller:
This letter is in response to your letter dated July 14, 1995
regarding the subject matter. The screenings from the apple
processing operation, spent diatomaceous earth filter -aid, and
apple pomace may be considered "agricultural" and, therefore, do
not fall under our regulations since there is no wastewater
treatment involved.
However, the sludge resulting from a wastewater treatment
process is regulated by this Office; therefore, a permit is
required prior to any land application.
If you have any questions concerning this matter, please do
not hesitate to contact Mr. Bou-Ghazale or me by telephone at ( 704 )
663-1699 or at the address shown on the letterhead.
Sincerely,
D /'4 .
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
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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703-662-3401 FAX [phone]
August 25, 1995
Mr. Steven Bograd
DEHNR
Division of Environmental Management
919 North Main Street
Mooresville, NC 28115
Dear Mr. Bograd:
We are writing in reference to your Notice of Violation dated August 21, 1995
concerning Permit No. WQ0003924 for our Lincolnton, North Carolina facility and our
phone conversations of today. As we discussed, I am certain that the VOC analytical
results for the four monitoring wells were included with the other forms and reports sent
to the DEM Compliance Group in Raleigh for the months noted in the NOV; copies of
the VOC results are enclosed as you requested. We also will obtain numerical results for
the coliform tests noted and forward them to you.
If you have additional questions or need additional information, please contact us.
Sincerely,
NATIONAL FRUIT PRODUCT COMPANY, INC.
J
James C. Zombro, Jr.
Manager - Environmental Affairs
cc: V. E. Miller
Joel Thinnes

State of North Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
OPM%eOOOOM%,t�
�EHNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 21, 1995
National Fruit Product Company, Incorporated
Post Office Box 2040
Winchester, Virginia 22601
Attention: Mr. Ver;lis E. Miller
RE: Notice Pf Violation of Permit Conditions
Permit WQ0,003924/GW90266
Lincoln County, N.C.
Dear Mr. Miller:
A review of the subject permit and your compliance
monitoring data indicates that you are in violation.of the
following permit condition:
Permit Condition IV(2): The monitor wells shall be sampled
every February, June and October; the results of the
sampling and analysis shall be sent to the N.C. Division of
Environmental Management on Form GW-59 every March, July and
November. Submitted monitor reports indicate National Fruit
Products, Inc. is not following the required schedule. In
particular, the last sampling event occurred on.April 18,
1995 and the results were not received until August 4, 1995.
In addition, results for VOC analyses have not been
submitted since June 17, 1994.
The submitted monitoring reports also indicate MW-1, MW-2,
MW-3 and MW-4 have levels of coliform exceeding the standards
outlined in Commission Rule 15A NCAC 2L .0202(g)(19). To ensure
accurate results, you should chlorinate the monitoring wells
(please see enclosed chlorination guidelines) and check your
QA/QC procedures. In addition, actual numerical results of
coliform analysis must be reported on the GW-59 form instead of
indicating "0" or "fail".
919 North Main. Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

a0 SENDER:-- -
Complet3 items 1 and/or 2 for additional services.
I also wish to receive the
y
® s Complete i*.emi 3, and 4a & b.
i
following services (for an extra
to
Ci
w Print your name'and address on the reverse of this form so that we can
return this card'to you.
• Attach.this form to the front of the mailpiece, or on the back if space
1 . ❑Addressee's Address
N
y
®
F does not permit., • ,.
L Write "Return Receipt Requested" on the mailpiece below the article number.
2. ❑ Restricted Delivery
+�
The Return Receipt will show to whom the article was delivered and the date
Consult postmaster for fee.
4
C delivered.
3. Article Addressed to:
4a. Article Number
m NATIONAL FRUIT PRODUCT CO INC
P 848 363 344 (8/11/95)
E ATTN: MR VERLIS E MILLER
4b. Service Type
ElRegistered ❑ InsuredtMN
cc.
0 PO BOX 2040
KI Certified ❑ COD
c
WINCHESTER VA 22601
❑ Express Mail ❑ Return Receipt for
uJ
Merchandise
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7. Date of Delivery
Q
(PERM NOV—GW# 90266)
I r n 7
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5. Signature (Addressee)
8. Addressee's Address (Only if requested
a
and fee is paid)
C
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6. Si nature (Agent)
"'Form 3811, D ember 1991� � .s.oPo:lsea—as2- 4- DOMESTIC RETURN RECEIPT
-- - -- - — — - — -- --- --
R.84.8 —363 344
8/�ceipt for
Certified Mail
i n No Insurance Coverage Provided
Do not use for International Mail
(See Reverse)
Sent to
NATIONAL FRUIT PROD CO
Street endATTN : MR VERL I S E MILL
P.O., S,fftd e 2040
WINCHESTER VA 22601
Postage
$
IN
:R

