NC0082821_Regional Office Historical File Pre 2018 (14)

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
Sam Koon
Southern States Fertilizer
6606 West Broad Street
Richmond, VA 23230
Dear Mr. Koon:
RFR.
& NATURAL RESOURCES
March 24, 1995 1995
MAR 28
DIVISION OF ENVIRONMENTAL '+'AIIAGEPAENT
MOORESVILLE MEAL OFFICE
Subject: NPDES Permit No. NC0082821
S.S. Fertilizer Plant
Iredell County
The Division agrees with Southern States' request to reduce pH. monitoring from weekly
to 2/month, consistent with monitoring requirements forgroundwater remediation projects.
Enclosed please find the corrected pages. The enclosed pages should be inserted into your
existing permit and the old pages discarded. This permit is issued pursuant to the requirements
of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between
North Carolina and the U. S. Environmental Protection Agency dated December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this
modification of the permit are unacceptable to you, 'you have the right to an adjudicatory hearing
upon written requestwithin thirty (30) days following receipt of this letter. 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 demand is made, this decision shall
be final and binding.
Please take notice that this permit is not transferable. Part II, E.4. addresses the
requirements to be followed in case of change in ownership or control of this discharge.
This permit does not affect the legal requirement to obtain other permits which may be
required by the Division of Environmental Management or permits required 'by the Division of
Land Resources, Coastal Area Management Act or any other Federal or Local governmental
permit that may be required.
If you have any questions concerning this permit, please contact Susan Wilson at telephone
number 919/733-5083.
Sicereiy,
Preston Howard, Jr., P.E.
cc: Mr. Roosevelt Childress, EPA
Mooresville _ Regional .Office
Compliance
Central Files
Permit File
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

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SUMMER (April 1- October 31) Permit No. NC0082821
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent. Characteristics
Flow**
NH3 as N
Total Suspended Residue
Copper
Chlorides
NO3-N
Chronic Toxicity***
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorus
Lbs/day
Discharge Limitations Monitoring
Units (specify) Measurement
Mon. Avg. Daily Max Mon. Avg. Daily Max, Frequency
Continuous
7.8 mg/I 2/Month
30.0 mg/I 45.0 mg/I 2/Month
Monthly
Monthly
Monthly
Quarterly
Monthly
Monthly
Requirements
Sample
Tyne
Recording
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
*Sample
Location
E
E
E
E
E
E
E
E
E
* Sample location: E - Effluent
** All volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is not feasible, then the discharger shall 1
record the approximate time that discharge began and ended, along with the instantaneous flow at the time of the effluent sampling.
*** Chronic Toxicity (Ceriodaphnia) P/F at 3%; See Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -WINTER (November 1- March 31) Permit No. NC0082821
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 001. Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow**
NH3 as N
Total Suspended Residue
Copper
Chlorides
NO3 - N
Chronic Toxicity***
Total Nitrogen (NO2+NO3+TKN)
Total Phosphorus
Discharge Limitations
Lbs/day
Units (specify)
Monitoring
Measurement
Mon. Avg. Daily Max Mon. Avg, Daily Max, Frequency
Continuous
2/Month
30.0 mg/1 45.0 mg/1 2/Month
Monthly
Monthly
Monthly
Quarterly
Monthly
Monthly
Requirements
Sample
Type
Recording
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
*Sample
Location
E
E
E
E
E
E
E
E
E
* Sample location: E - Effluent
** All volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is not feasible, then the discharger shall
record the approximate time that discharge began and ended, along with the instantaneous flow at the time of the effluent sampling.
*** Chronic Toxicity (Ceriodaphnia) P/F at 3%; See Part III, Condition E.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent by grab
sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

DoraSign Evelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NC0082821
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,
Southern States Cooperative, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Statesville Fertilizer Plant
2582 Salisbury Highway
Six Miles East of Statesville
Iredell County
to receiving waters designated as Fourth Creek in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective August 1, 2019.
This permit and authorization to discharge shall expire. at midnight on March 31, 2024.
Signed this day. 7/8/2019
r—DocuSigned by:
n ,
l'.-- 8328B44CE9EB4A1...
Linda Culpepper, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 7

DovSign Er ielope ID: CE09F386-1 C34-4CEB-B476-38E5F37F2553
Permit NC0082821
- SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this
permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority
to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included
herein.
Southern States Cooperative, Inc.
is hereby authorized to:
1. Continue to operate an existing 0.144 MGD groundwater remediation system with the following
components:
• Three recovery wells
♦ Lift station with wet well
• Caustic solution tank with pH measuring device
The facility is located six miles east of Statesville at the Statesville Fertilizer Plant, off U.S. Highway
70, in Iredell County; and
2. Discharge from said treatment works at the location specified on the attached map into Fourth Creek
[HUC: 030401020402], classified C waters in subbasin 03-07-06 of the Yadkin -Pee Dee River Basin.
Page 2 of 7

Do:riSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NC0082821
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B.0400 et seq., 02B.0500 et seq.]
Grade 1 Physical Chemical WPCS [15A NCAC 08G .0302]
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee
is authorized to discharge from outfall 001. Such discharges shall be limited and monitored' by the
Permittee asspecified below:
EFFLUENT CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
eDMR Code
Monthly Average,
�z, -,
Daily
Maximum
Measurement
Frequency
Fre uenc
Sample
T e�.
Yp '
Sample
',location_
Flow2 (MGD) 50050
Monitor & Report
Continuous
Recording
Effluent
Total Suspended Solids (mg/L) C0530
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
NH3 as N (April 1— October 31) (mg/L) C0610
7.8 mg/L
35.0 mg/I
2/Month
Grab
Effluent
NH3 as N (November 1 — March 31) (mg/L) C0610
Monitor & Report
2/Month
Grab
Effluent
pH (su) ' 00400
> 6.0 and < 9.0 standard units
2/Month
Grab
Effluent
Copper (pg/L) 01042
Monitor & Report
Monthly
Grab
Effluent
Chlorides (mg/L) 00940
Monitor & Report
Monthly
Grab
Effluent
Total Nitrates (NO3 — N) (mg/L) 00620
Monitor & Report
Monthly
Grab
Effluent
Total Nitrogen: (NO2+NO3+TKN) (mg/L) C0600
Monitor & Report
Monthly
Grab
Effluent
Total Phosphorus (mg/L) . C0665
Monitor & Report
Monthly
Grab
Effluent
Hardness — Total as
00900
[CaCO3 or (Ca+MG)] (mg/L)3
Monitor &.Report
Monthly
Grab
Effluent
Chronic Toxicity4(mg/L) TGP3B
Monitor & Report
Quarterly
Grab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using NC DWR's eDMR system. See
Condition A. (3.).
2. All volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is not
feasible, then the discharger shall record the approximate time that discharge began and ended, along with the
instantaneous flow at the time of the effluent sampling.
3. Effluent hardness sampling should be performed in conjunction with sampling for hardness dependent metals
(Copper).
4. Chronic Toxicity (Ceriodaphnia dubia) 7-day pass/fail test at 3% in February, May, August and November.
See condition A. (2.).
Conditions:
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 7

D rcuSign Envelope ID: CE09F386-1 C34-4CEB-B476-38E5F37F2553.
Permit NC0082821
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B.0200]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 3 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
February, May, August and November. These months signify the first month of each three-month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during
representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge
below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-3
(original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed, Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental. Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three-month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Page 4 of 7

Dci:uSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NC0082821
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY), continued
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Form submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the
last day of the month following the month of the initial monitoring.
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
[G.S.143-215.1(B)1
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program
reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21,
2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic
Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Page 5 of 7

Doj�uSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NC0082821
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary -waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative forms approved -by the Director. Duplicate signed copies shall be submitted to the mailing
address above. See "How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month following the
issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
Starting on December 21, 2020, the permittee must electronically report the following compliance
monitoring data and reports, when applicable:
• . Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request a
Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of
each electronic submission. The permittee should use the EPA's website resources to identify the
initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity
(EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool for
each type of electronic submission and for each state. Instructions on how to access and use the
appropriate electronic reporting tool will be available as well. Information on. EPA's NPDES
Electronic Reporting Rule is found at: http://www2.epa.gov/compliance/final-national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule.
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an
electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the
Division. Requests for temporary electronic reporting waivers must be submitted in writing to the
Division for written approval at least sixty (60) days prior to the date the facility would be required
under this permit to begin submitting monitoring data and reports. The duration of a temporary
waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports
shall be submitted electronically to the Division unless the permittee re -applies for and is granted a
new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers
are not transferrable. Only permittees with an approved reporting waiver request may submit
Page 6 of 7

DocuSigngnvelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Permit NC0082821
monitoring data and reports on paper to the Division for the period that the approved reporting
waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found on
the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that personas described in Part II,
Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and logincredentials to access the eDMR system. For more information on North Carolina's
eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following
web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
A. (4.) NUTRIENT REOPENER FOR HIGH ROCK LAKE
[NCGS 143.215.1 (b)]
This permit may be reopened and modified to implement nutrient requirements in accordance with any
future TMDL and/or nutrient management strategy for High Rock :Lake.
Page 7 of 7

DccuSign Epvelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
Copyright ©:2013,Ntional Geographic Society,—i-cubed
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NC0082821
Receiving Stream: Fourth Creek
Stream Segment: 12-108-20
River Basin: Yadkin -Pee Dee
County: Iredell
Stream Class: C
Sub -Basin #: 03-07-06
HUC: 030401020402
SCALE
1:20,000

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 1_ of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar year. In the case of fecal
coliform, the geometric mean of such discharges. •
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter '
One of the following, distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
(3)
Version 11/09/2011.2

DqcuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 2 of 18
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
> , Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters ,
> Influent samples shall not be collected more than once per hour.
• Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
• Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of nonnal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWR or "the Division"
The Division of Water Resources, Departmentof Environmental Quality.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Version 11/09/2011.2

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the. CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling. period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Resources.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act,,or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
Version 11/09/2011.2 ---

D9cuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 4 of 18
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a personshall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR • 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II.C.4), "Upsets" (Part II.C.5) and "Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights -
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
g•
Version 11/09/2011.2

DpcuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 5 of 18
7. Severability -
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Pennittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the :Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a. All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: byyeither a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization -specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individualoccupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
Version 11/09/2011.2

DpcuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 6 of 18
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility of f nes and imprisonment, for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.410)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Pennittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator: in
Responsible Charge (Back-up ORC).
Version 11/09/2011.2

DGcuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page7of18
(3) within seven calendar days of vacancies in both ORC and Back-up ORC. positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
• Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
• Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.41(m)(3)]
(1) Anticipated bypass. if the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at least ten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice):
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury or severe property damage;
(B) There were no feasible alteratives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
• condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
Version 11/09/2011.2

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 8 of 18
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is final administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Pernittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. 1Vlonitorine and Records
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.41(j)].
2. Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reportedon a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
Version 11/09/2011.2

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 9 of 18
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part l of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908) or visit https://deq.nc.gov/about/divisions/water-resources/water-
resources-data/water-sciences-home-page/laboratory-certification-branch for information regarding laboratory
certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or methodrequired to be maintained under this permitshall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41].
6 Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of allmonitoring information, including:
➢ all calibration and maintenance records
> all original strip chart recordings for continuous monitoring instrumentation
➢ copies of all reports required by this permit
➢ copies of all data used to complete the applicationfor this permit
Version 11/09/2011.2

DocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
• `
NPDES Permit Standard Conditions
Page 10 of 18
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions, of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable tunes, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
Version 11/09/2011.2

pociSignn Envelope ID: CE09F386-1 C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 11 of 18
particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Pennittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence_ of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part 11.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Pennittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnornal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1.31.8, all reports prepared in accordance with the terms shall be available for public inspection at the offices
—Version 11/09/2011.2

pocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 12 of 18
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2) or in Section 309 of the Federal Act.
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities, that primarily collect or treat municipal or domestic wastewater and have
an average annual flow greater than 200,000 gallons per day shall provide an annual report to the Permit Issuing
Authority and to the users/customers served by the Permittee (NCGS 143-215.1C). The report shall summarize the
performance of the collection or treatment system, as well as the extent to which the facility was compliant with
applicable Federal or State laws, regulations and rules pertaining to water quality. The report shall be provided no
later than sixty days after the end of the calendar or fiscal year, depending upon which annual period is used for
evaluation.
The report shall be sent to:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 11/09/2011.2

3ocuSign Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 13 of 18
PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-394], no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
c.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows of has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 1.tg/L) for acrolein and acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
Version 11/09/2011.2

DocuSigq Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 14 of 18
PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following definitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and (j) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Pernittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the.POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge pen -nit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition .above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
Version 11/09/2011.2

Docur,ign,Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 15 of 18
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficientinformation
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards.
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Pennittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
(3)
(5)
(7)
Version 11/09/2011.2

QocuSign,Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 16 of 18
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.44(j)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.44(j)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUO)
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.44(j)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Perrnittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(f)(2) and 403.9]
3. Monitoring, Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Perrnittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
Version 11109/20.11.2

C{ocuSign,Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit Standard Conditions
Page 17 of 18
enforceable Pretreatment Standard s as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all lUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtC)
The Pennittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (IUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)] •
7. POTW Inspection & Monitoring of their IUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;
b. Sample all Significant Industrial Users (SIUs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical Industrial User for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02110908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.44(j)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual. Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
Version 11/09/2011.2

Ciociign,Envelope ID: CE09F386-1C34-4CEB-B476-38E5F37F2553
NPDES Permit. Standard Conditions.
Page 18 of 18
NC DEQ / Division of Water Resources / Water Quality Permitting Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with, pretreatment requirements;
b. Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (IUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
IUs in SNC, a summary of data or other information related to significant noncompliance determinations for
IUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (IUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .09080); 40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [15A NCAC 02H
.0906(b)(9) and (10) and .0905; 40 CFR 403.8(f)(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 11/09/2011.2

A_TA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
April 2, 2014
Ms. Lauren Faulkner
Southern States Cooperative, Inc.
P. O. Box 26234
----Richmond, VA 23260
Subject: Issuance of NPDES Permit NC0082821
Southern States - Statesville Fertilizer Plant WWTP
Iredell County
Dear Ms. Faulkner:
John E. Skvarla, III
Secretary
APR 102014
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant
to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as
subsequently amended).
This fmal permit contains no significant changes to its terms from those found in the draft permit sent to
you on January 24, 2014. However, you are reminded of the new condition requiring electronic
reporting of discharge monitoring report (DMR) data using the Division's eDMR internet application.
This new requirement will become effective on February 1, 2015.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. 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 (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless
such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Resources or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required. I;
APR 14 2014
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 •
Phone: [phone] \Internet: www.ncwaterquality.org
An Equal opportunity \Affirmative Action Employer— Made in part by recycled paper

Ms. Lauren Faulkner
NC0082821 Permit Renewal 2014
p•2
If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919)
807-6398, or via e-mail at [e-mail].
Sincer-ly,
Thomas A. Reeder
cc: Central Files
1VI�`' or it Regio aLQfficeAVateiQ l ty,
NPDES File
ec: Aquatic Toxicology Unit
1

Permit NC0082821
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful standards
and regulations promulgated and adopted by the North Carolina Environmental Management
Commission, and the Federal Water Pollution Control Act, as amended,'
Southern States Cooperative, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Statesville Fertilizer Plant
2582 Salisbury Highway
Six Miles East of Statesville
Iredell County
to receiving waters designated as Fourth Creek in the Yadkin -Pee Dee River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective May 1, 2014.
This permit and authorization to discharge shall expire at midnight on March 31, 2019.
Signed this day April 2, 2014.
as A. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 8

Permit NC0082821
i
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the
permit conditions, requirements, terms, and provisions included herein.
Southern States Cooperative, Inc.
is hereby authorized to:
1. Continue to operate an existing 0.144 MGD groundwater remediation system with the following
components:
♦ Three recovery wells
• Lift station with wet well
• Caustic solution tank with pH measuring device
The facility is located six miles east of Statesville at the Statesville Fertilizer Plant, off U.S. Highway
70, in Iredell County.
2. Discharge from said treatment works at the location specified on the attached map into Fourth Creek,
classified C waters in subbasin 03-07-06 of the Yadkin -Pee Dee River Basin.
Page 2 of 8

Permit NC0082821
PART I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 001. Such discharges shall be limited and monitored].
by the Permittee as specified below:
EFFLUENT CHARACTERISTICS;
Parameter Code
LIMITS.
MONITORING REQUIREMENTS
Monthly
.Average
Daily
Maximum
'Measurement
Frequency
.. Sample
Type ;, .-
Sample
. Location
Flow2 50050
Monitor & Report
Continuous
Recording
Effluent
Total Suspended Solids C0530
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
NH3 as N (April 1— October 31) C0610
7.8 mg/L
35.0 mg/I
2/Month
Grab
Effluent
NH3 as N (November 1— March 31) C0610
Monitor & Report
2/Month
Grab.
Effluent
pH 00400
> 6.0 and < 9.0 standard units
2/Month
Grab
Effluent
Copper 01042
Monitor & Report
Monthly
Grab
Effluent
Chlorides - 00940
Monitor & Report •
Monthly
Grab
Effluent
Total Nitrates (NO3 — N) 00620
Monitor & Report
Monthly
Grab
Effluent
Total Nitrogen (NO2+NO3+TKN) C0600
Monitor & Report
Monthly
Grab
Effluent
Total Phosphorus C0665
Monitor & Report
Monthly
Grab
Effluent
Chronic Toxicity3 TP3B
•
Quarterly
Grab
Effluent
Footnotes:
1. No later than February 1, 2015 (270 days from the effective date of this permit), begin submitting
discharge monitoring reports electronically using NC DWR's eDMR application system. See
Condition A. (3.).
2. All: volumes of wastewater leaving the facility shall be monitored. If continuous flow monitoring is not
feasible, then the discharger shall record the approximate time that discharge began and ended, along with the
instantaneous flow at the time of the effluent sampling.
3. Chronic Toxicity (Ceriodaphnia dubia) 7-day pass/fail test at 3% in February, May, August and November.
See condition A. (2.).
There shall be no discharge of floating solids or visible foam in other than trace amounts
Page 3 of 8

Permit NC0082821
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 3 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in
the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised December 2010, or
subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"
(Revised- December 2010) or subsequent versions. The tests will be performed during the months of
February, May, August and November. These months signify the first month of each three month
toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained
during representative effluent discharge and shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV
below the permit limit, then multiple -concentration testing shall be performed at a minimum, in
each of the two following months as described in "North Carolina Phase II Chronic Whole
Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the parameter
code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally, DWR Form AT-
3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if
chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is
required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test
form indicating the facility name, permit number, pipe number, county, and the month/year of the report —
with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the
Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring
will be required during the following, month. Assessment of toxicity compliance is based on the toxicity
testing quarter, which is the three month time interval that begins on the first day of the month in which
toxicity testing is required by this permit and continues until the final day of the third month.
Page 4of8

Permit NC0082821
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY), continued
Should any test data from this monitoring requirement or tests performed by the North Carolina Division
of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
If the Permittee monitors any pollutant more frequently than required by this permit, the results of such
monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT
Form submitted.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls,
shall constitute an invalid test and will require immediate follow-up testing to be completed no later
than the last day of the month following the month of the initial monitoring.
Page 5 of 8

Permit NC0082821
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS
Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs)
and specify that, if a state does not establish a system to receive such submittals, then permittees must
submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates
that these regulations will be adopted and is beginning implementation in late 2013.
NOTE: This special condition supplements or supersedes the following sections within Part II of this
permit (Standard Conditions for NPDES Permits):
• Section B. (11.)
• Section D. (2.)
• Section D. (6.)
• Section E. (5.)
Signatory Requirements
Reporting
Records Retention
Monitoring Reports
1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1
Beginning no later than 270 days from the effective date of this permit, the permittee shall begin
reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month and
submitted electronically using eDMR. The eDMR system allows permitted facilities to enter
monitoring data and submit DMRs electronically using the internet. Until such time that the state's
eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation
(CROMERR), permittees will be required to submit all discharge monitoring data to the state
electronically using eDMR and will be required to complete the eDMR submission by printing,
signing, and submitting one signed original and a copy of the computer printed eDMR to the
following address:
NC DENR / DWR / Information Processing Unit
ATTENTION: Central Files / eDMR
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility
being physically located in an area where less than 10 percent of the households have broadband
access, then a temporary waiver from the NPDES electronic reporting requirements may be granted
and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or
alternative forms approved by the Director. Duplicate signed copies shall be submitted to the
mailing address above.
Requests for temporary waivers from the NPDES electronic reporting requirements must be
submitted in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid
for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted
electronically to the Division unless the permittee re -applies for and is granted a new temporary
waiver by the Division.
Page 6 of 8

Permit NC0082821
A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS, continued
Information on eDMR and application for a temporary waiver from the NPDES electronic reporting
requirements is found on the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Regardless of the submission method, the first DMR is due on the last day of the month following
the issuance of the permit or in the case of a new facility, on the last day of the month following the
commencement of discharge.
2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)1
All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II,
Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II,
Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR
reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit
the following web page:
http://portal.ncdenr.org/web/wq/admin/bog/ipu/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall make
the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION
WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information,
the information submitted is, to the best of my knowledge and belief true, accurate, and complete. I
am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations."
3. Records Retention [Supplements Section D. (6.)]
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from the
date of the report. This period may be extended by request of the Director at any time [40 CFR
122.41].
A. (4.) NUTRIENT REOPENER FOR HIGH ROCK LAKE
This permit may be reopened and modified to implement nutrient requirements in accordance with any
future TMDL and/or nutrient management strategy for High Rock Lake.
Page 7 of 8

Permit NC0082821
N..;m
t
C-
- .�f,
>�
„
I
\
r.
i1
.-
.
1 --1�,.
Itl
i
J
�,
t
a
,� %
rr
\,
1
i s
mop
t
.
h /}
j (I
�_
y $
`
' `YV'" '
'n %�. (/
r jz^ 1r r 1
Ka te�
`(j i a°
.� = y= =..� J
Z�i
\ \ � ' ! r ,,�
(�.��� y i{/_
� � �JJJ( ` 7 i V
t
/ 1
." --• ti
H`'�
),•\,...\\..)e../.:____,..0
_
1(�
i1ll%(~
, - ( (7,,, ,
\, , ' ��JJ_ S �/ f : >,,`
�1 ` ` \ J� `` }"��`�' `f 'i/—
-
{ s\
r
� ( ��
i �� z
�(I
s1)�
.
ll /
°, x
I
i ...---, --.,.;:... ,:,„Nc.e.,, fl',\._,.,,-).
i(
�: , • � r
. } .l� ,_ Q
♦\' 1Jrj`•
'^�
7 . V\ �`•
r.
ml
-• rot\L
`�-
•I c
�'�� Z ..F ���
Southern States Cooperative, Inc.
Latitude: 35°46'25" Sub -Basin: 03-07-06
;
Facility
Location '`
Longitude: 80°46'40" Quad Name: Statesville East
Stream Class: C Receiving Stream: Fourth Creek
North
NPDES Permit NC0082821
Iredell County
•
Page 8 of 8

NPDES Permit Standard Conditions
Page 1 of 18
PART II
STANDARD CONDITIONS FOR NPDES PERMITS
Section A. Definitions
2/Month
Samples are collected twice per month with at least ten calendar days between sampling events. These samples shall be
representative of the wastewater discharged during the sample period.
3/Week
Samples are collected three times per week on three separate calendar days. These samples shall be representative of
the wastewater discharged during the sample period.
Act or "the Act"
The Federal Water Pollution Control Act, also known as the Clean Water Act (CWA), as amended, 33 USC 1251, et.
seq.
Annual Average
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar. year. In the case of fecal
coliform, the geometric mean of such discharges.
Arithmetic Mean
The summation of the individual values divided by the number of individual values.
Bypass
The known diversion of waste streams from any portion of a treatment facility including the collection system, which is
not a designed or established or operating mode for the facility.
Calendar Day
The period from midnight of one day until midnight of the next day. However, for purposes of this permit, any
consecutive 24-hour period that reasonably represents the calendar day may be used for sampling.
Calendar Week
The period from Sunday through the following Saturday.
Calendar Quarter
One of the following distinct periods: January through March, April through June, July through September, and
October through December.
Composite Sample
A sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in
such a manner as to result in a total sample representative of the wastewater discharge during the sample period. The
Director may designate the most appropriate method (specific number and size of aliquots necessary, the time interval
between grab samples, etc.) on a case -by -case basis. Samples may be collected manually or automatically. Composite
samples may be obtained by the following methods:
(1) Continuous: a single, continuous sample collected over a 24-hour period proportional to the rate of flow.
(2) Constant time/variable volume: a series of grab samples collected at equal time intervals over a 24 hour period
of discharge and combined proportional to the rate of flow measured at the time of individual sample
collection, or
(3) Variable time/constant volume: a series of grab samples of equal volume collected over a 24 hour period with
the time intervals between samples determined by a preset number of gallons passing the sampling point. Flow
measurement between sample intervals shall be determined by use of a flow recorder and totalizer, and the
preset gallon interval between sample collection fixed at no greater than 1/24 of the expected total daily flow at
the treatment system, or
Version 11/09/2011

NPDES Permit Standard Conditions •
Page 2 of 18
(4) Constant time/constant volume: a series of grab samples of equal volume collected over a 24-hour period at a
constant time interval. Use of this method requires prior approval by the Director. This method may only be
used in situations where effluent flow rates vary less than 15 percent. The following restrictions also apply:
> Influent and effluent grab samples shall be of equal size and of no less than 100 milliliters
> Influent samples shall not be collected more than once per hour.
➢ Permittees with wastewater treatment systems whose detention time < 24 hours shall collect effluent grab
samples at intervals of no greater than 20 minutes apart during any 24-hour period.
➢ Permittees with wastewater treatment systems whose detention time exceeds 24 hours shall collect effluent
grab samples at least every six hours; there must be a minimum of four samples during a 24-hour sampling
period.
Continuous flow measurement
Flow monitoring that occurs without interruption throughout the operating hours of the facility. Flow shall be
monitored continually except for the infrequent times when there may be no flow or for infrequent maintenance
activities on the flow device.
Daily Discharge.
The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the
calendar day for purposes of sampling. For pollutants measured in units of mass, the "daily discharge" is calculated as
the total mass of the pollutant discharged over the day. For pollutants expressed in other units of measurement, the
"daily discharge" is calculated as the average measurement of the pollutant over the day. (40 CFR 122.2; see also
"Composite Sample," above.)
Daily Maximum
The highest "daily discharge" during the calendar month.
Daily Sampling
Parameters requiring daily sampling shall be sampled 5 out of every 7 days per week unless otherwise specified in the
permit. Sampling shall be conducted on weekdays except where holidays or other disruptions of normal operations
prevent weekday sampling. If sampling is required for all seven days of the week for any permit parameter(s), that
requirement will be so noted on the Effluent Limitations and Monitoring Page(s).
DWQ or "the Division"
The Division of Water Quality, Department of Environment and Natural Resources.
Effluent
Wastewater discharged following all treatment processes from a water pollution control facility or other point source
whether treated or untreated.
EMC
The North Carolina Environmental Management Commission
EPA
The United States Environmental Protection Agency
Facility Closure
Cessation of all activities that require coverage under this NPDES permit. Completion of facility closure will allow this
permit to be rescinded.
Geometric Mean
The Nth root of the product of the individual values where N = the number of individual values. For purposes of
calculating the geometric mean, values of "0" (or "< [detection level]") shall be considered = 1.
Grab Sample
Individual samples of at least 100 mL collected over a period of time not exceeding 15 minutes. Grab samples can be
collected manually. Grab samples must be representative of the discharge (or the receiving stream, for instream
samples).
Version 11/09/2011

NPDES Permit Standard Conditions
Page 3 of 18
Hazardous Substance
Any substance designated under 40 CFR Part 116 pursuant to Section 311 of the CWA.
Instantaneous flow measurement
The flow measured during the minimum time required for the flow measuring device or method to produce a result in
that instance. To the extent practical, instantaneous flow measurements coincide with the collection of any grab
samples required for the same sampling period so that together the samples and flow are representative of the discharge
during that sampling period.
Monthly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar month. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Permit Issuing Authority
The Director of the Division of Water Quality.
Quarterly Average (concentration limit)
The arithmetic mean of all samples taken over a calendar quarter.
Severe property damage
Substantial physical damage to property, damage to the treatment facilities which causes them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a
bypass. Severe property damage excludes economic loss caused by delays in production.
Toxic Pollutant:
Any pollutant listed as toxic under Section 307(a)(1) of the CWA.
Upset
An incident beyond the reasonable control of the Permittee causing unintentional and temporary noncompliance with
permit effluent limitations and/or monitoring requirements. An upset does not include noncompliance caused by
operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive
maintenance, or careless or improper operation.
Weekly Average (concentration limit)
The arithmetic mean of all "daily discharges" of a pollutant measured during the calendar week. In the case of fecal
coliform or other bacterial parameters or indicators, the geometric mean of such discharges.
Section B. General Conditions
1. Duty to Comply
The Permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of
the CWA and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of a permit renewal application [40 CFR 122.41].
a. The Permittee shall comply with effluent standards or prohibitions established under section 307(a) of the
CWA for toxic pollutants and with standards for sewage sludge use or disposal established under section
405(d) of the CWA within the time provided in the regulations that establish these standards or prohibitions or
standards for sewage sludge use or disposal, even if the permit has not yet been modified to incorporate the
requirement.
b. The CWA provides that any person who violates section[s] 301, 302, 306, 307, 308, 318 or 405 of the Act, or
any permit condition or limitation implementing any such sections in a permit issued under section 402, or any
requirement imposed in a pretreatment program approved under sections 402(a)(3) or 402(b)(8) of the Act, is
subject to a civil penalty not to exceed $37,500 per day for each violation. [33 USC 1319(d) and 40 CFR
122.41(a)(2)]
c. The CWA provides that any person who negligently violates sections 301, 302, 306, 307, 308, 318, or 405 of
the Act, or any condition or limitation implementing any of such sections in a permit issued under section 402
of the Act, or any requirement imposed in a pretreatment program approved under section 402(a)(3) or
402(b)(8) of the Act, is subject to criminal penalties of $2,500 to $25,000 per day of violation, or
Version 11/09/2011

NPDES Permit Standard Conditions
Page 4 of 18
imprisonment of not more than 1 year, or both. In the case of a second or subsequent conviction for a negligent
violation, a person shall be subject to criminal penalties of not more than $50,000 per day of violation, or by
imprisonment of not more than 2 years, or both. [33 USC 1319(c)(1) and 40 CFR 122.41(a)(2)]
d. Any person who knowingly violates such sections, or such conditions or limitations is subject to criminal
penalties of $5,000 to $50,000 per day of violation, or imprisonment for not more than 3 years, or both. In the
case of a second or subsequent conviction for a knowing violation, a person shall be subject to criminal
penalties of not more than $100,000 per day of violation, or imprisonment of not more than 6 years, or both.
[33 USC 1319(c)(2) and 40 CFR 122.41(a)(2)]
e. Any person who knowingly violates section 301, 302, 303, 306, 307, 308, 318 or 405 of the Act, or any permit
condition or limitation implementing any of such sections in a permit issued under section 402 of the Act, and
who knows at that time that he thereby places another person in imminent danger of death or serious bodily
injury, shall, upon conviction, be subject to a fine of not more than $250,000 or imprisonment of not more than
15 years, or both. In the case of a second or subsequent conviction for a knowing endangerment violation, a
person shall be subject to a fine of not more than $500,000 or by imprisonment of not more than 30 years, or
both. An organization, as defined in section 309(c)(3)(B)(iii) of the CWA, shall, upon conviction of violating
the imminent danger provision, be subject to a fine of not more than $1,000,000 and can be fined up to
$2,000,000 for second or subsequent convictions. [40 CFR 122.41(a)(2)]
f. Under state law, a civil penalty of not more than $25,000 per violation may be assessed against any person
who violates or fails to act in accordance with the terms, conditions, or requirements of a permit. [North
Carolina General Statutes § 143-215.6A]
Any person may be assessed an administrative penalty by the Administrator for violating section 301, 302,
306, 307, 308, 318 or 405 of this Act, or any permit condition or limitation implementing any of such sections
in a permit issued under section 402 of this Act. Administrative penalties for Class I violations are not to
exceed $16,000 per violation, with the maximum amount of any Class I penalty assessed not to exceed
$37,500. Penalties for Class II violations are not to exceed $16,000 per day for each day during which the
violation continues, with the maximum amount of any Class II penalty not to exceed $177,500. [33 USC
1319(g)(2) and 40 CFR 122.41(a)(3)]
2. Duty to Mitigate
The Permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal in
violation of this permit with a reasonable likelihood of adversely affecting human health or the environment [40
CFR 122.41(d)].
3. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing" (Part II.C.4), "Upsets" (Part II.C.5) and "Power Failures"
(Part II.C.7), nothing in this permit shall be construed to relieve the Permittee from any responsibilities, liabilities,
or penalties for noncompliance pursuant to NCGS 143-215.3, 143-215.6 or Section 309 of the Federal Act, 33 USC
1319. Furthermore, the Permittee is responsible for consequential damages, such as fish kills, even though the
responsibility for effective compliance may be temporarily suspended.
4. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the Permittee
from any responsibilities, liabilities, or penalties to which the Permittee is or may be subject to under NCGS 143-
215.75 et seq. or Section 311 of the Federal Act, 33 USG 1321. Furthermore, the Permittee is responsible for
consequential damages, such as fish kills, even though the responsibility for effective compliance may be
temporarily suspended.
5. Property Rights
The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive
privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any
infringement of Federal, State or local laws or regulations [40 CFR 122.41(g)].
6. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any onshore or offshore physical structures or
facilities or the undertaking of any work in any navigable waters.
g.
Version 11/09/2011

• NPDES Permit Standard Conditions
Page 5 of 18
7. Severability
The provisions of this permit are severable. If any provision of this permit, or the application of any provision of
this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby [NCGS 150B-23].
8. Duty to Provide Information
The Permittee shall furnish to the Permit Issuing Authority, within a reasonable time, any information which the
Permit Issuing Authority may request to determine whether cause exists for modifying, revoking and reissuing, or
terminating this permit or to determine compliance with this permit. The Permittee shall also furnish to the Permit
Issuing Authority upon request, copies of records required by this permit [40 CFR 122.41(h)].
9. Duty to Reapply
If the Permittee wishes to continue an activity regulated by this permit after the expiration date of this permit, the
Permittee must apply for and obtain a new permit [40 CFR 122.41(b)].
10. Expiration of Permit
The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to
discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required
by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a
later date has been granted by the Director. (The Director shall not grant permission for applications to be
submitted later than the expiration date of the existing permit.) [40 CFR 122.21(d)] Any Permittee that has not
requested renewal at least 180 days prior to expiration, or any Permittee that does not have a permit after the
expiration and has not requested renewal at least 180 days prior to expiration, will subject the Permittee to
enforcement procedures as provided in NCGS 143-215.6 and 33 USC 1251 et. seq.
11. Signatory Requirements
All applications, reports, or information submitted to the Permit Issuing Authority shall be signed and certified [40
CFR 122.41(k)].
a All permit applications shall be signed as follows:
(1) For a corporation: by a responsible corporate officer. For the purpose of this Section, a responsible
corporate officer means: (a) a president, secretary, treasurer or vice president of the corporation in charge
of a principal business function, or any other person who performs similar policy or decision making
functions for the corporation, or (b) the manager of one or more manufacturing, production, or operating
facilities, provided, the manager is authorized to make management decisions which govern the operation
of the regulated facility including having the explicit or implicit duty of making major capital investment
recommendations, and initiating and directing other comprehensive measures to assure long term
environmental compliance with environmental laws and regulations; the manager can ensure that the
necessary systems are established or actions taken to gather complete and accurate information for permit
application requirements; and where authority to sign documents has been assigned or delegated to the
manager in accordance with corporate procedures .
(2) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or
ranking elected official [40 CFR 122.22].
b. All reports required by the permit and other information requested by the Permit Issuing Authority shall be
signed by a person described in paragraph a. above or by a duly authorized representative of that person. A
person is a duly authorized representative only if:
(1) The authorization is made in writing by a person described above;
(2) The authorization specified either an individual or a position having responsibility for the overall operation
of the regulated facility or activity, such as the position of plant manager, operator of a well or well field,
superintendent, a position of equivalent responsibility, or an individual or position having overall
responsibility for environmental matters for the company. (A duly authorized representative may thus be
either a named individual or any individual occupying a named position.); and
(3) The written authorization is submitted to the Permit Issuing Authority [40 CFR 122.22]
Version 11/09/2011

NPDES Permit Standard Conditions •
Page 6 of 18
c. Changes to authorization: If an authorization under paragraph (b) of this section is no longer accurate because
a different individual or position has responsibility for the overall operation of the facility, a new authorization
satisfying the requirements of paragraph (b) of this section must be submitted to the Director prior to or
together with any reports, information, or applications to be signed by an authorized representative [40 CFR
122.22]
d. Certification. Any person signing a document under paragraphs a. or b. of this section shall make the following
certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED:
"1 certify, under penalty of law, that this document and all attachments were prepared under my direction or
supervision in accordance with a system designed to assure that qualified personnel properly gather and
evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or
those persons directly responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for
submitting false information, including the possibility, of and imprisonment for knowing violations."
12. Permit Actions
This permit may be modified, revoked and reissued, or terminated for cause. The filing of a request by the
Permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes
or anticipated noncompliance does not stay any permit condition [40 CFR 122.41(f)].
13. Permit Modification, Revocation and Reissuance, or Termination
The issuance of this permit does not prohibit the permit issuing authority, from reopening and modifying the permit,
revoking and reissuing the permit, or terminating the permit as allowed by the laws, rules, and regulations
contained in Title 40, Code of Federal Regulations, Parts 122 and 123; Title 15A of the North Carolina
Administrative Code, Subchapter 02H .0100; and North Carolina General Statute 143.215.1 et. al.
14. Annual Administering and Compliance Monitoring Fee Requirements
The Permittee must pay the annual administering and compliance monitoring fee within thirty days after being
billed by the Division. Failure to pay the fee in a timely manner in accordance with 15A NCAC 02H .0105(b)(2)
may cause this Division to initiate action to revoke the permit.
Section C. Operation and Maintenance of Pollution Controls
1. Certified Operator
Owners of classified water pollution control systems must designate operators, certified by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), of the appropriate type and grade for the
system, and, for each classification must [T15A NCAC 08G .0201]:
a. designate one Operator In Responsible Charge (ORC) who possesses a valid certificate of the type and grade at
least equivalent to the type and grade of the system;
b. designate one or more Back-up Operator(s) in Responsible Charge (Back-up ORCs) who possesses a valid
certificate of the type of the system and no more than one grade less than the grade of the system, with the
exception of no backup operator in responsible charge is required for systems whose minimum visitation
requirements are twice per year; and
c. submit a signed completed "Water Pollution Control System Operator Designation Form" to the Commission
(or to the local health department for owners of subsurface systems) countersigned by the designated certified
operators, designating the Operator in Responsible Charge (ORC) and the Back-up Operator in Responsible
Charge (Back-up ORC):
(1) 60 calendar days prior to wastewater or residuals being introduced into a new system; or
(2) within 120 calendar days following:
➢ receiving notification of a change in the classification of the system requiring the designation of a new
Operator in Responsible Charge (ORC) and Back-up Operator in Responsible Charge (Back-up ORC)
of the proper type and grade; or
➢ a vacancy in the position of Operator in Responsible Charge (ORC) or Back-up Operator in
Responsible Charge (Back-up ORC).
Version 11/09/2011

NPDES Permit Standard Conditions
Page 7 of 18
(3) within seven calendar days of vacancies in both ORC and Back-up ORC positions replacing or designating
at least one of the responsibilities.
The ORC of each Class I facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least weekly
➢ Comply with all other conditions of 15A NCAC 08G .0204.
The ORC of each Class II, III and IV facility (or the Back-up ORC, when acting as surrogate for the ORC) must:
➢ Visit the facility'as often as is necessary to insure proper operation of the treatment system; the treatment
facility must be visited at least five days per week, excluding holidays
➢ Properly manage and document daily operation and maintenance of the facility
➢ Comply with all other conditions of 15A NCAC 08G .0204.
2. Proper Operation and Maintenance
The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control
(and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions
of this permit. Proper operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary facilities only
when necessary to achieve compliance with the conditions of the permit [40 CFR 122.41(e)].
NOTE: Properly and officially designated operators are fully responsible for all proper operation and maintenance
of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a
member of the Permittee's staff.
3. Need to Halt or Reduce not a Defense
It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or
reduce the permitted activity in order to maintain compliance with the condition of this permit [40 CFR 122.41(c)].
4. Bypassing of Treatment Facilities
a. Bypass not exceeding limitations [40 CFR 122.41(m)(2)]
The Permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but
only if it also is for essential maintenance to assure efficient operation. These bypasses are not subject to the
provisions of Paragraphs b. and c. of this section.
b. Notice [40 CFR 122.4101m)(3)]
(1) Anticipated bypass. If the Permittee knows in advance of the need for a bypass, it shall submit prior notice,
if possible at leastten days before the date of the bypass; including an evaluation of the anticipated quality
and effect of the bypass.
(2) Unanticipated bypass. The Permittee shall submit notice of an unanticipated bypass as required in Part
II.E.6. (24-hour notice).
c. Prohibition of Bypass
(1) Bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass, unless:
(A) Bypass was unavoidable to prevent loss of life, personal injury -or severe property damage;
(B) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities,
retention of untreated wastes or maintenance during normal periods of equipment downtime. This
condition is not satisfied if adequate backup equipment should have been installed in the exercise of
reasonable engineering judgment to prevent a bypass which occurred during normal periods of
equipment downtime or preventive maintenance; and
(C) The Permittee submitted notices as required under Paragraph b. of this section.
(2) Bypass from the collection system is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for a bypass as provided in any current or future system -wide collection system
permit associated with the treatment facility.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 8 of 18
(3) The Permit Issuing Authority may approve an anticipated bypass, after considering its adverse effects, if
the Permit Issuing Authority determines that it will meet the three conditions listed above in Paragraph c.
(1) of this section.
5. Upsets
a. Effect of an upset [40 CFR 122.41(n)(2)]: An upset constitutes an affirmative defense to an action brought for
noncompliance with such technology based permit effluent limitations if the requirements of paragraph b. of
this condition are met. No determination made during administrative review of claims that noncompliance was
caused by upset, and before an action for noncompliance, is fmal administrative action subject to judicial
review.
b. Conditions necessary for a demonstration of upset: Any Permittee who wishes to establish the affirmative
defense of upset shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant
evidence that:
(1) An upset occurred and that the Permittee can identify the cause(s) of the upset;
(2) The Permittee facility was at the time being properly operated; and
(3) The Permittee submitted notice of the upset as required in Part II.E.6.(b) of this permit.
(4) The. Permittee complied with any remedial measures required under Part II.B.2. of this permit.
c. , Burden of proof [40 CFR 122.41(n)(4)]: The Permittee seeking to establish the occurrence of an upset has
the burden of proof in any enforcement proceeding.
6. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters
shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant
from such materials from entering waters of the State or navigable waters of the United States except as permitted
by the Commission. The Permittee shall comply with all applicable state and Federal regulations governing the
disposal of sewage sludge, including 40 CFR 503, Standards for the Use and Disposal of Sewage Sludge; 40 CFR
Part 258, Criteria For Municipal Solid Waste Landfills; and 15A NCAC Subchapter 2T, Waste Not Discharged To
Surface Waters. The Permittee shall notify the Permit Issuing Authority of any significant change in its sludge use
or disposal practices.
7. Power Failures
The Permittee is responsible for maintaining adequate safeguards (as required by 15A NCAC 02H .0124) to
prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means
of alternate power sources, standby generators or retention of inadequately treated effluent.
Section D. Monitoring and Records
1. Representative Sampling
Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge.
Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the
discharge for the period the sample represents. All samples shall be taken at the monitoring points specified in this
permit and, unless otherwise specified, before the effluent joins or is diluted by any other wastestream, body of
water, or substance. Monitoring points shall not be changed without notification to and the approval of the Permit
Issuing Authority [40 CFR 122.41(j)].
2.- Reporting
Monitoring results obtained during the previous month(s) shall be summarized for each month and reported on a
monthly Discharge Monitoring Report (DMR) Form (MR 1, 1.1, 2, 3) or alternative forms approved by the
Director, postmarked no later than the last calendar day of the month following the completed reporting period.
The first DMR is due on the last day of the month following the issuance of the permit or in the case of a new
facility, on the last day of the month following the commencement of discharge. Duplicate signed copies of these,
and all other reports required herein, shall be submitted to the following address:
Version 11/09/2011

NPDES Permit Standard Conditions
Page 9 of 18
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Flow Measurements
Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected
and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The
devices shall be installed, calibrated and maintained to ensure that the accuracy of the measurements is consistent
with the accepted capability of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge
volumes. Flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained
to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device.
The Director shall approve the flow measurement device and monitoring location prior to installation.
Once -through condenser cooling water flow monitored by pump logs, or pump hour meters as specified in Part I of
this permit and based on the manufacturer's pump curves shall not be subject to this requirement.
4. Test Procedures
Laboratories used for sample analysis must be certified by the Division. Permittees should contact the Division's
Laboratory Certification Section (919 733-3908 or http://portal.ncdenr.org/web/wq/lab/cert) for information
regarding laboratory certifications.
Facilities whose personnel are conducting testing of field -certified parameters only must hold the appropriate field
parameter laboratory certifications.
Test procedures for the analysis of pollutants shall conform to the EMC regulations (published pursuant to NCGS
143-215.63 et. seq.), the Water and Air Quality Reporting Acts, and to regulations published pursuant to Section
304(g), 33 USC 1314, of the CWA (as amended), and 40 CFR 136; or in the case of sludge use or disposal,
approved under 40 CFR 136, unless otherwise specified in 40 CFR 503, unless other test procedures have been
specified in this permit [40 CFR 122.41].
To meet the intent of the monitoring required by this permit, all test procedures must produce minimum detection
and reporting levels that are below the permit discharge requirements and all data generated must be reported down
to the minimum detection or lower reporting level of the procedure. If no approved methods are determined
capable of achieving minimum detection and reporting levels below permit discharge requirements, then the most
sensitive (method with the lowest possible detection and reporting level) approved method must be used.
5. Penalties for Tampering
The CWA provides that any person who falsifies, tampers with, or knowingly renders inaccurate, any monitoring
device or method required to be maintained under this permit shall, upon conviction, be punished by a fine of not
more than $10,000 per violation, or by imprisonment for not more than two years per violation, or by both. If a
conviction of a person is for a violation committed after a first conviction of such person under this paragraph,
punishment is a fine of not more than $20,000 per day of violation, or by imprisonment of not more than 4 years,
or both [40 CFR 122.41].
6. Records Retention
Except for records of monitoring information required by this permit related to the Permittee's sewage sludge use
and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR
503), the Permittee shall retain records of all monitoring information, including:
> all calibration and maintenance records
> all original strip chart recordings for continuous monitoring instrumentation
> copies of all reports required by this permit
> copies of all data used to complete the application for this permit
These records or copies shall be maintained for a period of at least 3 years from the date of the sample,
measurement, report or application. This period may be extended by request of the Director at any time [40 CFR
122.41].
Version 11/09/2011