National Fruit Product Company, Inc.
August 21, 1995
Page Two
You are requested to submit analytical results for VOCs and
coliform for the October 17, 1994, March 7, 1995 and April 18,
1995 sampling events within 14 days of receipt of this letter or
an explanation of why you cannot comply. It should be noted that
the violations cited above and any additional documented
violations could result in the initiation of an enforcement
action by this Office in accordance with General Statute 143-
215.6A, which provides for a $10,000 assessment of civil
penalties for each violation. Each day that the violations
continue may be considered a separate violation.
Should you have any questions.concerning this Notice,
contact Steven Bograd at [phone], ext. 241.
Sincerely,
iB. ith Overcash, P.E.
Re onal Supervisor
Enclosures: Chlorination Guidelines
cc: Rex Gleason - Mooresville Water Quality Section
Bob Cheek - Permits and Compliance Unit, Raleigh

NATIONAL FRUIT PRODUCT COMPANY, INC.
` P.O. Box 2040, Winchester, Virginia 22604-1240 Lvi
J 703= 662-3401 FAX [phone] N.C. DEPT. of
ENVIRONMENT, HEALTH,.
July 14, 1995 & NATURAL RESOURCES
Mr. Rex Gleason JUL 1 7 1995
Water Quality Regional Supervisor
DIVISION OF
' nr
DEHNR WORML, L
919 North Main Street
Mooresville, NC 28115
1� Dear Mr. Gleason:
1�
_ We are writing in reference to the Notice of Violation and Recommendation for
Enforcement dated July 6, 1995, concerning the land application of sludge from the
wastewater storage tank at National Fruit's Lincolnton, North Carolina plant.
In February of 1993 we contacted Mr. Alan Hardy of your office to determine if
permitting was required for the land application of screenings from the apple processing
operation, spent diatomaceous earth filter -aid, and apple pomace. Mr. Hardy stated that
he thought that this would come under the solid waste area of the Division of
Environmental Management and referred us to Mr. Rick Doby of your office. Mr. Doby
stated that a permit would not be required for land application and spreading of these
materials since they were agricultural in nature. Mr. Doby stated that the spreading must
be conducted so that pollution of adjacent land or streams did not occur. The sludge
removed from the wastewater holding tank consists of spent filter -aid and apple particles.
In light of the conversations with Mr. Hardy and Mr. Doby, we believed that the
land application of this material was legal and had no intentions of violating the law.
The operation ceased as soon as Mr. Bou-Ghazale notified the plant that the application
was in violation. Materials of this nature have been proven to be good soil conditioners
and a number of states, such as'Michigan and Pennsylvania, allow the land application of
these materials and other agricultural and food processing residuals, according to
accepted agricultural practices, without permitting. The material will improve the soil to
which it was applied and we propose to plant a suitable cover crop on the area.

Mr. Rex Gleason
July 14, 1995
Page 2
Currently we are in the process of completing a permit application for land
application of the material for submission to DEHNR.
If you have any questions or need additional information, please contact us.
Sincerely,
NATIONAL FRUIT PRODUCT COMPANY, INC.
Verlis E. Miller
Vice President - Manufacturing
cc: Randy Sodoma
Joel Thinnes

4
State of North Carolina
Department of Environment,
Health and Natural Resources 1 •
Mooresville Regional Office A
James B. Hunt, Jr., Governor ® � H N
Jonathan B. Howes, Secretary
Linda Diane Long, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
July_ 6, 1995
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Verlis E. Miller
Vice President -Manufacturing
National Fruit Product Company, Inc.
P.O. Box 2040
Winchester, Virginia 22604-1240
Subject: Notice of Violation and
Recommendation for Enforcement
NCGS 143-215.1- Control of
Sources of Water Pollution;
Permits Required.
National Fruit Products Plant
Lincoln County, N.C.
Dear Mr. Miller:
Chapter 143, Article 21 of the North Carolina General Statutes
(NCGS) authorizes and directs the Environmental Management
commission of this Department to protect and preserve the water and
air resources of the State. The Division of Environmental
Management has the delegated authority to enforce adopted pollution
control rules and regulations.
On July 5, 1995, Mr. Samar Bou-Ghazale of this Office
conducted an investigation at National Fruit Product Company, Inc.
in Lincoln County, N.C. During the investigation, it was noted
that sludge from the wastewater treatment plant had been land
applied at a site adjacent to Clarks Creek (SR 1282). This
unpermitted land application activity is a violation of NCGS 143-
215.1(a)(9).
919 North Main Street, Mooresville, North Carolina 28115 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 500% recycled/ 10% post -consumer paper -

Mr. Verlis E. Miller
July 6, 1995
Page 2
To comply with the General Statutes pertinent to discharges of
wastewater, it will be necessary to immediately discontinue the
land application operation. A permit for the land application of
the waste must be obtained if land application is to continue.
Pursuant to NCGS 143-215.6A, penalties or up zo *lu, uuu . uu per
day, per violation may be assessed against any person who fails to
apply for or to secure a permit required by G.S. 143-215.1.
This letter is to notify you that the Mooresville Regional
Office of the Division of Environmental Management plans to forward
a recommendation for enforcement action to the Director of the
Division of Environmental Management. The recommendation concerns
the violation of North Carolina General Statute 143-215.1(a)(9).
If you have justification that this violation was caused by
events or circumstances beyond National Fruit Product Co., Inc.'s
control, you must reply in writing to the Mooresville Regional
Office within ten (10) days after receipt of this notice. Your
justification will be reviewed and forwarded to the Director for
his consideration. In the absence of such justification, the
Director may proceed with the recommendation for enforcement.
Also, It is requested that a written response be submitted to
this Office by no later than July 17, 1995 explaining action taken
to restore areas affected by the land application. Please address
your response to Mr. Rex Gleason, Water Quality Regional
Supervisor, in this Office.
If you have any questions concerning this matter, please do
not hesitate to contact Mr. Bou-Ghazale, Mr. Gleason, or me at
[phone], at the address shown on the letterhead.
Sincerely,
/D /?- I � /-
B. Keith Overcash, P.E.
Regional Supervisor
/BG
incoln County Health Department

703-662-3401 FAX [phone] December 13, 1993
Mr. Samar Bou-Ghazale
Environmental Engineer I
Division of Environmental Management
DEC 1.41995
Water Quality Section
Mooresville, NC 28115
91V1SION OF ENVIRONMENTAL MANAGEMENT
Dear Mr. Bou-Ghazale •
MOOR MUZ REGIONAL OFFICE
We are writing in response to the Notice Of Violation dated
December 2, 1993 for our Lincolnton, North Carolina plant. spray
irrigation facility. The deficiencies stated in the Notice are
addressed below:
Records/Reports:
The additional volume of 60,000 gallons was sprayed on
November 6 to alleviate a full wastewater storage condition at the
plant and was to be reported on the monthly monitoring report. We
have always instructed the Lincolnton plant personnel to maintain
an irrigation volume of 60,000 gpd or less to insure no more than
an average application rate of 60,000 gpd; however, since Permit
No. WQ 0003924 states that the maximum application rate for the
irrigation field is 0.87 inches per acre per week and the
additional volume applied to the two zones did not exceed that
rate, we did not feel that the permit had been violated. The
figure of 60,000 gpd was stated as the average daily flow in our
permit application, a copy of which is attached.
Operations & Maintenance:
our analysis of wastewater volumes generated by plant
operations versus volumes reported to have been irrigated also show
large discrepancies and indicate that there were application rates
in excess of the permit limits and National Fruit's own Operation
Manual limits. Apparently our irrigation system operator, Mr.
Richard Kirkpatrick, did apply wastewater to the irrigation site in
volumes significantly in excess of these application rate limits.
Interviews with current Plant Manager - Jack Ross, current ORC
- Rick Leonhardt, previous ORC and Assistant Plant Manager - Mark
Burau, and Valley Operations Manager - Greg Hofe, who has Corporate
responsibility for the Lincolnton plant, indicate that Mr.
Kirkpatrick acted on his own in violating the application rate
limits and not on instructions from Management. Comments made by
Mr. Kirkpatrick to several other Lincolnton plant employees also
indicate that Management was not aware of the situation. During
interviews with him, Mr. Kirkpatrick would not shed any light on
what actually occurred. Mr. Kirkpatrick was responsible for
recording both the wastewater volumes generated by plant operations