NPDES Permit Standard Conditions
Page 10 of 18
7. Recording Results
For each measurement or sample taken pursuant to the requirements of this permit, the Permittee shall record the
following information [40 CFR 122.41]:
a. The date, exact place, and time of sampling or measurements;
b. The individual(s) who performed the sampling or measurements;
c. The date(s) analyses were performed;
d. The individual(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of such analyses.
8. Inspection and Entry
The Permittee shall allow the Director, or an authorized representative (including an authorized contractor acting as
a representative of the Director), upon the presentation of credentials and other documents as may be required by
law, to;
a. Enter, at reasonable times, upon the Permittee's premises where a regulated facility or activity is located or
conducted, or where records must be kept under the conditions of this permit;
b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring and control equipment), practices,
or operations regulated or required under this permit; and
d. Sample or monitor at reasonable times, for the purposes of assuring permit compliance or as otherwise
authorized by the CWA, any substances or parameters at any location [40 CFR 122.41(i)].
Section E Reporting Requirements
1. Change in Discharge
All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of
any pollutant identified in this permit more frequently than or at a level in excess of that authorized shall constitute
a violation of the permit.
2. Planned Changes
The Permittee shall give notice to the Director as soon as possible of any planned physical alterations or additions
to the permitted facility [40 CFR 122.41(1)]. Notice is required only when:
a. The alteration or addition to a permitted facility may meet one of the criteria for new sources at 40 CFR
122.29(b); or
b. The alteration or addition could significantly change the nature or increase the quantity of pollutants
discharged. This notification applies to pollutants subject neither to effluent limitations in the permit, nor to
notification requirements under 40 CFR 122.42(a)(1); or
c. The alteration or addition results in a significant change in the Permittee's sludge use or disposal practices, and
such alteration, addition or change may justify the application of permit conditions that are different from or
absent in the existing permit, including notification of additional use or disposal sites not reported during the
permit application process or not reported pursuant to an approved land application plan.
3. Anticipated Noncompliance
The Permittee shall give advance notice to the Director of any planned changes to the permitted facility or other
activities that might result in noncompliance with the permit [40 CFR 122.41(1)(2)].
4. Transfers
This permit is not transferable to any person without prior written notice to and approval from the Director in
accordance with 40 CFR 122.61. The Director may condition approval in accordance with NCGS 143-215.1, in
particular NCGS 143-215.1(b)(4)b.2., and may require modification or revocation and reissuance of the permit, or
a minor modification, to identify the new permittee and incorporate such other requirements as may be necessary
under the CWA [40 CFR 122.41(1)(3), 122.61] or state statute.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 11 of 18
5. Monitoring Reports
Monitoring results shall be reported at the intervals specified elsewhere in this permit [40 CFR 122.41(1)(4)].
a. Monitoring results must be reported on a Discharge Monitoring Report (DMR) (See Part II.D.2) or forms
provided by the Director for reporting results of monitoring of sludge use or disposal practices.
b. If the Permittee monitors any pollutant more frequently than required by this permit using test procedures
approved under 40 CFR Part 136 and at a sampling location specified in this permit or other appropriate
instrument governing the discharge, the results of such monitoring shall be included in the calculation and
reporting of the data submitted on the DMR.
6. Twenty-four Hour Reporting
a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance that
potentially threatens public health or the environment. Any information shall be provided orally within 24
hours from the time the Permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the Permittee becomes aware of the circumstances. The written submission
shall contain a description of the noncompliance, and its cause; the period of noncompliance, including exact
dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected to
continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncompliance [40
CFR 122.41(1)(6)].
b. The Director may waive the written report on a case -by -case basis for reports under this section if the oral
report has been received within 24 hours.
c. Occurrences outside normal business hours may also be reported to the Division's Emergency Response
personnel at [phone], [phone] or [phone].
7. Other Noncompliance
The Permittee shall report all instances of noncompliance not reported under Part II.E.5 and 6. of this permit at the
time monitoring reports are submitted. The reports shall contain the information listed in Part II.E.6. of this permit
[40 CFR 122.41(1)(7)].
8. Other Information
Where the Permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted
incorrect information in a permit application or in any report to the Director, it shall promptly submit such facts or
information [40 CFR 122.41(1)(8)].
9. Noncompliance Notification
The Permittee shall report by telephone to either the central office or the appropriate regional office of the Division
as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following:
a. Any occurrence at the water pollution control facility which results in the discharge of significant amounts of
wastes which are abnormal in quantity or characteristic, such as the dumping of the contents of a sludge
digester; the known passage of a slug of hazardous substance through the facility; or any other unusual
circumstances.
b. Any process unit failure, due to known or unknown reasons, that render the facility incapable of adequate
wastewater treatment such as mechanical or electrical failures of pumps, aerators, compressors, etc.
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass without treatment of all
or any portion of the influent to such station or facility.
Persons reporting such occurrences by telephone shall also file a written report within 5 days following first
knowledge of the occurrence. Also see reporting requirements for municipalities in Part IV.C.2.c. of this permit.
10. Availability of Reports
Except for data determined to be confidential under NCGS 143-215.3 (a)(2) or Section 308 of the Federal Act, 33
USC 1318, all reports prepared in accordance with the terms shall be available for public inspection at the offices
of the Division. As required by the Act, effluent data shall not be considered confidential. Knowingly making any
false statement on any such report may result in the imposition of criminal penalties as provided for in NCGS 143-
215.1(b)(2) or in Section 309 of the Federal Act.
Version 11/09/2011

NPDES Permit Standard Conditions
Page 12 of 18
11. Penalties for Falsification of Reports
The CWA provides that any person who knowingly makes any false statement, representation, or certification in
any record or other document submitted or required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than
$25,000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41].
12. Annual Performance Reports
Permittees who own or operate facilities that collect or treat municipal or domestic waste shall provide an annual
report to the Permit Issuing Authority and to the users/customers served by the Permittee (NCGS 143-215.1 C). The
report shall summarize the performance of the collection or treatment system, as well as the extent to which the
facility was compliant with applicable Federal or State laws, regulations and rules pertaining to water quality. The
report shall be provided no later than sixty days after the end of the calendar or fiscal year, depending upon which
annual period is used for evaluation.
The report shall be sent to:
NC DENR / Division of Water Quality / Surface Water Protection Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 11/09/2011

• NPDES Permit Standard Conditions
Page 13of18
PART III
OTHER REQUIREMENTS
Section A. Construction
a. The Permittee shall not commence construction of wastewater treatment facilities, nor add to the plant's treatment
capacity, nor change the treatment process(es) utilized at the treatment plant unless (1) the Division has issued an
Authorization to Construct (AtC) permit or (2) the Permittee is exempted from such AtC permit requirements
under Item b. of this Section.
b. In accordance with NCGS 143-215.1(a5) [SL 2011-394], no permit shall be required to enter into a contract for the
construction, installation, or alteration of any treatment work or disposal. system or to construct, install, or alter any
treatment works or disposal system within the State when the system's or work's principle function is to conduct,
treat, equalize, neutralize, stabilize, recycle, or dispose of industrial waste or sewage from an industrial facility and
the discharge of the industrial waste or sewage is authorized under a permit issued for the discharge of the
industrial waste or sewage into the waters of the State. Notwithstanding the above, the permit issued for the
discharge may be modified if required by federal regulation.
Issuance of an AtC will not occur until Final Plans and Specifications for the proposed construction have been
submitted by the Permittee and approved by the Division.
c.
Section B. Groundwater Monitoring
The Permittee shall, upon written notice from the Director, conduct groundwater monitoring as may be required to
determine the compliance of this NPDES permitted facility with the current groundwater standards.
Section C. Changes in Discharges of Toxic Substances
The Permittee shall notify the Permit Issuing Authority as soon as it knows or has reason to believe (40 CFR 122.42):
a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of
any toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the following
"notification levels";
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and, acrylonitrile; five hundred micrograms per liter
(500 µg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for
antimony;
(3) Five times the maximum concentration value reported for that pollutant in the permit application.
b. That any activity has occurred or will occur which would result in any discharge, on a non -routine or infrequent
basis, of a toxic pollutant which is not limited in the permit, if that discharge will exceed the highest of the
following "notification levels";
(1) Five hundred micrograms per liter (500 µg/L);
(2) One milligram per liter (1 mg/L) for antimony;
(3) Ten times the maximum concentration value reported for that pollutant in the permit application.
Section D. Facility Closure Requirements
The Permittee must notify the Division at least 90 days prior to the closure of any wastewater treatment system covered
by this permit. The Division may require specific measures during deactivation of the system to prevent adverse
impacts to waters of the State. This permit cannot be rescinded while any activities requiring this permit continue at the
permitted facility.
Version 11/09/2011

NPDES Permit Standard Conditions •
Page 14 of 18
PART IV
SPECIAL CONDITIONS FOR MUNICIPAL FACILITIES
Section A. Definitions
In addition to the definitions in Part II of this permit, the following defmitions apply to municipal facilities:
Indirect Discharge or Industrial User
Any non -domestic source that discharges wastewater containing pollutants into a POTW regulated under section
307(b), (c) or (d) of the CWA. [40 CFR 403.3 (i) and (j) and 15A NCAC 02H .0903(b)(11)]
Interference
Inhibition or disruption of the POTW treatment processes; operations; or its sludge process, use, or disposal which
causes or contributes to a violation of any requirement of the Permittee's (or any satellite POTW's if different from the
Permittee) NPDES, collection system, or non -discharge permit or prevents sewage sludge use or disposal in
compliance with specified applicable State and Federal statutes, regulations, or permits. [15A NCAC 02H
.0903(b)(14)]
Pass Through
A discharge which exits the POTW into waters of the State in quantities or concentrations which, alone or with
discharges from other sources, causes a violation, including an increase in the magnitude or duration of a violation, of
the Permittee's (or any satellite POTW's, if different from the Permittee) NPDES, collection system, or non -discharge
permit. [15A NCAC 02H .0903(b)(23)]
Publicly Owned Treatment Works (POTW)
A treatment works as defined by Section 212 of the CWA, which is owned by a State or local government organization.
This definition includes any devices and systems used in the storage, treatment, recycling and reclamation of municipal
sewage or industrial wastes of a liquid nature. It also includes the collection system, as defined in 15A NCAC 2T
.0402, only if it conveys wastewater to a POTW treatment plant. The term also means the local government
organization, or municipality, as defined in section 502(4) of the CWA, which has jurisdiction over indirect discharges
to and the discharges from such a treatment works. In this context, the organization may be the owner of the POTW
treatment plant or the owner of the collection system into which an indirect discharger discharges. This second type of
POTW may be referred to as a "satellite POTW organization." [15A NCAC 02H .0903(b)(26)]
"Significant Industrial User" or "SIU"
An Industrial User that discharges wastewater into a publicly owned treatment works and that [15A NCAC 02H
.0903(b)(33)]:
1. Discharges an average of 25,000 gallons per day or more of process wastewater to the POTW (excluding sanitary,
noncontact cooling and boiler blowdown wastewaters); or
2. Contributes process wastewater which makes up five percent or more of the NPDES or non -discharge permitted
flow limit or organic capacity of the POTW treatment plant. In this context, organic capacity refers to BOD, TSS
and ammonia; or
3. Is subject to categorical standards under 40 CFR Part 403.6 and 40 CFR Parts 405-471; or
4. Is designated as such by the Permittee on the basis that the Industrial User has a reasonable potential for adversely
affecting the POTW's operation or for violating any pretreatment standard or requirement, or the POTW's effluent
limitations and conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options;
5. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraphs 1 or 2 of this definition above has no reasonable potential for adversely affecting the
POTW's operation or for violating any pretreatment standard or requirement, the POTW's effluent limitations and
conditions in its NPDES or non -discharge permit, or to limit the POTW's sludge disposal options, and thus is not a
Significant Industrial User (SIU); or
6. Subject to approval under 15A NCAC 02H .0907(b), the Permittee may determine that an Industrial User meeting
the criteria in paragraph 3 of this definition above meets the requirements of 40 CFR Part 403.3(v)(2) and thus is a
non -significant categorical Industrial User.
Section B. Publicly Owned Treatment Works (POTWs)
Version 11/09/2011

NPDES Permit Standard Conditions
Page 15 of 18
All POTWs must provide adequate notice to the Director of the following [40 CFR 122.42(b)]:
1. Any new introduction of pollutants into the POTW from an indirect discharger, regardless of the means of
transport, which would be subject to section 301 or 306 of CWA if it were directly discharging those pollutants;
and
2. Any substantial change in the volume or character of pollutants being introduced by an indirect discharger as
influent to that POTW at the time of issuance of the permit.
3. For purposes of this paragraph, adequate notice shall include information on (1) the quality and quantity of effluent
introduced into the POTW, and (2) any anticipated impact that may result from the change of the quantity or
quality of effluent to be discharged from the POTW.
Section C. Municipal Control of Pollutants from Industrial Users.
1. Effluent limitations are listed in Part I of this permit. Other pollutants attributable to inputs from Industrial Users
discharging to the POTW may be present in the Permittee's discharge. At such time as sufficient information
becomes available to establish limitations for such pollutants, this permit may be revised to specify effluent
limitations for any or all of such other pollutants in accordance with best practicable technology or water quality
standards. •
2. Prohibited Discharges
a. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibition against the
introduction of pollutants or discharges into the waste treatment system or waste collection system which
cause or contribute to Pass Through or Interference as defined in 15A NCAC 02H .0900 and 40 CFR 403. [40
CFR 403.5(a)(1)]
b. The Permittee shall develop and enforce their Pretreatment Program to implement the prohibitions against the
introduction of the following wastes in the waste treatment or waste collection system [40 CFR 403.5(b)]:
(1) Pollutants which create a fire or explosion hazard in the POTW, including, but not limited to,
wastestreams with a closed cup flashpoint of less than 140 degrees Fahrenheit or 60 degrees Centigrade
using the test methods specified in 40 CFR 261.21;
(2) Pollutants which cause corrosive structural damage to the POTW, but in no case discharges with pH lower
than 5.0, unless the works is specifically designed to accommodate such discharges;
Solid or viscous pollutants in amounts which cause obstruction to the flow in the POTW resulting in
Interference;
(4) Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a Discharge at a flow rate
and/or pollutant concentration which will cause Interference with the POTW;
(5) Heat in amounts which will inhibit biological activity in the POTW resulting in Interference, but in no
case heat in such quantities that the temperature at the POTW Treatment Plant exceeds 40°C (104°F)
unless the Division, upon request of the POTW, approves alternate temperature limits;
(6) Petroleum oil, non -biodegradable cutting oil, or products of mineral oil origin in amounts that will cause
Interference or Pass Through;
(7) Pollutants which result in the presence of toxic gases, vapors, or fumes within the POTW in a quantity that
may cause acute worker health and safety problems; or
(8) Any trucked or hauled pollutants, except at discharge points designated by the POTW.
c. The Permittee shall investigate the source of all discharges into the POTW, including slug loads and other
unusual discharges, which have the potential to adversely impact the Permittee's Pretreatment Program and/or
the operation of the POTW.
The Permittee shall report such discharges into the POTW to the Director or the appropriate Regional Office.
Any information shall be provided orally within 24 hours from the time the Permittee became aware of the
circumstances. A written submission shall also be provided within 5 days of the time the Permittee becomes
aware of the circumstances. The written submission shall contain a description of the discharge; the
investigation into possible sources; the period of the discharge, including exact dates and times; if the
discharge has not ceased, the anticipated time it is expected to continue; and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the noncompliance,
(3)
Version 11/09/2011

NPDES Permit Standard Conditions
Page 16 of 18•
3. With regard to the effluent requirements listed in Part I of this permit, it may be necessary for the Permittee to
supplement the requirements of the Federal Pretreatment Standards (40 CFR, Part 403) to ensure compliance by
the Permittee with all applicable effluent limitations. Such actions by the Permittee may be necessary regarding
some or all of the industries discharging to the municipal system.
4. The Permittee shall require any Industrial User (IU) discharging to the POTW to meet Federal Pretreatment
Standards developed under Section 307(b) of the Act as amended (which includes categorical standards and
specific local limits, best management practices and narrative requirements). Prior to accepting wastewater from
any Significant Industrial User (SIU), the Permittee shall either develop and submit to the Division a new
Pretreatment Program or, as necessary, a modification of an existing Pretreatment Program, for approval as
required under section D below as well as 15A NCAC 02H .0907(a) and (b). [40 CFR 122.44(j)(2)]
5. This permit shall be modified, or alternatively, revoked and reissued, to incorporate or modify an approved POTW
Pretreatment Program or to include a compliance schedule for the development of a POTW Pretreatment Program
as required under Section 402 (b)(8) of the CWA and implementing regulations or by the requirements of the
approved State pretreatment program, as appropriate.
Section D. Pretreatment Programs
Under authority of sections 307 (b) and (c) and 402(b)(8) of the CWA and implementing regulations 40 CFR 403,
North Carolina General Statute 143-215.3(14) and implementing regulations 15A NCAC 02H .0900, and in accordance
with the approved pretreatment program, all provisions and regulations contained and referenced in the pretreatment
program submittal are an enforceable part of this permit. [40 CFR 122.44(j)(2)]
The Permittee shall operate its approved pretreatment program in accordance with Section 402(b)(8) of the CWA, 40
CFR 403, 15A NCAC 02H .0900, and the legal authorities, policies, procedures, and financial provisions contained in
its pretreatment program submission and Division approved modifications thereof. Such operation shall include but is
not limited to the implementation of the following conditions and requirements. Terms not defined in Part II or Part IV
of this permit are as defined in 15A NCAC 02H .0903 and 40 CFR 403.3.
1. Sewer Use Ordinance (SUOJ
The Permittee shall maintain adequate legal authority to implement its approved pretreatment program. [15A
NCAC 02H .0903(b)(32), .0905 and .0906(b)(1); 40 CFR 403.8(f)(1) and 403.9(b)(1) and (2)]
2. Industrial Waste Survey (IWS)
The Permittee shall implement an IWS consisting of the survey of users of the POTW collection system or
treatment plant, as required by 40 CFR 403.8(f)(2)(i-iii) and 15A NCAC 02H .0905 [also 40 CFR 122.44(j)(1)],
including identification of all Industrial Users that may have an impact on the POTW and the character and amount
of pollutants contributed to the POTW by these Industrial Users and identification of those Industrial Users
meeting the definition of SIU. Where the Permittee accepts wastewater from one or more satellite POTWs, the
IWS for the Permittee shall address all satellite POTW services areas, unless the pretreatment program in those
satellite service areas is administered by a separate Permittee with an approved Pretreatment Program. The
Permittee shall submit a summary of its IWS activities to the Division at least once every five years, and as
required by the Division. The IWS submission shall include a summary of any investigations conducted under
paragraph C.2.c. of this Part. [15A NCAC 02H .0903(b)(13), .0905 and .0906(b)(2); 40 CFR 403.8(0(2) and 403.9]
3. Monitoring Plan
The Permittee shall implement a Division -approved Monitoring Plan for the collection of facility specific data to
be used in a wastewater treatment plant Headworks Analysis (HWA) for the development of specific pretreatment
local limits. Effluent data from the Plan shall be reported on the DMRs (as required by Parts II.D and II.E.5.). [15A
NCAC 02H .0903(b)(16), .0906(b)(3) and .0905]
4. Headworks Analysis (HWA) and Local Limits
The Permittee shall obtain Division approval of a HWA at least once every five years, and as required by the
Division. Within 180 days of the effective date of this permit (or any subsequent permit modification) the
Permittee shall submit to the Division a written technical evaluation of the need to revise local limits (i.e., an
updated HWA or documentation of why one is not needed) [40 CFR 122.44]. The Permittee shall develop, in
accordance with 40 CFR 403.5(c) and 15A NCAC 02H .0909, specific Local Limits to implement the prohibitions
listed in 40 CFR 403.5(a) and (b) and 15A NCAC 02H .0909. Pursuant to 40 CFR 403.5, local limits are
Version 11/09/2011

NPDES Permit Standard Conditions
Page17of18
enforceable Pretreatment Standards as defined by 40 CFR 403.3(1). [15A NCAC 02H .0903(b)(10), .0905, and
.0906(b)(4)]
5,. Industrial User Pretreatment Permits (IUP) & Allocation Tables
In accordance with NCGS 143-215.1, the Permittee shall issue to all Significant Industrial Users, permits for
operation of pretreatment equipment and discharge to the Permittee's collection system or treatment works. These
permits shall contain limitations, sampling protocols, reporting requirements, appropriate standard and special
conditions, and compliance schedules as necessary for the installation of treatment and control technologies to
assure that their wastewater discharge will meet all applicable pretreatment standards and requirements. The
Permittee shall maintain a current Allocation Table (AT) which summarizes the results of the HWA and the limits
from all IUPs. Permitted IUP loadings for each parameter cannot exceed the treatment capacity of the POTW as
determined by the HWA. [15A NCAC 02H .0906(b)(6), .0909, .0916, and .0917; 40 CFR 403.5, 403.8(f)(1)(iii);
NCGS 143-215.67(a)]
6. Authorization to Construct (AtC)
The Permittee shall ensure that an Authorization to Construct permit (AtC) is issued to all applicable Industrial
Users for the construction or modification of any pretreatment facility. Prior to the issuance of an AtC, the
proposed pretreatment facility and treatment process must be evaluated for its capacity to comply with all
Industrial User Pretreatment Permit (IUP) limitations. [15A NCAC 02H .0906(b)(7) and .0905; NCGS 143-
215.1(a)(8)]
7. POTW Inspection & Monitoring of their IUs
The Permittee shall conduct inspection, surveillance, and monitoring activities as described in its Division
approved pretreatment program in order to determine, independent of information supplied by Industrial Users,
compliance with applicable pretreatment standards. [15A NCAC 02H .0908(e); 40 CFR 403.8(f)(2)(v)] The
Permittee must:
a. Inspect all Significant Industrial Users (SIUs) at least once per calendar year;
b. Sample all Significant Industrial Users (SIUs) at least once per calendar year for all SIU permit -limited
parameters including flow except as allowed under 15A NCAC .0908(e); and
c. At least once per year, document an evaluation of any non -significant categorical. IndustrialUser for
compliance with the requirements in 40 CFR 403.3(v)(2), and either continue or revoke the designation as non-
significant.
8. IU Self Monitoring and Reporting
The Permittee shall require all Industrial Users to comply with the applicable monitoring and reporting
requirements outlined in the Division -approved pretreatment program, the industry's pretreatment permit, or in 15A
NCAC 02H .0908. [15A NCAC 02H .0906(b)(5) and .0905; 40 CFR 403.8(f)(1)(v) and (2)(iii); 40 CFR
122.44(j)(2) and 40 CFR 403.12]
9. Enforcement Response Plan (ERP)
The Permittee shall enforce and obtain appropriate remedies for violations of all pretreatment standards
promulgated pursuant to section 307(b) and (c) of the CWA (40 CFR 405 et. seq.), prohibitive discharge standards
as set forth in 40 CFR 403.5 and 15A NCAC 02H .0909, specific local limitations, and other pretreatment
requirements. All remedies, enforcement actions and other, shall be consistent with the Enforcement Response
Plan (ERP) approved by the Division. [15A NCAC 02H .0903(b)(7), .0906(b)(8) and .0905; 40 CFR 403.8(f)(5)]
10. Pretreatment Annual Reports (PAR)
The Permittee shall report to the Division in accordance with 15A NCAC 02H .0908. In lieu of submitting annual
reports, Modified Pretreatment Programs developed under 15A NCAC 02H .0904 (b) may be required to submit a
partial annual report or to meet with Division personnel periodically to discuss enforcement of pretreatment
requirements and other pretreatment implementation issues.
For all other active pretreatment programs, the Permittee shall submit two copies of a Pretreatment Annual Report
(PAR) describing its pretreatment activities over the previous calendar year to the Division at the following
address:
Version 11/09/2011

NPDES Permit Standard Conditions - .
Page18of18
NC DENR / Division of Water Quality / Surface Water Protection Section
Pretreatment, Emergency Response, and Collection Systems (PERCS) Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
These reports shall be submitted by March 1 of each year and shall contain the following:
a. Narrative
A narrative summary detailing actions taken, or proposed, by the Permittee to correct significant non-
compliance and to ensure compliance with pretreatment requirements;
b. Pretreatment Program Summary (PPS)
A pretreatment program summary (PPS) on forms or in a format provided by the Division;
c. Significant Non -Compliance Report (SNCR)
A list of Industrial Users (lUs) in significant noncompliance (SNC) with pretreatment requirements, and the
nature of the violations on forms or in a format provided by the Division;
d. Industrial Data Summary Forms (IDSF)
Monitoring data from samples collected by both the POTW and the Significant Industrial Users (SIUs). These
analytical results must be reported on Industrial Data Summary Forms (IDSF) or on other forms or in a format
provided by the Division;
e. Other Information
Copies of the POTW's allocation table, new or modified enforcement compliance schedules, public notice of
lUs in SNC, a summary of data or other information related to significant noncompliance determinations for
lUs that are not considered SIUs, and any other information, upon request, which in the opinion of the Director
is needed to determine compliance with the pretreatment implementation requirements of this permit;
11. Public Notice
The Permittee shall publish annually a list of Industrial Users (lUs) that were in significant noncompliance (SNC)
as defined in the Permittee's Division -approved Sewer Use Ordinance with applicable pretreatment requirements,.
and standards during the previous twelve month period. This list shall be published within four months of the
applicable twelve-month period. [15A NCAC 02H .0903(b)(34), .0908(b)(5) and .0905 and 40 CFR
403.8(f)(2)(viii)]
12. Record Keeping
The Permittee shall retain for a minimum of three years records of monitoring activities and results, along with
support information including general records, water quality records, and records of industrial impact on the
POTW and shall retain all other Pretreatment Program records as required by 15A NCAC 02H .0908(f). [15A
NCAC 02H .0908(f); 40 CFR 403.12(o)]
13. Pretreatment Program Resources
The Permittee shall maintain adequate funding and qualified personnel to accomplish the objectives of its approved
pretreatment program. and retain a written description of those current levels of inspection. [15A NCAC 02H.
.0906(b)(9) and (10) and .0905; 40 CFR 403.80)(3), 403.9(b)(3)]
14. Modification to Pretreatment Programs
Modifications to the approved pretreatment program including but not limited to local limits, modifications, POTW
monitoring of their Significant Industrial Users (SIUs), and Monitoring Plan modifications, shall be considered a
permit modification and shall be governed by 40 CFR 403.18, 15 NCAC 02H .0114 and 15A NCAC 02H .0907.
Version 11/09/2011

FINENEDINCDENR/DWR
JAN .2 3 2020
WQROS
MOORESVIL E REGIONAL OFFICE
Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
Prepared for
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230
Submitted to
North Carolina Department of Environmental Quality
Division of Water Resources
Mooresville Regional Office.
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
Prepared by
Duncklee & Dunham, P.C.
511 Keisler Drive, Suite 102
Cary, North Carolina
January 13, 2020
DUNCKLEE & DUNHAM, P.0

AVo V P 20 ao - Pd -- oo 5-Z

DUNCKLEE
& DUNHAM
January 13, 2020
Mr. Edward Watson
North Carolina Department of Environmental Quality
Division of Water Resources
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville, North Carolina 28115
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE — SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DUNCKLEEDUNHAM.COM
Reference: Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
Incident Number 5038
Dear Mr. Watson:
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. is pleased to
submit this Report of Annual Groundwater Monitoring for the above -referenced site. This report
summarizes the work we conducted and presents our recommendations derived from groundwater
monitoring in October and November 2019. Please contact Jayson Kilcoyne at [phone], extension
108, if you have any questions or require additional information.
Sincerely,
Duncklee & Dunham, P.C.
Peter Sumner, G.I.T.
Staff Geologist
yson A. Kilcoyne.
Project Manager II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist / Vice President
ec: Jennifer Bunting — Southern States C000perative, Inc. (e-copy)
P:\Southem States\Statesville Fertilizer - 50200\Reports\2019\19778 - Annual GW Rep.docx
MAILING ADDRESS — POST OFFICE Box 639 — CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DEQ REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061

Table of Contents
1 Introduction 1
1.1 Site Location, Description, and History 1
1.2 Summary of Remedial Actions 2
2 Treatment -System Maintenance and Monitoring 2
3 Monitoring Well -Sampling Activities and Results 3
3.1 Monitoring Well -Sampling Methodology 3
3.2 Results from Sampling Event 3
3.2.1 Nitrate Results and Trends 4
3.2.2 Ammonia Results and Trends 4
4 Recommendations 5
Figures
1 Site Topographic Map
2 Site Map with Cross -Section Traces
3 Map of Treatment System Discharge Line
4 Potentiometric Surface Map — October 2019
5 Shallow Aquifer Nitrate Isoconcentration Map — October 2019
6 Deep Aquifer Nitrate Isoconcentration Map — October/November 2019
7 Cross Section A -A' — October 2019
8 Cross Section B-B' — October 2019
Tables
1 Historical Recovery Well Results
2 Summary of Water -table Elevation Data
3 Summary of Groundwater Analytical and Field Parameter Results
Appendices
A Laboratory Analytical Reports
B Trend Graphs of Nitrate and Ammonia in Groundwater

Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, North Carolina
January 13, 2020
1 Introduction
1.1 Site Location, Description, and History
The Southern States Cooperative, Inc. (Southern States) fertilizer plant (site) is located at
2582 Salisbury Highway (Old U.S. Highway 70), approximately 6 miles east of Statesville, North Carolina
(Figure 1). The site is developed with several buildings that include a fertilizer -manufacturing building, an
office building, a warehouse, several small support buildings, and multiple aboveground storage tanks
(ASTs; Figure 2). The site is utilized for the manufacture, storage, and distribution of fertilizer. The site
is bordered to the north by Salisbury Highway; to the east by McNess Road, across which are Fertie
Technologies and Land 0' Lakes Purina; to the south by U.S. Highway 70 Bypass (70 Bypass), across
which are single-family residences; and to the west by agricultural land. The 70 Bypass crosses east to
west through the southern portion of the site and separates approximately 13 acres from the main property
consisting of approximately 61 acres to the north.
Groundwater at the site contains ammonia and nitrate from releases of liquid ammonium nitrate that
apparently flowed into four surface -water ponds formerly on the site. Two ponds were formerly located
approximately 1,000 feet southwest of the main plant, and two ponds were formerly located east and
southeast of the main plant. These ponds are referenced in the Corrective Action Plan (CAP) dated January
28, 1994, submitted by Canonie Environmental Services, Inc. (Canonie) to the North Carolina Department
of Environment, Health and Natural Resources (DEHNR), Division of Environmental Management (now
called the Department of Environmental Quality, or DEQ). The DEHNR approved the CAP in 1994. The
CAP showed the extent of impact to groundwater was defined with reasonable certainty. The objectives of
the CAP were to remediate groundwater and to prevent off -site migration of the contaminant plume.
Canonie developed a groundwater -sampling plan that established a semiannual groundwater -sampling
schedule to monitor the effectiveness of the CAP.
In an email dated April 30, 2014, to Duncklee & Dunham from Andrew Pitner of DEQ, they agreed with
our recommendation in the 2013 Annual Groundwater Monitoring and Treatment System Effectiveness
Report to reduce the frequency of groundwater monitoring from semiannual to annual.
On behalf of Southern States, Duncklee & Dunham researched nitrate -treatment technologies, evaluated
remedial alternatives for the subject site, and reported our findings to DEQ in the 2015 Annual Groundwater
Monitoring and Treatment System Effectiveness Report, dated November 9, 2015. We recommended in
the report that the continued operation of the existing treatment system appears to be the most cost-effective
approach to remove contaminant mass from groundwater and control off -site migration of the plume. We
met with DEQ personnel at the subject site on December 9, 2015, to discuss the findings and remedial
alternatives presented in our 2015 report. During this meeting, DEQ requested and Southern States agreed
to 1) begin semiannual sampling of the extraction wells, 2) collect vertical -gradient data from the
monitoring wells that surround RW-2, and 3) extend the operational period of the treatment system
throughout the year.
DUNCKLEE & DUNHAM, P.C.
1

Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
January 13, 2020
Page 2 of 5
1.2 Summary of Remedial Actions
Groundwater -recovery wells RW-2, RW-5r and RW-6 were constructed as part of the CAP. These wells
pump groundwater to a treatment system, in which the pH is adjusted by adding a caustic solution to the
water prior to discharge into Fourth Creek (Figure 3).
The groundwater -treatment system is permitted under the National Pollution Discharge Elimination System
(NPDES) program. Duncklee & Dunham conducts bi-monthly site visits to maintain and monitor the
treatment system. We collect effluent water samples bi-monthly and report the data to DEQ on monthly
Discharge Monitoring Reports (DMRs).
2 Treatment -System Maintenance and Monitoring
The groundwater -treatment system operated during this reporting period from October 17, 2018, to October
15, 2019. The system operated for 351 days during this operation period. On February 13, 2019, facility
personnel observed that the caustic pump to the treatment system was not pumping caustic solution into the
wet well and temporarily shut off the system for repairs. On February 27, 2019, facility personnel replaced
a valve in the caustic pump and a North Carolina licensed Grade I Wastewater Operator (operator)
reactivated the system. During a March 25, 2019, site visit, the operator found that the water line leading
from RW-2 ,to the treatment system was broken. Facility personnel shut off the well to repair the piping
and the well was reactivated on March 28, 2019.
A summaryof the volumes of water removed by each extraction well during this reporting period is detailed
below.
Monitoring Period: October 17, 2018 — October 15, 2019
Well ID
Volume of Water (Gallons)
RW-5r
1,203,866.8
RW-6
1,133,417.0
RW-2
19,139,355.0
Duncklee & Dunham collects water samples bi-annually from the three recovery wells. We collect the
samples from spigots located near the wellheads and submit the samples to Prism Laboratories, Inc. (Prism)
to be tested for nitrate according to the United States Environmental Protection Agency (EPA) Method 300
and ammonia nitrogen according to SM4500. The results are summarized in Table 1 and the laboratory
analytical reports are in Appendix A.
In accordance with the NPDES permit, the operator collects treatment system effluent samples bi-monthly
for analysis of total suspended solids (TSS) according to Method SM 2540D and ammonia nitrogen
according to SM 4500. The operator also collects monthly effluent samples for analysis of copper according
to EPA Method 200.7, total phosphorus according to SM 4500, total Kjeldahl nitrogen according to EPA
Method 351.2, total nitrate and chloride according to EPA Method 300. In accordance with the current
permit issued on August 1, 2019, the operator now collects monthly effluent samples for total hardness
according to EPA Method 200.7. We submit the effluent samples to Prism for laboratory analysis. The
operator also collects effluent samples for analysis of Ceriodaphnia chronic toxicity (chronic toxicity)
according to the December 2010 North Carolina Phase II Chronic Whole Effluent Toxicity test procedure.
DUNCKLEE & DUNHAM, P.C.

Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
January 13, 2020
Page 3 of 5
We collected samples to be tested for chronic toxicity in November 2018, and in February, May, and
September 2019. We resampled for chronic toxicity testing in August 2019 and September 2019 due to
invalid tests resulting from a freon gas release in the laboratory. We submitted these samples to Pace
National (Pace [formerly ESC Lab, Sciences]) and submitted quarterly chronic toxicity reports to DEQ as
required by the NPDES permit.
3 Monitoring Well -Sampling Activities and Results
Duncklee & Dunham conducted annual groundwater -monitoring activities on October 29 and 30, 2019.
We purged and re -sampled monitoring well K65W6E on November 11, 2019, to verify an abnormally low
nitrate concentration in the sample collected during the October event. Prior to purging and sampling each
well, we measured depths to the water table with an electric water -level probe and recorded these data on
field -sampling data sheets. These depths and respective water -table elevations are summarized on Table 2.
A map of the potentiometric surface that illustrates the direction of groundwater flow for the October 2019
sampling event is presented as Figure 4. The direction of groundwater flow during the event was S5°W
and the average hydraulic gradient was 0.047 ft/ft, which is consistent with historical trends.
3.1 Monitoring Well -Sampling Methodology
Duncklee & Dunham collected groundwater samples from 10 of the 14 monitoring wells during the October
2019 sampling event. We did not sample K65W6D because this well is damaged and has historically been
dry during sampling events since February 1993. K65W7C is damaged and has remained dry since April
2011. Monitoring wells K65W7F and K65W7G were dry during this event.
Duncklee & Dunham purged the wells and collected samples with a submersible, electric pump fitted with
new, disposable polyethylene tubing from the wells greater than 60 feet in depth, and used a peristaltic
pump fitted with new tubing for the wells less than 60 feet in depth. We collected the groundwater samples
using low -flow sampling techniques. During the sampling process, we recorded field measurements for
dissolved oxygen (DO), oxidation-reduction potential (ORP), pH, temperature, turbidity, and electrical
conductivity (Table 3).
Duncklee & Dunham discharged the groundwater samples directly into labeled laboratory -provided
containers, recorded the samples on a chain -of -custody form, and transported the containers to Prism in a
cooler filled with ice. Prism tested the samples for nitrate according to EPA Method 300 and ammonia
nitrogen according to SM4500. The laboratory analytical reports are in Appendix A.
3.2 Results from Sampling Event
Nitrate isoconcentration maps are presented as Figures 5 and 6. Nitrate and ammonia concentrations are
displayed on Cross Sections A -A' and B-B', Figures 7 and 8, respectively. The test results are summarized
on Table 3 and graphs of the nitrate and ammonia trends over time are in Appendix B.
DUNCKLEE & DUNHAM, P.C.

Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
January 13, 2020
Page 4 of 5
3.2.1 Nitrate Results and Trends
We observed the following with respect to the nitrate results.
• Samples from saprolite wells K65W6A, -6B, -6N, and -7J, and samples from bedrock wells K65W6E,
-7K and -7L contained nitrate at concentrations that exceed the North Carolina groundwater quality
standard (2L standard) of 10 mg/L.
• The nitrate concentration in the sample from saprolite well K65W6N decreased from 110 mg/L during
the previous sampling event to 90 mg/L in October 2019. The nitrate concentration in the sample from
well K65W7L decreased from 110 mg/L to 96 mg/L. The nitrate concentration in the sample from well
K65W7J decreased from 120 mg/L to 89 mg/L, which is the lowest concentration detected in samples
from this well since October 2005.
• Samples from bedrock monitoring well K65W6E, located near the former location of Pond B, have
exhibited an increasing trend in nitrate concentrations since May 1997.
• The sample from bedrock well K65W6B, located in the northern zone of the plume, contained nitrate
at a concentration that exceeds the 2L standard, but remains consistent with historical concentrations.
• The nitrate concentration in the sample from saprolite well K65W6A, located in the core of the plume,
increased from 93 mg/L to 160 mg/L. The October 2018 sample from bedrock well K65W7K contained
nitrate at a concentration of 96 mg/L, which is the highest concentration detected in samples from this
well since October 2009.
• Samples from saprolite wells K65W6M and -7D and bedrock well K65W7H, at the southern extent of
the plume, did not contain nitrate at concentrations that exceed the 2L standard.
3.2.2 Ammonia Results and Trends
We observed the following with respect to the ammonia results.
• The sample collected from saprolite well K65W7J contained ammonia at a concentration that exceeds
the current Interim Maximum Allowable Concentration (IMAC) of 1.5 mg/L. Ammonia concentrations
in samples from K65W7J have exceeded the IMAC since October 2010. The 2019 sample contained
ammonia at a concentration of 5.5 mg/L, which is the highest ammonia concentration detected in this
well.
• The sample collected from bedrock well K65W7K, located in the center of the plume, contained
ammonia at a concentration that exceeds the IMAC, but remains consistent with historical
concentrations.
• The ammonia concentration in the sample from bedrock well K65W7L decreased from 5.5 mg/L during
the previous sampling event to 1.2 mg/L in October 2019, which is below the IMAC.
• Samples from bedrock monitoring well K65W6E, located near the former location of Pond B, have
exhibited a decreasing trend in ammonia concentrations since November 2011. The ammonia
concentration in the sample slightly decreased from 0.36 mg/L during the previous event to 0.16 mg/L
in November 2019.
• Samples from saprolite wells K65W6A, -6B, -6M, -6N, and -7D and bedrock well K65W7H did not
contain ammonia at detectable concentrations.
DUNCKLEE & DUNHAM, P.C.

Report of Annual Groundwater Monitoring
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
January 13, 2020
Page 5 of 5
4 Recommendations
Based on the information presented above, Duncklee & Dunham recommends the following:
• Continue to operate the groundwater -treatment system in accordance with the CAP.
• Test groundwater samples collected from the three recovery wells for nitrate and ammonia on a bi-
annual basis and conduct the next event in June 2020.
• Continue the groundwater -monitoring program on an annual basis and conduct the next sampling event
in October 2020.
DUNCKLEE &.DUNHAM, P.C.

SOJn!d

r
\_` ‹r.P.1_ 3�� 1 , J:;_j}I,.)1(,�% 1,
f� L
0 2000'
Contour Interval = 10ft
4000'
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 Keislcr Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.dunckleedunham.com
NC Geo. License No. C-261
Site Topographic Map
Southern States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
mrw
Checked By:
5k
Project Number:
50200
Date: References:
November 2018 IUSGS TopoView Statesville East- 1995
Scale:
1"=2000'
Size:
8.5" x I1"
Layers:
0,1
Filename:
P:1SoOhem SUta\sutcs,;ne Fertilizer- 501901CAD1Site Topo.dxg
Figure
1

B- tBrook R'.d
250' 500'
Contour Int rval = 10'
Oo
t9
Warehouse
K65W6N
Statesville
Fertilizer
Plant
K65W6D
K65WGB
Site Map with Cross -Section Traces
Southern States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
K6®6E
K65W6A
RW-5r
median
System
Drawn By:
pis
Checked By:
SK
Project Number:
50200
Date:
December 2019
References:
NC OnMep - ned<g Cerny. Field Notts
Scale: Size:
1"=250' 11"x171I
ayers:
0-14
Filename:
M.SwtFvn SYtes..m.e RAIL= 3020UG1Riu Map dvg
Fcrti
Technologies
Cardinal
Logistics
Management
Legend
Q Boundary of Subject Site
Boundary of Tax Parcel
xxxxxtf Railroad Tracks
15 Topographic Map Contours
El Water -supply Well
® Saprolite-Screened Monitoring Well
Bedrock -Screened Monitoring Well
Damaged Monitoring Well
Recovery Well
Cross Section Transects
0-0
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS AND ENGINEERS
511 Keisler Drive Suite 102
Cary. North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.duncklecdunham.com
NC Geo. License No. C-261

•
(WS
11
1000'
Fourth Creek
Fourth Creek Sewage
Treatment Plant
John Long Road
Salisbury Highway
2000
(to
l9
I I
Southem States
Fertilizer Plant
L
■
Highway
70
Map of Treatment System Discharge Line
Southem States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Ifci Buckbee Road
Drawn By:
mnv
Scale:
1" = 1000' 11" x 17" 0,1-6
Checked By: Project Number:
5K 50200
Size: Layers:
Date:
November 2018
References:
nc- ede5Ccumy
Filename:
lFvhem Su¢3SaYmiile FcrWsr- 50:OPd'APTrea.. 5yvm Wcharge Lute
LOP deg
Discharge
Point to Creek
Outfall 001
At
Legend
I I
Boundary of Subject Site
Boundary of Tax Parcel
0 Boundary of Water Bodies
- Treatment System Discharge Line
1 II
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS ANDENGINEERS
511 Keister Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.dunckleedunlarn.eom
NC Geo. License No. C-261

B t Brook R d
B(785.82)
K5 W7D
K65 W 7H
K65W7F
DRY
250' 500
Contour Interval = 10'
t7a
M
U.S. Highw
K65W7C
RW-2
K65W7
DRY\
Warehouse
® (832.27)
Statesville
Fertilizer
Plant
K65W6N
K65W7L
K65W6D
RW-6
ig Forest Drive
(804.61)
K65W6B
(848.46)
1Lmcdiati
System
Potentiometr c Surface Map - October 2019
Southem Stat s Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By: (Checked By:
pjs SK
Project Number:
50200
Date:
December2019
References:
NCenAap•ht. Cowry.FieId Nou.
Scale: Size:
1"=250' 11"x17"
Layers:
0-12,14,21
Filename:
P.l.wMn SauAsua.vale Foul., GM . wp.dw;
Fcrti
Technologies
Cardinal
Logistics
Management
Legend
® Boundary of Subject Site
Boundary of Tax Parcel
4 iO4+8 H1f Railroad Tracks
�eso� Topographic Contour (in ft amsl)
( Water -Supply Well
S Saprolite-Screened Monitoring Well
Bedrock -Screened Monitoring We11
93 Damaged Monitoring Well
Recovery Well
(785.82) Water -Table Elevation (in ft amsl)
DRY Well Dry; Water Level Not Measured
✓�.pa Potentiometric-Surface Contour
'v.._ Groundwater Flow Direction
Note: ft amsl - Feet above mean sea level
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS AND ENGINEERS
511 Keisler Drive Suite 102
Cary. North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.dunckleedunham.com
NC Geo. License No. C-261

o--„,...1\.....s.c.....
Warehou/se
I�\O
/
Statesville
/
/
Fertilize/
PIgpF
SO/-
/
/ / /
/
/ .Bg5W6N
K65 W 7H ev�:... RW-2
K65W7F•" K65W7
DRY DRY
"Sa
250'
Contour Interval = 10'
00
t9
mcdiatich
System
/
Cardinal
Logistics
Management
500'
Shallow Aquifer Nitrate Isoconcentration Map - October 2019
Southem States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
pjs
Checked By:
SK
Project Number:
50200
Date:
December 2019
References:
NC tre..I>p-u d<a C,.,a Field Ndu
Lab rm.
Scale:
1" = 250'
Size:
11"x17"
Layers:
0-12,14,25
Filename:
P.l9wMvn SmteSSutendle Fut izer-50200 ...te Map deg
Legend
Q Boundary of Subject Site
Boundary of Tax Parcel
xxx«xtW Railroad Tracks
�eso•••• Topographic Contour (in ft amsl)
® Water -Supply Well
9 Saprolite-Screened Monitoring Well
Bedrock -Screened Monitoring Well
® Damaged Monitoring Well
® Recovery Well
(0 29) Nitrate Concentration in mg/L
DRY Well Dry; Not Sampled
./� so Nitrate Isoconcentration Contour in m
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS AND ENGINEERS
511 Keisler Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
nww.duncklccdunham.com
NC Geo. License No. C-261

K65W7D
®K65W7C
(1.0)
K65W7H
K65W7F
250'
500'
Contour Int rva1= 10'
t i;
co
YI
Warehouse
Statesville
Fertilizer
Plant
K65 W6B®
/ (340 A) 1 1
g€# / K655W6E
F K'"655W6A 1
RW-Sr
/ # mcdiati
System /
// / / 1 /
/
/ //// (7/
ii
Sc. /e / / /
/ I'' / /
Deep Aquifer Nitrate Isoconcentration Map - October/November 2019
Southern States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
pis
Checked By: Project Number: Date:
5k 50200 December2019
References:
NCOvellap.b,&fC y. Field Na<>
I.ab rrr,de
Scale: Size: Layers: Filename:
1" = 250' 11" x 17" 0-12,14,23 PIS.d.m SYamiSteten. Fmil= 5e:000ADS. Maydvg
Ferti
Technologies
Legend
Boundary of Subject Site
0 Boundary of Tax Parcel
+a+Nxxr Railroad Tracks
�rda� Topographic Contour (in ft amsl)
® Water -Supply Well
Saprolite-Screened Monitoring Well
Bedrock -Screened Monitoring Well
® Damaged Monitoring Well
- , Recovery Well
(019) Nitrate Concentration in mg/L
/� sa Nitrate Isoconcentration Contour in m
Note: A- Result is above laboratory analyser calibration range.
DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS AND ENGINEERS
511 Keisler Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
+nv+r.duncklecdunham.com
NC Geo. License No. C-261

Monitoring Well with Outer Casing
00
O
O
00
O
I I I I I
I I I I I
-r + +
+ ++ + +
+ + +
+ +
+ + +
1 +
+
+ + +
r + ++T
+ +
++
+ + .
+ + +
+ + +
+ + +-
+ + +
+ +
+ + —
+ T +
+ + +
+ +
+ +
+ + i-
T + +
+ r
+ T +
+ + +
4- J ++
+ +-+ +
+ +T+ +
+ +• r+ + +
• + +
+
• + -+
++r
+ + + + + - + + +
+ + + +
+ + — +
+ + +
_+T
+ + + --i.2 +
+
+ +11
+ + —m+
+ + .- + °r
+ -I-
+ + +
+ + +
+ + -
+++
+ + + + +
+ +
+ + + - + 4. 4- +
+-' +
+ 4 t
+ + + + + ++ ++ +
r+ + r
+
— + + i +- + +++ + +
+ + + - + 1 go,+ + + + +
+ + + -o T + + + +%'
+ - X- + + + +
+ +++. +++ +�J
+ + + + + + + + + + 4
++ + + +
T i- + + + +
+ +
+ + + -- + + + + + + + pAI
+ + + + r + 4USD
as
+ + + T-4+ a
+ + + +
4-+ + + +
- + + + + + IIIIIIIIIIIIIIIIIIIIIIIIIIIIII1I IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII■
•
+ + + + — + . + ..
+ + + T+ + 1 4- -V
+ + +. , -+ + i +
+ + + r +
+
-i
++ ++ + +
-+ ++ +
++ +
+ + ++ + +
+ + + T -I- + +
+- + r i- + + +
- + +
+ + + + +- + +
+ + + i_ + + i
+ + + + ++ 4 +
- + + + + + y
+ 4-+ + 41:
wa
+
1011WU
I. L
+
I I I 1 I
+ + +
+ i +
+ + +
�ro
O �!
E:
O �
II
rr
ij
4-
ff
f
II
II
,
.I
1 I
11
U I
tAb
ii
1'
ij
111111111111111114
+
+ + T +
+ T+ r+
f
<5
paw
o0
40
11,
O
III I
1111
1 I 1 I 1 I I IIIIIII 1 1 1 I 1 1 1 1 1 1 I 1 1 1 1 1 1 I 1 1 1
O A 000 N a
O O O O O
Elevation (ft above mean sea level)
Itit lt
O A 000
O O O
Cross Section A -A' — October 2019.
Southem States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
pis
Checked By:
SK
Project Number.
50200
Date:
December 2019
References:
FWANa LebguWt.
Scale:
See Scale Bar
Size:
Layers:
0,1-5,30-32
Filename:
P.lSmeb®StaktStakrvdl, rattim-50100fAD01335 Sacti®a.dvg
lillilENVIRONMENTAL GEOLOGISTS & ENGINEERS
DUNCKLEE & DUNHAM
511 Keisler Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.duncklcedonham.com
NC Geo. License No. C-261
11"x17"

00
114
g g.
1. B '4
n
4E7?
g
0 '0
10 E.
5'
0,
00
CZ,
00
00
00
00
1 1 1 1 1 1
I 1 1 1
1 1 1 1 1 1 1
1 1 1 1 1 1
4- 1-
÷ + +
+ + +
+ 1- ÷
4- + +
+ 4- 4-
+ + + --
+ + ÷
+ + +
+ + +
± + + -
+ + +
4- + +
+ + +
+ + +
+ + ±-
+ + +
+ 1- +
+ + 4-
+ -t- ±
4- 1- +
+ + -F +
+ + +
+ + +
1- + +
+ + +
+ + +
+ + + +
÷ - +
CZ- -
+ n +
+ - R.. +
o
+ g. +
+. + +
— + + • +
+ + +
— + + +
÷ + +
+ + +
+ + +
-H + 4
+ + +
+ + + +
+ + +
+ + + -I
- ÷ +
+ ÷ - 4
+ + 1-
+ + + +
+ + +
+ + + 4.
+ + +
+ + + 4
+ 4- +
+ + + +
+ + + ,
4- + + 4
+ + +
+ --• .il.
+
+
+ ,
+ - 1
+
+ - 2
+
4- --
+ ir
+
+ 4
,
+
+
+
+
4-
i--
-1-6,*
irs
3
A
00
Partially ,—',.--,
---.." 'a ' 'Weathered Rock -- ,...-7.
A.,\__.__;,z_.__:_,,..___\•, -,,,... --‘,..\,,____
,
Aes
.3"
,
^5'
A0
1
+ ÷ +
+ + 1-
+ 4- 4- 4
Muni
+ + +
+- + 4-
+ +
+ + +
+ + +
+ + +
-F 4-
+ 4- +
-- + +
+++
Wallil
÷rj ÷ +
+ + +
+ + +
+ + +
4- ÷ +
+ + +
+ + +
+ + +-
++-++
+ ÷ + +
+ + +
+ + + 1
+ + +
+ + + 4
+ + ÷
+ + ÷ +
+ +
+
1-
+
÷
+
+ -
+
÷4re
+
7 1
/
I'
,
l
,
5
r6.
II I!III
41
I
1 1 1 1 1 1 1
IIIIII
1 1 1 1 1 1 1
1 1 1 1 1 1 1
/ 1 1 1 1 1 1
1 1 1 1 1 1 1
1 1 1 1 / 1 1
o a
Elevation (ft above mean sea level)
00
0
0
OM
00
CO
00
Cross Section B-B' — October 2019
Southern States Cooperative - Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
pis
Checked By:
"SK
Project Number:
50200
Date:
December 2019
References:
Red Nota. Lab Mail.
Scale:
See Scale Bar
Size:
11" x 17"
Layers:
0,1-5,30-32
Filename:
Motthcm StausZtattmIN Feadirsz 502LO.C.Croas Scdiontrin
ll)DUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 Keisler Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
www.dunclileedunham.cona
NC Geo. License No. C-261

Tables

Table 1
Historical Recovery Well Results
Statesville Fertilizer Plant
Statesville, North Carolina
Well ID
RW-2
RW-5r
RW-6
Analyte
Nitrate
Ammonia
pH
Nitrate
Ammonia
pH
Nitrate
Ammonia
pH
2L Standard
10
1.5*
6.5-8.5
10
1.5*
6.5-8.5
10
1.5*
6.5-8.5
Sample Date
Sample Results
3/13/2012
42
3.1
NT
176
26.8
NT
93.9
6.3
NT
12/22/2015
NT
1.5
NT
NT
20
NT
NT
13
NT
1/7/2016
24
NT
NT
160 A
NT
NT
89
NT
NT
5/26/2016
29
0.46
NT
120
54
NT
92
15
NT
1/31/2017
28
1.6
5.75
130
88
5.11
100
8.9
5.46
6/13/2017
33
1.1
5.57
NT
NT
NT
110
9.9
4.98
8/28/2017
NT
NT
NT
150
68
4.31
NT
NT
NT
12/21/2017
26
1.3
5.39
NT
NT
NT
95
4.6
5.52
3/19/2018
NT
NT
NT
110
84
4.80
NT
NT
NT
6/8/2018
25 A
1.2
5.96
180 A
31
4.75
95 A
8.7
5.58
12/11/2018
24
1.0
5.91
160
25
5.15
99
10
5.49
6/24/2019
26
1.1
5.81
150
27
5.02
110
14
5.36
Average
30
1.4
-
139
49.9
-
98.6
10.1
Notes:
Units in mg/L - milligrams per liter
2L standard -1 SA NCAC 02L groundwater quality standard
pH was measured in the field and recorded in standard units
Bold text indicates concentration exceeds the laboratory reporting limit
* - Indicates value is an Interim Maximum Allowable Concentration (IMAC)
Shaded cell indicates concentration exceeds the 2L or IMAC Standard
NT-Not tested
Qualifiers:
A - Result is above laboratory analyzer calibration range
\\dddc\Project Files \Southern States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Historical Recovery Well Results.xlsx

Table 2
Summary of Water -Table Elevation Data
Statesville Fertilizer Plant
Statesville, North Carolina
`
Water
Well ID
Aquifer
Code
Date
Measured
TOC
Elevation
Total Well
Depth (ft)
Depth to
Water Table
Table
Elevation
(ft amsl)
(ft BTOC)
(ft amsl)
K65W6A
Saprolite
10/30/19
864.52
58
28.69
835.83
K65W6B
Saprolite
10/29/19
871.55
30
23.09
848.46
K65W6D
Saprolite
NM
846.37
38
NM
NM
K65W6E
Bedrock
10/30/19
864.89
133
29.73
835.16
K65W6M
Saprolite
10/29/19
838.12
50
33.51
804.61
K65W6N
Saprolite
10/29/19
845.30
50
13.03
832.27
K65W7C
Saprolite
NM
809.72
22
NM
NM
K65W7D
Saprolite
10/29/19
800.64
23
14.82
785.82
K65W7F
Saprolite
DRY
796.15
28
DRY
DRY
K65W7G
Saprolite
DRY
795.98
15
DRY
DRY
K65W7H
Bedrock
10/29/19
796.07
112
16.74
779.33
K65W7J
Saprolite
10/30/19
848.20
60
41.24
806.96
K65W7K
Bedrock
10/30/19
849.32
121
44.00
805.32
K65W7L
Bedrock
10/30/19
848.14
200
43.05
805.09
Notes:
TOC - Top of casing
amsl - Above mean sea level
NM - Not measured due to well casing being damaged and inaccessible
DRY - Well was dry during this sampling event
ft BTOC - Feet below top of casing
Aquifer Code - Represents aquifer being monitored at this well location
P:\Southem States Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Annual Report Tables.xls

Table 3
Summary of Groundwater Analytical and Field Parameter Results
Statesville Fertilizer Plant
Statesville, North Carolina
Laboratory Data
Field Parameters
Well ID
Date
Nitrate
mg/L
Ammonia
mg/L
pH
Temp.
Degrees
Conductivity
Turbidity
ORP
DO
Standard Units
mS/cm
NTUs
mV
mg/L
2L Standard
10
1.5*
Celsius
K65W6A
10/30/19
160
<0.10
5.98
17.8
3.98
1.10
274.2
0.42
K65W6B
10/29/19
46
<0.10
3.98
18.0
1.55
1.16
448.1
2.55
K65W6D
NS
NS
NS
NM
NM
NM
NM
NM
NM
K65W6E
11/11/19
340 A
0.16
6.69
17.6
6.31
1.83
143.1
0.29
K65W6M
10/29/19
0.29
<0.10
5.58
17.7
0.061
35.80
193.9
6.52
K65W6N
10/29/19
90
<0.10
5.84
18.3
1.58
1.63
228.2
1.54
K65W7C
NS
NS
NS
NM
NM
NM
NM
NM
NM
K65W7D
10/29/19
<0.20
<0.10
4.86
16.9
0.129
9.45
130.5
0.22
K65W7F
DRY
DRY
DRY
NM
NM
NM
NM
NM
NM
K65W7G
DRY
DRY
DRY
NM
NM
NM
NM
NM
NM
K65W7H
10/29/19
1.0
<0.10
6.49
18.1
0.114
1.81
141.2
5.40
K65W7J
10/30/19
89
5.5
5.70
16.5
1.10
71.3
324.4
0.35
K65W7K
10/30/19
96
2.3
6.64
16.3
1.54
2.58
230.6
1.68
K65W7L
10/30/19
96
1.2
4.05
16.6
1.60
1.49
437.5
4.22
Notes:
2L standard - 15A NCAC 02L groundwater quality standard
K65W6E resampled on 11/11/2019 due to abnormally low nitrate concentration
Bold text indicates concentration above the laboratory reporting limit
* - Indicates value is an Interim Maximum Allowable Concentration (IMAC)
Shaded cell indicates concentration exceeds 2L Standard or IMAC
NS - Not sampled
DRY- Dry well; not sampled
NM- Not measured
mS/cm - Millisiemens per centimeter
NTUs - Nephelometric turbidity units
mV - Millivolts
mg/L - Milligrams per liter
A - Result is above laboratory analyzer calibration range
\\dddc\Project Files\Southern States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Annual Report Tables

Appendix A

i�.' LABORATORIES, INC,
FiRISM
Duncklee & Dunham
Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
NC Certification No. 402
NC Drinking Water Cert No. 37735
SC Certification No. 99012
Case Narrative
12/18/2018
Project: Statesville Site - Groundwater Monitoring
Project No.: 50200
Lab Submittal Date: 12/12/2018
Prism Work Order: 8120202
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
Angela D. Overcash
VP Laboratory Services
Reviewed By Robbi A. Jones For Angela D. Overcash
President/Project Manager
Data Qualifiers Key Reference:
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 1 of 9

LR1SMFull -Service Analytical &
Environmental Solutions
•7LABORATORIES, INC.
Sample Receipt Summary
12/18/2018
Prism Work Order: 8120202
Client Sample ID Lab Sample ID Matrix Date/Time Sampled Date/me Received
RW-2 8120202-01 Water 12/11/18 12:15 12/12/18 14:08
RW-5R 8120202-02 Water 12/11/18 11:30 12/12/18 14:08
RW-6 8120202-03 Water 12/11/18 11:45 12/12/18 14:08
Samples were received in good condition at 3.0 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224.0543
Phone: [phone] - Toll Free Number: 1-800/529-6364.- Fax: [phone]
Page 2 of 9

PRISM I Fun -Service An &
Environmental Solutions
®.'LABORATORIES, INC.
Summary of Detections
12/18/2018
Prism Work Order: 8120202
Prism ID Client ID Parameter Method Result Units
8120202-01 RW-2
8120202-01 RW-2
8120202-02 RW-5R
8120202-02 RW-5R
8120202-03 RW-6
8120202-03 RW-6
Nitrate as N
Ammonia as N
Nitrate as N
Ammonia as N
Nitrate as N
Ammonia as N
*300.0 24 mg/L
'SM4500-NH3 G 1.0 mg/L
*300.0 160 mg/L
*SM4500-NH3 G 25 mg/L
*300.0 99 mg/L
'SM4500-NH3 G 10 mg/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 3 of 9

Full -Service Analytical &
Environmental Solutions
Laboratory Report
12/18/2018
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: RW-2
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 8120202-01
511 Keisler Dr Project No.: 50200 Prism Work Order: 8120202
Cary, NC 27518 Sample Matrix: Water Time Collected: 12/11/18 12:15
Time Submitted: 12/12/18 14:08
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by lon Chromatography
Nitrate as N 24 mg/L 1.0 0.41 10 `300.0 12/13/18 2:38 BMS P8L0172
General Chemistry Parameters
Ammonia as N 1.0 mg/L 0.10 0.049 1 `SM4500-NH3 G 12/17/18 8:59 CLB P8L0214
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] -Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 4 of 9

/PIA I S1OR M
l�UeOME$ ING
Full -Service Analytical &
Environmental Solutions
Laboratory Report
12/18/2018
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: RW-5R
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 8120202-02
511 Keisler Dr • Project No.: 50200 Prism Work Order: 8120202
Cary, NC 27518 Sample Matrix: Water Time Collected: 12/11/18 11:30
Time Submitted: 12/12/18 14:08
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by Ion Chromatography
Nitrate as N 160 mg/L 1.0 0.41 10 `300.0 12/13/18 2:06 BMS P8L0172
General Chemistry Parameters
Ammonia as N 25 mg/L 2.0 0.98 20 •SM4500-NH3 G 12/17/18 8:59 CLB P8L0214
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 5 of 9

/PRISM
, UBOMNNE$ INC.
Full -Service Analytical &
Environmental Solutions
Laboratory Report
12/18/2018
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: RW-6
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 8120202-03
511 Keisler Dr Project No.: 50200 Prism Work Order: 8120202
Cary, NC 27518 Sample Matrix: Water Time Collected: 12/11/18 11:45
Time Submitted: 12/12/18 14:08
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/me ID
Anions by Ion Chromatography
Nitrate as N 99 mg/L 1.0 0.41 10 `300.0 12/13/18 3:26 BMS P8L0172
General Chemistry Parameters
Ammonia as N 10 mg/L 0.10 0.049 1 'SM4500-NH3 G 12/17/18 8:59 CLB P8L0214
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 6 of 9

:PRISM
✓UBORATOBIEO INC
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
Anions by Ion Chromatography - Quality Control
Analyte
Project: Statesville Site - Groundwater
Monitoring
Project No: 50200
Result
Level II QC Report
12/18/18
Prism Work Order: 8120202
Time Submitted: 12/12/2018 2:08:OOPM
Reporting Spike Source %REC RPD
Limit Units Level Result %REC Limits RPD Limit Notes
Batch P8L0172 - NO PREP
Blank (P8L0172-BLK1) Prepared &Analyzed: 12/12/18
Nitrate as N
BRL 0.10 mg/L
Blank (P8L0172-BLK2) Prepared &Analyzed: 12/13/18
Nitrate as N
BRL 0.10 mg/L
LCS (P8L0172-BS1) Prepared &Analyzed: 12/12/18
Nitrate as N
3.97 0.10 mg/L 4.000 99 90-110
LCS (P8L0172-BS2) Prepared &Analyzed: 12/13/18
Nitrate as N
4.20 0.10 mg/L 4.000 105 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1.800/529.6364 - Fax: [phone]
Page 7 of 9

4AISM
'LABOMTORIEB ING
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
General Chemistry Parameters - Quality Control
Analyte
Level II QC Report
12/18/18
Project: Statesville Site - Groundwater Prism Work Order: 8120202
Monitoring Time Submitted: 12/12/2018 2:08:OOPM
Project No: 50200
Result
Reporting
Spike Source
Limit Units Level Result %REC
%REC
Limits
RPD
RPD Limit Notes
Batch P8L0214 - NO PREP
Blank (P8L0214-BLK1)
Prepared &Analyzed: 12/17/18
Ammonia as N
LCS (P8L0214-BS1)
BRL
0.10 mg/L
Prepared & Analyzed: 12/17/18
Ammonia as N
2.45 0.10 mg/L 2.500 98 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 8 of 9

=�
IIVI
CHAIN
I Full -Service Analytical &
Solutions PAGE
OF CUSTODY RECORD
`
OF QUOTE O TO ENSURE PROPER BILLING:
LAB USE ONLY
YES NO N/A
��
W
AftEnvironmental
l
-: ''-
Samples INTACT upon arrival?
/
LaQawnvoaies ins S5G '- is vYr ( e..Lj I f 7�
Project Name: l "G
Received ON WET ICE? �1
449 Springbrook Road • Charlotte, NC 28217
Phone [phone] • Fax: [phone] Short Hold Analysis: Yes) (No) UST Protect: (Yes) (NO)
PROPER PRESERVATIVES Indicated?
0)
Please ATTACH any pr specific reporting (QC LEVEL 111 ill
Received WITHIN HOLDING TIMES? �o—
a
tr!
Client Company Name:��
,. �� ,.
INTACT?
D-
-r-aLe&% provisions and/or QC Requirements
Report To/Contact Name: r m.A }-'i CQ/*�jtn.t-/
CUSTODY SEALS
VOLATILES rec'd W/OUT HEADSPACE? �
Invoice To:
Reporting Address:
PROPER CONTAINERS used? \j_
Address:
TEMP: Therm ID: I Obswroeel. / Orwr 3•e"),C
--
Phone:
(Cfr r5Wgraax (Yes) (Nod)":
Purchase Order No./Billing Reference
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
Email Address: J riy,f Ovf ih lCt�c.ky_L{<a4,,.�j,/,l,I;,` o (Wasted
EDD Type: PDF
Due Date ❑ 1 Day ❑ 2 Days ❑ 3 Days O 4 Days O 5 Days
fl
Certification: NELAC DOD FL NC
K Excel
Other "Working Days" ❑ 6-9 Days 0 Standard 10 days O Push Work dust Be
} ,} r
Site Location Name: t4.4's Ie -I (1`7d 1(
SC OTHER NIA
�,011_' el C Samples received after 14:00 will be processed next business day.
Site Location Physical Address: Tumaround time is based on business days• excluding weekends and holidays.
Water Chlorinated: YES NO_
(SEE RERSE FOR TERMS 8. CONDITIONS REGARDING BYPRISM LABORATORIES, INC CLIENT)TO ENT)
RENDERED[CES
Sample Iced Upon Collection: YES_ NO_
CLIENT
SAMPLE DESCRIPTION
DATE
COLLECTED
TIME
COLLECTED
MATRIX
(SOIL,
SAMPLE CONTAINER
PRESERVA-
TIVES
ANAIWIS REQUESTED
/ �f REMARKS
• 1L, 3s / /
i
PRISM
LAB
ID NO.
• TYPE
SEE BELOW
NO.
SIZE
MILITARY
HOURS
WATER OR
SLUDGE)
./t,1 fr
121 c'
twacp
P
2
--
x
•
ai
� Sr
(3o
f .
--
a
-6
ll'
k
K
63
(�.
PRESS DOWN FIRMLY -
3 COPIES
Sampler's Signature
Sampled By (Print Name) A.ySiI� ! act GAVnn+t�
Affiliation
Upon reli r quashing, this Cha f ustody Is your authorization for Prism to proceed with the analyses as requested above. Any changes must be
submi • writing to the Prim roJect Manager. There will be charges for any changes after analyses have been initialized.
PRISM USE ONLY
Rartquis • • • = : (Signature)
Racely By. {Sig uro)
i' —=�-�
Oars
�z-rr- r�
MUlttarylHours
:o
Additional Comments:
site Arrival Time:
= --
r6
Relinquish.. p
� %_ r .0 `Re
ived By: (SI arure) -
, gate
Site Departure Time:
f'�Jy�
Tech Fee:
Relinquish • • .y(Signature)
.
df h=_ Lat eralntlos By:
Date,Field
jGaalp-•
l/" i' , I
19JahZ
(y I (S
Mileage:
Method of Shipment NOTE: ALL SAMPLE COOLERS SHOULD BE TAPED SHUT WITH CUS SEALS FOR TRANSPORTATION TO THE LABORATORY.
COC Group Not
SAMPLES ARE NOT ACCEPTED AND VERIFIED AGAINST COC UNTIL RECEIVED AT THE LABORATORY.
CICICIdet Fed Ex UPS Handvered CI Prism Field Service CI Other
/� ‘1 0 Z O
`�
NPDES:
❑ NC ❑ SC
UST:
❑ NC ❑ SC
GROUNDWATER:
ElNC ❑ SC
DRINKING WATER:
❑ NC IDSC
SOLID WASTE:
❑ NC ❑ SC
RCRA:
❑ NC CISC
CERCLA
❑ NC ❑ SC
LANDFILL
CINC ❑ SC
OTHER: SEE REVERSE FOR
❑ NC ❑ SC TERMS a CONDITIONS
*CONTAINER TYPE CODES: A = Amber C = Clear G= Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)
ORIGINAL

Divider
Page

kis
LA80RATORIE$ INC
Duncklee & Dunham
Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
NC Certification No. 402
NC Drinking Water Cert No. 37735
SC Certification No. 99012
Case Narrative
6/28/19 13:37
Project: Statesville Site - Groundwater Monitoring
Project No.: must have for invoicing
Lab Submittal Date: 06/24/2019
Prism Work Order: 9060338
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
Angela D. Overcash
VP Laboratory Services
Reviewed By Terri W. Cole For Angela D. Overcash
Project Manager
Data Qualifiers Key Reference:
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 1 of 9

R I S M I Full -Service Analytical &
Environmental Solutions
LABORATORIES we
Sample Receipt Summary
06/28/2019
Prism Work Order: 9060338
Client Sample ID
Lab Sample ID Matrix Date/Time Sampled Date/Time Received
RW-2
RW-5
RW-6
9060338-01 Water 06/24/19 11:40 06/24/19 15:00
9060338-02 Water 06/24/19 10:50 06/24/19 15:00
9060338-03 Water 06/24/19 11:05 06/24/19 15:00
Samples were received in good condition at 3.0 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 2 of 9

R 1 S M I -"LABORATORIES, INC, Full -Service Analytical &
Environmental Solutions
II
Summary of Detections
06/28/2019
Prism Work Order: 9060338
Prism ID Client ID Parameter Method Result Units
9060338-01 RW-2
9060338-01 RW-2
9060338-02 RW-5
9060338-02 RW-5
9060338-03 RW-6
9060338-03 RW-6
Nitrate as N
Ammonia as N
Nitrate as N
Ammonia as N
Nitrate as N
Ammonia as N
*300.0 26 mg/L
'SM4500-NH3 G 1.1 mg/L
*300.0 150 mg/L
*SM4500-NH3 G 27 mg/L
*300.0 110 mg/L
*SM4500-NH3 G 14 mg/L
This report shouldnot be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 3 of 9

LPRISM
;'LABORATORIES, isc
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
Project: Statesville Site - Groundwater
Monitoring
Project No.: must have for invoicing
Sample Matrix: Water
Laboratory Report
06/28/2019
Client Sample ID: RW-2
Prism Sample ID: 9060338-01
Prism Work Order: 9060338
Time Collected: 06/24/19 11:40
Time Submitted: 06/24/19 15:00
Parameter
Result
Units Report MDL
Limit
Dilution Method Analysis Analyst
Factor Date/Time
Batch
ID
Anions by Ion Chromatography
Nitrate as N
General Chemistry Parameters
26
mg/L
2.0 0.54 10 *300.0 6/25/19 16:25 BMS P9F0399
Ammonia as N
1.1
mg/L
0.10 0.051 1 'SM4500-NH3 G 6/26/19 9:53 CLB P9F0390
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page4of9

PRISM
ZUBORATORrna ING
Full -Service Analytical &
Environmental Solutions
Laboratory Report
06/28/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: RW-5
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9060338-02
511 Keisler Dr Project No.: must have for invoicing Prism Work Order: 9060338
Cary, NC 27518 Sample Matrix: Water Time Collected: 06/24/19 10:50
Time Submitted: 06/24/19 15:00
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by Ion Chromatography
Nitrate as N 150 mg/L 2.0 0.54 10 *300.0 6/26/19 16:55 BMS P9F0399
General Chemistry Parameters
Ammonia as N 27 mg/L 1.0 0.51 10 *SM4500-NH3 G 6/26/19 9:53 CLB P9F0390
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 5 of 9

jRISM
%LABONATONtES. INn
Full -Service Analytical &
Environmental Solutions
Laboratory Report
06/28/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: RW-6
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9060338-03
511 Keisler Dr Project No.: must have for invoicing Prism Work Order: 9060338
Cary, NC 27518 Sample Matrix: Water Time Collected: 06/24/19 11:05
Time Submitted: 06/24/19 15:00
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by lon Chromatography
Nitrate as N 110 mg/L 2.0 0.54 10 *300.0 6125/19 17:54 BMS P9F0399
General Chemistry Parameters
Ammonia as N
14 mg/L 1.0 0.51 10 *SM4500-NH3 G 6/26119 9:53 CLB P9F0390
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 6 of 9

P R I S M I Full -Service Analytical &
Environmental Solutions
LAeOMrosrEa ING
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Anions by Ion Chromatography - Quality Control
Analyte
Level II QC Report
6/28/19
Project: Statesville Site - Groundwater Prism Work Order: 9060338
Monitoring Time Submitted: 6/24/2019 3:00:OOPM
Project No: must have for
invoicing
Result
Reporting
Limit Units
Spike Source
Level Result %REC
%REC
Limits
RPD
RPD Limit Notes
Batch P9F0399 - NO PREP
Blank (P9F0399-BLK1)
Prepared & Analyzed: 06/25/19
Nitrate as N
LCS (P9F0399-BS1)
BRL
0.20 mg/L
Prepared & Analyzed: 06/25/19
Nitrate as N
3.86 0.21 mg/L 4.000 97 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 7 of 9

4E2RISM
' //LABORATORI INC.
® es
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
General Chemistry Parameters - Quality Control
Analyte
Level I1 QC Report
6/28/19
Project: Statesville Site - Groundwater Prism Work Order: 9060338
Monitoring Time Submitted: 6/24/2019 3:00:OOPM
Project No: must have for
invoicing
Result
Reporting
Limit Units
Spike Source
Level Result %REC
%REC
Limits
RPD
RPD Limit Notes
Batch P9F0390 - NO PREP
Blank (P9F0390-BLK1)
Prepared & Analyzed: 06/26/19
Ammonia as N
LCS (P9F0390-BS1)
BRL
0.10 mg/L
Prepared & Analyzed: 06/26/19
Ammonia as N
2.50 0.10 mg/L 2.500 100 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 8 of 9

PRISM
LABDAAIDITES Ir:C
449 Springbrook Road • Charlotte, NC 28217
Phone [phone]. • Fax: [phone]
Client Company Name: ' e"e __
Report To/Contact Name:
Reporting Address:
Full -Service Analytical &
Environmental Solutions
bl
1'
/
zr
,•1
�r•.L
CHAIN OF CUSTODY RECORD
PAGE I OF I QUOTE O TO ENSURE PROPER BILLING:
Project Name: CZLr PecAd �fiFL'-1� Lr i;Arai? 4iC%f5
Short Hold Analysis: (Yes) (No) UST Project: (Yet) (NO)
`Please ATTACH any project specific reporting (QC LEVEL 111 111 IV)
provisions and/or QC Requirements
Invoice To: -
Address:
LAB USE ONLY
Samples INTACT upon arrival?
Received ON WET ICE?
PROPER PRESERVATIVES indicated?
Received WITHIN HOLDING TIMES?
CUSTODY SEALS INTACT?
VOLATILES rec'd W/OUT HEADSPACE?
PROPER CONTAINERS used? _
TEMP: Therm IDC ( I 3bserved: 7 • 1°c / Corr: 3 • v�C
YES NO N/A
0)
0)
a)
0)
cu
13
rnone: Fax (Yes) (No):
•
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
Certification• NELAC DOD FL NC
'
Purchase Order No./Billing Reference
Email Address: Requested
Due Date ❑ 1 Day ❑ 2 Days ❑ 3 Days ❑ 4 Days ❑ 6 Days
EDD Type: PDF Excel Other "Working Days" ❑ 6-9 Days ❑ Standard 10 days Rush Work Must Be
SC OTHER N/A
❑
Pre -Approved
Site Location Name: Samples received after 14:00 will be processed next business day.
Water Chlorinated: YES_ NO_
Semple Iced Upon Collection: YES_ NO_,
Site Location Physical Address: Turnaround time Is based on business days, excluding weekends and holidays.
(SEE REVERSE FOR TERMS & CONDmONS REGARDING SERVICES
RENDERED BY PRISM LABORATORIES, INC. TO CUENT)
CLIENT
SAMPLE DESCRIPTION
DATE
COLLECTED
TIME
COLLECTED
MATRIX
(SOIL,
SAMPLE CONTAINER
PRESERVA-
TIMES
ANALYSIS REQUESTED
/ o� 1V REMARKS
/
/ `�Y .,
/ . / /
PRISM
LAB
ID NO.
*TYPE
SEE BELOW
NO.
SIZE
MILITARY
HOURS
WATER OR
SLUDGE)
ll2_1
G AILf-1 ii_
11 )
it,'4rt'-
/'
2
5-GOf1TT:
uti /flz'61-
/
V.
a I
4)',L
%cam+
P
,-)
✓
► .
el
ku.",-(s
‘,/
1 i cc
ii
il
d...
1/
I
‘,./
6)3
l�,,�/
./
%/
PRESS DOWN FIRMLY -
3 COPIES
Sampler's Signature /�_�
-{/A�:l
Sampled By (Print Name) !jyyisLS' / , 7.i -1
Affiliation 4)` �Lviaf Z w % .r4.7rq
Upon this Chain Cus�t� Is iequested
relinquishing, of y your authorization for Prism to proceed with the analyses as above. Any changes must be /
submitted in writing to the Prism Project Manager. There will bo charges for any r ranges after analyses have been Initialized.
PRISM USE ONLY
Relinquished By.' Si noturo) �-! y
Received By: (Signature)' .q��xy� ,J�{''�.�ypp/ .
Date
% f i
Military/Houurs
Additional Comments:
Site Arrival Time:
Refinqu By: (Signature) ' •'
Received By. (Signature)
Date /`
Site Departure Time:
Relinquished By. (Signature)
(
Received For Prism Laboratories By7
Field Tech Fee:
4
' „' `�j�
, ."----0-
(Date (�/_
6.- -kck
lC -00
Mileage:
Method of Shipment NOTE: AU. SA Pi tA RS S OULD 9E TAPED SHLT WITH CUSTODY SEALS FOR SPORTATIO TO THE LABS fORY.
COC Group No.
SAMPLES ARE NOT CEPTED AND VERIFIED AGAINST COC UNTIL RECEIVED AT THE LA RATORY. //
❑ Fed Ex 0 UPS Hand -delivered Prism Field Service 0 Other I/
/� �/
(A �J 3 V
NPDES:
CINC ❑ SC
UST:
❑ NC ❑ SC
GROUNDWATER:
).kNC ❑ SC
DRINKING WATER:
❑ NC CISC
SOLID WASTE:
❑ NC ❑ SC
RCRA:
0 NC 0 SC
CERCLA
0 NC ❑ SC
LANDFILL
0 NC 0 SC
OTHER: SEE REVERSE FOR
0 NC ❑ SC TERMS & CONDITIONS
*CONTAINER TYPE CODES: A = Amber C = Clear G= Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)
ORIGINAL

Divider
Page

Full -Service Analytical &
Environmental Solutions
AllinlIME' LABORATORIES, INC.
Duncklee & Dunham
Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
NC Certification No. 402
NC Drinking Water Cert No. 37735
SC Certification No. 99012
Case Narrative
11/6/19 12:47
Project: Statesville Site - Groundwater Monitoring
Project No.: 50200
Lab Submittal Date: 10/30/2019
Prism Work Order: 9100461
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
Angela D. Overcash
VP Laboratory Services
Reviewed By Angela D. Overcash
VP Laboratory Services
Data Qualifiers Key Reference:
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 1 of 16

I ulrvice Analytical &
,lP R I S M FEnvl ironmentSeal Solutions
It ! 1A90RATOPIES, ING
Sample Receipt Summary
11/06/2019
Prism Work Order: 9100461
Client Sample ID
Lab Sample ID Matrix Date/Time Sampled Date/Time Received
K65W7D 9100461-01 Water 10/29/19 14:00 10/30/19 16:15
K65W7H 9100461-02 Water 10/29/19 15:10 10/30/19 16:15
K65W6M 9100461-03 Water 10/29/19 16:30 10/30/19 16:15
K65W6N 9100461-04 Water 10/29/19 17:25 10/30/19 16:15
K65W6B 9100461-05 Water 10/29/19 18:25 10/30/19 16:15
K65W7K 9100461-06 Water 10/30/19 8:15 10/30/19 16:15
K65W7L 9100461-07 Water 10/30/19 9:25 10/30/19 16:15
K65W7J 9100461-08 Water 10/30/19 10:30 10/30/19 16:15
K65W6A 9100461-09 Water 10/30/19 12:00 10/30/19 16:15
K65W6E 9100461-10 Water 10/30/19 13:25 10/30/19 16:15
Samples were received in good condition at 3.3 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 2 of 16

•
P R I S M I Full -Service Analytical &
Environmental Solutions
/LABORATORIES, INC.
Summary of Detections
11/06/2019
Prism Work Order: 9100461
Prism ID Client ID Parameter Method Result Units
9100461-02 K65W7H
9100461-03 K65W6M
9100461-04 K65W6N
9100461-05 K65W6B
9100461-06 K65W7K
9100461-06 K65W7K
9100461-07 K65W7L
9100461-07 K65W7L
9100461-08 K65W7J
9100461-08 K65W7J
9100461-09 K65W6A
9100461-10 K65W6E
Nitrate as N *300.0 1.0 mg-N/L
Nitrate as N *300.0 0.29 mg-N/L
Nitrate as N *300.0 90 mg-N/L
Nitrate as N *300.0 46 mg-N/L
Nitrate as N *300.0 96 mg-N/L
Ammonia as N 'SM4500-NH3 G 2.3 mg-N/L
Nitrate as N *300.0 96 mg-N/L
Ammonia as N 'SM4500-NH3 G 1.2 mg-N/L
Nitrate as N *300.0 89 mg-N/L
Ammonia as N *SM4500-NH3 G 5.5 mg-N/L
Nitrate as N *300.0 160 mg-N/L
Nitrate as N *300.0 3.6 mg-N/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 3 of 16

'ISM
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W7D
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-01
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/29/19 14:00
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by Ion Chromatography
Nitrate as N BRL mg-N/L 0.20 0.054 1 *300.0 10/31/19 10:00 BMS P9K0012
General Chemistry Parameters
Ammonia as N BRL mg-N/L 0.10 0.051 1 •SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 4 of 16

4ISMI
._7LABORAiOHIE$ ING
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W7H
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-02
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/29/19 15:10
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Datefine ID
Anions by Ion Chromatography
Nitrate as N 1.0
General Chemistry Parameters
mg -NIL 0.20 0.054 1 *300.0 10/31/19 11:19 BMS P9K0012
Ammonia as N BRL mg-N/L 0.10 0.051 1 "SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 5 of 16

PRISM
LABORATORIES, INC.
Full -Service Analytical 8
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W6M
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-03
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/29/19 16:30
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Daterme ID
Anions by Ion Chromatography
Nitrate as N 0.29 mg -NIL 0.20 0.054 1 *300.0 10/31/19 11:34 BMS P9K0012
General Chemistry Parameters
Ammonia as N BRL mg-N/L 0.10 0.051 1 `SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 6 of 16

PRISM
-' LABORATORIES. INC.
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical 8,
Environmental Solutions
Laboratory Report
11/06/2019
Project: Statesville Site - Groundwater Client Sample ID: K65W6N
Monitoring Prism Sample ID: 9100461-04
Project No.: 50200 Prism Work Order: 9100461
Sample Matrix: Water Time Collected: 10/29/19 17:25
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Datefine ID
Anions by Ion Chromatography
Nitrate as N 90 mg -NIL 2.0 0.54 10 *300.0 10/31/19 13:06 BMS P9K0012
General Chemistry Parameters
Ammonia as N BRL mg-N/L 0.10 0.051 1 *SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 7 of 16

LPRISM
✓LABORATORIES INC.
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W6B
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-05
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/29/19 18:25
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Daterme ID
Anions by lon Chromatography
Nitrate as N 46 mg-N/L 2.0 0.54 10 •300.0 10/31/19 14:23 BMS P9K0012
General Chemistry Parameters
Ammonia as N BRL mg-N/L 0.10 0.051 1 •SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 8 of 16

PRISM
LAECRATORlE9. INC.
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W7K
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-06
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/30/19 08:15
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/me ID
Anions by Ion Chromatography
Nitrate as N 96 mg-N/L 2.0 0.54 10 `300.0 10/31/19 13:21 BMS P9K0012
General Chemistry Parameters
Ammonia as N 2.3 mg-N/L 0.10 . 0.051 1 `SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 9 of 16

4RISM
7UBORATORIES. ING
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Project: Statesville Site - Groundwater Client Sample ID: K65W7L
Monitoring Prism Sample ID: 9100461-07
Project No.: 50200 Prism Work Order: 9100461
Sample Matrix: Water Time Collected: 10/30/19 09:25
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/Time ID
Anions by Ion Chromatography
Nitrate as N 96 mg-N/L 2.0 0.54 10 *300.0 10/31/19 14:38 BMS P9K0012
General Chemistry Parameters
Ammonia as N 1.2
mg -NIL 0.10 0.051 1 `SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1.800/529-6364 - Fax: [phone]
Page 10 of 16

/PIRISM
,LABORATORIES, INC
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W7J
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-08
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/30/19 10:30
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Datefine ID
Anions by Ion Chromatography
Nitrate as N 89 mg-N/L 2.0 0.54 10 *300.0 10/31/19 15:26 BMS P9K0012
General Chemistry Parameters
Ammonia as N 5.5 mg-N/L 0.10 0.051 1 *SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224.0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page11 of 16

L...
RISMM
LABORATORIES, INC.
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W6A
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-09
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/30/19 12:00
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor Date/me ID
Anions by Ion Chromatography
Nitrate as N 160 mg-N/L 2.0 0.54 10 *300.0 10/31/19 15:41 BMS P9K0012
General Chemistry Parameters
Ammonia as N BRL mg-N/L 0.10 0.051 1 'SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 12 of 16

PRISM
'i.ABoa rowel. rNa
Full -Service Analytical &
Environmental Solutions
Laboratory Report
11/06/2019
Duncklee & Dunham Project: Statesville Site - Groundwater Client Sample ID: K65W6E
Attn: Jayson Kilcoyne Monitoring Prism Sample ID: 9100461-10
511 Keisler Dr Project No.: 50200 Prism Work Order: 9100461
Cary, NC 27518 Sample Matrix: Water Time Collected: 10/30/19 13:25
Time Submitted: 10/30/19 16:15
Parameter Result Units Report MDL Dilution Method Analysis Analyst Batch
Limit Factor DateTme ID
Anions by Ion Chromatography
Nitrate as N 3.6
General Chemistry Parameters
mg-N/L 0.20 0.054 1 *300.0 10/31/19 14:07 BMS P9K0012
Ammonia as N BRL mg-N/L 0.10 0.051 1 *SM4500-NH3 G 11/4/19 10:21 CLB P9K0025
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 13 of 16

Y
P . 1 S M LFull-Service Analytical &
Environmental Solutions
7LABOMTONIE$ wa
Duncklee & Dunham Project: Statesville Site - Groundwater
Attn: Jayson Kilcoyne Monitoring
511 Keisler Dr Project No: 50200
Cary, NC 27518
Anions by Ion Chromatography - Quality Control
Level II QC Report
11/6/19
Prism Work Order: 9100461
Time Submitted: 10/30/2019 4:15:OOPM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P9K0012 - NO PREP
Blank (P9K0012-BLK1) Prepared &Analyzed: 10/31/19
Nitrate as N
BRL 0.20 mg-N/L
LCS (P9K0012-BS1) Prepared &Analyzed: 10/31/19
Nitrate as N 4.04 0.21 mg-N/L 4.000 101 90-110
LCS Dup (P9K0012-BSD1) Prepared: 10/31/19 Analyzed: 11/01/19
Nitrate as N 3.97 0.21 mg-N/L 4.000 99 90-110 2 200
Matrix Spike (P9K0012-MS1)
Source: 9100461-01 Prepared &Analyzed: 10/31/19
Nitrate as N
Matrix Spike Dup (P9K0012-MSD1)
3.99 0.21 mg-N/L 4.000 0.0753 98 90-110
Source: 9100461-01 Prepared &Analyzed: 10/31/19
Nitrate as N
4.05 0.21 mg-N/L 4.000 0.0753 99 90-110 2 15
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 14 of 16

PRISM
...1111171ABOMTOPIE9, INC.
Full -Service Analytical &
Environmental Solutions
Duncklee & Dunham Project: Statesville Site - Groundwater
Attn: Jayson Kilcoyne Monitoring
511 Keisler Dr Project No: 50200
Cary, NC 27518
General Chemistry Parameters - Quality Control
Level II QC Report
11/6/19
Prism Work Order: 9100461
Time Submitted: 10/30/2019 4:15:OOPM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P9K0025 - NO PREP
Blank (P9K0025-BLK1)
Prepared & Analyzed: 11/04/19
Ammonia as N
BRL 0.10 mg-N/L
LCS (P9K0025-BS1) Prepared & Analyzed: 11/04/19
Ammonia as N
2.44 0.10 mg-N/L 2.500 97 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 15 of 16