and the volumes spray irrigated, and was responsible for notifying
the ORC and Plant Management of any problems with the operation.
Facility Site Review:
The berm deficiencies on the west side of the spray field have
been corrected and any other weak areas of the berm have been
reinforced. The rain runoff contamination from the blacktop area
was caused by bins of cull or decayed apples stored on the blacktop
awaiting disposal; these cull apples should have been and are now
being stored in an area near the Apple Shed so that any leakage
from them drains to the plant wastewater system and does not
contaminate stormwater runoff. The ground in this area of concern
has been plowed to facilitate recovery. Normal, sound apples do
not cause contamination of stormwater.
Self -Monitoring Report:
The discrepancies between the wastewater volumes generated by
the plant operations and the volumes irrigated have been addressed
previously. Currently the wastewater volumes generated, the
volumes irrigated, wastewater storage condition, and irrigation
operations are being monitored by the ORC, Lincolnton Plant
Maintenance Manager, Lincolnton Plant Manager, Valley Operations
Manager, and the Corporate Environmental Affairs Manager in order
to prevent a recurrence of the problems addressed in the Notice of
Violation.
It is not and has not been National Fruit's intent to violate
the conditions of Permit No. WQ0003924; if this had been the case,
Mr. Kirkpatrick would not have been disciplined in October, 1993
for beginning to spray on the same irrigation zone for the second
day in a row. Within three weeks of this disciplinary action, the
plant wastewater storage capacity suddenly became a problem and
questions about operation of the irrigation field began to surface.
In order to insure proper operation of the irrigation field, Mr.
Kirkpatrick was relieved of his responsibilities as irrigation
field operator and the ORC, Rick Leonhardt, assumed actual
operation of the system.
We regret the occurrence of these problems and believe that
the correct steps have been taken to prevent their recurrence. If
you have any questions or need any additional information, please
do not hesitate to contact us.
Si cerely,
e`f�1is E. ifier
_'e�
Vice -President Manufacturing
NATIONAL FRUIT PRODUCT CO., INC.
VEM:bfh
cc: Greg Hofe
James Zombro
Jack Ross
file: c:\work\engineer\zombro\nov

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nNorth Carolina Department of Environment, Health, and Natural Resources
DEM USE ONLY
Environmental Management Commission
Permit Number -
NON -DISCHARGE PERMIT APPLICATION
'in accordance with NC General Statutes Chapter 143, Article 21
County: Lincoln
Applicant (name of board, individual, or others): Application Date:
National Fruit Product Co., Inc.
Project (name of city, village,•town, sanitary district, establishment):
National Fruit Product Co., Inc., Lincolnton, NC Plant
FOR:
Brief Project Description:
® Non -Discharge Treatment/Disposal Facilities
Spray irrigation of process wastewater
❑ Pretreatment Facilities
frcm manufacture of bottled vinegar,
canned and glass -packed apple sauce,
❑ Sewer Collection System (private)
bottled apple juice, and bottled fruit
❑ Extension of Sewer Systems (public)
flavored drinks.
❑ Sludge Disposal
❑ Spray Irrigation
NATURE OF WASTEWATER:
❑ Domestic Sewage
® Sludge/Industrial Waste
-
ated om letion Date:
rctutrent y �n operation
❑ Other Waste
From (sewers, pretreatment plant): Serving (city, institution, industry):
National Fruit Prod. Co., Lincolnton Plant i
i same
Into (name of treatment plant): Average Daily Gallons Sewage or Waste Flow:
same ; 60,000 GPD
At (location of plant): cooling water discharge (NPDES No.)
Lincolnton, NC to surface water onl —> NC00 ��7r1
Name and Complete
N/A
Address of Engineering Firm: Zip Code:
Telephone No.
Applicant assures that proposed works will be constructed, supervised, operated and maintained in accordance
with approved plans and specifications or approved changes thereto.
Print Name: Ver11S E. Miller Mailing
Address: NatioDAl Fruit Prod. Co. ,P.O. Box 2040
VP — ufactur`i�ngg Winchester, VA
Title: Zip Code:22601
Signaturei� �/ �i Telephone No. / 703 / 662-3401
INSTRUCTIONS:
1.Fill-in All Spaces. If not applicable, enter N/A.
2.Secure appropriate signature (mayor/city manager for municipality, chairman for sanitary district board, owner/proper official of
corporation, or legally constituted board or commission in charge of proposed works). A letter of authorization is required from
proper official if design engineer or other agent signs application.
3.Submit to Division of Environmental Management, Permits and Engineering Unit, P.O. Box 27687, Raleigh, NC 27611 the original.
and ALL carbon copies of the application, 3 sets of finalized plans, specifications and other supporting data as required by Com-
mission Rules, and permit fee. Plans and specifications must be signed and sealed by a registered North Carolina engineer.
FOR ASSISTANCE, CALL THE STATE CENTRAL OFFICE [phone]. PERMITS & ENGINEERING UNIT, OR:
Asheville [phone]
Fayetteville [phone]
Mooresville [phone]
Winston-Salem [phone]
59 Woodfin Place
Suite 714 Wachovia Bldg.
919 North Main Street
8025 North Point Boulevard
Asheville, NC 28801
Fayetteville, NC 28301
Mooresville, NC 28115
Suite 100
Raleigh [phone]
Washington [phone]
Wilmington [phone]
Winston-Salem, NC 27106
3800 Barrrett Drive
1424 Carolina Avenue
7225 Wrightsville Avenue
P.O. Box 27687
P.O. Box 1507
Wilmington, NC 28403
Raleigh, NC 27611
Washington, NC 27889

State of North Carolina
Department of Environment,TVA
Health and Natural Resources 4 • •
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary ID E M N R
A. Preston Howard, Jr., P.E., Director
DIVISION OF ENVIRONMENTAL MANAGEMENT
December 2, 1993
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. Verlis E. Miller
Vice President -Manufacturing
National Fruit Product Company, Incorporated
Post Office Box 2040
Winchester, Virginia 22601
Subject: Notice of Violation
National Fruit Product Co., Inc.
Lincolnton Plant
Non -Discharge Compliance
Evaluation Inspection
Permit No. WQ0003924
Lincoln County, N.C.
Dear Mr. Miller:
Enclosed is a copy of a non -discharge Compliance Evaluation
Inspection Report for the inspection conducted at the subject
facility on November 17, 1993, by Mr. Samar Bou-Ghazale of this
Office.
Because of numerous violations of permit limitations and
conditions, and North Carolina General Statute (NCGS) 143-215.1(a),
this letter is being issued as a Notice of Violation.
It is requested that a written respons.e be submitted to this
Office by December 14, 1993, addressing the deficiencies noted in
the Records/Reports, Operations And Maintenance, Facility Site
Review, and Self Monitoring sections of the enclosed report. In
responding, please address your comments to the attention of Mr.
Samar Bou-Ghazale.
Be advised that pursuant to NCGS 143-215.6A violation of
permit conditions and General statutes subjects the violator to
civil penalties not to exceed $10,000 per day per violation. This
office is considering the preparation of an enforcement action; you
will be advised of any action taken pertinent to our recommendation.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 60% recycled/ 10% post -consumer paper