/F:RISM
D
449 Springbrook Road • Charlotte, NC 28217
Phone [phone] • Fax: [phone]
Client Company Name: trklu tpuN,riph
Full -Service Analytical &
Environmental Solutions
Report To/Contact Name: ,., kiko jnz.
Reporting Address: 571 Iceutte Daze. Safe 102
Bea iglq
•
CHAIN OF CUSTODY RECORD
PAGE OF _ QUOTE N TO ENSURE PROPER BILLING:
Project Name: 162i re-4j ,r-> ked—
Short Hold Analysis: (fe (No) UST Project: (Yes) (NO)
*Please ATTACH any project specific reporting (QC LEVEL III III IV)
provisions and/or QC Requirements
Invoice To: Gr•of/
Address:
LAB USE ONLY
Samples INTACT upon arrival?
Received ON WET ICE?
PROPER PRESERVATIVES indicated'.
Received WITHIN HOLDING TIMES?
CUSTODY SEALS INTACT?
VOLATILES rec'd W/OUT HEADSPACE? _
PROPER•CONTAINERS used? i
TEMP:, Therm ID:~ 11 I OtSnrved �,�� °C 1 Com } i °t,
YES , NO
N/A
CD
CD
rnone:-ytt - Fax (Yes) (No):
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL
Certification: NELAC DOD FL NC
Purchase Order No./Billing Reference
Email Address: Z44o ' ie41eL.L ti✓,747►,.C.iVw-+
Requested Due Date ❑ 1 Day ❑ 2 Days ❑ 3 Days ❑ 4 Days •❑ 5'Days
EDD Type: PDF 7c Excel IC Other jrrt ��P ^'4=41Working Days" Rush Work
kedust Be
SC OTHER N/A
❑ 6-9'Days ❑Standard 10 days ❑
Site Location Name: '7" v:Ky -
> !�r'hila I`rr.�.t+r Samples received after 14:00 will be processed next business day.
Water Chlorinated: YES NO
Sample Iced Upon Collection: YES_ NO_
Site Location Physical Address: .7Ar tde%/i/C. Tumaroundtlnie Is based an business days, excluding weekends and holidays.
(SEE REVERSE FOR TER11S & CONDITIONS REGARDING SERVICES
RENDERED BY PRISM LABORATORIES, INC. TO CLIENT)
CLIENT
SAMPLE DESCRIPTION
DATE
COLLECTED
TIME
OLLECTED
CMILITARY
MATRIX
(SOIL,
SAMPLE CONTAINER
PRTIVES A
ANALYSIS REQUESTED
/f i� / / // , REMARKS
/il)s / 'I' / �/ , �
�` ! //
PRISM
ID NO.
*TYPE
SEE BELOW
NO.
SIZE
HOURS
WATER OR
SLUDGE)
k 6507,)
li�,.4r/il
►�1.00
w
z
2s�t.uL
1., �I�s6rl
o,
�SW?�
It.�I
i
02
03
k 6/v
17ZS
)
1
/' 4
I
K65148
Igo
1
4 S
¥.l 7K
iviscaff
CA/6
f
of
W '7i-
I
o11 5
1
J
0 i
kLiu 7,3.
low
o $
01
kG+16E
)3
(0
r
`` // �
PRESS DOWN FIRMLY -
3 COPIES
Sampler's Signature
Sampled By (Print Name)`, Vl�YCrrtr+"
Affiliation DA)
Upon relinquishing, this Chain of Custody is your authorization for Prism to procee ith the analyses as re uested above. Any changes must be
submitted In writing to the Prism Project Manager. There will be charges for any cha'es after analyses have been Initialized.
PRISM USE ONLY
Relinquish By: (Sfgnawro)
Received By: (Signature)
Date ‘
MWtefyIHOafs
Additional Comments:
Site Arrival Time:
Ce..~."-•••••"*"....—"-->
Relinqui d By: (Signatu
Received By: (Signature) r
Date
Site Departure lime:
Retinqulshed By: (Signature)
Received For Prism Laboratories By:
Dalon
Field Tech Fee:
�1Q/....\._.
y",}�'
\�� 1
Mileage:
Methatl of ShipmenC NOTE: ALL AMPLE COLERS SHOTAPED SHUT WITH CUSTODY SEALS FOR TRANSPOR ION TO LABORATORY.
COCGr p No.
SAMPLES ARE NOT CEPTED AND VERIFIED AGAINST COC UNTIL RECEIVED AT THE LABORA RY.
Ex ❑ Fed O UPS ❑ Hand -delivered Prism Field Service O Other
1 ,i1 r1�,ll I
�Ol L
NPDES:
CINC ❑ SC
UST:
❑ NC ❑ SC
GROUNDWATER:
❑ NC ❑ SC
DRINKING WATER:
❑ NC ❑ SC
SOLID WASTE:
O NC ❑ SC
RCRA:
❑ NC ❑ SC
CERCLA
❑ NC la SC
LANDFILL
❑ NC ❑ SC
OTHER: SEE REVERS FOR,
❑ NC ❑ SC TERMS 8 CONDITIONS'
*CONTAINER TYPE CODES: A = Amber C = Clear G= Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)
ORIGINAL

1
Divider
Page

RISM
, " LABORATORIES, INC,
Duncklee & Dunham
Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
NC Certification No. 402
NC Drinking Water Cert No. 37735
SC Certification No. 99012
Case Narrative
11/18/19 14:49
Project: Statesville Site - Groundwater Monitoring
Project No.: must have for invoicing
Lab Submittal Date: 11/11/2019
Prism Work Order: 9110198
This data package contains the analytical results for the project identified above and includes a Case Narrative, Sample
Results and Chain of Custody. Unless otherwise noted, all samples were received in acceptable condition and processed
according to the referenced methods.
Data qualifiers are flagged individually on each sample. A key reference for the data qualifiers appears at the end of this case
narrative.
Please call if you have any questions relating to this analytical report.
Respectfully,
PRISM LABORATORIES, INC.
Angela D. Overcash
VP Laboratory Services
Reviewed By Angela D. Overcash
VP Laboratory Services
Data Qualifiers Key Reference:
A Result is above calibration range.
BRL Below Reporting Limit
MDL Method Detection Limit
RPD Relative Percent Difference
* Results reported to the reporting limit. All other results are reported to the MDL with values between MDL and
reporting limit indicated with a J.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 1 of 7

4aRISMI
unomaom¢a we
Full -Service Analytical &
Environmental Solutions
Sample Receipt Summary
11/18/2019
Prism Work Order: 9110198
Client Sample ID
Lab Sample ID Matrix Date/Time Sampled Date/Time Received
K65W6E 9110198-01 Water 11/11/19 13:05 11/11/19 16:15
Samples were received in good condition at 3.1 degrees C unless otherwise noted.
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 2 of 7

jRISM
ABOMIOrIEQ INC.
Full -Service Analytical &
Environmental Solutions
Summary of Detections
11/18/2019
Prism Work Order: 9110198
Prism ID Client ID Parameter Method Result Units
9110198-01 K65W6E
9110198-01 K65W6E
Nitrate as N
Ammonia as N
*300.0
'SM4500-NH3 G
340 A
0.16
mg-N/L
mg-N/L
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 3 of 7

PRISM
7LABORATORIES, ING
Duncklee & Dunham
Attn: Jayson Kilcoyne
511 Keisler Dr
Cary, NC 27518
Full -Service Analytical &
Environmental Solutions
Project: Statesville Site - Groundwater
Monitoring
Project No.: must have for invoicing
Sample Matrix: Water
Laboratory Report
11/18/2019
Client Sample ID: K65W6E
Prism Sample ID: 9110198-01
Prism Work Order: 9110198
Time Collected: 11/11/19 13:05
Time Submitted: 11/11/19 16:15
Parameter
Result
Units Report
Limit
MDL Dilution Method Analysis Analyst
Factor Date/Time
Batch
ID
Anions by Ion Chromatography
Nitrate as N
General Chemistry Parameters
340 A mg-N/L
2.0 0.54 10 *300.0 11/12/19 14:01 BMS P9K0278
Ammonia as N
0.16
mg-N/L
0.10 0.051 1 *SM4500-NH3 G 11/15/19 10:47 CLB P9K0274
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 4 of 7

L121— I S n Full -Service Analytical &
' V' Environmental Solutions
7UBORATORIEa ING
Duncklee & Dunham Project: Statesville Site - Groundwater
Attn: Jayson Kilcoyne Monitoring
511 Keisler Dr Project No: must have for
Cary, NC 27518 invoicing
Anions by ion Chromatography - Quality Control
Level II QC Report
11/18/19
Prism Work Order: 9110198
Time Submitted: 11/11/2019 4:15:OOPM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P9K0278 - NO PREP
Blank (P9K0278-BLK1) Prepared & Analyzed: 11/12/19
Nitrate as N
BRL 0.20 mg-N/L
LCS (P9K0278-BS1) Prepared & Analyzed: 11/12/19
Nitrate as N
3.87 0.21 mg-N/L 4.000 97 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529-6364 - Fax: [phone]
Page 5 of 7

PRISM
�: - Ue0RATORIq ING
Full -Service Analytical &
Environmental Solutions
Duncklee & Dunham Project: Statesville Site - Groundwater
Attn: Jayson Kilcoyne Monitoring
511 Keisler Dr Project No: must have for
Cary, NC 27518 invoicing
General Chemistry Parameters - Quality Control
Level II QC Report
11/18/19
Prism Work Order: 9110198
Time Submitted: 11/11/2019 4:15:OOPM
Reporting Spike Source %REC RPD
Analyte Result Limit Units Level Result %REC Limits RPD Limit Notes
Batch P9K0274 - NO PREP
Blank (P9K0274-BLK1) Prepared: 11/14/19 Analyzed: 11/15/19
Ammonia as N
BRL 0.10 mg-N/L
LCS (P9K0274-BS1) Prepared: 11/14/19 Analyzed: 11/15/19
Ammonia as N
2.41 0.10 mg-N/L 2.500 96 90-110
This report should not be reproduced, except in its entirety, without the written consent of Prism Laboratories, Inc.
449 Springbrook Road - P.O. Box 240543 - Charlotte, NC 28224-0543
Phone: [phone] - Toll Free Number: 1-800/529.6364 - Fax: [phone]
Page 6 of 7

7---1 ► I t/
LABORATORIES INC.
449 Springbrook Road • Charlotte, NC 28217
Phone [phone] • Fax: [phone]
Client Company Name:
Report To/Contact Name:
Reporting Address: J!
Full -Service Analytical &
Environmental Solutions
g.nclr.f(j1j1t-VeAl,..:..a FL
/— 4+•4 k 7/
S krd `L
,, yr A C 7.137,
CHAIN OF CUSTODY RECORD
PAGE t OF 1 QUOTE P TO ENSURE PROPER BILLING,
Project Name: .S} 5i„1 v MPt.r + P4
Short Hold Analysis: es (No) UST Project: (Yes)\ NO)�)
*Please ATTACH any project specific reporting (QC LEVEL 111 III IV)
provisions and/o C Requirements
Invoice To:
Address: 4
LAB USE ONLY
Samples INTACT upon arrival?
Received ON WET ICE?
PROPER PRESERVATIVES Indicated?'
Received WITHIN HOLDING TIMES? %c
CUSTODY SEALS INTACT?
VOLATILES rec'd W/OUT HEADSPACE?
PROPER CONTAINERS used?
TEMP: Therm ID: -1-12 -y Observed: 'T U' °C /.Colr. y ( °C
YES NO
X .
N/A
n
a)
rn
tt)
O_
rnoneahfl rn'-i, v rax(Yes) o
TO BE FILLED IN BY CLIENT/SAMPLING PERSONNEL'
Certification: NELAC DoD FL NC
. Purchase Order No./Billing Reference
Email Address: d.1Srrl Cit��r. f apeti- .6041. Due Date O 1 Day ❑
Requested 2 D .❑ 3 Days O 4 Days ❑ 5 Days
K Rush kust Be
EDD Type: PDF ?G Excel'Other . n Q,;,4IviIG(A,U {1,;.,.,,,� "Working Days" ❑ 6-9 Days ' Standard 10 days ❑
SC OTHER NIA
Pre-ApprovedhWork
Site Location Name: S f ,- Gi f) jf,.rt Samples received after 14:00 will be processed next business day.
Water Chlorinated: YES_ NO_
I,
Sample Iced Upon Collection: YES_ NO_
`r.SFil;;l'
Slte Location Physical Address: -/G'aV i)l . A.IL Turnaround time Is based on business days, excluding weekends and holidays.
(SEE REVERSE FOR TERMS & CONDITIONS REGARDING SERVICES
RENDERED BY PRISM LABORATORIES, INC. TO CLIENT)
CLIENT
SAMPLE DESCRIPTION
DATE
COLLECTED
TIME
COLLECTED
MATRIX
(SOIL,
SAMPLE CONTAINER
PRESERVA-
TIVES
ANALYSIS REQUESTED
/ %
./+a/ / / ` // REMARKS
//,r ' / /
PRISM
LAB '
ID NO:F
*TYPE
SEE BELOW
NO.
SIZE
MILITARY
HOURS
WATER OR
SLUDGE)
k6 (E
/l/jil113ac
r
2. o L.
tyZ
�C
0Il
t
I n
no 62,..
b y{�
PRESS DOWN FIRMLY -
3 COPIES
Signature .
Sampled By (Print Name) t,
`
Affiliation �J
Upon this Chain Custody Is for Prism to the
relinquishing, of you authorization proceed with analyses as uested above. Any changes must be
submitted in writing to the Prism Project Manager. There will be charges for any changes after analyses have been Initialized.
PRISM USE ONLY
Relinquished '=yfrpi Bture)
Rarely By. signs
Dgie
/I-1/49
Ivmnarynroars
/ 3
Additional Comments:
Site AmvalTime:
Rellnqulshe• By . Ig azure) . -
//--//1 /6/1---
Received By: (Signature)
Date
ii.-
Site Departure Time:
Relinquish t'Anature) Receiceristn Labonatorias By:
Date
Field Tech Fee:
C
161 S
Method of Shipment NOTE: AU. SAMPLE COOLERS SHOULD BE TAPED SHUT WITH CUSTODY SEALS FOR TRANSPORTATION TO THE LABORATORY.
COC Group No.
Mileage:
SAMPLES ARE NOT ACCEPTED AND VERIFIED AGAINST COC UNTIL RECEIVED AT THE LABORATORY.
Fed Ex ❑ UPS ❑ Hand -delivered P ' m Field Service ❑ Other
j( I 0
{!
�t0
NPDES:
❑ NC 0 SC
UST:
0 NC ❑ SC
G O DWATER:
a' NC 0 SC
DRINKING WATER:
0 NC ❑ SC
SOLID WASTE:
CI ❑ SC
RCRA:
0 NC CI
CERCLA
0 NC 0 SC
LANDFILL
0 NC 0 SC
OTHER: SEE REVERSE FOR
0 NC ❑ SC TERMS & CONDITIONS
'CONTAINER TYPE CODES: A = Amber C = Clear G= Glass P = Plastic; TL = Teflon -Lined Cap VOA = Volatile Organics Analysis (Zero Head Space)
- ORIGINAL

Appendix B

Concentration in mg/L
400
K65W6A (Saprolite)
350 -
300 -
250 -
200 -
150 -
100 -
50 -
Treatment System Became Operational (1994)
Nitrate Results
—o—•Ammonia
Nitrate 2L Standard
• • , _ • • _ , s , ♦ • • • , • , • • • , •
re)V T N. • 00 N R b h T 0 N R b h a
.� O, T O, a O O O O O O O O
r w w w w w • w w 10 w w w w w w w w w w w w • w w w w w I w w
Date
Date
2/13/90
1/22/92
4/16/92
7/27/92
10/21/92
2/10/93
4/8/93
8/3/93
10/7/93
3/8/94
9/27/94
8/2/95
11/8/95
Nitrate(mg/1)
370
252
360
360
311
30
210
340
330
250
260
250
180
Ammonia (mg/1)
No Data
Date
2/8/96
5/9/96
11/15/96
5/20/97
11/18/97
5/19/98
11/19/98
3/30/99
11/3/99
3/28/00
11/16/00
4/5/01
10/24/01
Nitrate (mg/1)
240
260
210
106
243
121
199
236
240
220
200
180
190
Ammonia (mg/1)
No Data
Date
3/29/02
10/18/02
5/2/03
10/17/03
4/16/04
10/28/04
7/18/05
10/27/05
4/26/06
10/23/06
5/1/07
10/15/07
4/25/08
Nitrate (mg/1)
235
170
140
84
200
150
170
190
160
150
140
30.9
92.8
Ammonia (mg/I)
No Data
77
0.24
NS
NS
NS
0.23
NS
0.14
0.13
0.25
0.36
Date
4/9/09
10/30/09
4/6/10
10/21/10
4/22/11
11/2/11
5/10/12
11/7/12
5/23/13
11/20/13
5/30/14
5/21/15
5/25/16
Nitrate (mg/1)
152
186
135
122
118
120
162
105
124
157
141
129
170
Ammonia (mg/1)
NS
0.10
0.16
0.19
0.30
0.33
0.24
0.88
<0.10
0.12
<0.10
0.12
0.16
Date
7/28/17
10/16/18
10/30/19
Nitrate (mg/1)
150
93
160
Ammonia (mg/1)
0.11
0.11
<0.10
P5Southem States \ Statesville Fertilizer- 50200tTables_Exccl\Current Annual Report tables\}listorical Nitrate Trend Graphs with Tables.xls

Concentration in mg/L
160
K65W6B (Saprolite)
140 -
120 -
100 -
80 -
60 -
40 -
20
0
Treatment System Became Operational
(1994)
Nitrate Results
-.--Ammonia Results
Nitrate 2L Standard
--� N . , C' 0 b [- 00 O\ 0 eV en V' V1 b n 00 ON O ---. N M V' V1 b r` 00 O\
O� O\ O\ O\ ON O\
O O O O O O
.D .D .0 P Cn
AO ? A ? Ad .D
L d N 4D AN p P
d d N
w AN w w w w w w w w w w w w w w w w w w w w w w w w w
Date
Date
2/13/90
1/22/92
4/16/92
7/27/92
10/21/92
2/10/93
4/8/93
8/3/93
10/7/93
3/8/94
9/27/94
3/30/99
11/3/99
Nitrate (mg/1)
22
22
15
26
16
7.6
6.8
28
29
19
18
89.4
140
Ammonia (mg/1)
No Data
Date
10/24/01
5/2/03
10/17/03
4/16/04
10/28/04
7/18/05
10/27/05
4/26/06
10/23/06
5/1/07
10/15/07
4/25/08
4/9/09
Nitrate (mg/1)
78
92
40
41
44
33
35
28
23
31
31
32
40
Ammonia (mg/1)
No Data
<0.1
<0.1
<0.1
NS
NS
0.12
<0.1
<0.1
<0.1
NS
<0.1
<0.1
Date
10/29/09
4/6/10
10/22/10
4/21/11
11/1/11
5/9/12
11/7/12
5/23/13
_ 11/20/13
5/29/14
5/21/15
5/25/16
7/28/17
Nitrate (mg/1)
55.9
34.5
30.2
26.9
38.4
34.2
39.8
59.6
28.5
31.8
35.8
51
80
Ammonia (mg/1)
<0.1
<0.10
1.4
0.61
<0.10
<0.10
NS
0.33
0.13
0.19
0.11
0.19
<0.10
Date
10/15/18
10/29/19
Nitrate (mg/1)
51
46
Ammonia (mg/1)
0.17
<0.10
P:\Southern States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Hiistorical Nitrate Trend Graphs with Tables.xls

Concentration in mg/L
0
n r in N
K65W6D (Saprolite)
--Nitrate Results
o
ON
to
6
a
N
w
os
b0
Q
Date
rn
?
w
elVI
Ca A
Q w
Date
8/1/90
1/22/92
2/10/93
4/8/93 to 10/30/19
Nitrate (mg/1)
0.63
0.17
0.25
Dry
Ammonia (mg/1)
No Data
Dry
P:\Southem States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\.listorical Nitrate Trend Graphs with Tables.xls

Concentration in mg/L
K65W6M (Saprolite)
1
0.9
0.8
0.7
0.6
0.5
0.4
0.3
0.2 -
0.1 -
0
•
- .-Nitrate Results
Ammonia Results
o
8 8
U
to
8
to
8 8 J U U
Q a o A A
Date
00
Date
12/19/08
4/9/09
10/29/09
4/6/10
10/22/10
4/21/11
11/1/11
5/9/12
11/6/12
5/23/13
11/20/13
5/29/14
5/21/15
5/25/16
7/27/17
Nitrate (mg/1)
0.44
<.10
0.15
0.16
0.28
0.14
0.37
<0.20
1.0
0.44
0.49
0.33
0.26
0.54
0.28
Ammonia (mg/1)
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
Date
10/15/18
10/29/19
Nitrate (mg/1)
0.22
0.29
Ammonia (mg/1)
<0.10
<0.10
P:\Southern States Statesville Fertilizer - 50200\Tables Excet\Current Annual Report tables\1Hstorical Nitrate Trend Graphs with Tables.xls

Concentration in mg/L
120
110
100
90
80
70
60
50
40
30
20
10
0
K65W6N (Saprolite)
---Nitrate Results
- Ammonia Results
- Nitrate 2L Standard
eo rn o
O O
8 8 8 8
A Q to to
r+t V
8 8
Q Q
Date
8
Q
8 8 8
a A to
Date
12/19/08
4/9/09
10/29/09
4/7/10
10/22/10
4/21/11
11/1/11
5/10/12
11/6/12
5/23/13
11/20/13
5/29/14
5/21/15
5/25/16
7/27/17
Nitrate (mg/1)
16.7
61.9
82.3
67.2
66.6
61.4
50.2
48.5
50.4
32.1
57.3
44.7
56.1
58
63
Ammonia (mg/1)
6.6
3.5
1.7
1.4
1.2
1.3
0.99
0.35
0.93
0.18
1.1
0.32
<0.10
<0.10
<0.10
Date
10/15/18
10/29/19
Nitrate (mg/1)
110
90
Ammonia (mg/1)
0.65
<0.10
P:\Southem States\Statesville Fertilizer - 50200\Tables Excel\Current Annual Report tables\}Iistorical Nitrate Trend Graphs with Tables.xls

K65W7C (Saprolite)
140
120
--Nitrate Results
•Ammonia Results
-Nitrate 2L Standard
100
t
E
0
0 80
o
1
uTreatment
0 60
System Became Operational
(1994)
U
40
20
0
O N M 7 vo so r` W as O
T o. 9` Q` a, T O O O O O O O O O O
N N N N . N az N d d ., N 41 t. N ., N N N
w w w w w w w w w w w w w w w w w w w w w
Date
Date
2/13/90
1/22/92
2/10/93
10/17/03
7/18/05
10/28/05
4/25/08
12/19/08 to 10/21/10
4/21/11
11/1/11 to 10/29/19
Nitrate (mg/1)
93
130
13
82
33
53
<0.10
Dry
9.4
Dry
Ammonia (mg/1)
No Data
9
NS
2.3
29.4
Dry
<0.10
Dry
P:\Southem States \Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Historical Nitrate Trend Graphs with Tables.xls

Concentration in mg/L
40
K65W7D (Saprolite)
35 -
30 -
25 -
20 -
15
10
1
Treatment System Became Operational
(1994)
- Nitrate Results
--A-Ammonia Results
- Nitrate 2L Standard
O N [h 7 Vl ,0 n 00 01 O N Nl et' V7 b l� 00 D\ O N - ul ti O.
01 0% 0\ D, 01 0, 0, 0, 0, 01 O O O O O O O O C.
"A ❑ -4 o ❑ o o ❑ ❑ o 0 0 0 0 '3 0 0 0 0 ; o 0 0 ; 'i
�--� �--� �--. �-y ti .--a ry Y-. i--. �--� ry -. �--� �--a �'-� 1--. y ti r-. �--• �--� �-y �--� �--. i--. ti
Date
Date
8/1/90
1/22/92
2/10/93
3/30/99
11/3/99
3/28/00
11/16/00
4/5/01
10/24/01
3/29/02
10/18/02
5/2/03
10/17/03
Nitrate (mg/1)
11
2
0.57
0.775
2
1
2
1.1
<0.10
1.1
2.4
1.4
0.05
Ammonia (mg/1)
No Data
0.41
<0.10
Date
4/16/04
10/28/04
7/18/05
10/27/05
4/25/06
10/23/06
5/1/07
4/25/08
4/16/09
10/29/09
4/6/10
10/21/10
4/21/11
Nitrate (mg/1)
1.3
2.4
0.48
2
1.1
15
39
0.48
0.21
<0.10
0.22
<0.10
0.16
Ammonia (mg/1)
<0.10
NS
NS
0.12
<0.10
1.1
2.1
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
Date
11/2/11
5/9/12
11/6/12
5/23/13
11/19/13
5/28/14
5/20/15
5/25/16
7/27/17
10/15/18
10/29/19
Nitrate (mg/1)
<0.20
<0.20
<0.020
<0.020
0.15
0.30
0.07
0.24
<0.10
2
<0.20
Ammonia (mg/1)
0.18
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
P:\Southem States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Historical Nitrate Trend Graphs with Tables.xls

180
160
K65W7F (Saprolite)
140 -
E 120 -
• 100
d
▪ 80 -
0
60 -
40 -
20
0
--Nitrate Results
- Ammonia Results
- Nitrate 2L Standard
Treatment System Became Operational
(1994)
O- rt n
'4 -A n
Z ♦,Y A7*--T A ♦, •, • ♦ , A Q- tA, A
Ul b n 00 C\ O .r N co V Vt sz, l� 00 O. O .+ N r+1 cr
7 01 G\ 01 D\ O O O O O O O O O
Date
Date
8/1/90
1/22/92
4/16/92
7/27/92
10/21/92
2/10/93
4/8/93
8/3/93
10/7/93
3/8/94
9/27/94
2/8/96
5/9/96
Nitrate (nig/1)
99
100
109
79
79
110
100
100
96
1.6
94
150
6.1
Ammonia (mg/1)
No Data
Date
3/28/00
11/16/00
10/24/01
3/29/02
10/18/02
5/2/03
10/17/03
4/16/04
10/28/04
7/18/05
10/27/05
4/26/06
10/23/06
Nitrate (mg/1)
5.1
0.52
20
33
17
3
21
8.5
<0.1
20
NS
31
15
Ammonia (mg/1)
No Data
<0.10
NS
<0.10
NS
NS
NS
0.12
1.1
Date
4/25/08
4/9/09
10/29/09
4/6/10
10/21/10
4/21/11
11/1/11
5/9/12
11/6/12
5/23/13
11/19/13
5/29/14
5/20/15
Nitrate (mg/1)
61.9
33.6
Dry
9.2
30.7
6.7
Dry
Dry
10.7
4.1
NS
18.4
16.5
Ammonia (mg/1)
<0.10
<0.10
Dry
<0.10
<0.10
<0.10
Dry
Dry
<0.10
<0.10
NS
2.5
<0.10
Date
1/7/16
5/26/16
7/27/17
10/15/18
10/29/19
Nitrate (mg/1)
34
98
50
Dry
Dry
Ammonia (mg/1)
0.77
<0.10
<0.10
Dry
Dry
P:\Southem States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Historical Nitrate Trend Graphs with Tables.xls

280
260 -
240 -
220 -
t-1 200 -
180 -
d
°0 120 -
U
100 -
80 -
60 -
40 -
20 -
K65W7G (Saprolite)
—6--Nitrate Results
—.—Ammonia Results
—Nitrate 2L Standard
Treatment System Became Operational (1994)
0
00 b
a o
4
t� 00 a 0 .r
n ti ti ti .-. ti ti ti .-. ti ti ti n
Date
Date
8/1/90
1/22/92
2/10/93
2/8/96
11/3/99
11/16/00
10/24/01
3/29/02
10/18/02
5/2/03
10/17/03
10/28/04
7/18/05
Nitrate (mg/1)
1.7
1.9
2.6
3.5
2.9
3.6
2.8
31
32
1.3
0.4
4.4
1.7
Ammonia (mg/1) I
No Data
<0.10
<0.10
NS
NS
Date
4/25/06
10/23/06
5/1/07 to 4/6/10
10/21/10
4/21/11
11/1/11
5/9/12
11/6/12
5/23/13
11/19/13
5/28/14
5/20/15
Nitrate (mg/1)
16
29
Dry
3.3
Dry
Dry
Dry
6.2
1.7
NS
118
248
Ammonia (mg/1)
<0.10
4
Dry
<0.10
Dry
Dry
Dry
<0.10
<0.10
NS
9.0
81.2
Date
1/7/16
5/25/16
7/27/17
10/15/18
10/29/19
Nitrate (mg/1)
56
Dry
Dry
Dry
Dry
Ammonia (mg/1)
6.7
Dry
Dry
Dry
Dry
P:\Southern States\Statesville Fertilizer - 50200\Tables Excel\Current Annual Report tables\I-Iistorical Nitrate Trend Graphs with Tables.xls

300
250
K65W7J (Saprolite)
200
0
a
0
a 150 -
u
u
0
100
50
---Nitrate Results
Ammonia Results
—Nitrate 2L Standard
0 ♦ ♦ ♦ ♦ ♦---.1. .1.— # A ♦ k ♦ ♦ ♦ ♦ •
h b CDN Kl 'Dr V1 0
9 • 9 0O O O
O ▪ 0 ▪ O O O O O O 0 O O 0 O
Date
l00 p�
O O O
Date
10/28/04
7/18/05
10/27/05
4/26/06
10/23/06
5/1/07
10/15/07
4/25/08
12/18/08
4/9/09
10/30/09
4/7/10
10/22/10
Nitrate (mg/1)
100
140
74
150
180
140
14.4
178
204
191
199
157
172
Ammonia (mg/1)
NS
NS
<0.10
<0.10
<0.10
0.10
0.6
0.86
0.79
1.7
1.7
1.4
2.2
Date
4/21/11
11/2/11
5/10/12
11/7/12
5/23/13
11/19/13
5/29/14
5/22/15
5/26/16
7/27/17
10/16/18
10/30/19
Nitrate (mg/1)
162
184
134
185
187
191
193
146
150
140
120
89
Ammonia (mg/1)
3.3
2.8
4.2
2.2
2.5
3.8
2.8
3.4
4.0
3.5
5.3
5.5
P:\Southem States\Statesville Fertilizer - 502001Tables Excel\Current Annual Report tables\1Lstorical Nitrate Trend Graphs with Tables.xls

Concentrations in mg/L
K65W6E (Bedrock)
350 -
300 -
250 -
200 -
150 -
100 -
50 -
-6-Nitrate Results
- Ammonia Results
- Nitrate 2L Standard
Treatment System Became Operational (1994)
0 - �• - ♦♦ ♦, ,A A -A A♦ •, •A.Ar,•r, A4r A A A A, M ,♦ ,I
O CVrr1 V a 'D l> 00 ON O N rrl Y Vt 'O CO ON 0 rn Vl l0 r- 00 ai
O, C; ON ? ON ON 0, ON ON 01 0 O O O O 0 O O 0 0
Date
Date
8/1/90
1/22/92
2/10/93
8/2/95
11/8/95
2/8/96
5/9/96
11/15/96
5/20/97
11/18/97
5/19/98
11/19/98
3/30/99
Nitrate (mg/1)
7.3
37
27
4.4
5
56
7.9
8.5
11.7
24.1
30.9
49.9
50.4
Ammonia (mg/1)
No Data
Date
11/3/99
3/28/00
11/16/00
4/5/01
10/24/01
3/29/02
10/18/02
5/2/03
10/17/03
4/16/04
10/28/04
7/18/05
10/27/05
Nitrate (mg/1)
56
67
68
62
78
81
76
62
60
90
100
120
150
Ammonia (mg/1)
No Data
<0.10
<0.10
<0.10
NS
NS
<0.10
Date
4/26/06
10/23/06
5/1/07
10/15/07
4/25/08
12/18/08
4/9/09
10/30/09
4/6/10
10/22/10
4/22/11
11/2/11
5/10/12
Nitrate (mg/1)
140
150
150
14.2
169
202
253
44.4
243
203
311
278
181
Ammonia (mg/1)
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
0.5
<0.10
1.7
0.62
1.6
1.8
0.33
Date
11/7/12
5/23/13
11/20/13
5/30/14
5/21/15
5/25/16
7/28/2017
8/30/17
10/16/18
11/11/19
Nitrate (mg/1)
223
196
297
275
263
320
74
330
350
340
Ammonia (mg/1)
1.2
0.56
1.6
1.0
1.5
0.92
0.7
0.44
0.36
0.16
P:\Southem States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Hlstorical Nitrate Trend Graphs with Tables.xls

Date
12/19/08
4/9/09
10/29/09
4/6/10
10/21/10
4/21/11
11/1/11
5/9/12
11/6/12
5/23/13
11/19/13
5/29/14
5/20/15
5/25/16
Nitrate (mg/1)
0.30
0.26
0.36
0.47
0.36
0.40
0.36
0.72
0.54
0.74
0.52
0.67
0.79
0.76
Ammonia (mg/1)
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
<0.10
Date
7/27/17
10/ 15/ 18
10/29/19
Nitrate (mg/1)
1.1
0.8
1
Ammonia (mg/1)
<0.10
<0.10
<0.10
P:\Southem States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\ Historical Nitrate Trend Graphs with Tables.xls

slxsalgey Tim sydeuj puaiy aleq!N leouols!g\salget uodag jemmy lualnDvaox-a salgcy\00ZOS - lam a, 911Insa3elS\salelS waylno \:d
£'Z
S'Z
S'Z
S'Z
8'Z
CZ
0'£
8'Z
£'Z
9'Z
CZ
87
(!/8w) e!uoiuu
96
L8
Z8
98
Z7.8
9'58
Z'06
L'98
9'S8
I'L8
£'S8
£'Z6
(I/$w) ale1!N
61/0E/01
81/91/01
LIILZIL
9I/9Z/S
SI/ZZ/S
V1/6Z/S
£I/6I/II
£I/£Z/S
ZI/L/II
ZI/0I/S
1I/Z/II
II/IZ/4
awl
8'£
9'£
9'£
Z'4
1'4
817
Z'4
S'4
I I
L'£
l'4
SN
SN
(y2tu) u!uouuuy
91,8
4YL
4'66
VS6
801
S'66
6'SZ
68
0ZI
001
061
68
18
Om) olEliM
0I/ZZ/O1
0I/L/4
60/0£/01
60/6/4
80/6I/Z!
80/SZ/4
LO/SI/0I
L0/I/S
90/£Z/0I
90/SZ/4
S0/LZ/0I
S0/8I/L
40/8Z/0I
alea
a1 I
O O O
(.9 0 0 (.9
�O 00 �1 O1
O O
n n
O O
0o J
r
F
piepuelS'TL
sllnsax e!u0wwy
silnsag aleA!N�-
0
- OZ
- 04
- 09
OS
001
- 0ZI
- 04I
- 091
- 081
0I3oiPag) NLMS9N
00Z
90w a! aopa.ijaaaaoj

K65W7L (Bedrock)
200
180
—.—Nitrate Results
--.--Ammonia Results
Nitrate 2L Standard
-
160 -
t 140 -
a
120 -
a
0
` 100
a
u
u
a
c j 80 -
60 -
40
20
0
0 0 0 0 0 0 0 `� .n. VD .�. O0 a
'T `" it a i> i� o i> t iT i> ', o 0
O O O O O O O O O O O O O O O O
Date
Date
10/28/04
7/18/05
10/27/05
4/25/06
10/23/06
5/1/07
10/15/07
4/25/08
12/19/08
4/9/09
10/30/09
4/7/10
10/22/10
Nitrate (mg/1)
22
98
110
130
120
99
30.5
104
103
93.8
103
85.7
95.2
Ammonia (mg/1)
NS
NS
7.7
7.4
11
11
12.9
12.4
10.4
10.1
9.4
9.0
12.8
Date
4/21/11
11/2/11
5/10/12
11/7/12
5/23/13
11/19/13
5/29/14
5/22/15
5/26/16
7/27/17
10/16/18
10/30/19
Nitrate (mg/1)
96.4
116
94.9
97.8
94.5
94.7
94.2
101.0
100
89
110
96
Ammonia (mg/1)
7
12
10.7
4.9
9.5
9.5
9.4
9.3
7.2
4.5
5.5
1.2
P:\Southern States\Statesville Fertilizer - 50200\Tables_Excel\Current Annual Report tables\Hiistorical Nitrate Trend Graphs with Tables.xls

Watson, Edward M
From:
Sent:
To:
Cc:
Subject:
Colin Carraway <[e-mail]>
Tuesday, January 28, 2020 12:45 PM
Watson, Edward M
Jayson Kilcoyne
[External] Statesville Fertilizer Plant RW-6 Update
open attachments unless
Edward,
The pump for recovery well RW-6 at the Southern States — Statesville Fertilizer Plant was replaced and reactivated today
(1/28/20) at about 1030.
Regards,
Colin Carraway, G.I.T.
Staff Geologist
511 Keisler Drive, Ste. 102
Cary, North Carolina 27518
[phone] x 112
colin!a dunckleedunham.com
ww w. dunckleed unham.com
DUNCKLEE & IDUN -HA ul
ENVIRONMENTAL GEOLOGISTS # ENGINEERS
A Professional Geologic and Engineering Corporation
1

Watson, Edward M
From: Watson, Edward M
Sent: Wednesday, February 5, 2020 1:29 PM
To: Colin Carraway
Subject: RE: [External] Statesville Fertilizer Plant System Update (2/4/2020)
Thank you for the notification.
From: Colin Carraway [mailto:[e-mail]]
Sent: Tuesday, February 4,12020 3:09 PM
To: Watson, Edward M <[e-mail]>
Cc: Jayson Kilcoyne <[e-mail]>
Subject: [External] Statesville Fertilizer Plant System Update (2/4/2020)
Edward,
The plant manager of the Southern States — Statesville Fertilizer Plant notified us today that power at the facility went
down this morning after a power pole broke, including power to the system. I was just notified again that power has
just been restored, and the system and all three wells are back up and running. The plant manager said the wells were
down for a total of about eight hours today.
Regards,
Colin Carraway,
Staff Geologist
511 Keisler Drive, Ste. 102
Cary, North Carolina 27518
[phone] x 112
co linra;;d unckleedunham. com
www.dunckleedunham.coin
DUNCKLEE & DUNHAM
ItONMENIAL GEOLOGISTS E +CiSEEfi.S
A Professional Geologic and Engineering Corporation
1

Watson, Edward M
From:
Sent:
To:
Cc:
Subject:
Colin Carrawa [e-mail]>
Friday, Ja uary-10, 2 0 8:54 AM
Watson, Eder
Jayson Kilcoyne
[External] Southern States - Statesville Fertilizer Plant Update
open-- attachments u less
Edward,
Yesterday (1/9/20) while conducting system O&M at the Statesville Fertilizer Plant treatment system, I discovered
recovery wells RW-5r and RW-6 were not turning on/moving water. We believe this is a result of the power surge that
stopped the system during my previous visit. RW-2 and the rest of the system is operating as normal. I have notified
facility personnel, and they are coordinating with a well driller to pull each pump and check the electrical components. I
will keep you updated as more information arises.
Best Regards,
Colin Carraway, G.I.T.
Staff Geologist
511 Keisler Drive, Ste. 102
Cary, North Carolina 27518
[phone] x 112
col in(adunckleedunham.com
ww-w-.dunekleedunham.com
DUNCILEE & DUNHAM
NV1RONMENTAL GEOLOGISTS ;tc. ENGINEERS.
A Professional Geologic and Engineering Corporation
1

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 01-2020 (January 2020)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
G
Composite Sample Time
Total Composite Time
Operator Arrival Time
Operator Time On Site
ORC On Site?"
No Reporting Reason`••`
50050
00400
C0610
C0530
C0600
C0665
00940
01042
00900
Continuous
2 X month
2 X month
2 X month
Monthly
Monthly
Monthly
Monthly
Monthly
Recorder
Grab
Grab
Grab-
Grab
Grab
Grab
Grab
Grab
FLOW
pH
NH3-N-Cone
TSS - Cone
TOTALN-
TOTALP - Coot
CHLORIDE
COPPER
TOT HARD
2400 clock
Hrs
2400 clock
Hrs
Y/BIN
mgd
su
mg/I
mg/I
mg/1
mg/I
mg/1
mg/I
mg/1
I
0.072
2
0.072
3
0.072
4 1
0.072
5
0.072
6
0.072
7
0.072
8
0.072
9
0930
2.25
Y
0.066
6.95
0.21
< 2.5
25
0.18
33
< 0.02
190
10
0.066
1I
0.066
12
0.066
13
0.066
14
0.066
15
0.066
16
0.066
17
0.066
18
0.066
19
0.066
20
0915
4.5
Y
0.07
6.84
0.21
<2.5
21
0.07
22
0.07
23
0.07
24
0.07
25
0.07
26
0.07
27
0.07
28
0.07
29
0.07
30
0.07
31
0.07
Mon hly Average Limit:
30
}Ionthly Average:
0.069097
0.21
0
25
0.18
33
0
190
Daily Maximum:
0.072
6.95
0.21 -'
0
25
0.18
33
0
190
Daily Minimum:
0.066
6.84
0.21
0
25
0.18
33
0
190
'•" No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation - Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation - Holiday

NPDE PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southem States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 01-2020 (January 2020)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
Composite Sample Time
Total Composite Time
E
1.
T.
Operator Time On Site
5
No Reporting Reason.***
00620
Monthly
Grab
NO3-N
2400 clock
Hrs
2400 clock
Hrs
Y/B/N
mg/I
1
2
3
4
5
6
7
8
9
0930
2.25
Y
25
10
11
12
13
14
15
16
17
18
19i
20I
0915
4.5
Y
211
22
23
24
25
26
27
28
29
30
31
Mon hly Average Limit:
Monthly Average:
25
Daily Maximum:
25
Daily Minimum:
25
"" No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation — Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation — Holiday

NPDES PERMIT NO.: NC0082821 PERMIT VERSION: 5.0 PERMIT STATUS: Active
FACILITY NAME: Statesville Fertilizer Plant CLASS: PC-1 COUNTY: Iredell
OWNER NAME: Southern States Cooperative Inc ORC: Colin Charles Carraway ORC CERT NUMBER: 1007935
GRADE: PC-1 ORC HAS CHANGED: No
eDNIR PERIOD: 01-2020 (January 2020) VERSION: 1.0 STATUS: Submitted
COMPLIANCE STATUS: Compliant CONTACT PHONE #: [phone] SUBMISSION DATE: 02/10/2020
02/10/2020
0
RC/Certifier Signature: Colin Carraway E-Mail:[e-mail] Phone #:[phone] Date
By this signature, I certify that this report is accurate and complete to the best of my knowledge.
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.
If1the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by part II.E.6 of
the NPDES permit.
02/10/2020
Permittee/Submitter Signature:*** Colin Carraway E-Mail:[e-mail] Phone #:[phone] Date
Permittee Address: 2582 Salisbury Hwy Statesville NC 28677 Permit Expiration Date: 03/31/2024
I certify. under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations.
LAB NAME: Duncklee & Dunham
CERTIFIED LAB #: 5484
PERSON(s) COLLECTING SAMPLES: Colin Carraway
CERTIFIED LABORATORIES
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit [phone] or by visiting http://portal.ncdenr.org/web/wq/swp/ps/npdes/forms.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the parameters on the DMR
for entire monitoring period.
** ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).

NPDES PERMIT NO.: NC0082821
s
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 01-2020 (January 2020)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
I;teport Comments:
*Two recovery well pumps (RW-5r & RW-6) were damaged from a power surge on 12/23/19 and had to be replaced. The pump to RW-5r was replaced and activated on 1/20/20,
and the pump to RW-6 was replaced and activated on 1/28/20.*

NPDES'PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC -I
eDMR PERIOD: 12-2019 (December 2019)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
u
3
F
E
-
0
J
Total Composite Time
E
3
_
b
Operator Time OR Site
p
u
0
50050
00400
C0610
C0530
C0600
C0665
00940
0104E
00900
Continuous
2 X month
2 X month
2 X month
Monthly
Monthly
Monthly
Monthly
Monthly
a
Recorder
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
tt
Z
FLOW
pH
NH3-N-Cone
TSS -Conc
TOTAL N -
TOTAL P - Coac
CHLORIDE
COPPER
TOT HARD
2400 clock
Hrs
2400 clock
Hrs
WWN
mgd
su
mg/1
mg/l
mg/1
mg/l
mg/l
mg11
mg/1
1
'
0.0003
2
0.0003
3
0.0003
4
0.0003
5,
0.0003
6
0.0003
7
0.0003
8
0.0003
9
0.0003
18
0.0003
11
0.0003
12
0.0003
13
1030
4.75
Y
0.043
6.48
0.57
3.9
18
0.32
34
<0.02
190
14
0.043
15
0.043
16
0.043
17
0.043
18
0.043
19
0.043
20.
0.043
21
0.043
22
0.043
23
0.043
24
0.043
25
0.043
26
0.043
27
0.043
28
0.043
29
0.043
30
1015
4.75
Y
0.072
8.44
< 0.1
< 2.9
31
0.072
Mon hly Average Limit:
30
Monthly Average:
0.028342
0.285
1.95
18
0.32
34
0
190
Daily Maximum:
0.072
8.44
0.57
3.9
18
0.32
34
0
190
Daily Minimum:
0.0003
6.48
0
0
18
0.32
34
0
190
**** No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation - Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation - Holiday

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 12-2019 (December 2019)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
Composite Sample Time
Total Composite Time
F
a
_
Operator Time On Site
U
o
&
00620
z
Monthly
a
C
z'
Grab
NO3-19
2400 clock
Hrs
2400 clock
Hrs
Y/a/N
mg/1
1I
2I
3
4'
5I
61
7
8
.
9
10
II
12
13
1030
4.75
Y
19
14
15
'
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
1015
4.75
Y
31
Moo hly'Average Limit:
Monthly Average:
19
Dolly Maximum:
19
Doily Minimum:
19 .
'•" No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation — Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation — Holiday

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 12-2019 (December 2019)
COMPLIANCE STATUS: Compliant
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
CONTACT PHONE #: [phone]
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SUBMISSION DATE: 01/24/2020
01/24/2020
ORC/Certifier Signature: Colin Carraway E-Mail:[e-mail] Phone #:[phone] Date
By this signature, I certify that this report is accurate and complete to the best of my knowledge.
T e permittee'shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.
Iithe facility is noncompliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by part II.E.6 of
the NPDES permit.
i
Piermittee/Submitter Signature:*** Colin Carraway E-Mail:[e-mail] Phone #:[phone] Date
Permittee Address: 2582 Salisbury Hwy Statesville NC 28677 Permit Expiration Date: 03/31/2024
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the, information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME: Duncklee & Dunham
CERTIFIED LAB #: 5484
PERSON(s) COLLECTING SAMPLES: Colin Carraway
01/24/2020
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit [phone] or by visiting http://portal.ncdenr.org/web/wq/swp/ps/npdes/forms.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the parameters on the DMR
for entire monitoring period.
** ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2)(D).

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 12-2019 (December 2019)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
Report Comments:
System back in operation on 12/13/19 after tube broken on vacuum pump was repaired.
System down a separate time after power surge on 12/23/19, and was reset/back in operation during ORC visit on 12/30/19.

NPDES PERMIT NO.: NC0082821
I<ACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 11-2019 (November 2019)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
21
p'
Composite Sample Time
Total Composite Time
Operator Arrival Time
Operator Time On Site
ORC On Site?"
_
i
,
Z
24
y'
50050
00400
C0610
C0530
C0600
C0665
00940
01042
00900
Continuous
2 X month
2 X month
2 X month
Monthly
Monthly
Monthly
Monthly -
Monthly
Recorder
Grab
Grab
Grab
Grab
Grab -
Grab
Grab
Grab
FLOW
pH
NH3-N-Cone
ISS-Cone
TOTAL N -
TOTAL P - Conc
CHLORIDE
COPPER
TOT HARD
2400 clock
Hrs
2400 dock
Hrs
YIB/N
-
mgd
su
mg/1
mg/1
mg/I
me
mg/1
mg/I
mg/1
1
...
0.059
2
0.059
3
-
0.059
4
0.059
-
-
5
0.059
-
6,
0.059
'
7
0.059
8
0.059
9,
0.059
t6
0.059
II
0945
2
Y
0.059
6.74
1.3
<2.5
39
0.28
48
<0.02
270
12
0.027
Li
0.027 - -.
14
0.027
15
0.027
16
0.027
17
..
0.027
• •
18
1000
0.75
Y
0.027
6.68 •.
19
-
- -
0.027
20
1045
1
B
0.027
6.75
21
•
0.027
-
22
0.027
23
- ' .
0.027
24
0.027
25
1030
1.75
B
0.027
6.76 .
< 0.1
< 2.5
26
0
27
0
28
0
29
-
0
30
0
Mon hly Average Limit:
30
Monthly Average:
'0034233
0.65
0
39
0.28
48
0
270
Daily Maximum:
0.059
6.76
1.3
0
39
0.28 -
48
0
270.
Daily Minimum:
0
6.68
0
0
39 -
0.28
48
0
270
."' No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation — Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation — Holiday

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
iDMR PERIOD: 11-2019 (November 2019)
PERMIT VERSION: 5.0
CLASS: PC-1
ORC: Colin Charles Carraway
ORC HAS CHANGED: No
VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1007935
STATUS: Submitted
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO (Continue)
a
Composite Sample Time
Total Composite Time
e
r
a
e`
a0
Operator Time On Site
=
o°
0
9
s
el
-
00620
TGP3B
Monthly
Quarterly
Grab
Grab
03
N-N
CERI7DPF
2400 clock
Hrs
2400 clock
Hrs
Y/B.N
mg/1
pass/fail
I
4
5
6
•
7
8
9
.
10
11
0945
2
Y
37
12
13
14
15
16
17
18
1000
0.75
Y
PASS
19
20
1045
1 .
B
PASS
21
22
-
23
24
25
1030
1.75
B,
26
27
28
•
29
30
Moo hly Average Limit:
Monthly Average:
37
Daily Maximum:
37
Daily Minimum:
37
- -
"" No Reporting Reason: ENFRUSE = No Flow-Reuse/Recycle; ENVWTHR = No Visitation — Adverse Weather; NOFLOW = No Flow; HOLIDAY = No Visitation — Holiday
I

NPDES PERMIT NO.: NC0082821 PERMIT VERSION: 5.0 PERMIT STATUS: Active
FACILITY NAME: Statesville Fertilizer Plant CLASS: PC-1 COUNTY: Iredell
OWNER NAME: Southern States Cooperative Inc ORC: Colin Charles Carraway ORC CERT NUMBER: 1007935
RADE: PC-1 ORC HAS CHANGED: No
e MR PERIOD: 11-2019 (November 2019) VERSION: 1.0 STATUS: Submitted
COMPLIANCE STATUS: Compliant • CONTACT PHONE #: [phone] SUBMISSION DATE: 12/31/2019
12/31/2019
ORC/Certifier Signature: Colin Carraway E-Mail:[e-mail] Phone- #:919-858-9898Date
By this signature, I certify that this report is accurate and complete to the best of my knowledge.
Tre permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by part II.E.6 of
the NPDES permit.
12/31/2019
P;ermittee/Submitter Signature:*** Coliri Carraway E-Mail:[e-mail] Phone #:[phone] Date
Permittee Address: 2582 Salisbury Hwy Statesville NC 28677 Permit Expiration Date: 03/31/2024
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME: Duncklee & Dunham
CERTIFIED LAB #: 5484
PERSON(s) COLLECTING SAMPLES: Colin Carraway, Lily Walker
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit [phone] or by visiting http://portal.ncdenr.org/web/wq/swp/ps/npdes/forms.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the parameters on the DMR
for entire monitoring period.
** ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then delegation of the signatory authority must lie on file with the state per 15A NCAC 2B
.0506(b)(2)(D).

NPDESPE1 MIT NO.: NC0082821
1
FACILITY NAME: Statesville Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE: PC-1
eDMR PERIOD: 11-2019 (November 2019)
• PERMIT VERSION: 5.0
PERMIT STATUS: Active
CLASS: PC-1 COUNTY: Iredell
ORC: Colin Charles Carraway : ORC CERT NUMBER: 1007935
ORC HAS CHANGED: No
VERSION: 1.0 STATUS: Submitted '
Report Comments:
*System broke and shut off on an unknown date, leading to lower totalizer readings than usual. The system was found to have had a ruptured tube leading to a vacuum pump
which was discovered and repaired on 12/13/19. Based on interpretation from totalizer values, it is likely the system shut off approximately 7-8 days after the visit on 11/11/19.
Therefore, it is estimated the system was down from —11/18/19-12/13/19, though the day the flow stopped is an approximation. The tubing had melted along a heated piece of
equipment, which stopped the recovery wells from cycling more water into the system once it had ruptured. The wells became operational again on 12/13/19 once the tube was
r�paired.*

Recovery Well Totalizer Readings and Recovery Volumes - 2018
Statesville Fertilizer Plant
ORC
Well ID
RW-5r RW-6 RW-2
Daily Flows
Number
On -site
Date
Meter Reading (Gallons)
Totals
(MGD)
of Days
Notes
AGD
12/21/2017
779,511.4
5,161,418.0
27,818,555.0
33,759,484.4
AGD
1/10/2018
781,378.2
5,170,004.0
27,818,555.0
33,769,937.2
20
Pipe burst in RW-2. System shut down-upgrades/repairs, 1/2/18-2/2/18
BLW
2/2/2018
781,950.8
5,170,600.1
27,971,035.0
33,923,585.9
0.007
23
AGD
2/19/2018
810,246.8
5,233,726.0
29,357,471.0
35,401,443.8
0.087
17
AGD
2/21/2018
810,246.8
5,241,597.1
29,509,581.0
35,561,424.9
0.080
2
RW-5r Down
BLW
3/7/2018
810,246.8
5,294,200.6
30,496,406.0
36,600,853.4
0.074
14
AGD
3/19/2018
821,769.9
5,340,550.1
31,313,865.2
37,476,185.2
0.073
12
RW-5r pump replaced and well reactivated
BLW
4/3/2018
896,970.1
5,396,200.9
32,298,205.1
38,591,376.1
0.074
15
BLW
4/26/2018
896,970.5
5,483,624.0
33,640,000.0
40,020,594.5
0.062
23
BLW
5/7/2018
927,130.8
5,527,298.0
34,061,643.0
40,516,071.8
0.045
11
Pipe leak at RW-2, shut off
AGD
5/9/2018
940,450.1
5,534,741.0
34,067;355.0
40,542,546.1
0.013
2
RW-2 reactivated
BLW
5/21/2018
1,008,140.8
5,578,085.0
34,102,000.0
40,688,225.8
0.012
12
JAK
6/8/2018
1,111,021.5
5,644,889.0
36,030,184.0
42,786,094.5
0.117
18
JAK
6/20/2018
1,180,698.0
5,690,300.1
36,771,340.5
43,642,338.6
0.071
12
otal Removed (ga
% Contribution
1,186.E
4%
528,882.1
5%
8,952,785.5
91%
9,882,854.2
181 Total Days
171 Adjustment for days in 2018
31 Days system off

100.0% 100.0%
100.0% -
90.0%
80.0%
70.0% -
T
r..
60.0%
L
ai
O 50.0%
aJ 40.0%
a 30.0%
20.0%
10.0% -__
System Operation• Efficiency -. 2014-2018
100.O% 100.O%
48.8%
far.
Converted to Annual
System Operation
71.8%
68.8%
81.9% �---
Notes:
2014 to 2015 - system off between April and November, as approved by DEQ.
2018 data is as current as June 20, 2018

Page 1 of 4
A newsletter about soil, sediment, and groundwater characterization and remediation technologies
PAUnited States
Environmental Protection'
Agency
Performance Monitoring: Evaluating a Wheat Straw PRB for Nitrate Removal at an
Agricultural Operation
Contributed by Stephen R. Hutchins Ph.D., and Richard T. Wilkin, Ph.D., U.S. EPA National Risk Management
Laboratory
The U.S. EPA Office of Research and Development's National Risk Management Research Laboratory
(NRMRL) is conducting long-term monitoring of a permeable reactive barrier (PRB) for remediation of
groundwater contaminated with nitrate from a now -closed swine concentrated animal feeding operation
(CAFO) in Oklahoma. Extensive groundwater contamination by both nitrate and ammonium arose from a
leaking waste lagoon during seven years of operation. The selected remediation strategy involved installing an
interception trench barrier for recovery and subsequent above -ground treatment of ammonium through use of
an evaporation basin. A PRB containing commercial wheat straw as the reactive matrix was installed for in situ
treatment of nitrate resulting from nitrification of the lagoon's ammonium plume and also from excessive land
application of lagoon effluent.
The PRB was constructed in 2003 in a shallow aquifer consisting of fractured sandstone with interspersed clay
and sand lenses that are underlain by a thick layer of shale at approximately 25 to 50 feet below ground
surface (bgs). A trench approximately 840 feet long and 4 feet wide was excavated to intercept the
contaminant plume at 8 to 18 feet bgs. Approximately 4,500 square and 300 round bales of wheat straw were
emplaced in the trench. The rate of groundwater flow through the PRB is estimated at 500 feet/day.
The PRB was not
constructed on
level terrain. As a
result, much of it
slopes sharply
toward a center
drainage area
between access
wells NB1 and NB3
(Figure 1). A seep
in this drainage
area emanates
from the top
surface of the PRB
and consequently
acts as a seasonal
discharge point.
Because the PRB
matrix is 500 to
4,000 times more
permeable than the
aquifer matrix,
there is a
significant potential
for longitudinal flow
within the PRB
toward this seep.
1.44nn•//nl,, !urn AMR/rvrnrinn4o/nnwoltrokknonrifwiucv nnnr nfm9iocntno1121') "cm
11/11111111G

Page 2 of 4
In 2004, NRMRL
researchers
established
transects across
the PRB at two
locations, each
with fully screened
2-inch PVC wells
upgradient, within,
and downgradient
of the PRB (Figure
2). Although the
goal was to place
three wells inside
the PRB at each
transect,
uncertainties
regarding the
location of the PRB
boundary led to the
final position of well
T2B being slightly
upgradient of the
PRB at transect #2.
To provide vertical
resolution of water
quality within the
PRB, cluster wells were also installed at
transect #2 using 0.25-inch polyethylene
tubing with 6-inch-long stainless steel well
screens to a depth of 14 to 23 feet bgs
(Figure 2). Quarterly monitoring of the
transect wells for multiple parameters began
in 2004; this schedule was scaled back to
annual sampling in 2008 and continues to
the present. During the nine-year study
period, groundwater elevations fluctuated by
as much as 4-6 feet due to weather
extremes, which included droughts in 2004
and 2011 and excessive rainfall in 2007.
These conditions also affected PRB
performance.
«rd
r.
52 Seep
PIN G
+snot'
1
Figure 1. Aerial view of PRB, wells, and surface features at the Oklahoma
CAFO site.
Denitrification occurred rapidly within the
PRB soon after construction. Although
monitoring of the transect wells did not begin
until 2004, analysis of samples from the five
PRB access wells taken four months after
start-up revealed an actively reducing
environment. Reducing conditions included an oxidation-reduction potential of -63 to -98 millivolts and pH of
3.7 to 4.5, with high organic carbon (total organic carbon (TOC) of 1,030 to 3,920 milligrams per liter [mg/L])
and no detectable nitrate (< 0.004 mg/L nitrate -nitrogen). Ammonium production, however, was substantial (36
to 250 mg/L ammonium ion -nitrogen). One source of ammonium could be the decomposition of organic
nitrogen in the straw. Another potential source is the dissimilatory nitrate reduction to ammonium (DNRA),
which is common among fermentative bacteria and would be expected under conditions of low oxygen, low
nitrate, and high TOC.
Figure 2. Groundwater quality monitoring wells
within the PRB at transect #2.
11 H A11111f

Page 3 of 4
Over time, the high ammonium concentrations dissipated. Based on transect well data, monitoring results
showed that denitrification was occurring at both transect locations and the PRB chemistry generally began
working as expected. After two years of PRB operation, subsidence was observed along the barrier length.
Subsidence worsened with time to the point that ground surface elevations dropped as much as 5 feet at the
centerline along much of the PRB, especially in sections northeast of the seep. The subsidence was attributed
primarily to extensive decomposition of the straw matrix, and the decision was made to not replenish this
material. Excessive rainfall likely exacerbated this condition in 2007, when the PRB began collecting runoff and
creating a temporary infiltration gallery along much of its length.
These events are evident in the water chemistry at transect #1 (Figure 3). For the first four months, nitrate was
generally absent within the PRB and excess TOC existed for denitrification. The nitrate concentrations dropped
slowly in the downgradient well TIE and then unexpectedly rose. This trend may be due to a greater
component of longitudinal flow within the PRB at this location toward the seep, thereby providing partial
isolation of this well location. It is also possible that ammonium initially produced by DNRA migrates
downgradient of the PRB and, as the groundwater slowly aerates, is converted to nitrate through nitrification.
T1� dirrrrrr
�TII�
M_.
•e 3. Transect #1 groundwater nitrate and TOC profiles in upgradient (TIA), within-PRB (T1B,
T1 D) and downgradient (T1 E) wells.
The effect of excessive rainfall in 2007 can be seen in the water chemistry data; infiltrating runoff caused
substantial outflow from the PRB in both directions, drastically lowering nitrate levels in both upgradient well
T1A and downgradient well Ti E (Figure 3). The event also appears to have brought TOC into the PRB at this
location, although TOC levels subsequently dropped rapidly and continued to decline. The decrease in TOC
corresponds with an increase of nitrate within the PRB, which has led to substantial failure of the PRB at this
location.

,
Page 4 of 4
At
Tran ett#2
itrate
-. T21\
z
ti3: Jun05 ;;:lun47: , Jur0t Jun11
Jun, 03 Jun 05 Aut 07 Jun 09 Jiro 11
•e 4. Transect #2 groundwater nitrate and TOC profiles in upgradient (T2A, T2B), within-PRB
T2D), and downgradient (T2E) wells.
In contrast, the PRB continues to perform effectively at transect #2. Denitrification is quite active, and nitrate
concentrations have remained below 0.2 mg/L nitrate -nitrogen in the downgradient well T2E since 2007 (Figure
4). Unlike transect #1, TOC persisted for a longer time within the PRB at this location. This persistence may be
attributed to the downward slope of the PRB in both directions at this point, which reduces longitudinal flow
along the PRB length and lowers the infiltration components, consequently preserving more of the straw matrix.
The high rainfall event in 2007 also caused outflow from the PRB in both directions at this transect; however,
recovery time for well T2A was much longer than for well T2B.
Overall results of monitoring since 2004 indicate that the PRB is beginning to fail, especially in areas where
longitudinal flow and infiltration of rainfall runoff may have rapidly depleted TOC. Because replenishment of the
straw matrix or backfill of the subsided areas is not expected, it is unclear whether the PRB performance will
outlast the anticipated reduction in nitrate mass influx. The high levels of ammonium initially produced within
the PRB are an additional concern, since the amount of ammonium transported to areas beyond the PRB is
unknown. For the past seven years, ammonium plumes have been observed at two downgradient wells (MW34
and MW35) with levels of ammonium ion -nitrogen peaking at 10 to 13 mg/L and slowly dropping to current
levels of 2 to 4 mg/L.
NRMRL plans to continue monitoring performance of the PRB as long as possible. Discussions are pending
between responsible parties and regulatory personnel on what additional steps, if any, need to be undertaken
to bring this site to appropriate closure status.
l,ffo,c-I,//r,l„ ,,,.,ogre/„«,..7,,.,4.-1/«e.,,.,1+..n/4«.,«,14/.,:,..., n:. .. —noire F 11 /1 n/',n1 e

NITRATE POLLUTION OF GROUNDWATER Page 1 of 14
NITRATE POLLUTION OF GROUNDWATER
Prepared by: Lee Haller, Patrick McCarthy, Terrence O'Brien, Joe Riehle, and Thomas Stuhldreher
NITRATE ABSTRACT
Nitrogen is a major constituent of the earth's atmosphere and occurs in many different gaseous forms
such as elemental nitrogen, nitrate and ammonia. Natural reactions of atmospheric forms of nitrogen
with rainwater result in the formation of nitrate and ammonium ions. While nitrate is a common
nitrogenous compound due to natural processes of the nitrogen cycle, anthropogenic sources have
greatly increased the nitrate concentration, particularly in groundwater. The largest anthropogenic
sources are septic tanks, application of nitrogen -rich fertilizers to turfgrass, and agricultural processes.
Levels of nitrates in groundwater in some instances are above the safe levels proposed by the EPA and
thus pose a threat to human health. Particularly in rural, private wells, incidence of methemoglobinemia
appears to be the result of high nitrate levels. Methemoglobinemia, or blue baby syndrome, robs the
blood cells of their ability to carry oxygen. Due to the detrimental biological effects, treatment and
prevention methods must be considered to protect groundwater aquifers from nitrate leaching and high
concentrations. Treatment through ion -exchange and other processes can rehabilitate already
contaminated water, while prevention, such as reduced dependence on nitrogen -rich fertilizers can lower
the influx of nitrates.
Table of Contents
• I. ABSTRACT
• II. INTRODUCTION
• III. BODY
• A. Nitrogen Cycle
• B. Major Sources of Nitrate Pollution
• C. Environmental Protection Agency Regulations
• D. Problems Associated With High Nitrate Levels
• E. Clean-up of Nitrate from Water
• F. Prevention
• IV. CASE STUDY: IOWA
• V. CONCLUSION
• WORKS CITED
ALPHA MODEL FGA-60N 30,000 GRAIN WHOLE HOUSE NITRATE REMOVAL UNIT
(SALT BASED UNIT SIMILAR TO A WATER SOFTENER IN OPERATION)
CALL WITH ANY QUESTIONS 973-293-7856
1.+, .II......11 n ni')ni

NITRATE POLLUTION OF GROUNDWATER
Page 2 of 14
Have a E oesti ?mower
.�
a:Lea,ve, Pe
Live Chat by Provide5upport
INTRODUCTION
Nitrate is a problem as a contaminant in drinking water (primarily from groundwater and wells) due to
its harmful biological effects. High concentrations can cause methemoglobinemia, and have been cited
as a risk factor in developing gastric an intestinal cancer. Due to these heath risks, a great deal of
emphasis has been placed on finding effective treatment processes to reduce nitrate concentrations to
safe levels. An even more important facet to reduce the problem are prevention measures to stop the
leaching of nitrate from the soil. Some suggest that reducing the amount of fertilizers used in agriculture
will help alleviate the problem, and may not hurt crop yields. Other new developments in leach pits and
slurrystores help to control the nitrate that comes from stored manure. By installing these prevention
methods and reducing the amount of fertilizer used, the concentration of nitrate in the groundwater can
be reduced over time. Treatment processes, such as ion exchange can have an immediate effect on
reducing levels in drinking water. These processes do not remove all the nitrate, but can help to bring the
concentration down to the suggested level of 10mg/L.
NITROGEN CYCLE (Atmosphere -Soil)
Nitrogen is the most abundant element in the atmosphere, composing nearly 80% of the air we breathe
(Berner and Berner, 1987). Gaseous nitrogen can be found in many forms, the major ones consisting of
N2, N20, NO, NO2, NH3 (Gaillard, 1995). Some of these gases readily react with rain water to produce
nitrate and ammonium ions in solution. These ions can become part of the soil layer composition, or
even enter into a groundwater solution.
The two most important compounds that result from the reaction of these gases and rainwater are nitrate
(NO3-, an anion) and ammonium (NH4+, a cation). In the atmosphere major sources of nitrate include
reactions caused by lightning, photochemical oxidation in the stratosphere, chemical oxidation of
ammonia, soil production of NO by microbial processes, and fossil fuel combustion (Gaillard, 1995).
Ammonia in the air comes from fertilizer manufacturing, anaerobic decay of organic matter, bacterial
decomposition of excreta, and the burning of coal (Gaillard, 1995). Anthropogenic activities have a
major impact on the levels of these compounds that are found in both rain water and the atmosphere.
Many of the major sources of nitrate and ammonium come from the use and production of fertilizers and
the burning of fuels, as listed above.
Nitrate that leaves the atmosphere can be converted back into elemental nitrogen, through the process of
denitrification. This often takes place in the soil through the activity of bacteria that reduce the nitrate.
Ammonium can undergo the process of nitrification, which is an oxidation reaction, that converts it to
nitrate. Through this mechanism, the nitrogen in the ammonium ion is released back into the atmosphere
(Berner and Berner, 1987). After the conversion from elemental into nitrogenous ions in solutions of
rainwater, the nitrogen in these compounds can be exhausted back to the atmosphere by the pathways
previously described, thus completing the cycle.
1inni'nic

NITRATE POLLUTION OF GROUNDWATER Page 3 of 14
MAJOR SOURCES OF NITRATE POLLUTION
Although there are many sources of nitrogen (both natural and anthropogenic) that could potentially lead
to the pollution of the groundwater with nitrates, the anthropogenic sources are really the ones that most
often cause the amount of nitrate to rise to a dangerous level. Waste materials are one of the
anthropogenic sources of nitrate contamination of groundwater. Many local sources of potential nitrate
contamination of groundwater exist such as, "sites used for disposal of human and animal sewage;
industrial wastes related to food processing, munitions, and some polyresin facilities (Vomocil, 1987);
and sites where handling and accidental spills of nitrogenous materials may accumulate" (Hallberg and
Keeney, 1993, p. 303). Septic tanks are another example of anthropogenic source nitrogen
contamination of the groundwater. Many areas of the United States and other countries have reported
significant contamination of groundwater from septic tanks. Ground water contamination is usually
related to the density of septic systems (Hallberg and Keeney, 1993). In densely populated areas, septic
systems can represent a major local source of nitrate to the groundwater. However in less populated
areas septic systems don't really pose much of a threat to groundwater contamination.
When natural sources contribute a high concentration of nitrate to the groundwater it is usually as a
result of anthropogenic disturbance. One example of this is the effect of forested areas on the leaching of
nitrate to the groundwater. Natural, mature forests conserve nitrogen but human disturbances can lead to
nitrate pollution of the groundwater. However, while this is a potential problem for groundwater, forests
represent a very small source of nitrogen compared to agriculture (Hallberg and Keeney, 1993).
Non-agricultural
One potentially large source of nitrogen pollution of groundwater is the application of nitrogen -rich
fertilizers to turfgrass. This occurs on golf courses and in residential areas. There are five fates for this
nitrogen once it is applied to turfgrass. It may be:
1) taken up by plants
2) stored in soil
3) lost to atmosphere
4) lost to groundwater
5) lost to runoff (Bocher, 1995)
Many studies have shown that most of the nitrogen, about 30 to 50 percent is taken up by the plant.
According to an United States Golfing Association study only one to two percent of the nitrogen is
leached beyond the root zone (Bocher, 1995). This finding may be slightly biased because this is the
result that the USGA desires. Also, this result may occur only when the nitrogen fertilizer is applied
carefully and properly. Certain circumstances could lead to more of the nitrogen leaching to the
groundwater. Six main factors affect nitrogen leaching:
1) nitrogen rate - One study showed that at one pound of nitrogen per 1,000 square feet, no leaching
occurred.
2) nitrogen source - Slow -release fertilizers are a nitrogen source that can reduce the chance of leaching.
3) application timing - In late fall, plants take up less nitrogen and there is a greater chance for leaching
to occur.
4) irrigation practices - The more irrigation that takes place the greater the chances for nitrate leaching.
5) soil texture - The sandier the soil the more chance for nitrate leaching.
6) age of site - Younger sites usually have less organic matter and need to be fertilized more therefore
increasing the chance of leaching. (Bocher, 1995)

NITRATE POLLUTION OF GROUNDWATER Page 4 of 14
Agricultural: Fertilizers and Animal Wastes
The main source of nitrate pollution in the groundwater results from the actions of farmers. "Farming
alone pollutes more of our groundwater resources than anything else. Because too many farmers are
caught up in an escalating cycle of pollution" (Behm,1989, p. 2). The farmers first deplete the soil by
"excessive, repeat planting" and then try to replenish the resulting less -productive soil by putting more
and more nitrogen -based fertilizer on the land in an attempt to keep crop yields constant.
One example of proof that farming is a major cause of groundwater pollution is that nitrate problems are
most common in the spring, which is the time that fanners apply nitrogen fertilizer to their fields. Also,
in a study done by Burkart and Kolpin (1993) it is found that samples of water from wells surrounded by
more than 25% land in corn and soybean have a dramatically larger frequency of excess nitrate (30%)
than wells with approximately 25% of the surrounding land in corn or soybean (11%) . Also many of the
same factors that effect nitrogen leaching in turfgrass affect it in crop fields. For example, the use of
irrigation increases the chance of nitrate pollution. "The frequency of excess nitrate was also larger
where irrigation was used within 3.2 km of a well (41 %) than where no irrigation was used
(24%)" (Burkart and Kolpin, 1993, p. 654). In areas where "the soils over the aquifer are predominantly
sand, sorption of herbicides is limited and the rate of recharge is rapid, resulting in a relatively large
potential for contamination of aquifers with ... nitrates" (Burkart and Kolpin, 1993, p. 654).
One problem caused by farms results from the grazed grasslands and feedlots. In grazing pastures
animal wastes are concentrated in small pastures, this leads to inefficient use of nitrogen and causes the
potential for groundwater contamination by nitrate. This problem is even worse in Europe where grazing
pastures are usually more intensively fertilized than in the U.S., therefore there is more nitrate available
to be leached to the groundwater (Hallberg and Keeney, 1993). Even small farms can contribute to the
problem of excess nitrates because of the high concentrations of manure that they may have in the
barnyard or feedlot areas (Hallberg and Keeney, 1993).
One of the better ways to get rid of manure is to use it to fertilize cropland. "Such organic material is
often considered a desirable nitrogen source because the nitrogen is in the mineralization -immobilization
cycle longer and thus is more slowly available" (Hallberg and Keeney, 1993, p. 303). For this reason, it
is a safer fertilizer than chemical fertilizer. However manure use does have many drawbacks such as
variable composition and quality and the extra time for nitrogen to be mineralized may not coincide with
the high rate of nitrogen needed by the crop. The main problem is the fact that an accurate estimation of
net nitrogen availability is very difficult to determine (Hallberg and Keeney, 1993). Therefore fanners
usually apply an excess of manure to the crop to insure that enough nitrogen will be available for the
growing process.
Obviously the more nitrogen fertilizer a farmer uses the greater the chance of nitrate pollution of
groundwater. "Farmers still consider nitrogen fertilizer 'cheap insurance' against crop failure" (Looker,
1991). Approximately one dollar's worth of fertilizer could bring in ten dollars of corn if the soil has a
lack of nitrogen. So the farmer would, financially speaking, much rather add too much nitrogen than too
little. To add to this problem, it is very difficult to determine exactly how much nitrogen a crop will
need before harvest time due to yearly change in yields and weather conditions. Even if farmers cut
down on nitrogen fertilizer, there will still be some nitrate leaching. As Dennis Keeney, the director of
the Leopold Center for Sustainable Agriculture at Iowa State University, states, "Even if farmers add no
fertilizer to fields, tilling the earth with machinery makes land more susceptible to leaking
nitrogen" (Looker, 1991). Although sustainable practices may not eliminate nitrates, it might lower them
to a safe level. Obviously, if there is a chance of nitrogen pollution when no fertilizer is applied, the
chance of pollution is greatly increased when a large amount of fertilizer is applied.
1 1 /111NVl1 C

NITRATE POLLUTION OF GROUNDWATER Page 5 of 14
Manure Storage
Another potential source of nitrate leaching to the groundwater that deals with farming is the storage of
the manure. Farmers commonly store manure in large holes in the ground. While this is convenient and
relatively inexpensive for the farmer in the short term , it results in excessive leaching of nitrates. In an
attempt to prevent leaching some of these manure lagoons have been built with liners. However, as a
study at the University of Wisconsin at Madison showed, there is a gradual but continuous breakdown of
the liner and after some years the liner no longer retains the ability to prevent leaching of contaminants
from the manure to the soil below (Lagoon Reclamation, 1993). Problems also arise when these manure
lagoons are left idle for a long period of time without being properly broken down. It has been found
that an empty manure storage facility can be more hazardous to groundwater than a full one. The sides
of an empty lagoon are directly exposed to the sun and air. This results in the drying and cracking of the
soil material. Precipitation containing large amounts of dissolved oxygen will then convert the
ammonium in the contaminated soil and leftover manure to nitrates which can easily be leached out
(Lagoon Reclamation, 1993).
ENVIRONMENTAL PROTECTION AGENCY
REGULATIONS
The United States Environmental Protection Agency is currently establishing National Primary Drinking
Water Regulations for over 80 contaminants under the Safe Drinking Water Act (Vogt and Cotruvo,
1987). The goal is to reduce the contaminant concentrations of all drinking water to levels near those
prescribed in the Maximum Contaminant Level Goals (MCLGs) previously established by the EPA
(Vogt and Cotruvo, 1987). MCLGs are "non enforceable health goals" at which "no known or
anticipated adverse effects on health of persons occur and which allow an adequate margin of
safety" (Vogt and Cotruvo, 1987, p. 213-215). The Maximum Contaminant Levels (MCLs) are to be set
as close to the MCLGs as possible (Vogt and Cotruvo, 1987). In the case of nitrate concentrations, the
MCL has been set at 10 mg/L (ppm) as nitrogen which is also the proposed MCLG (Vogt and Cotruvo,
1987). For many contaminants, carcinogenicity is the primary characteristic which determines the MCL;
however, because there are no conclusive epidemiological studies which link nitrate to cancer in
humans, carcinogenicity was not taken into account in the establishment of the MCL for nitrate
(Kamrin, 1987). The determining factor in the EPA's decision to set the MCL at 10 mg/L was the
occurrence of methemoglobinemia in infants under of six months. The MCL reflects the levels at which
this condition may occur (Kamrin, 1987). Although the MCL for nitrogen was set at 10 ppm nitrate -
nitrogen, in 1976 the EPA suggested that water having concentrations above 1 ppm should not be used
for infant feeding (Rail, 1989). This guideline is very conservative and nitrate concentrations below 10
ppm are probably harmless as well. However, because concentrations this low are common, the EPA
hopes this guideline will induce people in rural areas to have their wells tested so that severe nitrate
contamination is detected and serious health problems are avoided in the future.
PROBLEMS ASSOCIATED WITH HIGH NITRATE LEVELS
When nitrate - nitrogen concentrations reach excessive levels there can be harmful biological
consequences for the organisms which depend on groundwater. Of course, human interest is of primary
concern when setting guidelines for acceptable nitrate levels and proper agricultural practices. The
United States Environmental Protection Agency established the current drinking water standard and
health advisory level of 10 mg/L nitrate -nitrogen (equivalent to 10 ppm nitrate -nitrogen or 45 ppm
nitrate) based on the human health risks due to nitrate consumption (Kross, 1993). Although there have
been studies performed attempting to link nitrate consumption to various illnesses, only
LuY.//_,....Y a:—F 1.-4.Y1 1 1 /1 n/nn1 c

NITRATE POLLUTION OF GROUNDWATER Page 6 of 14
methemoglobinemia, (also infant cyanosis or blue -baby syndrome) has been proven to result from
ingestion of water containing high nitrate concentrations, above 10 ppm (Kross, 1993).
Blue -baby Syndrome
Cases of blue -baby syndrome usually occur in rural areas which rely on wells as their primary source of
drinking water. Often these wells become contaminated when they are dug or bored and are located
close to cultivated fields, feedlots, manure lagoons or septic tanks (Comly, 1987; Johnson et al., 1987).
The most contaminated wells are usually those that were dug rather than drilled and have poor or
damaged casings (Comly, 1987; Johnson et al., 1987). Until recent awareness of the dangers of nitrate
contaminated groundwater prompted testing for nitrate concentrations, along with other contaminants,
wells with dangerously high nitrate concentrations usually went unnoticed until health problems were
brought to attention. A few isolated cases of methemoglobinemia, primarily in the rural United States,
have served as the catalyst for what has grown into a broad awareness and concern for nitrate
contamination.
Methemoglobinemia is the condition in the blood which causes infant cyanosis, or blue -baby syndrome.
Methemoglobin is probably formed in the intestinal tract of an infant when bacteria converts the nitrate
ion to nitrite ion (Comly, 1987). One nitrite molecule then reacts with two molecules of hemoglobin to
form methemoglobin. In acid mediums, such as the stomach, the reaction occurs quite rapidly (Comly,
1987). This altered form of blood protein prevents the blood cells from absorbing oxygen which leads to
slow suffocation of the infant which may lead to death (Gustafson, 1993; Finley, 1990). Because of the
oxygen deprivation, the infant will often take on a blue or purple tinge in the lips and extremities, hence
the name, blue baby syndrome (Comly, 1987). Other signs of infant methemoglobinemia are
gastrointestinal disturbances, such as vomiting and diarrhea, relative absence of distress when severely
cyanotic but irritable when mildly cyanotic, and chocolate -brown colored blood (Johnson et al., 1987;
Comly, 1987).
Treatment of infant cyanosis is simple once the condition has been recognized. If the patient is mildly
affected, then he/she must simply refrain from drinking from the contaminated well for a few days and
the body will replenish the hemoglobin by itself in a few days (Johnson et al., 1987). However, if the
patient is severely cyanotic, methylene blue must be administered intravenously in a dosage of 1-2
mg/kg of body weight for a ten-minute period and improvement should be prompt (Johnson et al.,
1987).
Methemoglobinemia most often affects infants of less than six months in age. Comly cites several
factors that make infants more susceptible to nitrate compounds that adults. The primary reason is that
infants possess much less oxidizable hemoglobin than adults, so a greater percentage of their
hemoglobin is converted to methemoglobin which greatly decreases the blood's ability to carry oxygen.
Other possible reasons are that nitrite ions may be more strongly bound by infantile hemoglobin due to
immaturity of certain enzymes, and that the kidneys of infants have inferior excretory power which may
favor retention of nitrite for longer periods of time (1987).
Steps can be taken to prevent the child from becoming a victim of methemoglobinemia. Residents of
rural areas should have their wells tested, especially if pregnant women or infants are consumers of the
well water. If the well is contaminated, other water source alternatives are other safe wells, bottled
water, a new, deeper well, or a water purification system which is capable of removing the nitrates
(Johnson et al., 1987). Comly suggests that because cyanotic babies usually contract
methemoglobinemia from the water used to prepare their formulas, formulas which use diluted whole
milk are less risky than those prepared from powdered or evaporated milk which require large amounts
of water in preparation (Lukens, 1987). Breast feeding or the use of bottled water in formula preparation
1...- - /I_ ----'---------- --�_ /�]�_..i�.0 1-4-1
11 /111/.1111 G

NITRATE POLLUTION OF GROUNDWATER Page 7 of 14
offer the safest solution, especially if the groundwater quality is unknown (Johnson et al., 1987).
Since 1945, there have been over 2000 cases of infant methemoglobinemia reported in Europe and
North America with 7 to 8 percent of the afflicted infants dying (Rail, 1989). However, problems can be
severe as shown in a specific 1950 report, there were 144 cases of infant methemoglobinemia with 14
deaths in a 30 day period in Minnesota (Johnson et al., 1987). This of course was an isolated case.
However, it shows that nitrate concentrations in well water can increase to deadly levels rapidly and the
issue of nitrate contamination should not be ignored.
Stomach and Gastrointestinal Cancer
Although many studies have been performed attempting to link stomach and gastrointestinal cancer to
nitrate intake, there is no conclusive evidence that there is a correlation. In fact, two particular studies in
the United Kingdom have shown an inverse relationship where instances of stomach cancer are highest
in areas where the groundwater concentration of nitrate is lowest and vice versa (Payne, 1993; Forman
et al., 1985). Scientists claim that nitrate represents a potential risk because of nitrosation reactions
which, with appropriate substrates present, form N-nitroso compounds which are strongly carcinogenic
in animals (Forman, 1985). In other areas of the world such as Columbia, Chile, Japan, Denmark,
Hungary, and Italy, similar studies have suggested a correlation, although there still exists no concrete
evidence to support this theory (Forman, 1985). At present, no other toxic effects have been observed
under conditions of high nitrate levels. Even at exposure to levels of 111mg/L there were no adverse
conditions in infants except for methemoglobinemia (Gustafson, 1993). Other claims that intake of
nitrate contaminated groundwater is linked to birth defects, and hypertension and high blood pressure in
adults are also unsubstantiated. This inconsistency suggests that nitrate alone cannot be the only cause of
elevated regional gastric cancer mortality rates, but these could result from a number of other factors,
such as high pesticide levels, presence of coliform bacteria, and/or other groundwater contaminants.
CLEAN-UP OF NITRATE FROM WATER
Nitrate causes problems as a contaminant in drinking waters taken primarily from aquifers. In dealing
with the nitrate problem in subsurface waters, there are two options for achieving safe nitrate levels.
First of all there are non -treatment techniques that consist of blending drinking waters, or changing
water sources. The second alternative is the use of treatment processes, such as ion exchange, reverse
osmosis, biological denitrification and chemical reduction to actually remove portions of the pollutant.
However, the most important thing to note about these clean-up procedures is that neither of these
methods are completely effective in removing all the nitrogen from the water. Treatment can remove
some of the nitrate, but with varying efficiencies, much of which can depend on other substances found
in the water. The non -treatment processes attempt to bring the nitrate concentration down to a safer
level, through blending with cleaner waters.
Non -treatment:
The non -treatment sources are quite easy to understand in their logic; combine water with lower levels
of nitrate with waters of higher levels until a safe quantity is reached, or if possible just avoid the
problem by utilizing another source. These methods attempt to reach the suggested nitrate level of
10mg/L or less in potable water (Moore, 1991). In order to use any of these options the nitrate problem
must be localized to a very precise area. According to Guter (1981) four common alternatives are:
1) Raw water source substitution: In this case an entirely new sources of drinking water is used to
replace the heavily polluted water.
1 1 1 /1 IA /"1 c

NITRATE POLLUTION OF GROUNDWATER Page 8 of 14
2) Blending with low nitrate waters: As a simple example, if the current well water supply contains 15
mg/L of nitrates, then this could be combined with an equal amount of water with a concentration of 5
mg/L to achieve a safe concentration of 10 mg/L.
3) Connection to an existing regional system: This involves using a system that is already set up to
service the area, instead of drawing water from the contaminated well.
4) Organizing a regional system: This is similar to the use of an existing regional system. One can
"...form a new regional utility by joining with other nearby systems which may be having similar water
quality problems..." (Guter, 1981, p. 19).
The advantages of these methods, especially combining existing resources, is the spread of the costs of
monitoring water quality amongst many different areas. This greatly reduces expenses and helps to
provide safer drinking water to larger numbers of people. However, these applications can only be
utilized if the contamination of nitrate is confined to a specific area, otherwise tapping into other local or
regional sources to dilute the water would only result in perpetuating the problem.
Besides these methods of providing safer waters with lower nitrate concentrations, there are treatment
methods. The most important idea to note about these processes, however, is that none of them are
completely effective in removing all nitrate from well water, or any other subsurface water. Each one of
these method's success rates depends on the conditions of plant operation and the other contaminants
found in the water. The main sources of research for nitrate removal consist of ion exchange, bio-
chemical denitrification, and reverse osmosis. Today the primary system in use is ion exchange.
Ion Exchange:
In the ion exchange process special resins are used to substitute chloride ions (C1-) for the nitrate
radical. This method of removal requires several steps for successful decontamination. Essentially, the
process relies on the fact that water solutions must be electronically neutral, and therefore by inserting a
negative ion, another negative ion can be removed from the water. Besides the negative nitrate radical
(NO3- ), common anions include sulfate radical, chloride ion, bisulfate ion, bicarbonate ion and
carbonate ion. Some of the common cations or positive ions are calcium, magnesium and sodium (Guter,
1981).
The first part of the process is the selection of an appropriate resin for the removal of the specific
problematic ion, which in this case is nitrate. However, current resins are not completely nitrate
selective, and often remove other anions before removing the nitrogenous compound. "Resin beds are
made up of millions of tiny spherical beads, which usually are about the size of medium sand
grains" (Guter,1981, p. 21). As the solution passes through these beds, the chloride anions are released
into the water, removing first the sulfate ion, then the nitrate radical. The entire process is composed of
four major steps to remove the selected ions from solution:
1) Resin recharge
2) Anion exchange
3) Resin becomes "exhausted"
4) Resin regeneration
In the first step of the process, the bed is recharged, reaching its maximum exchange capacity. The resin
at this time has enough chloride ions to carry out the exchange as the solution passes through the
complex. The ion exchange is the next part of the process. The resin bed begins to remove the sulfate
radicals first, then when the majority of S042- has been removed from the water the exchange of nitrate
and chloride begins. The completion of this phase is the third step as the resin becomes "exhausted" of

NITRATE POLLUTION OF GROUNDWATER Page 9 of 14
the ion used for exchange. At this point no more anions leave the solution. Finally, in the fourth
component of the process, the bed is regenerated by passing a strong solution over the resin displacing
the removed ions with the chloride (C1-) ion (Guter, 1981).
This method of nitrate removal does not completely eliminate the contaminant from solution. However,
"one such facility [of ion exchange] in the San Joaquin Valley resulted in a nitrate reduction from 16 to
2.6mg/L" (Moore, 1991,p. 238). The cost of the removal amounted to 24.2 cents/1000 gal (Moore,
1991). So far this has proven to be the most effective and efficient treatment process.
Bio-chemical Denitrification:
By using denitrifying bacteria and microbes, the nitrate ion can be reduced into its elemental state of N2.
These organism are able to carry out this process through a reaction such as:
6H+ + 6NO3- + 5CH3OH -> 3N2 + 5CO2 + 13H20 (Zajic, 328).
By using a chemical such as ethanol, the removal of nitrate is possible. Sometimes it is necessary to
convert the nitrogen from the ammonium ion into nitrite with the use of nitrosomas (specialized
bacteria) to facilitate the removal of all nitrogen from the solution (Shuval, 1977). The nitrite compound
is then oxidized to nitrate, which can then be eliminated by the reaction shown above.
Besides the use of special bacteria, photosynthetic algae can remove nitrates from water. Using the
stoichiometric relationship of (Zajic, 329):
aCO2 + cNO3- + ePO43- + (c+3e)H+ + 1/2(b-c-3e)H20 ->
CaHbNcOdPe + (a+b/4+c/5-d/2-5e/4)02
Both of these processes can be somewhat effective in removing nitrate, however, biological organism
are influenced by other toxic chemicals or compounds that may be found in the water. These toxins can
reduce greatly the effectiveness and efficiency with which the organisms eliminate the nitrate solution
(Organization for Economic Co -Operation and Development, 1974). Another important note about these
processes is that "... the practice of prechlorination greatly reduces the effectiveness of such techniques.
Nitrates are, in most cases, rapidly oxidized by chlorine:.." (Moore, 1991, p. 238). However, the greatest
benefit of the bio-chemical denitrification is the fact that the nitrogen is completely removed in its
gaseous elemental form (Organization for Economic Co -Operation and Development, 1974). There is no
residue or problems with disposal.
PREVENTION
Non-agricultural
Based on the six factors affecting nitrate leaching in turfgrass, seven practices can be adopted by
turfgrass managers to help prevent the leaching of nitrates. One of the most important steps is to limit
the amount of nitrogen applied; "Use slow -release nitrogen sources, or low rates of soluble nitrogen
applied more often, where possible"(Bocher, 1995, p. 66). Also the turfgrass manager should be very
cautious about adding nitrogen during periods in which the ground is not yet frozen but the grass is not
growing. The manager should avoid over -irrigation, which increases the chance of nitrate leaching while
doing nothing for the plant. Effort should be made to reduce the amount of nitrogen applied to older
sites and collect drainage water instead of allowing it to drain into a river or stream. Finally, the
turfgrass manager should use zeolite amendments. Zeolite is, "a mineral with a high cation exchange
11 /111/'1111 C

NITRATE POLLUTION OF GROUNDWATER Page 10 of 14
capacity that can hold on to things like potassium, calcium, phosphorous, magnesium or
ammonium" (Bocher, 1995, p. 66). Most of these steps of prevention are even more important in areas
of sandy soil. By following these steps the turfgrass manager will greatly reduce the chances of nitrate
leaching into groundwater. If proper measures are taken, the fertilizing of golf courses, and athletic
fields will not result in nitrogen pollution of groundwater (Neal, 1995).
Agricultural
Many of these same steps can be implemented by farmers as well to prevent nitrate leaching. The most
important step for farmers is to reduce the amount of nitrogen applied to the crops. This is easier said
than done because most farmers consider nitrogen fertilizer to be "cheap insurance" against a crop
failure (Looker, 1991). As previously mentioned, nitrogen is a definite limiting factor in crop yields. "If
soil lacks nitrogen, a dollar spent on the fertilizer can bring $10 in extra corn" (Looker, 1991).
Therefore, from a financial standpoint, a farmer would obviously rather add too much nitrogen to his
crop than too little.
In 1990, according to the U.S. Department of Agriculture, the rate of nitrogen fertilizer use in Iowa (a
state whose farmers lead the nation in cutting back on nitrogen) was 127 pounds per acre (Looker,
1991). However, the director of the Leopold Center for Sustainable Agriculture at Iowa State University,
Dennis Keeney, believes that farmers could eventually use only 75 pounds per acre and still have no
drop off in yields. Mr. Dan Stadtmueller is an example of an Iowan farmer who greatly reduced his
fertilization practices. According to an article in the Des Moines Register, Mr. Stadtmueller "is a miser
with nitrogen fertilizer". Some of Stadtmueller's fields get as little as 60 pounds of fertilizer per acre,
without displaying a decreasing yield (Looker, 1991).
There have been some steps taken to try and lessen the amount of nitrogen fertilizer used by farmers.
One such measure is a law written by then member of the Iowa House of Representatives, Paul Johnson.
This law taxed fertilizer and pesticides and used the money raised from this tax to research and show
fanners how to use fewer chemicals without losing money (Looker, 1991). Also, Alfred Blackmer, an
Iowa State University agronomist devised a test that enables farmers to measure nitrogen already in the
soil more accurately. Dan Stadtmueller, the "miser" of nitrogen fertilizer, switched to a method of
farming called, ridge tillage in 1975. This method enables him to put small amounts of fertilizer in
permanent seedbeds instead of covering the entire field. Stadtmueller switched to this method in 1975
and insists that it is more profitable. However in 1991 only about two percent of farmers in Iowa used
the method (Looker, 1993). Stadtmueller figures that this is because the majority of the farmers are
afraid of change (Looker, 1993). This also represents the problem with the tests and laws that have
recently been formed, it might take some time to convince farmers that they can switch to new
techniques without losing money in the process.
Manure Storage Sites
Another method of prevention in the area of farming deals with manure lagoons. This is an easier
problem to solve because there are proven solutions which are also better for the farmer in the long run.
One technique of manure storage that is better than the aforementioned manure lagoons is storing the
manure in concrete pits. Another possible solution is the installation of a storage facility termed a
Slurrystore. These facilities are proven to store manure without leaking and are actually more
convenient for the farmer once they are installed.
Flood Plain Management
b446,•//i:n:nm rcnvviiro nnmwsi4re4iren 1-61m1 11 /1 n1')n1 c