V,175 .171 222
Receipt for
Certified Mail
No Insurance Coverage Provided
Do not use for International Mail
(See Reverse)
Sent to Mr. Verlis, E. Miller
Street and No.
Post Office Box 2040
P.O., State and ZIP Code
Winchester, VA 22601
Postage
� j

• Mr. Verlis E. Miller
Page 2
December 1, 1993
The enclosed report should be self-explanatory; however,
should you have any questions concerning this report, please do not
hesitate to contact Mr. Bou-Ghazale, Mr. D. Rex Gleason, (Water
Quality Regional Supervisor), or me.
Sincerely,
Brenda J. Smi �h,P.G.
Regional Supervisor
Enclosure
cc: Lincoln County Health Department
SBG

Name and Location of Facility Inspected
Facility Type
National Fruit Product Company, Incorporated
Spray Irrigation
Lincolnton, North Carolina Plant
Post Office Box 2040'
Permit Number
Winchester, Virginia 22601
WQ0003924
Entry Time 3:00 Ll AM LXPM
Exit- Time/Date
5:15 PM Nov. 17, 1993
Name(s) of On -Site Representative(s)
Title(s)
Mr. Jack Ross, Plant Manager
Mr. Bill Dembicki, Maint. Manager
Mr. Rick Leonhardt, ORC
Phone No.(s)
704-735-2531
Name, Address of Responsible Official
Title
Mr. Verlis E. Miller
Vice President -Manufacturing
National Fruit Product Company,Inc.
Post Office Box 2040
Phone No.
Winchester, Virginia 22601
703- 662-3401
Contacted
Permit Effective Date
Permit Expiration Date
Yes No x
December 31, 1990
December 31, 1995
Areas Evaluated During Inspection
(S=Satisfactory, M=Marginal, U=Unsatisfactory, N=Not Evaluated)
S
Permit
Records/Reports
Facility Site Review
U
Operations & Maintenance
Self -Monitoring Report
Other
U
U
U
Summary of Findings/Comments (Attach additional sheets if necessary)
Records/Reports: On November 6, 1993 approximately 60,000 gallons of
wastewater were sprayed in excess of the permit requirements. This
additional amount was not noted in the field book but was included on a
separate sheet of paper. Also, the permittee did not report non-compliance
with the permit, as required by permit condition III-5d.-
operations & Maintenance: The permit limits the volume of wastewater to be
irrigated to 60,000 GPD. According to our investigation, this permitted
discharge limit has been exceeded.
Facility Site Review:
Adequate measures have not been taken to prevent wastewater runoff from
the spray field. Waterflow over the west side of the spray field was noted
bypassing the existing berm and flowing into a water course in violation
of permit conditions II-4, 5, and 6.
Rain runoff from the parking lot where apples are being stored must be
contained by either covering the apples or by treating the discharged
water, neither is being done at this time.
Name(s) and Signature(s) of Inspector(s)
Date
Samar Bou-Ghazale
11/24/1993
Agency/Office/Telephone
DEHNR/Mooresville.[phone]

Self -Monitoring Report:
The spray irrigation data shows that 8,573,867 gallons
had been sprayed between November, 1992 and October, 1993.
The wastewater production shows that 15,882.,333 gallons
had been produced during the same period. The storage
capacity of the facility is only 950,000 gallons; thus
there is approximately 6,000,000 gallons of wastewater not
accounted for.