NITRATE POLLUTION OF GROUNDWATER Page 11 of 14
One method of prevention of nitrate pollution of groundwater that is unrelated to farming is actually a
method not of new technology but of going back to old ideas. "Traditionally, flood plains in Britain were
not vigorously farmed, but land drainage now allows these zones to be plowed up or managed more
intensively as grassland" (Haycock, 1990, p. 291). They point out that this action results in the rapid
conduction of nitrate contaminated groundwater across the flood plain whereas this water was once
allowed to drain slowly across the flood plain. After work in the upper Thames Basin in England,
Haycock and Burt discovered that a grass -covered flood plain can greatly reduce the nitrate
concentration of groundwater throughout the winter. One example they use to prove this point is that as
a result of a major runoff incident in 1990, the nitrate concentration of groundwater increased by about
400% while the grass covered flood plain maintained a nitrate -buffering capacity near its mean level
(Haycock,1990). Haycock and Burt conclude that, "flood plains need to be preserved in (or returned to)
their undrained state as these areas sustain a potential to reduce nitrate concentrations in ground water
throughout the year" (Haycock, 1990, p. 291).
CASE STUDY: IOWA
Given the health risks associated with nitrate contamination of groundwater, government agencies are
concerned with the nitrate levels in public drinking water supplies. The United States Environmental
Protection Agency has set the health advisory level at l0ppm NO -N or 45ppm NO for drinking water
supplies. Although certain studies indicate that nitrates in drinking water have a carcinogenic effect, the
EPA standard is based only on the non -cancer health effects such as infantile methemoglobinemia.
While the EPA regulations safeguard public water supplies, private, rural well -water supplies are
unregulated. Since farming runoff is a significant source of nitrates in groundwater, these private, rural
wells are potentially unsafe.
To determine the safety of private wells, state environmental agencies have surveyed and tested wells. In
Iowa, where anthropogenic inputs of nitrates due to intensive agriculture are high, a state-wide rural
well -water survey was conducted. The survey was performed between April 1988 and June 1989, taking
686 samples from across the state. While the study was limited to Iowa, the Iowa Department of Natural
Resources claims that the results can be extrapolated to other rural areas with intensive agricultural
production. The natural background concentration of nitrate -nitrogen in Iowa is less than 2 mg/L. Higher
concentrations indicate a loading from anthropogenic sources (Kross et al. 1993).
The study revealed that many private wells suffer from nitrate contamination; approximately 18.3% of
Iowa's private, rural wells have NO -N concentrations exceeding the EPA health advisory level. Results
also show that the contamination of shallow wells (less than 15m in depth) is much more prevalent than
contamination of deep wells. Thirty-five percent of wells less than 15m deep exceed the 10 mg/L
threshold. The mean concentration for these shallow wells was even over the health advisory limit
(Kross et al. 1993). However, in Iowa contamination of deep wells has grown more common in recent
years, indicating a more pervasive problem.
Doctors at the State University of Iowa Medical Center have encountered many babies suffering from
diarrhea and other symptoms consistent with methemoglobinemia. After a battery of tests to determine
the cause, it was found that all of these infants were being fed water from private wells in Iowa. The NO
-N level of the water from these wells was found to range from 64 to 140ppm and the severity of the
symptoms appears to roughly correspond to the nitrate levels in the water. Doctors from Cedar Rapids,
Fort Dodge and hospitals across the state have documented many additional cases of apparent nitrate -
induced methemoglobinemia (Comly, 1945).
CONCLUSIONS
1 , „A/I1A1

NITRATE POLLUTION OF GROUNDWATER Page 12 of 14
The main concern with high levels of nitrate in groundwater is the increased incidence of
methemoglobinemia. Also known as blue -baby disease, it causes the child to develop a bluish or grayish
tint around the extremities. If left untreated the baby will not receive enough oxygen through the blood
and could die. This problem arises primarily in rural areas where nitrate levels are not well monitored.
With regard to the nitrate problem in groundwaters the best suggestion to avoid health risks is to have
wells checked frequently and to reduce the fertilization of fields. The overload of nitrogenous fertilizers
to the soils actually kills the biota that help to provide nitrogen to the soil, which the crop plants can use.
By using much lower amounts of fertilizers these crops may still be as productive as those produced
under heavily fertilized soils, due to the healthier environment for the microbes. If the farmer adds large
amounts of fertilizer in the beginning then he is forced to use more and more each year. Using only
moderate to low amounts at the outset allows the farmer to avoid the entrapment into this vicious cycle.
Furthermore, many of the aforementioned prevention methods can be incorporated to help reduce nitrate
leaching from the soil into the groundwater. Slurrystores and concrete lagoon pits can greatly reduce the
concentration of nitrate. By avoiding over -irrigation of a field both turfgrass managers and farmers can
help to control the leaching of nitrate to the groundwater.
The clean-up of nitrate from the contaminated waters is not an easy job. So far, the most effective and
widely used technique for removal is ion exchange model FGA-60N 30,000 grain whole house nitrate
unit. Other processes are either in an experimental stage or not as universally employed. The nitrate can
most effectively be removed in a plant and is not treated while still in the aquifer. While nitrate cannot
be completely removed from groundwater, the use of treatment methods such as ion exchange and the
adoption of preventative measures, will help to reduce nitrates to biologically safe levels.
WORKS CITED
A.O. Smith Harvestore Products, 1993, Harvestore Products Today,
Communications Group, Freeport, IL, v. 32, no. 2.
Barron County Land Conservation Department (producer), 1993, Lagoon
Reclamation, (video).
Berner, E., and Berner, R., 1987, The Global Water Cycle, Prentice Hall, New
Jersey, p. 102-119.
Behm, Don, 1989, Ill Waters: The Fouling of Wisconsin's Lakes and Streams
(Special Report), The Milwaukee Journal, p. 2.
Bocher, Lori Ward, 1995, Tracing the Flow of Chemicals: How to Reduce Nitrate
and Pesticide Leaching, Turf Science, p. 64-67.
Burkart, Michael R. and Kolpin, Dana W., 1993, Hydrologic and Land -Use
Factors Associated with Herbicides and Nitrate in Near -Surface Aquifers,
Journal of Environmental Quality, v. 22, p. 646-656.
Comly, H. H., 1987, Cyanosis in Infants Caused by Nitrates in Well Water,
Journal of the American Medical Association, v. 257, p. 2788-2792.
Environment Directorate, 1974, Waste Water Treatment Processes for Phosphorus and Nitrogen
Removal, Organization for Economic Co -Operation and
//....... t.4.,...1
11 /111I 1\1 C

NITRATE POLLUTION OF GROUNDWATER Page 13 of 14
Development, Paris, p. 109.
Finley, B., 1990, Well -water Nitrates Endanger N. Colorado, Denver (Colorado)
Post, 16 November.
Forman, D., Al-Dabbagh, S., and Doll, R., 1985, Nitrates, nitrites and gastric
cancer in Great Britain, Nature, v. 313, p. 620-625.
Gaillard, J.F., February, 1995, Lecture on Nitrogen Cycle.
Guter, Gerald A., 1981, Removal of Nitrate from Contaminated Water Supplies
for Public Use, Environmental Protection Agency, Cincinnati.
Gustafson, D. I., 1993, Pesticides in Drinking Water, Van Hostrand Reinhold, New
York, p. 241.
Hallberg, G.R. and Keeney, D.R., 1993, Nitrate, Alley, William A., ed., Regional
Ground -water Quality, Van Nostrand Reinhold, New York, p.297-322.
Haycock, Nicholas, 1990, Handling Excess Nitrates, Nature, v. 348, p. 291.
Johnson, C. J., Bonrud, P. A., Dosch, T. L., Kilness, A. W., Senger, K. A., Busch,
D. C., and Meyer, M. R., 1987, Fatal Outcome of Methemoglobinemia in
an Infant, Journal of the American Medical Association, v. 257, p. 2796-2797.
Kamrin, M. A., 1987, Health Implications of Groundwater Contaminants, in
D'Itri, F.M., Wolfson, L. G., eds., Rural Groundwater Contamination,
Lewis, Chelsea, MI., p. 226 - 233.
Kross, B. C., Hallberg, G. R., Bruner, R., Cherryholmes, K., and Johnson, K. J.,
1993, The Nitrate Contamination of Private Well Water in Iowa, American
Journal of Public Health, v. 83, p. 270-272.
Lewis, Chelsea, MI., p. 213 223. Environment Directorate, 1974, Waste Water
Treatment Processes for Phosphorus and Nitrogen Removal,
Organization for Economic Co -Operation and Development, Paris, p. 109.
Looker, Dan, 1991, Nitrogen Use Still Too High, Experts Say, Des Moines (Iowa)
Register.
Lukens, J. N., 1987, The Legacy of Well -Water Methemoglobinemia, Journal of
the American Medical Association, v. 257, p. 2793-2795.
Moore, James W., 1991, Inorganic Contaminants of Surface Water: Research and
Monitoring Priorities, Springer-Varlag, New York City, p. 333.
Neal, L.,1995, Turfgrass Nitrogen Evaluated, Water Environment and Technology, p. 57.
Payne, M. R., 1993, Farm waste and nitrate pollution, in Jones, J. G., ed.,
Agriculture and the Environment, Ellis Horwood Limited, New York, p. 63-
1 1 /1111"1111.

NITRATE POLLUTION OF GROUNDWATER Page 14 of 14
73.
Rail, C. D., 1989, Groundwater Contamination: Sources, Control, and Preventive
Measures, Technomic, Lancaster, PA, p. 139.
Shuval, Hillel I., 1977, Water Renovation and Reuse, Academic Press, New York
City, p. 463.
Vogt, C., and Cotruvo, J., 1987, Drinking Water Standards: Their Derivation and
Meaning, in D'Itri, F.M., Wolfson, L. G., eds., Rural Groundwater
Contamination,.
Zajic, J. E., 1971, Water Pollution Disposal and Reuse, Volume 1, Marcel Dekker,
New York City, p'. 389.
PRODUCTS
h++n•/Ainin r rAnnnrc nrrimin; +r. +incr. l.fm1
iiiinhnic

SINGE 1898
www.burnsmcd.com
A Burns & McDonnell Publication
2009 No. 2
A Different Approach for Removing Nitrate
Biological Pre -Treatment in a Drinking Water. Application
By Andrea E. Josefiak. PE
Drinking water utilities face a universal
concern: The need for water has begun to
outpace high -quality drinking water supplies.
Many water agencies are faced with problems
related to high concentration of nitrates. The
city of Thornton, Colo., is one municipality
facing this challenge.
Background
Thornton s primary water supply is influenced
by upstream discharges and nitrate levels
above the Environmental Protection Agency
maximum contaminant level (MCL) of 10 mg/L
have occasionally been recorded. During the
winter months, the total flow contribution from
upstream wastewater discharges can be as high
as 70% of the entire flow, resulting in elevated
levels of ammonia, phosphorus and nitrate. The
city decided to evaluate the implementation of
biological nitrate removal (BNR) processes as
pretreatment for removing nitrate in surface
water upstream of its water treatment plant.
The city previously intended to utilize reverse
osmosis (RO) membranes to treat a 15 million -
gallon -per -day (MGD) side stream at its Wes
Brown Water Treatment Plant (WTP) in
order to reduce nitrate and total dissolved
solids (TDS) to acceptable levels. The 15 MGD
capacity was based on treating one-third of the
flows at the WTP, enough to reduce the highest
concentrations recorded in the gravel lakes to
the MCL. RO treatment would have provided
additional benefits including reduction in
TDS, further removal of total organic carbon
(TOC), and reductions in endocrine -disrupting
compounds and micropollutants. However,
permitting issues related to RO concentrate
disposal inhibited the implementation of RO
technology.
Figure 1: Each of three processes
selected for testing successfully
reduced nitrates.
42
Test Results of Biological Nitrate Removal Methods
36 —
30 —
24 —
12 —
0
City
influent —.
nitrate
spike
Methanol
feed
pump
failure
NO, N Goal = 2 mg/L
•
�\��\�0 �\,•�\0b <\\ A\��\Q� 1\O�
e
1��0� 1�tiCP
e)
Date
Influent NO3 N Concentration
♦--i--� Manufacturer A Datalogger: Effluent NO9 N Concentration
1.-0-0- Manufacturer B Datalogger Effluent NO3 N Concentration
Manufacturer C Datalogger: Effluent NO3 N Concentration
NO9 N;Goal
rz

60
48 —
E
• 36 —
co
m
e 24 —
0
• -
o 12-
City Lab Data: Feed Water and Manufacturers A, B and C TOC Concentrations
3
♦--♦--� City Lab'Data:
City Lab Data:
•-1--1. City Lab Data:
City Lab'Data:
1 1 1
\1h \tip a\▪ �? - /
Date
Feed Water TOC Concentration
Manufacturer A TOC Concentration
Manufacturer B TOC Concentration
Manufacturer C TOC Concentration
Since the initial design of the Wes Brown WTP,
several biological processes have emerged as
potential treatment options for nitrate removal.
These options are similar to those used for post-
denitrification in wastewater applications and
have primarily been implemented in industrial
applications. These processes have been used
in drinking water applications in Europe, but
rarely in the United States.
To select the best -performing and most cost-
effective BNR treatment process, the city hired
Burns & McDonnell to conduct an evaluation
of available technologies and, from this
evaluation determine up to three BNR
alternatives that should be pilot tested. After
pilot testing, the city wished to design/construct
the preferred alternative. These phases will
be conducted over a three-year period. The
evaluation of alternative BNR processes was
completed in 2007 and pilot testing was
conducted from February 4, 2008, to August 28,
2008. Design of the 15-MGD biological nitrate
removal pre-treatment system will occur in 2009
with the goal of reducing nitrates in Thornton's
South Platte River raw water supply to below
the MCL. It is anticipated that this system will
be constructed between Thornton's South Tani
Reservoir and East Gravel Lake No. 4 (EGL4).
Thornton has a unique gravel lake system that
provides raw water diversion through a 7,000
acre-foot reservoir (the South Tani Reservoir),
from which the BNR system would draw.
Water is then conveyed to a 3,000 acre-foot
reservoir (EGL4), where the BNR system would
discharge before being delivered to the city's
water treatment plant. These storage reservoirs
provide a unique buffering of the water from
fluctuations, since they provide a lot of storage
and a long detention time — more than four
months of storage at the city's maximum
demands.
Denitrification
Denitrification occurs when facultative
heterotrophic bacteria are subjected to an
environment that is absent of oxygen and
contains nitrate and a carbon (i.e., food) source.
The facultative bacteria utilize nitrate -nitrogen
as the terminal electron acceptor during energy
formation, resulting in the formation of nitrogen
gas (with nitrite formation as an intermediate
step), which is released to the atmosphere. All
biological nitrogen removal is based on the
reduction of nitrate to nitrogen gas (N2):
NO3- + 6H+ + 5e- -4 0.5N2 + 3H20
Pilot Study
The city and Burns & McDonnell conducted
a two -season pilot study to demonstrate the
feasibility of utilizing biological processes to
• I • 1 • 1
Figure 2: The effluent TOC
before carbon feed optimization.
In taking this process from
wastewater to drinking water,
a key concern is not increasing
TOC levels across the units
since TOC is a precursor for
disinfection byproducts. Based
on these initial results, a carbon
feed optimization phase was
implemented in pilot tests.
TECHBriels 2009 No. 2
2
Burns & McDonnell

Figure 3: TOC after carbon
optimization. The effluent
TOC concentrations from the
pilot units closely follow the raw
water TOC levels, indicating little
increase in TOC levels across the
three units.
E
C'
O
28 —
24 —
20 —
16—
c
O
H,
12-
4-
0
remove nitrate from drinking water supplies
and to determine full-scale operating conditions
and design criteria for three biological
processes. After an extensive evaluation
in 2007, the available biological processes
were narrowed to three alternatives, which
were piloted:
• AnoxKaldnes Moving Beds
(Moving Bed Bio-Reactor or MBBR)
• Infilco Degremont Inc. (IDI) Nitrazue
(Packed Bed Biological Filter)
• GE Water & Process Technologies ABMet°
(Packed Bed Biological Filter)
All three processes are of the fixed -film
(attached growth) type. With fixed -film
denitrification, the organisms are attached to
an inert support media. The water containing
nitrate is introduced to the media. Although
various media can be used, the goal is to
maximize the surface area available for the
biofilm to develop. It is important to note,
however, how different each of the technologies
piloted are. MBBRs use inert engineered media
within a moving bed to maximize surface area
for microbial growth, whereas packed -bed
biological reactors use apackedbed of
granular media.
The AnoxKaldnes unit is a MBBR type, which is
a biological process that does not provide any
additional filtering of the water, whereas the GE
and IDI units are of the packed -bed type, which
provide filtering. The AnoxKaldnes unit had
three reactors, each filled with plastic media to
allow more surface area for the media to grow.
The first two reactors were mechanically mixed
anoxic zones and the third reactor was an
aerated (aerobic) zone. There is no backwashing
or waste stream for the AnoxKaldnes unit,
unlike the GE and IDI unit.
The GE unit consisted of a reactor filled with
carbon media. Influent flows down thorough
the reactor and the reactors are backwashed
periodically to remove solids and degassed to
release any air trapped within the media. The
IDI unit is similar to a conventional media filter.
Water flows upward across the media. The unit
is backwashed to remove solids and periodically
air scoured. For the GE unit, the carbon
City Lab Data: Feed Water and Manufacturers A, B and C TOC Concentrations -
Steady State Phase
H=_
t , t
Ax-
Date
City Lab Data: Feed Water TOC Concentration
City Lab Data: Manufacturer A Final Effluent TOC Concentration
City Lab Data: Manufacturer B Effluent TOC Concentration
City Lab Data: Manufacturer,C Effluent TOC Concentration
Burns & McDonnell
3
TECHBriefs 2009 No. 2

provides the surface area for the media to grow
and for the IDI unit, a proprietary sand media is
used as the surface area.
The goal of the pilot study was to treat the
nitrate -nitrogen present in the source water to a
maximum acceptable effluent nitrate -nitrogen
concentration of up to 2 mg/L by means of
biological denitrification, when the influent
nitrate concentration is at 10 mg/L or greater.
Obtaining this goal includes, but is not limited
to, the following objectives:
• Determine process performance (specifically
nitrate removal percent reduction) and
preliminary design criteria at both cold and
warm temperatures through winter and
summer pilot seasons.
• Determine the hydraulic loading rate that will
provide the basis for full-scale design and the
range of acceptable loading rates.
• Determine the efficiency (recovery) of the
process at the design hydraulic loading rate.
• Determine the impact of fluctuations in raw
feed water quality, specifically variations
in nitrate concentrations, temperature,
pH, dissolved oxygen (DO), phosphorous,
TOC and alkalinity on performance.
• Determine the impact of raw water
nitrate excursions.
• Determine optimal carbon source type and
dose for sustaining denitrification process.
• Characterize backwash and waste streams
(residuals volume and concentration).
• Determine backwashing, air scouring
and/or mixing frequencies/conditioning
requirements.
• Determine if any screening or other treatment
process, chemical addition, etc. is required
upstream of the process.
• Determine if any filtration/clarification/
polishing is required downstream of
the process.
• Evaluate seeding and startup processes and
determine impact of both cold temperature
and warm temperature on seeding.
• As a secondary objective, determine
removal efficiency of endocrine disrupter
compounds (EDCs).
• Determine the ability to remove organic
matter (TOC removal).
• Assess operational difficulty/flexibility.
• Evaluate/determine operation and
maintenance issues.
Pilot Study Results
Piloting of all three technologies was completed
on Aug. 28, 2008. All three pilot manufacturers
were successful in exhibiting the ability to meet
the pilot goals for nitrate removal (no more
than 2 mg/L nitrate -nitrogen) and met study
expectations. Figure 1 (on page 1) shows nitrate
removal below the pilot goal of 2 mg/L nitrate -
nitrogen for all three manufacturers. Note that
one of the manufacturers experienced a feed
pump failure and the city's spiking of influent
nitrate was increased for a short duration
of time, in which all three systems quickly
responded.
Outcome
All three processes are being evaluated for
full-scale implementation. This project is the
first study of biological denitrification pre-
treatment processes upstream of a drinking
water treatment plant for surface water nitrate
removal in the United States. The study is also
unique in that it evaluates the denitrification
process at cold water temperatures. Due
to this innovative project, the city and
Burns & McDonnell have been selected to
participate in a Water Research Foundation
Study, Project No. 4202, titled "Biological Nitrate
Removal Pre -Treatment System for a Drinking
Water Application; with the final report
anticipated to be published in early 2010.
Burns & McDonnell is assisting the city in
soliciting proposals from each of the three
manufacturers with the intent of entering into
a letter of understanding with the selected
manufacturer. The manufacturer selection will
be based on both economic and non -economic
criteria (best -value based, not just low bid).
Andrea E. Josefiak, PE,
is a senior chemical engineer
in the Burns & McDonnell
Infrastructure Group in Denver.
She has more than 12 years of
experience in the design and
construction of water treatment
facilities. She has a bachelor's
degree from Virginia Tech and a
master's 'degree in environmental
engineering from John Hopkins
University.
For more information, please e-mail:
[e-mail].
TECHBriefs 2009 No. 2
Burns & McDonnell

/C-' S "270-7 7) S. 0 va4 g 91 o /
r121L JJ r

Introduction
Subsurface agricultural drainage can allow large gains in agricultural productivity in
the midwestern United States. There is, however, concern about pollutants moving
through these systems. One specific water quality concern is nitrate, a form of nitrogen
that moves readily through the soil and often can be present in high amounts in clear
drainage waters. The water quality of our local streams, rivers, and lakes can be
negatively impacted by nitrate in tile drainage. Moreover, because many streams and.
rivers in this region lead to the Mississippi River, nitrate in midwestern agricultural
drainage also contributes to the hypoxic zone (or Dead Zone) in the Gulf of Mexico.
Fortunately there are a number of practices that can reduce the amount of nitrate in
drainage water. Woodchip bioreactors are a new option to reduce the amount of nitrate
in drainage before it gets to local surface waters. This factsheet describes key questions
relevant to this innovative approach to water quality.
Woodchip Bioreactor Basics
How do bioreactors work?
A woodchip bioreactor is made by routing drainage water through a buried trench
filled with woodchips. Woodchip bioreactors also are known as denitrification
bioreactors, a name that is slightly more descriptive of the actual process occurring
inside the bioreactor. Denitrification is the conversion of nitrate (NO3) to nitrogen
gas (dinitrogen, Nz) that is carried out by bacteria living in soils all over the world and
also in the bioreactor. These good bacteria, called denitrifiers, use the carbon in the
woodchips as their food and use the nitrate as part of their respiration process. Because
these bacteria also can breathe oxygen, providing anaerobic conditions through more
constantly flowing tile water helps ensure that the bacteria utilize the nitrate.
45 ft.
1 tt. soil
Bloreactor
From field
b bloreactor
24 in.
Bypass
Bow
Detail drawings not to scale.
Dimensions vary with drainage area.
10 in. 8in.
From
bioreactor
Figure 3: Descriptive illustration of a woodchip bioreactor (image by John Petersen,
www.petersenart.com)
IOWA STATE UNIVERSITY
Extension and. Outreach
To
bypass /
flow
Figure 1. Subsurface tile drain outlet
(courtesy of the Leopold Centerfor_
Sustainable Agriculture, Jerry -DeWitt
Figure 2. Woodchips commonly
woodchip bioreactors
PAR 1008` Octol er

installation
Figure.4.
install
Excavation fora bioreactor,
(courtesy ofthe Iowa Soybean
iation Environmental. Programs and
f excavation with woodchips
r;instal atton {courtesy of the
Association ,Environmental
Providing these denitrifiers an ample supply of carbon to eat and giving them
anaerobic conditions in the bioreactor offers them a perfect environment to remove
nitrate from drainage.
Two control structures are important parts of the bioreactor design, and each structure
plays a different role. The inflow control structure is responsible for routing water into
the bioreactor and for allowing excessive water to by-pass the bioreactor at high flow
events. The outflow control structure helps to retain water in the bioreactor so the water
remains in the bioreactor long enough for the bacteria to have time to remove nitrate
from the water before it leaves. These structures allow gates or stop logs to be lowered
into place to increase the amount of water routed into the reactor (inflow structure) or
increase the retention time of the water in the bioreactor (outflow structure). Likewise,
these gates also can be removed to decrease the amount of water treated and decrease
the retention time.
How big are woodchip bioreactors?
Most installations in Iowa to date have been approximately 100 to 120 feet long
and 10 to 25 feet wide. Typically, no land is taken out of production for a bioreactor.
Because bioreactors tend to have an orientation that is long and narrow, they fit well
in edge -of -field buffer strips and grassed areas.
Does the type of woodchip matter? Can I use materials other than chips?
Not all woodchips are created equal. To allow the good, denitrifying bacteria time
to remove the nitrate from the water, bioreactors are designed based on a specific
flow rate of water that the woodchips allow (that is, hydraulic conductivity of the
woodchips). Using chips that have many fine materials, shredded materials, dirt, and
gravel can change this allowable rate of water flow, meaning the bioreactor may not
work as intended. Currently chips usedin bioreactor research have had the majority
of the chips falling within the'/+ -inch to 1-inch size range. Chips made from treated
or preserved wood are not recommended because this limits the bacteria's ability to use
the carbon in the wood. Also, including green material such as leaves or conifer needles
is not recommended due to their relatively high nitrogen content and their potential
to quickly be degraded. A number of other carbon source materials such as corn cobs,
corn stalks, wheat straw, cardboard, and newspaper have been investigated, but
research has recommended woody material because it provides a sustainable carbon
source that lasts longer.
What is the life of a bioreactor?
Research has estimated bioreactor lifespans of 15 to 20 years, after which the woodchips
would be replaced if treatment was to be continued. Because it is a new practice, no
bioreactors have been in the ground long enough to have direct evidence of longevity.
The oldest working denitrification system that treats septic wastewater was 15 years old
in 2010.
How many acres of drainage can I treat?
Most current bioreactor designs have been successful at reducing the amount of nitrate
in drainage from 30 to 80 acres. Some larger designs have been installed and are being
watched closely for performance.
Installation/Operation
Are certain areas better than others for woodchip bioreactors?
Bioreactors are specifically designed to treat subsurface drainage water that contains
high amounts of nitrogen as nitrate and that has relatively little sediment. These systems
are not intended to treat runoff or water collected along terraces, and they work best
in drainage systems that have few surface intakes. Many bioreactors in Iowa have been
targeted for watersheds identified as having high nitrate in surface waters and having
a large percentage of land drained. Though some bioreactors are lined, they may not
2

be as effective in sandy areas because the drainage water being treated may leak into
the surrounding soil and escape treatment. Also, considerations should be made for
possible contaminants like the initial flushing of organics at each bioreactor regardless
of location.
How do 1 manage the bioreactor? How much management is required?
It is estimated that at minimum, twice per year the outlet control structure needs to
have gates either raised or lowered. In the spring and early summer, when drainage
water is typically flowing faster and in greater quantities, more gates should be lowered
into the outflow structure to retain water for a longer time in the bioreactor. Later when
drainage flow rates decrease, typically mid July; these gates in the outflow structure
should be removed so water can flow unimpeded through the bioreactor. The gates
should be reinserted in late fall prior to spring drainage events or in anticipation of the
possibility of late fall drainage. Management at each location will be site -specific and can
vary from year to year. Ideally; periodic samples would be taken at the site to confirm
bioreactor performance and help guide management decisions.
Will my tile back up because of my bioreactor?
The slope of the site will have the biggest impact on whether this is a significant issue.
A small amount of backup will occur, especially at flatter sites due to the way the inflow
control structure diverts water into the bioreactor. This has not been a significant issue
at the installations in Iowa thus far. Landowners will get a feel for the number of gates
or stop logs that can be comfortably lowered into the inflow control structure, and if
they feel that the site is not draining properly, these gates can be removed.
Will this work on an existing drainage system?
They are easy to install on existing systems, but the tile depth, diameter, and slope as
wellas tile connectivity need to be known. It also is helpful to have a good estimate of
the drainage area for the system. All the bioreactors in Iowa to date have been installed
on existing drainage systems.
Is there a yield or soil impact, and will a bioreactor work with other
conservation practices?
Because this is an edge -of -field practice, in -field yields will not be affected. Likewise,
bioreactors will have no impact on soil quality. Other practices such as cover crops and
adding perennials to a crop rotation can improve water quality while also maintaining
or enhancing soil quality. One of the biggest benefits of bioreactors being on the edge
of the field is that they are minimally impacted by what is done in the field. This means
that other conservation practices such as no -till, cover crops, and improved nutrient
management can be done in the field, and the bioreactor will continue to treat the
remaining nitrate that is lost in drainage.
Water Quality
How much nitrate will a woodchip bioreactor
remove? How big an impact will I have?
A bioreactor's annual nitrate load reduction can
range from about 10 percent to greater than
90 percent depending on the bioreactor, the
drainage system, and the weather patterns for a
given year. Based on research from Iowa, Illinois,
and Minnesota, most bioreactors show performance
of about 15 to 60 percent nitrate load removed per
year. It may be best to target fields or watersheds
that have higher nitrate loads in order to have the
biggest impact.
% Nitrate -Nitrogen Load Removed
100
80
60
40
20
0
Woodchip Controlled
Bioreactor Drainage
'Figure 6. Covering the woodchips;
geo-textile fabric before laying the
at a bioreactor installat oqnn ourt`esy qd
Programs a
Iowa Soybean Association Environmen
td Services)
Figure 7. Woodchip b oreacto
circular sumps and PLUG wells
monitoring (Northeast low'a -
Demonstration Farm)
Wetland Spring N
Fertilizer
Application
Cover
Crop
installation;
Crop
Rotation with
Perennials
Figure 8. Comparison of nitrate removal from bioreactors and other practices; bar shows
the average removal with the whisker showing plus and minus one standard deviation
(adapted from data from the authors)
3

icuitt re (USDA) prohibits
its programsand activities on the
atmnalorigin, age, disability, and
stet status, familial status,
xual`Orientation, genetic
fs reprisal, or because all or '
ncome-tsderived from any public
of atll prahihited bases'apply to all
wniudiSdbititios who require alternative . f
mmunicabon ofit ogram information (Braille,
tc) should'contact USDA's TARGET
600i(vo ce-and TDD). To file a complaint '
taUSDA, Director, Office of Civil •
1 t 14001nddpendence Avenua SW, Washington, DC
0250-941D orca1160�0 795 :?,(voice) or2g2720-6382.
tsF7ilequalop imtyProvider and employer..
°Babad
�Depar
tristianson Ph.D.
:' r Agricultural antiBiosystems
1
nd Graduate -Program
b e tlgriculturc, Iowa. State .
and s
andMatthew Helmets, Ph.D
olessor; Agricultural and
Engmeenng, Iowa State
Engineermg a
$ilSustama 1
Biosystem
55.41L9' tioiz was peer- reviewed
'Matndependent reviewers using a
double-blutd process.
Resear
vas
eopoli
and
orted by a -grant
ter,for Sustainable •
Praject Number
f om he'USDA North
gtori Sustaiiab1e Agriculture
Edueattori Graduate
11rograt.
authorsthank two
anonymous reviewers`*hose
improv dibis factsheet.
epartmen
tion inall
rental status.
information pobbcal'bell
(+ r Eft Dindrwduals
programs
meansfai
iscrimtna
bf Ag
Cooperative tension
and Technol
of Cooperative Extension work,
30 t314,_incooperatnitwiththe
gncultura=Cathenn A. Kress, director,
Service"owa State University of
" wa.
How do bioreactors compare to wetlands and other nitrate reduction strategies?
Bioreactors and wetlands often are compared because both technologies provide
edge -of -field or off -site treatment. In terms of percent reduction of nitrate loads,
wetlands have been shown to have nitrate removal of 40 to 70 percent. Bioreactors
have far smaller surface footprints than wetlands, but also receive drainage from far
smaller areas; bioreactors will treat drainage from a field -sized area while wetlands will
receive drainage from several thousand acres. Also, wetlands can be effective for other
water pollutants such as sediment and can have many additional benefits for wildlife
habitat and flood regulation.
A number of other practices in addition to bioreactors and wetlands can help reduce
nitrate export in drainage water. Several of these other options include improved
nutrient management, cover crops, crop rotations that include perennials, and
controlled drainage. In systems that are not tile -drained, nitrate could be moving to the
stream via shallow groundwater flow. In those cases, buffers or prairie strips can help
reduce nitrate export to the stream. The acceptability of any water quality practice will
vary by individual producer and individual farm, and it is likely that a variety of practices
applied across the landscape will be necessary to meet overall water quality goals.
Will the bioreactor remove other chemicals?
Woodchip bioreactors are specifically designed to reduce the amount of nitrate in
drainage, and may not be effective for other pollutants such as phosphorus, pesticides,
herbicides, and pathogens. However, the potential of bioreactors to remove some
of these pollutants is an area of ongoing research.
Are there negative side effects?
One of the first things a bioreactor owner may notice after installation is that the outflow
water is tea -colored. This is because these first waters contain some of the most readily
dissolvable organic material that will wash out in the initial weeks. This has been noted
at nearly every site and could be minimized by holding back some drainage water in
the field with the inflow control structure, and then allowing this accumulated water
to flush through the bioreactor as quickly as possible. Another possible side effect
is the export of methyl mercury if the water stays in the bioreactor too long, all the
nitrate will be removed through denitrification and other processes may begin. One
of these processes involves the transformation of sulfate, which is naturally present
in drainage water, to hydrogen sulfide gas. The bacteria that perform this process also
are involved in transforming mercury in the water or the chips to a toxic form called
methyl mercury. This concern can be minimized be managing the bioreactor closely
during low flow periods and monitoring for a rotten egg smell (hydrogen sulfide); if
this smell is detected, the outflow control structure should be lowered to allow water
to move unimpeded through the bioreactor. The last concern may be the production
of nitrous oxide, a greenhouse gas, which is a natural by-product of this denitrification
process. Research suggests that nitrous oxide emissions from bioreactors are a very small
percentage of the nitrate entering the systems. Though it is thought these concerns may
be minimized through good design and management, research still is ongoing.
How much do they cost? Who will help pay?
Most bioreactor installations in Iowa have been in the range of $7,000 to $10,000
in order to treat drainage from about 30 acres to over 100 acres. In Iowa, the
Environmental Quality Incentive Program (EQ1P) allows cost sharing for about half
the installation cost of this water quality practice. In 2011, the EQIP practice code
747 for denitrifying bioreactors specified $3,999.50 as a one -rime installation payment.
Also, location within a watershed that has an organized watershed group may help
increase a landowner's chances of finding other funding.
Where can I get more information?
Contact Laura Christianson ([e-mail]) or Matt Helmers ([e-mail])
Agricultural and Biosystems Engineering, Iowa State University, Ames, Iowa.
4

}
Nitrates Page 1 of 4
HOME
WATER
ISSUES
WATER
TREATMENT
GREY WATER
GREEN
PRODUCTS
GREEN
LIFESTYLE
RELATED
INFORMATION
CONTACT
Nitrate Removal
Environmental Alternatives
[phone]
petrich(c�whidbey.com
Nitrates
Removing Nitrate by Ion Exchange
Removal is Essential for Excess Nitrate
Five Nitrate Removal Methods
Understanding the Different Nitrate Units
Aqua Altematives
[phone]
Removing Nitrate by Ion Exchange
DESCRIPTION
Nitrate is a common contaminant in water supplies, and especially prevalent in surface water supplies and shallow wells. However, it can
be found in any water source.
Nitrate contamination of drinking water is generally a manmade problem. Fertilizer is the largest contributor to nitrate pollution. Some
sources say that poorly managed crops may only utilize 10% of the nitrate that is actually spread on the field. The runoff from these fields
ends up in surface water sources. Nitrate can also percolate down through the soil and end up in the drinking water aquifers. Other sources
of nitrate pollution are sewage treatment plants, septic systems, feed lots and industrial waste, both gas and liquid.
ANALYSIS
It is very important to know how nitrate is expressed in a water analysis so a water treatment system can be sized properly. The IUS
Environmental Protection Agency (EPA) has set a primary drinking water standard for nitrate. The maximum contaminant level (MCL) is 10
parts per million (ppm) nitrate as nitrogen (NO3 as N). A laboratory may also choose to express nitrate as nitrate (NO3as NO3) in the water
analysis, and in this case, the EPA MCL would be 44.2 pm (10ppm as N is equivalent to 44.2 ppm as NO3).
A good accurate water analysis is especially critical in this application, since a health issue is being addressed. The water analysis must
include nitrate and sulfate. Nitrate and sulfate levels are needed to calculate the operating capacity of the nitrate removal unit.
These parameters will have to be converted to their calcium carbonate equivalent. The conversion factor when nitrate is expressed as N is
3.57, and 0.81 when it is expressed as NO3. Typically sulfate is expressed as SO4 in a water analysis. Sulfate must also be converted to its
calcium carbonate equivalent by multiplying by 1.04. By converting to the calcium carbonate equivalent, the nitrate and the sulfate can be
compared as equals. It is also important to know the hardness, iron, total alkalinity, total dissolved solids (TDS) and pH.
ANION vs. CATION RESINS
Nitrate has a negative charge in water limy.' fipr, a+ o rom the.waterwith a ' :ongebase tT; si ca"in belr
lwegenerated
i D aliT _ agraandomo llarly fo a+water softener nion;reslnrlsaiess'dense.thaa cationzsoftening reslntscitl e baekitiash�ilow. ateyinult
Ve7e7176-e—d'as7com-rgEatvolaTaffaiiiVii.14 Check manufactures product data sheets for details.
Typical type 1 and type 2 strong -base anions will remove nitrate from water. Standard anion resins have an affinity for sulfate over nitrate.
The order of affinity is as follows: Sulfate-2>Nitrate-1>Chloride-1>Bicarbonate-1. These are the exhaustion bands in order of preference as
a unit exhausts. Sulfate has two negative charges (the valence) that give it a greater affinity to standard strong -base anion resin than nitrate
_ with one negative charge
pntisir ortaaitEate,can,,bebdumpea frornatkieseitypes of resin. = u ,mping=is;defined as the elev$ion;of nitratesyn the treafed
,z'ra-e e liTelleVelifigniffates inthe"raw (inft erit)i.w ei,eAsalieWro tttafemsternir, hexhausul siesfon fifeZWilkdisplacefi itrateskcausing a
Vnifieiti inOteaseiin.:nitrateilea ge.cor[espondingaa-the•nitRafend..ulfate-levels=in-the rawwater.
When the raw water sulfates are high, nitrates in the treated water can be significantly higher that the raw water. This can be
compensated for when sizing the system. It is also best to use a standard anion resin when the system is monitored and/or the sulfate
concentration is low.
There are selective nitrate resins on the market. These resins have a differeAwhanggaroup that makes it possible for_nitrates,to be
removed from water without the potential for dumping. 4P grate=selective-functional roups=includeitgettYlacnitte aripropylamine end.
; twbu is rrTor:
agq- sofa " slthe:nitrate islheldFpreferentiMlyacverisulta`t$ It should be noted that even though these resins are selective to
nitrates hey still remove other negatively charged ions, like bicarbonate alkalinity and sulfate, from the water.
Whether a standard anion resin or a selective nitrate resin is used, sodium chloride or potassium chloride is typically used to regenerate the
system. A high concentration of brine is used to strip nitrate from the anion resin. Care must be taken, as with any anion resin, to set an
appropriate backwash flow rate to prevent resin loss.
The backwash flow rate of an anion resin is considerably lower than a cation softening resin's, so check with the manufacturers'
specifications. The use of a screen or upper basket in the valve will help to prevent resin loss during the backwash.
Lain
11/1t1/')n1C

Nitrates Page 2 of 4
BE AWARE OF Ph CHANGES
All nitrate removal resins will remove alkalinity, including nitrate -selective resins. When alkalinity is removed from water, the pH will
decrease. The degree to which the pH will drop is dependent on the amount of alkalinity and carbon dioxide (CO2) in the water. The
decrease in pH occurs until the resin's capacity for alkalinity is reached; at that point the pH will start to return to the influent level. Generally,
on low total dissolved solids (TDS) water the pH drop will be more significant than on higher TDS water. Nitrates will be exchanged onto the
resin, and chlorides will be released into the water. This reaction will cause the chloride content of the treated water to increase. If the TDS
of the water is high, a salty taste may be detected. •
SYSTEM COMBINATIONS
Caution must be taken when a single unit utilizes both cation and anion for softening and nitrate removal. During the regeneration, high
levels of hardness and high alkalinity may exist, causing calcium carbonate precipitation. This precipitation can foul the resin bed and/or plug
the drain line. Separate softening and nitrate removal units will prevent the precipitation from occurring.
Demand -initiated valves should be used as the brains of the system. These valves will monitor the amount of water treated and
regenerate the resin before the capacity is exhausted.
Nitrate -selective resins should be used in point -of -use cartridges where the tendency to overrun the system exists. The selective resins
should be used on water with high sulfate concentrations. They should also be used when the system is not monitored. If the brine tank is not
filled or the valve fails, nitrate dumping will not occur when using a selective resin.
Standard anion resins should be used on systems that are monitored. Standard nitrate removal resins will generally have a higher operating
capacity than the nitrate -selective resins. They should be used on fee -lot applications where sulfate and nitrate removal is important.
It is beneficial to soften the water prior to nitrate removal. Softening will help to protect the nitrate removal system from fouling with metals
like iron. Nitrate removal by ion exchange is set up similar to softening, with some modifications. This type of water treatment is not difficult
and is within the expertise of most water treatment professionals....
SOURCE
Water Technology, Volume 23, Number 11, November 2000, "Removing Nitrate by Ion Exchange"
AUTHOR
Mike Keller is marketing specialist, domestic water services, for Sybron Chemicals, Inc. in Birmingham, N.J.
REFERENCES
1) Margaret McCasland, et al, "Nitrate: Health effects in Drinking Water," Natural Resources Comell cooperative Extension, Comell University,
pmep. cce. co melt. ed u/facts-slid es-self/facts/nit-haef-g rw65. html
2) Stan Ziarkowski, "Nitrate Removal by Ion Exchange" Internal Paper at Sybron Chemicals, Inc.
Removal is Essential for Excess Nitrate
Too much of this is common, natural ion poses health risks.
by Ellen R. Campbell
Water Technology, September 2006, p.32
Nitrate is a simple ion that can occur naturally in mineral deposits or as a major end -product of biological degradation. All living things
contain nitrogen in their proteins and DNZ, and microbes in soild and water tend to convert nitrogen compounds into nitrate, which is the
preferred nitrogen source for plants. All living things and their waste products will produce nitrate as they decompose. You can expect to
find elevate nitrate levels in agrigultural regions, areas of high population (human or animal) where there is poorly treated or untreated
sewage, and in industrial areas where metals, munitions, paper and other products are manufactured.
A very stable ion
Nitrate is extremely soluble in water. It is also very stable -- it tends to remain as nitrate, rarely combining with other compounds to
become more benign. It does not bind to soil particles, as many water contaminants do. This means it will move around with groundwater,
you may find a sudden nitrate problem miles away from a potential source, or years after a farm or factory is gone.
-
The term "nitrates" is often used when talking about nitrate. Nitrates refers to combined nitrate and nitrite. Nitrite (NO2) is a very reactive
ion and rarely lasts long — it will quickly react with other chemicals, or become nitrate or ammonia. Most nitrate detection methods actually
measure combined nitrate and nitrite. Nitrate (NO3) is colorless, odorless, and tasteless. Because it is so unreactive, it is not removed from
water by standard water treatment dquipments such as carbon filters or softeners.
Nitrate and health
When humans (and most animals) take up nitrate in food or water, most of it is quickly eliminated from the body through the urine. Nitrate
does not accumulate in body fat, as most herbicieds and psticides can do. It is not irritating to the skin or to mucous membranes. However,
if there is a constant intake of nitrate — as might be the case if drinking water contains high nitrate levels -- there wil always be some nitrate
present in the body, and this is when health problems may occur.
Consumption of excess nitrate can cause "blue baby syndrome," or methemoglobinemia, in infants by interering with the ability of the blood
to carry oxygen. Infants never should be given water containing more than the US Environmental Protection Agency (EPA) maximuym
contaminant limit of 10 parts per milion (ppm) nitrate-N (as nitrogen). Long-term consumption of excess nitrate may increase the risk for
cancer of the stomach and bladder, and non -Hodgkin's lymphoma. High nitrate levels may increase the chance for miscarriage, childhood
asthma, and even juvenile diabetes. The elderly and those with reduced stomach acidity (such as people taking antacids) may also have
problems with reduced oxygen in the blood. Livestock and pets are also affected by high nitrate levels in water.
L++_. //__,......,...._....,...1+,......,.+:_,,... /..,,.+,......:�,.+,. 1,.+...,_1 1 1 /1 AP1n1 c

• Nitrates
Page 3 of 4
Because of the nitrate's adverse effects on human health, the EPA has set the MCL for nitrate at 10ppm nitrate-N (45 ppm nitrate, or 0.71
millimolar nitrate) under the Clean Water Act and the Safe Drinking Water Act. Nitrate is a primary contaminant, meaning that all potable
water in public supplies must be tested at least yearly for nitrate. Nitrate is also monitored in groundwater by state and federal agencies.
Background nitrate levels rarely exceed 2 ppm nitrate-N.
The problem of drought
Because nitrate is unreactive and water-soluble, it will remain in a well or aquifer unles it is flushed out by water containing lower nitrate
levels. Crought — where the same quantity of nitrate is present, but in less water -- can dramatically increase the nitrate concentration of a
water source. Water that had been safe might, under drought conditions, exceed the EPA safe drinking water limit.
Conversely, sudden increases in groundwater following flooding or excessive rain can also cause nitrate levels to rise in wells by flushing
nitrate into a new area from a contaminated site. Large areas of the US are under drought conditions in the summers. If your business is
locate in an agricultrual region and drought conditions are present, new nitrate problems will start to show up.
Testing and removal
There are many methods for testing water for nitrate, from test strips to sending samples to a certified testing lab. Test methods vary
widely in accuracy and reliability, so choose the most reliable method available to you. On -site testing is always helpful, allowing you to
demonstrate directly that there is a problem. Test strips and test kits are manufactured by a number of companies. Enzyme -based nitrate
analysis has been used in biomedical research for many years and is now available in simplified test kit formats for on -site water testing.
Test kits based on this method can provide reliable data even when ther eare other contaminants in the water.
Because nitrate is so soulble and non -reactive, it can be very difficult to remove from water. Under some conditions, for example, ion
exchange media can actually increase the danger for nitrate: the media will have a higher attraction for less soluble ions such as sulfate, and
will release the cound nitrate ions to make room for the others, causing nitrate breakthrough. All nitrate treatments require careful monitoring
and maintenance.
On the horizon
Various biological systems are also on the horizon in the technology of nitrate removal. Microbes that use nitrate as an energy source can
be contained in a clomyun or tank system for water treatment. A more sophisticated approach pruifies the enzymes within these organisms
that catalyze the nitrate reduction reactions, and uses the enzymes alone for nitrate removal. The advantage of biological systems is that the
nitrate is converted to safe nitrogen gas, which does not contribute to the greenhouse effect. But it may be some years before these new
_ methods hurdle the technological, regulatory, and customer -perception barriers to make their way into common practice.
Ellen R. Campbell is vice president of The Nitrate Elimination Co., In, Lake Linden, MI, an environmental biotechnology company that develops enzyme -based
technologies for water testing and treatment. More information about the company is available at: hftp://www.nitrate.com. Campbell can be reached at:
[e-mail]. A.J. Kemppainen is a production/chemical engineer at the company.
Five Nitrate Removal Methods
by A.J. Kamppainen
Nitrate removal includes biodentrification, distillation, electrodialysis, ion exchange and reverse osmosis:
• Distillation boils water, leaving the nitrate behind, and then condenses and collects the steam/condensate. This process requires
relatively higher amounts of energy than other methods and is typically used when virtually complete removal of nitrate is desired.
• Electrodialysis uses an electrical current to move the nitrate threough a series of anoin and cation selective membranes. The
consecutive membranes concentrate the ions in a waste stream and away from the water. Electrodialysis may not be sot -effective for
small-scale production.
• Ion exchange uses a nitrate -selective resin to remove nitrate from water. Care must be used: as the resin exchange sites fill with
nitrate, nitrate breakthrough can occur as the resin reaches full nitrate capacity. Ion exchange is economical for large-scale nitrate
removal.
• Reverse osmosis (RO) traps the nitrate in a selctive membrane and allows the water to pass through. RO is the most common method
of nitrate removal and is cost-effective when a small amount of water needs to be purified (5 to 10 gallons daily).
• Biodenitrification is a process that is typically associated with large-scale wastewater treatment. In general, the nitrates are reduced to
nitrogebn using bacteria in an anaerobic environment.
Distillation, electrodialysis and reverse osmosis are very effective at removing nitrate from water. However, the high nitrate waste must still
be sidposed of properly or contamination of groundwater can occur.
Sources:
1. Scott Harmon, "Nitrate removal: Searching for the ideal in an imperfect world," Water Technology, November 2002.
2. David Elyanow and Janet Persechino, Advances in Nitrate Removal, GE WAter & Process Technologies, 2005
Understanding the Different Nitrate Units
by Ellen Campbell
Nitrate is reported in different terms (units) depending on where you live and your field of use. For example, 2 parts per million (ppm) nitrate-
N in New York would be reported as 9 ppm nitrate in California.
• To convert from ppm nitrate-N to nitrate, multiply the nitrate-N value by 4.4 (10ppm nitrate-Nx4.4=44 ppm nitrate).
• To convert from ppm nitrate to ppm nitrate-N, multiply the nitrate value by 0.23 (50 ppm nitratex0.23=11.5 ppm nitrate-N).
1�ffr�•//ti ni rrz cwt.{ Arno ltnrrl 'if; nnm /n70f0rn ifrotn l-ttm1
11/1n/')nis

• Nitrates
Page 4 of 4
US EPA Units
2 ppm nitrate-N
(NO3N, nitrate -nitrogen)
10 ppm nitrate-N
California, Europe
9-10 ppm nitrate (NO3)
45 or 50 ppm nitrate
Chemical Units
140 micromolar nitrate
710 micromolar nitrate
Retum to WATER DETAILS
Return to main page on WATER
Return to HOME page
httn•/hananar pn rirnaltprnat' vpe Cnm/VVafprnitrate. lifrn1
11/1nrn1G

Report of Annual Groundwater Monitoring and
Treatment System Effectiveness
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
November 9, 2015
Page 6 of 6
Greenan et al, 2009, USDA Technical Reports: Surface Water Quality — Denitrification in Wood Chip
Bioreactors at Dfferent Water Flows, 1664-1671.
Haller et al, Nitrate Pollution of Groundwater. http://www.reopure.com/nitratinfo.html
Hutchins, Stephen R., and Wilkin, Richard T., EPA Technology News & Trends —Evaluating a Wheat
Straw PRB for Nitrate Removal at an Agricultural Operation. http://www.clu-
in.org/products/newsltrs/tnandt/view new.cfiu?issue=0812.cfm
Kaspar et al, 2003, Final Report to the American Farm Bureau Foundation for Agriculture —Reducing
Nitrate Levels in Subsurface Drain Water with Organic Matter Incorporation.
http://www.agfoundation.org/aboutus/docs/ReducingNitrateLevels.pdf a 44
Kim et al, 2000, Water Environment Federation: Engineered Bioretention for Removal of Nitrate from
Stormwater Runoff http://www.psparchives.com/publications.htm r,
Siemens Corporation, 2011, Nitrate Removal from Groundwater.une4L rrifbarb
http://www.water. siemens.com/en/appl ications/groundwater_rmediation/nitrate_removal/pages/
default.aspx
Strietelmeier et al, 2001, Presentation: Use of a Unique BioBarrier to Remediation of Nitrate and
Perchlorate in Groundwater. International Containment and Remediation Conference, Orlando,
Florida, June 10-13, 2001. http://www.clu-
in.org/download/contaminantfocus/perchlorate/Strietelmeierl .pdf
University of California, Davis, 2012, Addressing Nitrate in California's Drinking Water — Technical 6r`✓, P> 1
Report 2: Nitrogen Sources and Loading to Groundwate. http://groundwaternitrate.ucdavis.edul ex,rou,a' '
University of California, Davis, 2012, Addressing Nitrate in California's Drinking Water — Technical
4'G/' ed efi/of Report 5: Groundwater Remediation and Management for Nitrate.‹ lw%�
f
��
http://groundwaternitrate.ucdavis.edu/ �,/«� e.".rot ,.al
F�r
US Department of Health and Human Services - ATSDR, 2011, Nitrates and Nitrites. 7?e_ f ,te e
http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=1186&tid=25 8
(A-b re"! d )
o
Widdowson, Mark and Killingstad, Marc, USGS Research Project: Nitrate Remediation — Laboratory
Project. http://wwwbrr.cr.usgs.gov/projects/EC biogeochemistiy/BioReac2.htm
,v Je p e,modot.lep 11A4 5/40 ;c 4 i'e t.
!�/o 6 f n�ro(�r _ cw di" kin/41)e'ft+�r, (&
Se w, Z. S. 4 Oleidedy - 'Lae
-y G` 444ii l7
Cot/
p'CS ~4
DUNCKLEE & DUNHAM, P.C.

NC DEQ: Does this apply to my site? Page 1 of 2
OR CARD A
Environmental Quality
NC DEQ
Does this apply to my site?
J
Session Law 2015-286 (http://www.ncleg.net/Sessions/2015Bills/House/HTML/H765v6.html) expands the
use of risk -based remediation to sites subject to remediation under the following programs or
requirements:
Inactive Hazardous Sites Response Act
Hazardous Waste Management Program
Solid Waste Management Program
National Priorities List Sites
Groundwater Protection Corrective Action Requirements (Article 21 of Chapter 143 of the General
Statutes)
Oil Pollution & Hazardous Substances Control Act
The new law is not applicable to sites subject to remediation under the following programs or
requirements:
Leaking Petroleum Underground Storage Tank Cleanup Program
Leaking Petroleum Above Ground Storage Tanks and other Sources of Petroleum Releases
Dry -Cleaning Solvent Cleanup Program
Pre-1983 Landfill Assessment and Remediation Program
The Coal'Ash Management Act of 2014
Animal Waste Management Systems
Risk -Based Remediation
https://deq.nc. gov/permits-regulations/risk-based-remediation/does-apply-my-site
7/16/2018

NC DEQ: Does this apply to my site?
Page 2 of 2.
Statutes and Rules (/permits-regulations/risk-based-remediation/statutes-and-rules)
Does this apply to my site? (/permits-regulations/risk=based-
remed iation/does-apply-my-site)
Procedures and Forms (/permits-regulations/risk-based-remediation/forms)
Technical. Guidance (/permits-regulations/risk-based-remediation/technical-quidance)
Risk Evaluation Resources (/permits-rules/risk-based-remediation/risk-evaluation-
resources)
Contacts (/permits-regulations/risk-based-remediation/contacts)
Share this page:
Facebook (https://www.facebook.com/sharer/sharer.php?u=https%3A%2F%2Fdeq.nc.gov%2Fpermits-
regulations%2Frisk-based-remediation%2Fdoes-apply-my-site)
Twitter (http://twitter.com/intent/tweet?url=https%3A%2F%2Fdeq.nc.gov%2Fpermits-regulations%
2Frisk-based-remediation%2Fdoes-apply-my-site)
https://deq.nc.gov/permits-regulations/risk-based-remediation/does-apply-my-site 7/16/2018

NC DEQ: Procedures and Forms Page 1 of 2
OR CARO A
Environmental Quality
NC DEQ
procedures and Forms
The Administrative Procedures for Risk -Based Environmental. Remediation of Sites provides the
administrative steps to obtain approval of risk -based remediation of a contaminated site pursuant to Part
8 of Article 9 of Chapter 130A of the North Carolina General. Statutes (130A-310.65-310.77). Refer to the
echnical Guidance page for more information about. conducting site investigations, planning for risk-
based remediation, and performing risk assessments. Contact the appropriate oversight program for any
program -specific requirements.
Administrative Procedures for Risk -Based Environmental Remediation of _
(https://files.nc.gov/ncdeq/Waste%
20Management/DWM/SF/RiskBasedRemediation/FlNAL AdminProceduresGuidance 20 1 80209%20WITH%
Sites 20FORMS.PDF)
Property Owner Consent to Risk -Based Remediation with
(https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRemediation/FINAL Property%20Owner%
dnstructions 20Consent%20form 20180209 fillableform%20final.pdf)
Notice of Intent to Remediate - Template with
(https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRemediation/FINAL Notice%20oWo20Inte:
Instructions 20Remediate 20180209 fillable%20form%20final.pdf)
Fee Calculation Worksheet with Instructions
(https://files.nc.gov/ncdeq/Waste%20Management/DWM/SF/RiskBasedRemediation/FINAL Fee%20Calc%
20Instructions 20180209 fillableform%20final.pdf)
Contaminated Property: Issues and
Liabilities (https://files.nc.gov/ncdeq/Waste%20Management/DWM/FINAL ContaminatedPropertiesPublication 20160718.pdf)
N.C.G.S. 130A, Article 9, Part 8, Risk -based Environmental ,Remediation of Sites
(https://files.nc.gov/ncdeq/Waste%20Management/DWM/Part%208 Article%209 Chap%20130A.pdf)
Stakeholder Feedback: Response to External Review Comments (July 2016)
(https://files.nc.gov/ncdeq/Waste%20Management/D WM/FINAL ResponsetoExternalComments 20160718.pdf)
Risk -Based Remediation
https://deq.nc.gov/permits-regulations/risk-based-remediation/forms 7/16/2018

NC DEQ: Procedures and Forms Page 2 of 2
Statutes and Rules (/permits-regulations/risk-based-remediation/statutes-and-rules)
Does this apply to my site? (/permits-regulations/risk-based-remediation/does-apply-my-site)
Procedures and Forms (/permits-regulations/risk-based-remediation/forms)
Technical Guidance (/permits-regulations/risk-based-remediation/technical-guidance)
Risk Evaluation Resources (/permits-rules/risk-based-remediation/risk-evaluation-resources)
Contacts (/permits-regulations/risk-based-remediation/contacts)
Share this page:
Facebook (https://www.facebook.cpm/sharer/sharer.php?u=https%3A%2F%2Fdeq.nc.gov%2Fpermits-
regulations%2Frisk-based-remediation%2Fforms)
Twitter (http://twitter.com/intent/tweet?url=https%3A%2F%2Fdeq.nc.gov%2Fpermits-regulations%2Frisk-
:based-remediation%2Fforms)
https://deq.nc.gov/permits-regulations/risk-based-remediation/forms 7/16/2018

NC DEQ: Statutes and Rules Page 1 of 3
OR CARD A
Environmental Quality
NC DEQ
Statutes and Rules
Risk -Based Environmental Remediation of Sites in its current form is established under Session
Law 2015-286 (http://www.ncleg.net/Sessions/2015Bills/House/HTML/H765v6.html) which
amended N.C.G.S. 130A, Part 8 of Article 9 of Chapter 130A of the North Carolina General
Statutes (130A-310.65-310.77),
(https://files.nc.gov/ncdeq/Waste%20Management/DWM/Part%208 Article%209 Chap%20130A.pdf)
G.S. 130A-310.66 - Purpose
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS
G.S. 130A-310.67 — Applicability
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS
G.S. 130A-310.68 - Remediation standards
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS
G.S. 130A-310.69 - Remedial investigation report; remedial action plans
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS
G.S. 130A-310.70 - Notice of intent to remediate
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBvSection/Chapter 130A/GS
G.S. 130A-310.71 - Review and approval of proposed remedial action plans
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS
G.S. 130A-310.72 - Financial assurance requirement
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBvSection/Chapter 130A/GS
130A-310.67.html)
130A-310.68.html)
130A-310.69.html)
130A-310.70.html)
130A-310.71.html)
130A-310.72.html)
G.S. 130A-310.73 - Attainment of the remediation standards
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A
G.S. 130A-310.73A - Remediation of sites with off -site migration of contaminants
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A
-310.73.html)
-310.73A.html)
G.S. 130A-310.74 - Compliance with other laws
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS_130A-310.74.html)
G.S. 130A-310.75 - Use of registered environmental. consultants
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A-310.74.html)
https://deq.nc.gov/permits-regulations/risk-based-remediation/statutes-and-rules 7/16/2018
130A-310.66.html)

NC.DEQ: Statutes and Rules Page 2 of 3
—. V. .VV.". V.V./ V . Sam Am* J. r/\. I I...J J.V Im... MJVJ VI .VMd. J
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A-310.76.html)
;G.S. 130A-310.76A - Risk -Based Remediation Fund
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A-310.76A.html)
G.S. 130A-310.77 - Construction of Part
(http://www.ncga.state.nc.us/EnactedLegislation/Statutes/HTMLBySection/Chapter 130A/GS 130A-310.77.html)
Rules of North Carolina Administrative Code that support the statutes include the following:
15A NCAC 2L - Groundwater Quality Standards (http://deq.nc.dov/about/divisions/water-
resources/planning/classif ication-standards/groundwater-standards)
15A NCAC 2C Well Construction Standards (http://deq.nc.dov/about/divisions/water-
resources/planning/classification-standards/rules)
15A NCAC 2B Surface Water and Wetlands Standards (http://deq.nc.gov/about/divisions/water-
resources/planninq/classification-standards/rules)
Risk -Based Remediation
Statutes and Rules (/permits-regulations/risk-based-remediation/statutes-
and-rules)
Does this apply to my site? (/permits-requlations/risk-based-remediation/does-apply-
my-site)
Procedures and Forms (/permits-requlations/risk-based-remediation/forms)
Technical Guidance (/permits-regulations/risk-based-remediation/technical-guidance)
Risk Evaluation Resources (/permits-rules/risk-based-remediation/risk-evaluation-
resources)
Contacts (/permits-regulations/risk-based-remediation/contacts)
https://deq.nc.gov/permits-regulations/risk-based-remediation/statutes-and-rules 7/16/2018

NC DEQ: Statutes and Rules
Share this page:
Page 3 of 3
Eacebook (https://www.facebook.com/sharer/sharer.php?u=https%3A%2F%2Fdeq.nc.gov%2Fpermits-
regulations%2Frisk-based-remediation%2Fstatutes-and-rules)
Twitter (http://twitter.com/intent/tweet?url=https%3A%2F%2Fdeq.nc.gov%2Fpermits-regulations%
2Frisk-based-remediation%2Fstatutes-and-rules)
https://deq.nc.gov/permits-regulations/risk-based-remediation/statutes-and-rules 7/16/2018

ii
SHI
7.5 MIT
521
BR 746
•

511 Keisler Drive, suite 102
Cary, North Carolina 27518
email: [e-mail]
phone: [phone], ext. 208
Website: www.dunckleedunham.com
.4 Professional Geologic and Engineering Corporation
ti

To promote a cooperative effort to reduce nutrients levels that are currently above the Title 15A
Subchapter 2L groundwater standards, it may be possible that Southern States Corporation could qualify
for the Risk -Based Remediation Program currently being implemented by NCDEQ. This program may
offer benefits that a CAP may not be able to provide. Should Southern States qualify for the Risk -Based
program, the current CAP will become inactive. However, boundaries of the on -site plume will be
required to be defined. This will also require that a Water Supply Well (WSW) survey be performed for a
radius of % mile from the edge of the plume. As this is currently a stipulation of the current CAP, this
survey will be required to be performed regardless.
To see if your operation qualifies for this program you may contact Remediation Co -Chair, Janet
Macdonald at [phone] or by email at [e-mail], or Remediation Co -Chair
Peter Doorn at [phone] or by email at [e-mail]. , regarding this program and the
site's eligibility. The NCDEQ website that describes the Risked -Based Remediation Program may be
found by performing an Internet search under NCDEQ Risk -based Remediation Program.
During the December 9, 2015 site visit, evidence of excessive nutrients was present at the Statesville
facility. The presence of algal growth on the ground surface, in intermittent streams and in surrounding
ponds all provide indication of the presence of excessive nutrients not being controlled at the. source.
During the most recent site visit, it was agreed that Semi-annual sampling be conducted. However, not
enough data has been collected to indicate if seasonal trends indicate a change in the increase/decrease
of the presence of nutrients in the groundwater at this facility.
Site visit discussions the .. introduction ... oa i _.._ ._. r f
cussions alsoaddressed thintroduction of wetland areas to aid in the reduction of.
nutrients through methods of Plant Nutrient Up -take by Phytoremediation. The implementation of and
the construction of a wetland does not require a permit from the Division of Water Resources. The
observation of existing wetland areas and downgradient land areas appear to be available on the site for
theconstruction of additional in -line wetland features.
The MRO requests recommendations to be provided to our office by Duncklee and Dunham for
alternative methods where nutrient reduction may be able -put into effect at this site. Also, as the
current site maps no longer represents the footprint of the property, please provide updated site maps,
with corrected property boundaries, and up -dated topographic maps in your next report.
Should you have questions regarding this letter, I may be reached by phone at [phone] or email
([e-mail]).
Sincerely,
Edward Watson
Hydrogeologist
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
cc: Duncklee and Dunham (via -email)

Pitner, Andrew
From: Pitner, Andrew
Sent: Wednesday, April 30, 2014 12:27 PM
To: 'Jayson Kilcoyne'; '[e-mail]'
Subject: RE: Statesville Fertilizer Plant sampling schedule
Hi Jayson & Vance,
I appreciate the email prompting review of the request made in the report. Given the long term data and contaminant
trends that exist at this site, it is appropriate to reduce the groundwater monitoring to annually. lb1NR er fers_that:this
mangle annual nionitdring event occur in=the spring (trad►tionally thislappeaxs to -have been in`the March/April%IVlay time
fr,arne) when groundwater levels are,likely.,at:.their<highest and;thefewest`.MWs w,ill.be diy.
Additionally, I have a couple of requests that can be incorporated into next year's annual report that can be submitted
after the spring 2015 sampling:
• Please update the receptor survey (the last one on file appears to be 2002);
• Please provide an analysis of the effectiveness of the current remediation strategy and provide a brief analysis of
other treatment options that may be appropriate for the site to reduce groundwater contaminant levels and
prevent potential migration of contaminants off site or to surface waters.
Thanks and feel free to let me know if either of you have any questions.
Andrew
Andrew Pitner, P.G. - [e-mail]
Division of Water Resources - Water Quality Regional Operations Section
Mooresville Regional Office (MRO)
North Carolina Department of Environment & Natural Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
MRO Main Phone: [phone]
Direct Office Phone: [phone]
MRO Fax: [phone]
DWR website: http://www.ncwater.org
NOTICE: Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
From: Jayson Kilcoyne[mailto:jayson(adunckleedunham.com]
Sent: Wednesday, April 30, 2014 7:41 AM
To: Pitner, Andrew
Subject: Statesville Fertilizer Plant sampling schedule
Hi Andrew,
I'm following up to see if you have reviewed the Annual Monitoring Report for the Southern States Cooperative -
Statesville Fertilizer Plant, Incident # 5038. Historically we have sampled the wells semi-annually and in the report we
recommend annual monitoring of the plume. Do you agree with our recommendation to adjust the monitoring schedule?
Thank you and Regards,
Jayson
Jayson A. Kilcoyne
Project Environmental Scientist II
Duncklee & Dunham, PC
1

BRP Southern States Iredell Co 6-27-08
From: Bruce Parris [[e-mail]]
Sent: Thursday, June 26, 2008 12:55.PM
To: charlotte Jesneck
Subject: Southern states, Iredell Co.
Charlotte,
Incident #5038, Southern States, Iredell Co, was one of the sites that was
initially designated as a DWQ lead.
DWQ-APS is questioning whether the site should actually be under their
jurisdiction.
The site processes raw materials into fertilizer for garden and farm use. They
currently use wet scrubbers in their process to eliminate discharges of
wastewater. The scrubbers came on-line in 1980. Prior to 1980, they
occasionally disposed of waste process water into the site lagoons. This
resulted in nitrate contamination in groundwater.
DWQ'S contention that the site is likely not under their jurisdiction is based
on the fact that they can find no evidence that the lagoons were ever
permitted (regardless of whether they should have been permitted).
However, since this is the type of activity that was subject to permitting (or
should have been permitted), I question whether it should remain with DWQ. The
problem with "should have been permitted/subject to permittin9" is that no
discharge is allowed under the General Statutes unless a permit is issued.
using common sense though, some activities would likely never be under a
permit, such as dumping concentrated waste chlorinated solvents. However, a
permit might be written for a discharge system and its associated treatment
structures for removal of chlorinated solvents (or other COC which we would
normally be
regulating) from a waste stream prior to discharge if a sufficient amount of
the contaminants could be removed prior to the discharge so as not to exceed
surface water or groundwater standards. This last situation is a "wastewater"
that would be required to have a permit or is "subject to permitting". So, if
a site didn't obtain a permit and discharged the wastewater and caused a
problem, does it then become ours, or stay in DWQ since the activity was
subject to permitting?
Since the activity at the Southern States site appears to have been something
for which a permit should have been obtained, do you think DWQ should keep the
site, orshould we take the site since a permit was never actually issued to
the site (though it was subject to permittin9).
Both answers have ramifications on the Division's jurisdiction on many other
sites. Perhaps our attorney's should look at this too. This is not an
adversarial situation with DWQ, but I'm seeking some guidance as this will
come up again for other sites.
Excepts for you assistance.
According to the February 8, 2007 MOA, DWQ will maintain groundwater incident
management responsibilities for:
" incidents caused by activities _subject to permitting_ under G.S.
143-215.1,"...
"G.S. 143-215.1:
143-215.1. control of sources of water pollution; permits required.
(a) Activities for Which Permits Required. - No person shall do any of the
following things or carry out any of the following activities unless that
person has received a permit from the Commission and has complied with all
conditions set forth in the permit:
(1) Make any outlets into the waters of the State.
(2) Construct or operate any sewer system, treatment works, or disposal system
within the state.
(3) Alter, extend, or change the construction or method of operation of any
sewer system, treatment works, or disposal system within the State.
(4) Increase the quantity of waste discharged through any outlet or processed
Page .1
1

BRP Southern States Iredell Co 6-27-08
in any treatment works or disposal system to any extent that would result in
any violation of the effluent standards or limitations established for any
point source or that would adversely affect the condition of the receiving
waters to the extent of violating any applicable standard.
(5) Change the nature of the waste discharged through any disposal system in
any way that would exceed the effluent standards or limitations established
for any point source or that would adversely affect the condition of the
receiving waters in relation to any applicable standards.
(6) Cause or permit any waste, directly or indirectly, to be discharged to or
in any manner intermixed with the waters of the State in violation of the
water quality standards applicable to the assigned classifications or in
violation of any effluent standards or limitations established for any point
source, unless allowed as a condition of any permit, special order or other
appropriate instrument issued or entered into by the Commission under the
provisions of this Article.
(7) Cause or permit any wastes for which pretreatment is required by
pretreatment standards to be discharged, directly or indirectly, from a
pretreatment facility to any disposal system or to alter, extend or change the
construction or method of operation or increase the quantity or change the
nature of the waste discharged from or processed in that facility.
(8) Enter into a contract for the construction and installation of any outlet,
sewer system, treatment works, pretreatment facility or disposal system or for
the alteration or extension of any such facility.
(9) Dispose of sludge resulting from the operation of a treatment works,
including the removal of in -place sewage sludge from one location and its
deposit at another location, consistent with the requirement of the Resource
Conservation and Recovery Act and regulations promulgated pursuant thereto.
(10) Cause or permit any pollutant to enter into a defined managed area of the
State's waters for the maintenance or production of. harvestable freshwater,
estuarine, or marine plants or animals.
(11) Cause or permit discharges regulated under G.S. 143-214.7 that result in
water pollution.
(12) Construct or operate an animal waste management system, as defined in
G.S. 143-215.10B, without obtaining a permit under either this Part or Part 1A
of this Article."...
"(a4) The Department shall regulate wastewater systems under rules adopted by
the Commission for Public Health pursuant to Article 11 of Chapter 130A of the
General Statutes except as otherwise provided in this subsection. No permit
shall be required under this section for a wastewater system regulated under
Article 11 of Chapter 130A of the General Statutes. The following wastewater
systems shall be regulated by the Department under rules adopted by the
Commission:
(1) wastewater systems designed to discharge effluent to the land surface or
surface waters.
(2) Wastewater systems designed for groundwater remediation, groundwater
injection, or landfill leachate collection and disposal.
(3) Wastewater systems designed for the complete recycle or reuse of
industrial process wastewater."
Bruce Parris - [e-mail]
Environmental Supervisor II, Western Region North Carolina Dept. of
Environment & Natural Resources DiV. of Waste M9t. - Superfund Section -
Inactive Hazardous Sites Branch Mooresville Regional Office 610 East Center
Street, Suite 301 Mooresville, NC 28115
Ph: [phone] Fax: [phone]
Page 2

BRP Southern States iredell Co 6-27-08
Page 3

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
I^I 1 I 2 IL I 3 I NC0082821 111 12 1 15/05/29 117
Type
18 Lc.]
I I I I I
Inspector Fac Type
19 I S j 201
2111I I I I I I I I I I I I I I I I I I I I I I I I I I I
66
I I I I I I I I 1
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
I 71 IN I 72 I �, I
67I1.o I 70Id LJ LJ
Reserved
73174 751
1
1 1 1 1 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to-POTW, also include
POTW name and NPDES permit Number)
Southern States Fertilizer Plant ,
2582 Salisbury Hwy
Statesville NC 28677
Entry Time/Date
10:30AM 15/05/29 .
Permit Effective Date
14/05/01
Exit Time/Date
11:55AM 15/05/29
Permit Expiration Date
19/03/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joshua Michael Hanks/ORC/919-858-9898/
Other Facility Data
-
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Danny Dillon,6606 W Broad St Richmond VA 232606234NP Crops/804-281-1000/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review • Effluent/Receiving Waters • Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Marcia Allocco MRO WQ//704-663-1699 Ext.2204/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type
3I NC0082821 111. 121 15/05/29 117 18
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NC0082821
Inspection Date: 05/29/2015
Owner -_Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Yes No NA NE
❑ ❑ • ❑
IN ❑ ❑ ❑
• ❑ ❑ ❑
▪ 1E1 El El
Comment: NC0082821 was reissued by the Division on April 2, 2014, with an effective date of May 1,
2014. The permit is set to expire on March 31, 2019. The previous compliance evaluation
inspection was conducted on March 2, 2010: The reissued permit required electronic
submission of the monthly discharge monitoring reports by February 1, 2015. The permittee
began electronic DMR submission in October 2014.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Yes No NA NE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Comment: The groundwater treatment system is typically shutdown from April to November of each
year. Temperature and pH are monitored for process control.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Yes No NA NE
II ❑ ❑ ❑
El 0 II 0
• ❑ ❑ ❑
❑ ❑ II ❑
Comment: Totalizers are installed on each of the three extraction wells and averaged over the number
of days of discharge for reporting on the DMRs.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Yes No NA NE
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ 11❑
11 ❑ ❑ ❑
MI ❑ ❑ ❑
Page# 3

Permit: NC0082821
Inspection Date: 05/29/2015
Owner - Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: The permit requires grab samples for all required parameters. All effluent samples are kept
on ice in a cooler until transfer to a courier for delivery to the analytical laboratory.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ ❑ •
❑ ❑ II ❑
Comment: There was no discharge of treated groundwater to the permitted outfall during the inspection.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is propertemperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Comment: On -site analyses are performed under field laboratory certification #5484, Duncklee &
Dunham, P.C. The permittee has also contracted Pace Analytical Services (laboratory
certification #12/40) and ESC Labs (toxicity) to provide the remaining testing requirements.
The field instrumentation used on site appeared to be properly calibrated and documented.
Reagent tracking had been implemented for the pH buffers.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Yes No NA NE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ OD
• ❑ ❑ ❑
• ❑ ❑ ❑
•
•
•
•
•
• ❑ ❑ ❑
Page# 4

Permit: NC0082821
Inspection Date: 05/29/2015
Owner - Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Record Keeping
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility. classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Yes No NA NE
❑ ❑ • ❑
❑ ❑ � ❑
III ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ■ ❑
The permittee's records were organized and well maintained and records requested during
the inspection were readily retrievable. DMRs were reviewed for Jan 2014 through Mar 2015.
No limit violations were reported and all monitoring frequencies were correct. ,
The treatment system is currently classified as a physical -chemical grade I system (PC-1).
The standard conditions of NC0082821 and 15A NCAC 08G .0204 require weekly visitation
of PC-1 classified systems and are separate from any sampling requirements specified in
an individual NPDES permit. Although, the permittee requested reduced visitation approval
from the Division in 2009, a formal declassification of the system was not made at that time.
It is only through declassification that operator visitations can be reduced. The permittee
should make a formal request to the Wastewater Operator Certification group to declassify
the system; otherwise the visitation frequency of the system will need to be increased to
weekly from the present twice per month.
Page# 5

BRP Fwd Southern States Iredell Co 6-27-08
From: Bruce Parris [Bruce:[e-mail]]
Sent: Friday, June27, 2008 4:58 PM
To: andrew.pitner; peggy.finley
Subject: [Fwd: Southern States, Iredell Co.]
Attachments: Southern States, Iredell Co.
Just to let you all know, I spoke with Charlotte Jesneck about who should be
managing this site, based on the MOA. Apparently, Charlotte, Dexter Matthews,
Jack Butler and maybe our attorneys had recently discussed this very issue
with regard to some other site issues that have arisen. The consensus was
that the MOA means that sites like this one should be under DWQ's jurisdiction
since the activity should have been permitted due to the discharge of a
"wastewater" (unless the activity occurred prior to the permitting rules being
enacted). If they had been dumping raw product on the ground, it would be
regulated by DWM because that activity would never have been permitted by DWQ
under 143-215.1. If DWM started regulating every situation where a wastewater
was dumped without a'permit, yet the activity was required to have obtained a
permit under 143-215.1, then DWQ's permitting program would be an empty shell
without significant enforcement structure. This was reportedly Dexter's
understanding with Alan Klimek, or so I am told.
If you like, we can sit down and discuss this. I only write and forward all
this information in email form so that we can all understand the basis for the
opinions regarding site jurisdiction relative to the MOA since I know it will
arise again as we all forge ahead with our respective programs.
Bruce
Bruce Parris - [e-mail]
Environmental Supervisor II, Western Region North Carolina Dept. of
Environment.& Natural Resources Div. of Waste M9t. - Superfund Section -
Inactive Hazardous Sites Branch Mooresville Regional Office 610 East Center
Street, Suite 301 Mooresville, NC 28115
Ph: [phone] Fax: [phone]
Page 1

Inspection Questions for Southern States Fertilizer Permit NC0082821
1. '-Eontintre- 's
2. - Wh c rg ve ofum%day?
3. Are there easonal-change-s-in_dischar a rate
`'flucuation-occurs?
4. Do you have recent data for Saprolite well K65W76?What are the current concentrations of
Nitrates and Ammonia in this well?
5. This permit expires on March 31, 2019. Have you begun to put together the permit renewal
package?
6. May I see the onsite maintenance records for the recovery wells. Is there a regular schedule
that maintenance keeps for the RWs and the Treatment system?
7. Southern States does not have a storm water discharge permit.
8. NCDEQ is implementing a policy regarding nutrient reduction. Expect to see Nutrient reduction
limits to be being added to the renewed permit.
9. The Permittee Name needs to be updated in BIMS. Please contact Derek Denard (919) 807-
6307 in Raleigh in update BIMS contact information for this facility.

DUNCKLEE
& DUNHAM
Julyj9, IO 8)
North Carolina Department of Environmental Quality
Division of Water Resources - Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Notification of Non-compliance
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NC0082821
To Whom It May Concern:
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
WWW DUNCKLEEDUNHAM COM
vt R'd PR e,,„„j 1(“(2.5tV
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee &
Dunham) submits this notification of non-compliance for the treatment system at the referenced site.
OntIV1ay77;20181a leak was discovered in the pipe connected to recovery well RW-2. The pump to the
well was immediately shut off by Duncklee & Dunham personnel and the pipe was repaired by facility
personnel. During this time, RW-5r and RW-6 remained active. Duncklee & Dunham personnel
reactivated the pump to RW-2 ont,May_9, 2018.
Water samples were collected from the effluent during this monitoring period on May 7, and 21, 2018. The
monthly average concentration for ammonia on the May 2018 eDMR was calculated to be 9.95 mg/L,
which is above the April to October Monthly Average Limit of 7.8 mg/L. However, the daily maximum
reading from the May 7, 2018, sample was 17 mg/L, which is below the April to October Daily Maximum
Limit of 35 mg/L. The eDMR sheet calculates the monthly average by adding the listed concentrations and
dividing the sum by the number listed. Based on historical effluent data for ammonia and recent June 2018
effluent results, ammonia is consistently below the monthly average when the three recovery wells are
operating. With recovery well RW-2 being off for less than 48 hours, we believe the elevated ammonia
concentration from the May 7, 2018, sample does not accurately represent the concentration discharged
over the course of the month. Based on the May 21, 2018, and June 2018 laboratory data, we do not believe
additional corrective actions are necessary and will continue normal treatment system operations in
accordance with the permit.
.WALLING .ADDRESS - POST OFFICE Box 639 - CA..RY, NOR.TH CAROLINA 27512
\Crit'LICAROLINA BOARD OF EXAMINERS FOR Iii\Gala: RS AND S1:RVIY;'.iiS LICENSE C-:>J;'
NORTH CAROLINA BOARD FOR I..ICENSING GEOLOGISTS LICENSE C-26 i
N(' DEQ LLE(i s FERED ENV IRONl1EN'rAL (.ONSUL: AN T NUMBER 0006I

Notification of Non-compliance
Southern States Fertilizer Plant
Statesville, North Carolina
July 9, 2018
Page 2 of 2
Please contact Jayson Kilcoyne at jaysonQdunckleedunhain.com or [phone],,ext. 108, if you have
any questions or require additional information.
Sincerely,
Duncklee & Dunham, P.C.
Jayson A. Kilcoyne
Project Manager
Senior Peer Review:
Thomas S. Dunham, L.G.
Vice President/Senior Geologist
ec: Jennifer Bunting — Southern States Cooperative, Inc.
Edward Watson — DEQ-DWR-Mooresville Regional Office
Attachments: May 2018 Discharge Monitoring Report
P:\Southem States\Statesville Fertilizer - 50200\Forms-Corresp\NOV_NCDEQ Cones \20181Notice-5-18 DMR.docx
DI_ NCNI,I F & DUNHAM, P.C.

Watson, Edward M
From: Adam Daniel <[e-mail]>
Sent: Thursday, January 11, 2018 2:01 PM
To: Watson, Edward M
Cc: Josh Hanks; Jayson Kilcoyne
Subject: [External] SS -Statesville System Update
CAUTION External email. Do not click links or open -attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Ed,
Updates on the treatment system at SS -Statesville:
The system was reactivated and inspected yesterday, with normal operation. After the system was reactivated, all of the
recovery wells were inspected and totalizer readings were collected. RW-5r and RW-6 had normal operation but we
observed a cracked pipe beneath the well head/within the vault on RW-2. Due to the malfunction, we decided to shut the
entire system down. During this time, Southern States plans to repair RW-2 along with other repairs on the lift station that
have been planned. The facility manager has contacted a subcontractor to fix the broken pipe and will be on -site within
the next few days. Our goal is to have the system operational within the next 7-10 days / or as soon as possible. If there
are any questions, feel free to either contact myself or Josh Hanks.
Thanks and have a great weekend!
Best Regards,
Adam/ Q. DQUVLCeV
Staff Environmental Scientist
Assistant Project Manager
511 Keisler Drive
Suite 102
Cary, North Carolina 27518
Office: [phone] ext. 106
Mobile: [phone]
adamOdunckleedunham.com
www.dunckleedunham.com
DUNCKLEE & DUNHAM
CNN GIN5“
.1 Professional Geologic and Engineering Corporation
ACtir
,121,4Aw,4,2,
&(J
1

Watson, Edward M
From: Josh Hanks <[e-mail]>
Sent: Tuesday, August 22, 2017 5:18 PM
To: Watson, Edward M
Cc: Jayson Kilcoyne; Tom Dunham
Subject: NC0082821 - Statesville Fertilizer July 2017 DMR
Attachments: 2017-07.PDF
Hi Edward,
Please find attached the July 2017 DMR. for the Statesville Fertilizer site. As we discussed last week, I have provided a
brief summary of the treatment system operational periods for 2017 below:
Date Range
System Status
01/01/2017 — 2/24/2017
System operating normally
2/24/2017
— 5/12/2017
System off due to replacement of pH probe and lift station repairs
5/12/2017
- 6/20/2017
System operating normally
6/20/2017
— 7/26/2017
System off due to replacement of back pressure valve on caustic
line
7/26/2017 — present day
System operating normally
If you have.any other questions or would like to discuss the treatment system in further detail, please feel free to
contact me or Jayson. Thank you and have a great week!
Josh
Joshua Hanks, GIT
Project Geologist I
Duncklee & Dunham, P.C.
511. Keisler Drive, Suite 102
Cary, North Carolina 27518
Mobile: [phone]
Office: 919-858-9898 x 112
www.dunckleedunham.com

Recovery Well Totalizer Readings and Recovery Volumes - 2018
Statesville Fertilizer Plant
ORC
On -site Ai.(MGD)•
Well ID
RW-Sr RW-6 RW-2
Totals
Daily Flows
Number
of Days
Notes
Date
Meter Reading (Gallons)
AGD
12/21/2017
779,511.4
5,161,418.0
27,818,555.0
33,759,484.4
AGD
1/10/2018
781,378.2
5,170,004.0
27,818,555.0
33,769,937.2
20
Pipe burst in RW-2. System shut down-upgrades/repairs, 1/2/18-2/2/18
BLW
2/2/2018
781,950.8
5,170,600.1
27,971,035.0
33,923,585.9
0.007
23
AGD
2/19/2018
810,246.8
5,233,726.0
29,357,471.0
35,401,443.8
0.087
17
AGD
2/21/2018
810,246.8
5,241,597.1
29,509,581.0
35,561,424.9
0.080
2
RW-5r Down
BLW
3/7/2018
810,246.8
5,294,200.6
30,496,406.0
36,600,853.4
0.074
14
AGD
3/19/2018
821,769.9
5,340,550.1
31,313,865.2
37,476,185.2
0.073
12
RW-5r pump replaced and well reactivated
BLW
4/3/2018
896,970.1
5,396,200.9
32,298,205.1
38,591,376.1
0.074
15
BLW
4/26/2018
896,970.5
5,483,624.0
33,640,000.0
40,020,594.5
0.062
23
BLW
5/7/2018
927,130.8
5,527,298.0
34,061,643.0
40,516,071.8
0.045
11
Pipe leak at RW-2, shut off
AGD
5/9/2018
940,450.1
5,534,741.0
34,067,355.0
40,542,546.1
0.013
2
RW-2 reactivated
BLW
5/21/2018
1,008,140.8
5,578,085.0
34,102,000.0
40,688,225.8
0.012
12
JAK
6/8/2018
1,111,021.5
5,644,889.0
36,030,184.0
42,786,094.5
0.117
18
JAK
6/20/2018
1,180,698.0
5,690,300.1
36,771,340.5
43,642,338.6
0.071
12
emoved (ga
% Contribution
4%
5%
91%
,882,854.2
181 Total Days
171 Adjustment for days in 2018
31 Days system off

SOC PRIORITY PROJECT: No
To: Western NPDES Unit
Surface Water Protection Section
Attention: Charles Weaver
Date: October 6, 2008
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Iredell
NPDES Permit No.: NC0082821
PART I - GENERAL INFORMATION
1. Facility and address: Southern States Fertilizer Plant
6606 West Broad Street
Post Office Box 26234
Richmond, VA 23260-6234
Physical Location
2582 Salisbury Highway
Statesville, NC 28677
2. Date of investigation: October 2, 2008
3. Report prepared by: Michael L. Parker, Environmental Engineer II
4. Person contacted and telephone number: Chriay, [phone]
5. Directions to site: The site is approx. 5 miles east of the junction of I-77 and US Hwy 70
(see address above).
6. Discharge point(s): Latitude: 35° 46' 25"
Longitude: 80° 46' 40"
USGS QuadNo.: D15SE
7. Receiving stream or affected surface waters: Fourth Creek
a. Classification: C
b. River Basin and Subbasin No.: Yadkin 030706
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream has excellent flow and is 25 - 30 feet wide at the point of discharge. The
downstream users are primarily agricultural, however, there are other permitted
dischargers (both municipal and private) below the point of discharge.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater: 0.144 MGD (Design Capacity)
b. What is the current permitted capacity: Not specified in the current permit.
c. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: There have been no ATCs issued in the past two years.

Page Two
d. Description of existing or substantially constructed WWT facilities: The existing
WWT facilities consist of three recovery wells, a wet well, a. flow meter, and pH
adjustment tank (caustic solution).
e. Description of proposed WWT facilities: There are no proposed WWT facilities at
this time.
f. Possible toxic impacts to surface waters: There are no toxic impacts expected.
2. Residual handling and utilization/disposal scheme: Residuals are not generated as part of
the remediation process.
3. Treatment plant classification: This facility does not meet the minimum criteria for a
Class I rating.
4. Compliance Background: There have been no recent compliance problems at this facility.
PART III - OTHER PERTINENT INFORMATION
1. Special monitoring or limitations (including toxicity) requests: None at this time.
2. Important SOC or Compliance Schedule dates: This facility is neither under an SOC nor
is one being proposed at this time. '
3. Alternative analysis evaluation: The nearest WWTP (Statesville Fourth Creek WWTP)
does not have denitrification equipment, therefore, this option is not available as an
alternative. There are no other known alternatives.
PART IV - EVALUATION AND RECOMMENDATIONS
The permittee requests renewal of the subject NPDES peiniit. There have been no
changes to the current method of operation since the last permit renewal nor are any proposed at
this time.
It is recommended the permit be renewed as requested.
Signature of Report Preparer
Water Quality Regional Supervisor
h:\dsr\dsr08\sostates. doc
/C.) e D�
Date
/D/? d/
Date

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 11, 2008
DANNY DILLON •
VICE PRESIDENT CROPS
SOUTHERN STATES COOPERATIVE INC
PO BOX 26234
RICHMOND VA 23260-6234
Dear Mr. Dillon:
Coleen H. Sullins, Director
Division of Water Quality
SEP 1 5 2008
DENR MRO
DWQ-Surface Water Protection
Subject Receipt of permit renewal application
NPDES Permit NC0082821
Southern States Fertilizer Plant
Iredell County
The NPDES Unit received your permit renewal application on September 10, 2008. A
member of the NPDES Unit will review your application. They will contact you if additional
information is required to complete your permit renewal. You should expect to receive a draft
permit approximately 30-45 days before your existing permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact
Charles Weaver at [phone].
Sincerely,
zafitu 44L1)12
Dina Sprinkle
NPDES Unit
cc: CENTRAL FILES
glonay aka : /Surface Water Protection
Lauren N. Barlow, Environmental Project Manager, Southern States Cooperative, Inc., P.O.
Box 26234, Richmond, VA 23260-6234
NPDES Unit
A ao
Mailing Address
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone [phone]
Fax [phone]
Location
512 N. Salisbury St.
Raleigh, NC 27604
aro ina
,Naturally
Internet: www.ncwateruualitv.org
Customer Service 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

SOUTHERN
STATES
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23230-1717
Mail Address: P.O. Box 26234
Richmond, Virginia 23260-6234
Telephone [phone]
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
September 5th, 2008
North Carolina Department of Environment and Natural Resources
Division of Water Quality -Point Source Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Mrs. Dina Sprinkle
RE: Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit No. NC0082821
Submittal of Permit Renewal Application
Dear Mrs. Sprinkle,
On behalf of the Statesville Fertilizer Plant in Statesville, North Carolina, the Southern States
Cooperative, Inc. (SSC) is pleased to submit this letter to the North Carolina Department of
Environment and Natural Resources for the permit renewal package for NPDES permit No.
NC0082821. The SSC Statesville Fertilizer Plant is located on Highway 70 about seven miles
east of Statesville. This facility has been operating as a fertilizer manufacturing plant since the
1950's and SSC purchased it in 1988 from W.R. Grace & Co. Before SSC purchased the
facility, the previous owner would occasionally discharge process water from the plant into two
unlined ponds at the back of the property. This discharge water leaked out of the ponds and
infiltrated the groundwater supply and so a groundwater recovery system was installed at the
site in 1994 to address the elevated ammonia and nitrate levels.
SSC still operates this remediation system and all of the process water is recirculated within the
plant without being discharged. The water is filtered through air scrubbers that use a wet system
that allows the water to be reused in the granulation process. There have been no significant
changes to the system since the last permit renewal package was submitted in 2003. The
effluent pumps were replaced this year and a new extraction well is going to be installed this
month that will replace one of the existing wells.
The Statesville plant does not generate any sludges or solids as a result of their water treatment
process and therefore the plant does not have a sludge management plan.
If you have any questions or need any additional information, please give me a call at 804-281-
1189.