I
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State of North Carolina
Department of Natural Resources and Comn3unity Development
Mooresville Regional Office
James G. Martin, Governor
S. Thom -at "es, Secretary
Mr. Greg Hofe
Plant Manager
National Fruit Product Co., Inc.
P. 0. Box 916
Lincolnton, N. C. 28092
Dear Mr. Hofe:
Albert F. Hilton, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 12, 1986
Subject: National Fruit Product Co., Inc.
Wastewater Spray Irrigation System
Permit No. 3917
Lincoln County
During the inspection conducted on February 18, 1986 by Mr. Thurman Horne,
the subject facilities were noted to be operating in non-compliance. The matter
of non-compliance was discussed at length with you and various observations and
suggestions were made.
This letter is intended to document that the following observations and
suggestions were made:
1) Irrigation should not occur during periods of inclement weather.
2) National Fruit Product Co., Inc. (NFP) should fully investigate
the design adequacy and operating procedures of the subject
facilities, Particular attention should be given to the
following:
a) Does NFP have adequate storage capacity for periods
of inclement weather? Based on the reported
estimated flow and the existing holding capacity,
it appears that considerably more capacity is needed.
b) Investigate possible methods of flow reduction. A
large '.portion of the existing flow is -reported to
be cooling water. It may be possible to discharge
this cooling water directly to surface waters
(An NPDES permit is required. An application form
is attached'.)
919 North Wn Street, PA. Boot 9So, MoomWoe, NBC. 28w4m • Te e*m 7o44634699
Ari Equal Opportunity.,Afffr= e.Action,EmpkrAr .

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Mr. Greg Hofe
March 12, 1986
Page Two
c) Is irrigation being properly rotated between
different segments of the application field?
There was considerable evidence (ponding, etc.)
that proper rotation is not being employed.
3) The subject permit expires June 30, 1986. An application for renewal
should be submitted as soon as possible. An application form is
attached. The application for renewal should be accompanied
by a report of your investigation to the extent that the matters
cif non-compliance are addressed and we are assured that the system
can be expected to perform properly in the future.
As you requested, attached are copies of various design requirements, monitoring
report forms, etc., which relate to your present and future activities.
Please be advised that a Notice of Noncompliance has been sent to your offices
in Winchester, Virginia (Mr. James C. Zombro). A copy is attached for your records.
We appreciate your letter of February 20, 1986 and are encouraged by the
actions you have initiated. We look forward to working with you to resolve the
problems that exist now.
If you have any questions or if we can be of any assistance, please contact
Thurman Horne or me.
S' ely,
e, m�
Ronald L. McMillan
Regional Supervisor
Enclosure
cc: Air. James Zombro
Enforcement and Emergency Response
George Everette
Lincoln County Health Department
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State of North Carolina
Department of Natural Resources and Comrriunity Development
Mooresville Regional Office
James G. Martin, Governor
S. Thomas -Rhodes, Secretary
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. James C. Zombro, P. E.
National Fruit Product Company, Inc.
Post Office Box 2040
Winchester, VA 22601
Dear Mr. Zombro:
Albert F. Hilton, Regional Manager
DIVISION OF ENVIRONMENTAL MANAGEMENT
March 12, 1986
Subject: Notice of Noncompliance
National Fruit Product Co., Inc.
Wastewater Spray Irrigation
System
.Permit No. 3917
Lincoln County, North Carolina
An inspection of the subject facility was conducted on February 18,
1986 by Mr. Thurman Horne of this Office. The inspection revealed that the
facility was operating in noncompliance with the terms of the subject Permit.
Mr. Horne observed that the facilities were not performing satisfactorily and
that the irrigation area was not adequately absorbing the applied wastewater.
The inspection was conducted during a steady, prolonged rainfall and yet
it was observed that irrigation was in progress. Spray irrigation should not
occur during periods of inclement weather. The irrigation equipment was
observed to be in disrepair and in need of proper maintenance.
The observed violations are considered to be serious and warrant your
immediate attention. It is requested that you investigate this matter and take
immediate action to correct the observed inadequacies.
We request that you submit a written response to this Office by no later
than April 1, 1986 detailing your intended actions and providing a schedule
for achieving compliance.
Failure to correct the noted inadequacies or respond as requested may
result in a recommendation for enforcement action and/or revocation of the
subject Permit.
919 Nor'h Mein Spent, PC) Box 950, Mooresville, N.C. 28115-0950 • Telephone [phone]
An Equal opportunity Affirmative Ar-ei_ F....���

Mr. James C. Zombro, P. E.
Page Two
March 12, 1986
If you have any questions regarding this matter, please contact Thurman
Horne or me (704/663-1699).
Sincerely,
f r i
Ronald L. McMillan
Regional Supervisor
cc: Mr. George Everette
Mr. Gil Vinzani
Enforcement and Emergency Response
Lincoln County Health Department
Mr. Greg Hofe
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