Southern States Cooperative, Inc. Statesville Fertilizer Plant
September 5'h, 2008
NPDES Permit Renewal Application
Lauren N. Barlow
Environmental Project Manager
Cc: Bruce T. Gray — Statesville Fertilizer Plant

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. DENR / Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number
NCOO g4 gal
If you are completing this form in computer use the TAB key or the up - down arrows to move from one
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
sou rn 5b es Gera-1i (Ire c.
5-Wakesvi Iie_ FQr+il;z.ec- ?6.nf
(0(00(0 . Droa c S-re 1
gI crrorict
VA '3(0cc
(goL) agl-ID( /
(gypg) I - 139
V/Q,nce. 0,aSSccop.car-)
2. Location of facility producing discharge:
Check here if same as above ❑
Street Address or State Road
City
State / Zip Code
County
05$a Sa. is\ cy
S-Wcesvi 1(Q
NC QSr? 7
_Iced e I(
3. Operator Information:
Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
. ()un c k\ eQ etnA� kr a+rY,
511 kesleir- Drive- Suii-e 10D
Gar^ ci
arv/;->o. - 75//
( gig) g5g-gg`pg
( gig ) S52 Qgc
4. Ownership Status:
Federal ❑ State El Private
Public ❑
Page 1 of 3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ❑ Other Ammonia, y *Ira1-e 47
ni )-r i -l-
6. Number of separate discharge points: I Outfall.Identification number(s) 001
7. Frequency of discharge: Continuous
If intermittent:
Days per week discharge occurs:
8. Treatment System Design flow D, 01-I MGD
Intermittent ❑
Duration:
zyfvs�d5,
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including
latitude and longitude): OL{� (1 7-N
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
A6%1 f / S adde d Mz //Lcn'nienT SyS leo') .
11. Is this facility located on Indian country? (check one)
Yes ❑ No X(
12. Additional Information
All applicants (including renewals):
➢ A USGS topographical map (or copy of the relevant portion) which shows all outfalls
➢ A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
➢ Engineering Alternative Analysis
➢ Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
➢ If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
➢ A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
➢ For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
➢ For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3 C-GW 05/08

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that'I am familiar with the information contained in the application and that to the
best of my knowledgeand belief such information is true, complete, and accurate.
Cyttio-
Printed naiile of Person Signing Title
gnature'of Applicant Date
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of
the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or
imprisonment not more than 5 years, or both, for a similar offense.)
Page 3 of 3
C-GW 05/08

EXPLANATION
APPROXIMATE LOCATION OF SITE
2000
1000 0
2000
APPROXIMATE SCALE IN FEET _
_
REF: U.S.G.S. 7.5 MINUTE TOPOGRAPHIC MAPS, STATESVILLE EAST, N.C. AND SHEPHERDS, N.C.; BOTH DATED 1969.
LAW
ENGINEERING St ENVIRONMENTAL SERVICES
CHARLOTTE, NORTH CAROUNA
SITE LOCATION
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
PREPARED
„I/
DATE 5/2/0�
CHECKE
DATE
JOB NO,
30150-6-1318
FIGURE
1

878.
/
_,-- Jam. -
/
d
872�85ji'V'
ater •
•
EXPLANATION
* APPROXIMATE LOCATION OF
DISCHARGE
• 878
REF.: U.S.G.S. 7.5 MINUTE TOPOGRAPHIC MAP OF STATESVILLE EAST, N.C. QUADRANGLE DATED 1969.
MACTEC
ENGINEERING & CONSULTING, INC.
CHARLOTTE, NORTH CAROIJNA
DATE
DATE (lb
of
JOB NO.
2000 1000 0
c I
2000
APPROXIMATE. SCALE IN FEET
DISCHARGE LOCATION MAP
SOUTHERN STATES FERTILIZER PLANT
STATESVILLE, NORTH CAROLINA
30150-0-1318
FIGURE

E
e\2003\disaharge.dwg Fri, 10 Sep 2003 — 4:32pm
P:\30140 environmentallobe\I 006\1318\drawl
DISCHARGE PIPE
DISCHARGE
POINT
=
REF.: RECORD OFCONSTRUCTIONPIPING LAYOUT, PREPARED BY CANONIE ENVIRONMENTAL, FIGURE 2, DATED 1-13-94 AND LAST REVISED ON 1-13-95.

EFFLUENT
NPDES PERMIT NO. NC0082821 - DISCHARGE NO. Qf1 MONTH June
FACILITY NAME Southern States Fertilizer Plant CLASS COUNTY Iredell
CERTIFIED LABORATORY (1) Pace Analytical Laboratories. inc. CERTIFICATION NO 12 / 40
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Chris Fay
__.__.-._PERS^v N(u)COLLEC T ING-SAivlrLt S 1-nriS. r ay
CHECK BOX IF ORC HAS CHANGED 0
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
x
(SIGNATURE F OPERATOR IN RESL6jONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
YEAR
2008
GRADE I _ CERTIFICATION NO. 987089 _
ORC PHONE [phone]
NO FLOW / DISCHARGE FROM SITE *
F
Q
o
I=I Operator Arrival Time I
7d1111 Clock
Operator Time
On Site
ORC On Site? **
tei
DAILY *1 t---•
RATE C7 El 5 c
0010 00400 00610 00530
00600
00665
01042
006200 i 00940
1002-0
ENTER
PARAMETER CODE
NAME AND UNITS
RF.I OW
Total Suspended C
Solids
Total Nitrogen
Total Phosphorous
Copper
Nitrate
Chloride
Chronic Toxicity
ABOVE
Y
z
`AZ
z
F
s HBS
Y/B/N
MGD
C
SU
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
MG/L
P/F
1
0.020
2
0.020
3
0.020
• ...
4
0.020
5
1300
1
ti'
0.020
18.7
7.01
1.7
; <2.0 .
` 0,88: •
: 0:12 ° '
<5:0
• ' 42:&
; 27.9
'
6
0.018
7
0.018
.
8
0.018
9
.
0.018
- • • •
_.., .
.
10
0.018
11
0.018
. .
. .
..
, .
12
0.018
13.0850
.
1.0
Y
' 0.01.8
- ..
t..
14
0.018
15
.0.018
_. .
16
0.018
17
-
0.018'
18
0.018
19
093C
1.0
y
0.018
_
20
-
No Flow
21
No- Flow
22
No Flow
23
No Flow
•
24
No Flow
25
No Flow
•
26
.
.
No Flow
-
•
27
No Flow
.
- :
-
28
No Flow
29
No Flow
30
No Flow
,
31
AVERAGE
0.019
18.7
7.01
1.7
<2
0.88
0.12
<5.0
42.8
• 27.9
MAXIMUM
0.020
18.7
7.01
1.7
<2 ..
0488 .
0 [2:::-,.<50
,
42:$' a
27:9 •
MINIMUM
0.018
18.7
7.01
1.7
<2
0.88
0.12
<5.0
42.8
27.9
Comp. (C) / Grab (G)
.
G
G
G
G • :
G ' :
_ G .
G
G'
.'G
G
Monthly Limit
6-9
*
•30
* 7.8 October - April Only
D W Q Foan M R 11 0.1,04 )

Facility Status: (Pleam check one of the follow ing)
A nm onihoring data and sampling frequenciesm eetpenn itraguiran ants
(inaluding w eddy averages, if applicable)
X
Com plzat
. A nm ontoring data and sari piing frequencies do NOT m eetpelm itraguiran tants
- Nonccra_p.rt
The porn ittee d-a3122TOrtto the D iractioror the appropriate Regicnal0 fEice any noncompliance thatpotentially
threatens public health orthe environm ent. Any infant atim a:m.11be pltvided Orally w ilhin 24 hams from the tin e the
perm tee beam e ag me of the crimum dances. A w ritlen sul:m ibn el -lanais° be pvEed. w ittin 5 days of the tin e the
pe2m kiss betxm es aw axe of the cumin stnoes.
If the facility is noncom pliant, p3ea... attach a list of corrective acttn.s being taken and a tin e-table for
in Proven ants to be m ade as required by Part ZEE -6of the N PD ES pen it. _
"I certify; underpenally of law , thatthis c3ocum entand anattachm entsw prepared 'aide= y dinaction °raver -vision
in aCcoidance w 1111 a system designed to ar:z=vrre thatcpali5ecl penettrielproperly gatherand evaluate the Mon atbn
atm B asad on my inquiry of the perm orpensonsWho m angel the system , orthom pereons directly resiconsiole
forgathering the inform ation, the int= aticn sutra lied is, to the bestofm y know ledge and beIief e, acanate, and
corn pkte. I am awaie thatthme aie significantpenalies forattn itting int= aizion, including the possibnity of
fines and in pdsartn entforlmow hung vioitbnp."
y •
PO Box 33366 Raleigh, NC 27636
Christopher M. Fay
Perm thee (Plaam print or type)
Signature of Pemr ithae***
(Requirad un.leas atm itind &a:tonically)
[phone] [e-mail]
. • D ate'
3131/2009
Fern itaseAdins PhaneNurn b em ailaddleas Pena itExpirationD aim
ADDITIONAL CERTIFIED LABORATORIES
C ratified Laboiatory (2) Duncklee & Dunham P.C.
Celli:1.J. Laboratory (3) \ -
'd-i'iti.,eecli,pboiatcyly (4)
C erttied Laboratory (5)
PARAM ETER CODES
Certfficaticn o 5484
Cofi&aitnNo--
Cemd&attnNo.--
Cm:d&mitnNo.
Pam eterC ode assfslance m ay be obtained by caning the N PD ES Unitat [phone] orby visiting the St wf-Arr.
W atm-Piot:action Seceon's w eb site ath2o enr.slatte nc uskr os and linking to the uns intnm ation pages.
Um only units ofm eas.man etidetsignalied in the ikoorting fPf-glity'sNPD ES porn itforiepoiting data.
* N o Fbw ischarge Fran Site: Check thishox ifno diediange occum arui, as a xesak, theme man° data to be
enterad foranof the paran etas on the DM R forthe enter m cnitoring pert& --
ORC On Sire?: 0 RC mustvtfacally and doom entvidation of facility as required pec1.5A NCAC 8G D204.
*** Signature of Pern tire: lEggned by other than the pear tee, then the delegattn of the signatory authority m ustbe an
fW.w ilh. the state perl5A N CA C 2B .0506)J). -
Page 2

aceAnalytical
www.pacela¢S.cam.
June 17, 2008
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
Pace Analytical Services, Inc.
9800 Kinney Ave. Suite 100
Huntersville, NC 28078
[phone]
Mr. Chris Fay
.Duncklee & Dunham
P.O. Box 33366
Raleigh, NC 27636
RE: Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
Dear Mr. Fay:
Enclosed are the analytical results for sample(s) received by the laboratory on June 06, 2008. The
results relate only to the samples included in this report. Results reported herein conform to the
most current NELAC standards, where applicable, unless otherwise narrated in the body of the
report.
Inorganic Wet Chemistry and Metals analyses were performed at our Pace Asheville laboratory and
Organic testing was performed at our Pace Huntersville laboratory unless otherwise footnoted. All
Microbiological analyses were performed at the laboratory where the samples were received.
If you have any questions concerning this report, please feel free to contact me.
Sincerely,
Kevin Herring
[e-mail]
Project Manager
Enclosures
REPORT OF LABORATORY ANALYSIS Page 1 of 19
. This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
1 „ I.CCCy

aeAnaIyticaI e
www.pacelabs.com
Piuja&t. --"------33-ST".".T ESVIEP- FERT coon^._.
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
CERTIFICATIONS
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Charlotte Certification IDs
Florida/NELAP Certification Number: E87627
Kansas Certification Number: E-10364
Louisiana/LELAP Certification Number: 04034
North Carolina Drinking Water Certification Number: 37706
North Carolina Wastewater Certification Number: 12
North Carolina Field Services Certification Number: 5342 -
South Carolina Certification Number: 990060001
South Carolina Bioassay Certification Number: 990060003
Tennessee Certification Number: 04010
Virginia Certification Number: 00213
Asheville Certification IDs
Florida/NELAP Certification Number: E87648
Louisiana/LELAP Certification Number: 03095
New Jersey Certification Number: NC011
North Carolina Drinking Water Certification Number: 37712
North Carolina Wastewater Certification Number: 40
North Carolina Bioassay Certification Number: 9
Pennsylvania Certification Number: 68-03578
South Carolina Certification Number: 99030001
South Carolina Bioassay Certification Number: 99030002
Tennessee Certification Number: 2980
Virginia Certification Number: 00072
Eden Certification IDs
North Carolina Drinking Water Certification Number: 37738
Virginia Drinking Water Certification Number: 00424
North Carolina Wastewater Certification Number: 633
REPORT OF LABORATORY ANALYSIS'
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
q`tt \ ..A\R=
Page 2 of 19

aceAnalytical
www.pacelapscom
riujeC%
SS STATES ILLE-PERT n9nn---
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
Pace Analytical Services, Inc.
9800 IGnceyAve. Suite 100
Huntersville, NC 28078
[phone]
Method: . EPA 200.7
Description: 200.7 MET ICP
Client:_ Duncklee & Dunham
Date: June 17, 2008
General Information:
1 sample was analyzed for EPA 200.7. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Sample Preparation:
The samples were prepared in accordance with EPA 200.7 with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 3 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
,.cco,,o�

aceAnalytical�
vr# w.pacelabs.corn:
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 26804
[phone]
PROJECT NARRATIVE
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Method: 40CFR PART 503
Description: Total Nitrogen Calculation
Client: Duncklee & Dunham
Date: June 17, 2008
General Information:
1 sample was analyzed for 40CFR PART 503. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
.The samples were analyzed within the method required hold times with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 4 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
ifie tac]=

e.
'aceAnalytical
mvvpacelabs:cmn
Project: Sa a IHi cavILLr= rERT ou�uu
Pace Project No.: 9220953
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
2225 Riverside Dr. 9800 kinceyAve. Suite 100
Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone]
PROJECT NARRATIVE
Method: SM 2540D
Description: 2540D Total Suspended Solids
Client: Duncklee & Dunham
Date: June 17, 2008
General Information:
1 sample was analyzed for SM 2540D. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Method Blank: •
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 5 of 19
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc..
[LLGJfri�J

e
aceAnalytical
www.pacelaJs.com.
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
2225 Riverside Dr. 9800 KinceyAve. Suite 100
Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone]
PROJECT NARRATIVE
Method: ' EPA 350.1
Description: 350.1 Ammonia
Client: Duncklee & Dunham
Date: June 17,2008
General. Information: -
1 sample was analyzed for EPA 350.1. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
•
Continuing Calibration: All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analyzes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes: All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
Duplicate Sample: _-
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 6 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
Ifiekc

aceAnalytical
vmavpa eIabs,com
Project: SS STATESVILEFLRI bu2~uu
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Method: EPA 351.2
Description: 351.2 Total Kjeldahl Nitrogen
Client: Duncklee & Dunham
Date: June 17, 2008
General Information:
1 sample was analyzed for EPA 351.2. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/2823
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 9220679001,9220929008
M1: Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
• MS (Lab ID: 126393)
• Nitrogen, Kjeldahl, Total
• MS (Lab ID: 126401)
• Nitrogen, Kjeldahl, Total
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
QC Batch: WETA/2823
R1: RPD value was outside control limits.
• DUP (Lab ID: 126394)
• Nitrogen, Kjeldahl, Total
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 7 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
„ �cee•e

aceAnalyticall3
wwwpacelabs com:
Rrojact:_._m- _ SS STAT_ESVILLEEERL50200..
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Method: EPA 353.2
Description: 353.2 Nitrogen, NO2/NO3 unpres
Client: Duncklee & Dunham
Date: June 17, 2008
General Information:
1 sample was analyzed for EPA 353.2. All samples were received in acceptable condition with any exceptions noted below._
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
- Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/2808
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 9220998002,9221002002
MO: Matrix spike recovery was outside laboratory control limits.
• MS (Lab ID: 125369)
_Nitrogen, Nitrate
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 8 of 19
This report shall not be reproduced, except In full,
without the written consent of Pace Analytical Services, Inc..

www.pacelabs.cem:
Project: — SS
SS STATESVILLETERT5uzu0
Pace Project No.: 9220953
Method: EPA 365.1
Description: 365.1 Phosphorus, Total
Client: Duncklee & Dunham
Date: June 17, 2008
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
2225 Riverside Dr. 9800 Kincey Ave. Suite 100
Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone]
PROJECT NARRATIVE
General Information:
1 sample was analyzed for EPA 365.1. All samples were received in acceptable condition with any exceptions noted below.
Hold Time: -
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
• Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/2816
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 9220789001,9220994001
M1: Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
• MS (Lab ID: 125791)
• Phosphorus
• MS (Lab ID: 125793)
• Phosphorus -
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
REPORT OF LABORATORY ANALYSIS Page 9 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
clue;:

aeeAnalytical e
wampacelabs,cam
--.--.—Project. — _—SS STATESVILILE PERT n'nn—
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
PROJECT NARRATIVE
Pace Analytical Services, Inc.
9600 Kincey Ave: Suite 100
Huntersville, NC 28078
[phone]
Method: SM 4500-CI-E
Description: 4500 Chloride
Client: Duncklee & Dunham
Date: June 17, 2008
General Information: •
1 sample was analyzed for SM 4500-CI-E. All samples were received in acceptable condition with any exceptions noted below.
Hold Time:
The samples were analyzed within the method required hold times with any exceptions noted below.
Initial Calibrations (including MS Tune as applicable):
All criteria were within method requirements with any exceptions noted below.
Continuing Calibration:
All criteria were within method requirements with any exceptions noted below.
Method Blank:
All analytes were below the report limit in the method blank with any exceptions noted below.
Laboratory Control Spike:
All laboratory control spike compounds were within QC limits with any exceptions noted below.
Matrix Spikes:
All percent recoveries and relative percent differences (RPDs) were within acceptance criteria with any exceptions noted below.
QC Batch: WETA/2814
A matrix spike and matrix spike duplicate (MS/MSD) were performed on the following sample(s): 9220947001
MO: Matrix spike recovery was outside laboratory control limits.
• MS (Lab ID: 125742)
• Chloride -
Duplicate Sample:
All duplicate sample results were within method acceptance criteria with any exceptions noted below.
Additional Comments:
This data package has been reviewed for quality and completeness and is approved for release.
REPORT OF LABORATORY ANALYSIS Page 10 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
�r�

accAnalytical m •
www.paceJabs•com
Project: SS STATESVILLE FERT50200
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
ANALYTICAL RESULTS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Sample: EFF060508
Parameters
Lab ID: 9220953001 Collected: 06/05/08 13:20 Received: 06/06/08 13:30 Matrix: Water
Results Units Report Limit DF Prepared Analyzed CAS No. Qual
200.7 MET ICP
Copper
2540D Total Suspended Solids
Total Suspended Solids
Total Nitrogen Calculation
Nitrogen
350.1 Ammonia
Nitrogen, Ammonia
351.2 Total Kjeldahl Nitrogen
Nitrogen, Kjeldahl, Total
353.2 Nitrogen, NO2/NO3 unpres
Nitrogen, Nitrate
365.1 Phosphorus, Total
Phosphorus
4500 Chloride
Chloride
Date: 06/17/2008 09:13 AM
Analytical Method: EPA 200.7 Preparation Method: EPA 200.7
ND ug/L 5.0 1 06/10/08 10:45 06/11/08 14:00 7440-50-8
Analytical Method: SM 2540D
ND mg/L 2.0 1 06/11/08 19:46
Analytical Method: 40CFR PART 503
43.7 mg/L 0.20 1 06/16/08 10:53 7727-37-9
Analytical Method: EPA 350.1
1.7 mg/L 0.10 1
Analytical Method: EPA 351.2
0.88 mg/L
Analytical Method: EPA 353.2
42.8 mg/L
Analytical Method: EPA 365.1
•
0.12 mg/L
Analytical Method: SM 4500-CI-E
27.9 mg/L
0.50 1
0.50 5
0.10 1
10.0 2
REPORT OF LABORATORYANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
N ACCOAO
06/09/08 20:41 7764-41-7
06/11 /08 19:02 7727-37-9
06/07/08 09:06
06/09/08 22:13 7723-14-0
06/09/08 16:00 16887-00-6
Page 11 of 19

(eAna(YticaI
wir&pacelabs.canr:
_ YITJf eL:L: SSSSTAIGSViLLC FER1 oucuu
Pace Project No.: 9220953
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
2225 Riverside Dr. 9800 Kincey Ave. Suite 100
Asheville, NC 28804 Huntersville, NC 28078
[phone] [phone]
QUALITY CONTROL DATA
QC Batch: WETA/2808 Analysis Method: EPA 353.2
QC Batch Method: EPA 353.2 Analysis Description: 353.2 Nitrate + Nitrite, Unpres.
Associated. Lab Samples: 9220953001
METHOD BLANK: 125365
Associated Lab Samples: 9220953001
Blank Reporting
Parameter Units Result Limit Qualifiers
Nitrogen, Nitrate - mg/L ND 0.10
LABORATORY CONTROL SAMPLE: 125366
Parameter
Units
Spike LCS LCS % Rec
Conc. Result % Rec .Limits Qualifiers
Nitrogen, Nitrate- mg/L 5 5.3 107 90-110
MATRIX SPIKE SAMPLE: 125367
9220998002 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Nitrogen, Nitrate mg/L ND 5 5.7 115 90-110
MATRIX SPIKE SAMPLE: 125369
9221002002 Spike MS MS % Rec
Parameter . Units Result -Conc. Result % Rec Limits- Qualifiers
Nitrogen, Nitrate mg/L; - 3.7 - 5 9.1 108 90-110 MO
SAMPLE DUPLICATE: 125368
Parameter
Units
9220998004 Dup
Result Result RPD Qualifiers
Nitrogen, Nitrate
mg/L. ND ND 0
SAMPLE DUPLICATE: 125370
9221002001 Dup
Parameter Units Result Result RPD Qualifiers
Nitrogen, Nitrate - -- mg/L 5.3 5.3 0
Date: 06/17/2008 09:13 AM
REPORT OF LABORATORY ANALYSIS Page 12 of 19
This report shall not be reproduced, except In full, -
without the written consent of Pace Analytical Services, Inc..
ACCCA

aceAnalytical
wwwpacetabs com.
Pace Analytical Services, Inc:
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Project: SS STATESVIELE FERT 50200
Pace Project No.: 9220953 -
Pace Analytical Services, Inc.
9800 IGncey Ave. Suite 100
Huntersviile, NC 28078
[phone]
QC Batch: WETA/2814 -. Analysis Method: SM 4500-CI-E
QC Batch Method: SM 4500-CI-E Analysis Description: 4500 Chloride
Associated Lab Samples: 9220953001
METHOD BLANK: 125740
Associated Lab Samples: 9220953001
Blank Reporting
Parameter Units Result Limit Qualifiers
Chloride mg/L ND 5.0
LABORATORY CONTROL SAMPLE: 125741
Parameter •
Spike LCS LCS % Rec
Units Conc.. Result % Rec Limits Qualifiers
- Chloride mg/L 20 20.7 104 90-110
MATRIX SPIKE SAMPLE: 125742
Parameter
9220947001 Spike MS MS % Rec
Units Result Conc. Result % Rec Limits Qualifiers
Chloride mg/L 92.2 20 99.8 38 75-125 MO
SAMPLE DUPLICATE: 125743
9220953001 Dup
Parameter Units Result Result RPD Qualifiers
Chloride mg/L " 27.9 28.7
Date: 06/17/2008 09:13 AM
REPORT OF LABORATORY ANALYSIS Page 13 of 19
This report shall not be reproduced, except in full, -
without the written consent of Pace Analytical Services, Inc..

aeAnalytical
!www.pacelabs,com
'"�P(OJeCr:�� J' '-4Y.7.7 j IHI tjVILLC FEE Dtmuu
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
QC Batch: WETA/2816 Analysis Method: EPA 365.1
QC Batch Method: EPA 365.1 Analysis Description: 365.1 Phosphorus, Total
Associated Lab Samples: 9220953001
METHOD BLANK: 125789
Associated Lab Samples: 9220953001
Blank Reporting -
Parameter Units Result Limit
Qualifiers
Phosphorus mg/L - - ND 0.10
LABORATORY CONTROL SAMPLE:. 125790
Spike LCS LCS %a Rec
Parameter Units Conc. Result % Rec Limits Qualifiers
Phosphorus mg/L 1 1.0 104 90-110
MATRIX SPIKE SAMPLE: 125791
Parameter
Units
9220994001 Spike MS MS % Rec
Result Conc. Result % Rec . • Limits Qualifiers
Phosphorus- - mg/L 6.7 1 7.6 86 90-110 M1
MATRIX SPIKE SAMPLE: 125793
9220789001 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Phosphorus
mg/L
0.93 1 1.8 87 90-110 M1
SAMPLE DUPLICATE: 125792
9220994002 Dup
Parameter Units Result Result ' RPD Qualifiers
Phosphorus -- mg/L 0.57 0.56 1
- SAMPLE DUPLICATE: 125794
Parameter
9220808002 Dup
Units Result Result RPD Qualifiers
Phosphorus
Date: 06/17/2008 09:13 AM
mg/L • 2.8 2.9 3
REPORT OF LABORATORY ANALYSIS Page 14 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
M �eeaq
Iiftekat

•
aceAnalyticale
vww. pacelabs.cp m
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALITY CONTROL DATA
Pace Analytical Services, Inc.
9800 IGncey Ave. Suite 100
Huntersville, NC 28078
[phone]
Project: SS STATESVILLE FERT 50200 -
Pace Project No.: 9220953
QC Batch: WETA/2817
QC Batch Method: EPA 350.1
Associated Lab Samples: 9220953001
Analysis Method:
Analysis Description:
EPA 350.1
350.1 Ammonia
METHOD BLANK: 125803
Associated Lab Samples: 9220953001
Blank Reporting
Parameter Units Result Limit Qualifiers
Nitrogen, Ammonia mg/L ND 0.10
LABORATORY CONTROL SAMPLE: 125804
Spike LCS ' LCS % Rec
Parameter Units Conc. Result % Rec Limits Qualifiers .
Nitrogen, Ammonia mg/L 5 5.0 -- 100 90-110
MATRIX SPIKE SAMPLE: 125805
9221033001 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Nitrogen, Ammonia mg/L 4.7 5 9.6 97 90-110
MATRIX SPIKE SAMPLE: 125807
9220607002 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits
Qualifiers
Nitrogen, Ammonia mg/L ND 5 4.7 94 90-110
SAMPLE DUPLICATE: 125806
9221033002 Dup
Parameter - Units Result Result RPD Qualifiers
Nitrogen, Ammonia
mg/L 17.1 17.0 .4
SAMPLE DUPLICATE: 125808
9220612001 Dup
Parameter Units Result . Result RPD Qualifiers
Nitrogen, Ammonia
Date: 06/17/2008 09:13 AM
mg/L 2.2 2.2 3
REPORT OF LABORATORY ANALYSIS Page 15 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
p �CCCyC

/%AnaIyflcaI
/ www.pace/abs,com
I
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
QUALITY CONTROL DATA
[phone]
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
QC Batch: MPRP/2498 Analysis Method: EPA 200.7
QC Batch Method: EPA 200.7 Analysis Description: 200.7 MET
Associated Lab Samples: 9220953001
METHOD BLANK: 125854
Associated Lab Samples: 9220953001
Parameter
Units
Blank Reporting
Result Limit Qualifiers
Copper ug/L ND
5.0
LABORATORY CONTROL SAMPLE: 125855
Parameter
Spike LCS LCS % Rec
Units Conc. Result % Rec Limits Qualifiers
Copper
ug/L
500 485 97 85-115
MATRIX SPIKE SAMPLE: 125856
9220640002 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Copper ug/L 7.1 500 449 88 70-130
SAMPLE DUPLICATE: 125857
9220947001 Dup
Parameter, Units Result Result RPD Qualifiers
Copper ug/L - ND 2.1J
Date: 06/17/2008 09:13 AM
REPORT OF LABORATORY ANALYSIS Page 16 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

aceAnalytical
www.pacelabs.cam
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
Pace Analytical Services, Inc. Pace Analytical Services, Inc.
2225 Riverside Dr. 9800 KinceyAve. Suite 100
Asheville, NC 28804 , Huntersville, NC 28078
[phone] [phone]
QUALITY CONTROL DATA
QC Batch: WETA/2823
QC Batch Method: EPA351.2
Associated Lab Samples: 9220953001
Analysis Method:
Analysis Description:
EPA 351.2
351.2 TKN
METHOD BLANK: 126391
Associated Lab Samples: 9220953001
Blank Reporting
Parameter Units Result Limit Qualifiers
Nitrogen, Kjeldahl, Total mg/L ND
0.50
LABORATORY CONTROL SAMPLE: 126392
Parameter
Units
Spike LCS LCS % Rec
Conc. Result — % Rec Limits Qualifiers
Nitrogen, Kjeldahl, Total mg/L 5 4.9 97 90-110
MATRIX SPIKE SAMPLE: 126393
Parameter
Units
9220929008 Spike MS MS % Rec
Result Conc. Result % Rec Limits Qualifiers
Nitrogen, Kjeldahl, Total
mg/L 0.54 5 • 4.8 85 90-110 M1
MATRIX SPIKE SAMPLE: 126401
9220679001 Spike MS MS % Rec
Parameter Units Result Conc. Result % Rec Limits Qualifiers
Nitrogen, Kjeldahl, Total-=- --- mg/L 1.2 5 4.0 56 90-110 M1
SAMPLE DUPLICATE: 126394
9220929009 Dup -
-
Parameter Units Result Result RPD Qualifiers
Nitrogen, Kjeldahl, Total
mg/L 1.4 0.99 32 R1
SAMPLE DUPLICATE:. 126396
9220663005 Dup
Parameter Units Result Result RPD Qualifiers
Nitrogen, Kjeldahl, Total
Date: 06/17/2008 09:13 AM
mg/L 775 788 2
REPORT OF LABORATORY ANALYSIS._ Page 17 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

/eAnaIytici
wwixpgcelaha com
Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC'28804
[phone]
QUALITY CONTROL DATA
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
QC Batch:
WET/4290 Analysis Method: SM 2540D
QC Batch Method: SM 2540D . Analysis Description: 2540D Total Suspended Solids
Associated Lab Samples: 9220953001
METHOD BLANK: 126850
Associated Lab Samples: 9220953001
Parameter
Total Suspended Solids mg/L =
ND 1.0
LABORATORY CONTROL SAMPLE: 126851
Spike LCS LCS % Rec
Limits Qualifiers
Parameter _ Units . Conc. Result % Rec
Total Suspended Solids
mg/L 250 . 204 82. _ 80-120
Blank Reporting -
Result Limit Qualifiers
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone]
Units
SAMPLE DUPLICATE: 126852 '
9220953001 " Dup
Parameter Units
Result - Result - RPD Qualifiers
ND ND 0
Total Suspended Solids mg/L
SAMPLE DUPLICATE: 126853
Parameter
Total Suspended Solids mg/L
Date: 06/17/2008 09:13 AM
9220916001 Dup Qualifiers --
Units Result— Result RPD
368 • 370 - • .5 -
REPORT OF LABORATORY ANALYSIS Page 18 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..
``

Pace Analytical Services, Inc.
2225 Riverside Dr.
Asheville, NC 28804
[phone]
QUALIFIERS
Pace Analytical Services, Inc.
9800 Kincey Ave. Suite 100
Huntersville, NC 28078
[phone],
Project: SS STATESVILLE FERT 50200
Pace Project No.: 9220953
DEFINITIONS
DF - Dilution Factor, if reported, represents the factor applied to the reported data due to changes in sample preparation, dilution of
the sample aliquot, or moisture content. - -
ND - Not Detected at or above adjusted reporting limit.
3 - Estimated concentration above the adjusted method detection limit and below the adjusted reporting limit.
MDL-Adjusted Method Detection Limit.
S - Surrogate
1,2-Diphenylhydrazine (8270 listed analyte) decomposes to Azobenzene.
Consistent with EPA guidelines, unrounded data are displayed and have been used to calculate % recovery and RPD values.
LCS(D) - Laboratory Control Sample (Duplicate) _
MS(D) - Matrix Spike (Duplicate)
DUP - Sample Duplicate
RPD - Relative Percent Difference
NC - Not Calculable. -
Pace Analytical is NELAP accredited. Contact your Pace PM for the current list of accredited analytes.
ANALYTE QUALIFIERS
MO Matrix spike recovery was outside laboratory control limits. ,__
M1 Matrix spike recovery exceeded QC limits. Batch accepted based on laboratory control sample (LCS) recovery.
R1 RPD value was outside control limits. -
Date: 06/17/2008 09:13 AM
REPORT OF LABORATORY ANALYSIS Page 19 of 19
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc..

rceAnalytital'
Section A
Required Client Information:
CAApany,
J etc,
SSBoc 333Gf
S2a-\eh�
-a7I6'3C
pima �S�vf
911'3Sg�
t % cR q
Requested Due Date/TAT:
H'
Section B
Required Protect Information: -
Re ort To:
Copy To:
Purchase Order No.: -
Project Number: �6rb
Section D Required- lient Information MATR X CODE
Valid Matrix Codes
DRINKING WATER DW
SAMPLE ID WASTE WATER WSW
PRODUCT P
SOIUSOLID SL One Character per box. - OIL OL
(A-Z. 0-9 / A• WIPE WP
Samples IDs MUST BE UNIQUE. AIR
RHER AR
TISSUE TS
F
0
6
Additional Comments:
0
5-
SEE REVERSE SIDE FOR INSTRUCTIdNS
co
w
S
,x
1
sxr
CHAIN -OF -CUSTODY / Analytical Request Document
The Chain -of -Custody is a LEGAL DOCUMENT. All relevant fields must be completed accurately.
Section C
Invoice Information:
Attention:
Company Name:_
Address:
Pace. Quote Reference:
Pace Project Manager.
Pace Prof le#:
vZiO—o�
NPDES
ST
Page: of
894835
REGULATORY AGENCY
❑ GROUND WATER ❑ DRINKING WATER
❑ RCRA
0 Other -
SITE LOCATION
DOA OIL , ❑IN ❑MI ❑MNJC
0OH ❑SC. ❑WI POTHER
pWO
U
w�?
G
COLLECTED
COMPOSITE START
COMPOSITE END/GRAB
DATE
TIME
DATE
RELINQUISHED BY / AFFIL ATION
TIME '
►3Zo
DATE
ao
J
o•o
U
co
it
OZ
48z
U
Preservatives
• Requested -
Analysis•
Unpreserved
3
x
Z
0
z
x
x
x
0
Z
0
co
Z
0
2
X
x
TIME ACCEPTED BY / AFFILIATION
3 30 �'i����.�
13336
SAMPLER NAME AND SIG►IATURE
PRINT Name of SAMPLEe�u
SIG TUBE of)/1P E
f
DATE TIME
I DATE Signed. 1(MM,( DD / YY1
/.536
ace Project Number
Lab I.D
WO% Ob1
SAMPLE CONDITION
J
cp
•>-

/
ceAralyticaf
641-ak...
Courier: x 0 UPS 0 USPS ❑Client• ❑ Commercial Pace Other
Custody. Seal on Cooler/Box Present: ❑ yes K no Seals intact: ❑ yes A no
Packing Material: ❑ Bubble Wrap ❑Bubble Bags None ❑Other
Client Name:`) /cL Puo✓ Project # ` q>"?-01.C3
Thermometer Used T060
r
Type of lceifWe) Blue None
40014,narr=.
Samples on ice, cooling process has begun
Cooler Temperature • �.
p -t
t—.0-
Biological Tissue is. Frozen: Yes Noel
Comments:
Date and Initi
contents/;
of pers amining
15 attg
Temp should be above freezing to 6'C
Chain of Custody Present:
Oyes ❑No ❑N/A
1: -
.
Chain of Custody Filled Out:
VgYes ❑No . ❑N/A
2:
_
Chain of Custody Relinquished:
/Yes ❑No ❑N/A
3.
•
Sampler Nahie & Signature on COC:
`0Yes ❑No , ❑N/A
4.
Samples Arrived within Hold Time:
VJYes ❑No ❑N/A
5.
Short Hold Time Analysis
Yes ❑No ❑N/A
6.
Rush Turn Around Time Requested:
/❑Yes No ❑N/A
7. -
Sufficient Volume: . ,
0Yes ❑No ❑N/A
8.
Correct Containers Used:
-Pace Containers Used:
11Yes . ❑No ❑N/A
OYes ❑No• ❑N/A
g.
•
Containers_ Intact:
¢/Yes -❑No ❑N/A
10. •
Filtered volume received for Dissolved tests
❑Yes ❑No l N/A
11.
Sample Labels match COC:
-Includes date/time/ID/Analysis Matrix:
¢Yes ❑No ❑N/A
12.
All containers needing preservation have been checked...
All containers needing preservation are found to be in
compliance with EPA recommendation.
exceptions: VOA, coliform, TOC, O&G; WI-DRO (water)
-
�Yes_❑No ❑N/A
rnYes ❑No ❑N/A
T
❑Yes ❑No
13.
- •
•
Initial when completed
Samples checked for dechlorination:
' If Yes •❑No ❑N/A
14.
Headspace in VOA Vials (>6mm):
DYes ❑No IXIN/A
15.
Trip Blank Present:
Trip Blank Custody Seals Present
Pace Trip Blank Lot # (if purchased): " N/A
.. ❑Yes ❑No . t71N/A
❑Yes ❑No 7N/A
16.
•
Client Notification/ Resolution:
Person Contacted:
Comments/ Resolution:
Date/Time:
Field Data Required? Y / N / . N/A
Project Manager Review:
Date:. /..-?-"A;;
IAn.w owe iMese. rl.e•nr It nffenit..n Aln•41, r`srnlInn nnrnnl:nr.ne enrnnlee nnn.. of ihte'rnrrn will Fie'edn4 M the Alnrth Mrnlinm r I-lMP

Permit NC0085731
If the test procedure performed as the first test of any single quarter results in a
failure or ChV below the permit limit, then multiple -concentration testing shall be
performed at a minimum, in each of the two following months as described in "North
Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure" (Revised -December
2010) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the
Effluent Discharge Monitoring Form (MR-1) for the months in which tests were performed,
using the parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value.
Additionally, DWR Form AT-3 (original) is to be sent to the following address:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, NC 27699-1623
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no. later
than 30 days after the end of the reporting period for which the report is made.
(Test data shalt be complete, .accurate —include all stipportifig chemical : h sicafl
Crneasurements an'd all concentration%response data,'and be certified by laboratory
(supe isor and ORC or approved desigaaie signature __Total residual chlorine of Slw,,effinenti
tom c ty sample must -be wmeasuredj6ii-dxeported.ifchlorine is`employed for--._disinfedtiti ofthe ;
t waste strew.
Should there be no discharge of flow from the facility during a. month in which toxicity
monitoring is required, the permittee will complete the information located at the top of the
aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,
county, and the month/year of the report with the notation of "No Flow" in the comment area
of the form. The report shall be submitted to the Water Sciences Section at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
based on the toxicity testing quarter, which is the three month time interval that begins on
the first day of the month in which toxicity testing is required by this permit and continues
until the final day of the third month.
Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Resources indicate potential impacts to the receiving stream, this
permit may be re -opened and modified to include alternate monitoring requirements or
limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as
minimum control organism survival, minimum control organism reproduction, and
appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.
Page 4 of 6

Nitrate Removal by Ion Exchange 1 The Solutions Source of the Water & Wastewater Ind... Page 1 of 4
search...
o Newsletters
o Subscribe
o Advertise
o Contact
eVOQUA lirm ansforingWater. Enriching Life look..
WATER TECHNOLOGIES`
o Current Issue
o Products
o Storefronts
o Top Projects
o Webinars
o Events
o White Papers
o Tech Reviews
o Archives
o Buyer's Guide
o Industrial
o Membranes
o Pumps
o Meters
o Pipes
°. Energy
o Small Systems
Nitrate Removal by Ion Exchange
Francis J. DeSilva, ResinTech, Inc. Facebook Twitter Google Plus Linkedln
Thu, 2003-03-27 14:03
Nitrates have no detectable color, taste or smell at the concentrations involved in drinking water supplies, and they do
not cause discoloration of plumbing fixtures, so they remain undetectable to our senses. Nitrate removal processes
must be either foolproof or include extensive monitoring of the treated water to detect breakthrough or determine the
need for regeneration. Nitrates in concentrations above 10 ppm expressed as N" (this can be expressed as 35.7 ppm
as calcium carbonate or 44.3 ppm as nitrate) are considered unsafe. Nitrates have no detectable color, taste or smell
at the
concentrations involved in drinking water supplies, and they do not cause discoloration of plumbing fixtures, so they
remain undetectable to our senses.
Nitrates do not interfere in non -potable domestic uses such as laundering. Therefore, nitrate removal processes must
be either foolproof or include extensive monitoring of the treated water to detect breakthrough or determine the need
for regeneration.
Infants are particularly susceptible to nitrates because their digestive systems do not operate in the exact same
manner as adults. Nitrates are converted by bacteria in the stomach of infants to toxic nitrites. At levels that would not
cause harm to adults, nitrates can cause methemoglobinemia in infants, a condition also known as "blue baby'
syndrome.
Nitrates present in a water supply can be a symptom of other contaminants in that source of water. Have a full public
health analysis performed on waters being considered for treatment. Disinfection may be necessary to counter other
health concems.
Sources of Nitrates
There are both natural and man-made sources of nitrates in groundwater. The main source of nitrate contamination
appears to be from agricultural operations, farm runoff and fertilizer usage. There also is some nitrate formed in the
atmosphere by oxidation of nitrogen oxides that are emitted from power plants and intemal combustion engines. One
other man-made source is industrial corrosion inhibitors that have leaked into the ecosystem.
Naturally occurring nitrate can result from a combination of nitrogen and oxygen through electrical discharges
(lightning). Also, nitrate is formed by Nitrobacter bacteria by oxidation of nitrites.
Resin Treatment Choices
Standard anion resins. The two types of standard resins commonly used for nitrate removal today are Type 1 and Type
2 strongly basic anion exchange resins. The Type 1 resin derives its ion exchange capabilities from the trimethylamine
group. The Type 2 resin derives its functionality from the dimethylethanolamine group. The relative order of affinity for
the three most common ions in drinking water compared to nitrates is
Sulfate> Nitrate> Chloride> Bicarbonate
Figure 1 a illustrates a breakthrough curve for a type 2
anion resin treating a water containing nitrates.
Selective resins.
The term "nitrate selective" refers to resins that retain nitrates more strongly than any other ions including sulfates. A
variety of functional groups can and have been placed into anion exchange resins that are nitrate selective. Most of
these resins are similar to the Type 1 resins, but they have larger chemical groups on the nitrogen atom of the amine
than the methyl groups that comprise a Type 1 resin. The larger size of the amine groups makes it more difficult for
divalent ions such as sulfates to attach themselves to the resin. This reorders the affinity relationships so that nitrate
has a higher affinity for the resin than sulfates even at drinking water concentrations. The affinity relationship for nitrate
selective resins in drinking water is
Nitrate > Sulfate > Chloride > Bicarbonate
A fair number of nitrate -selective resins have been synthesized, but only two are available commercially —the
tributylamine and triethylamine types. Although both the tributylamine and triethylamine resins are approved by most
European countries for potable water applications, they are not listed by FDA.
Generally speaking, nitrate selective resins have from 10 to 100 times higher relative affinities for nitrates against
sulfates than the standard resins. Because of this, it is the sulfate ion that would be "dumped." The phenomenon
known as "dumping" occurs when nitrate concentration in the treated water exceeds the concentration in the raw water.
When a nitrate selective resin is run past the point of exhaustion, the nitrate concentration of the treated water will not
rise past the concentration in the raw water.
Each of the two types of nitrate selective resin has its own advantages, depending on the application. The triethlyamine
structure, because of its smaller size, yields a resin with a higher operating capacity than the tributylamine type.
"ORVAL:CA
Automatic Watengiftratism Systems
1 aN cal tt[S ? t� a�•
i
4
WATE ML1ERS
Related Articles
Technology & Thank -You Notes
Students of the old school, cover your eyes. We've
seen the future of the water industry, and it's a
techie. Well, increasingly so, at least....
Fewell's Focus: Markets & Bold Action
As Eleanor Roosevelt once quipped, "Great minds
discuss ideas; average minds discuss events; small
minds discuss people.' This article by design will...
Editor's Focus: Internet of Things
Dubbed the first installation of its kind in the country
by the Nevada Center for Excellence, a new leak
etection system in Las Vegas is a...
MORE ARTICLES
Highly Versatile Laboratory
TOC Analyzers
Fast, sensitive
analysis of a wide
range of aqueous
samples
11/1(1/1111C'

Nitrate Removal by Ion Exchange I The Solutions Source of the Water & Wastewater Ind... Page 2 of 4
However, the tributylamine may provide lower chemical operating costs in large systems when regenerant use is
minimized through brine reclamation schemes.
Perchlorates & Technicium
The nitrate selective resins are designed to be sulfate "deselective" and, therefore, favor the removal of nitrates. These
same sulfate de -selective resins are finding favor in other specialty applications that need to minimize the impact of
sulfate and other anions on the removal capacity. Two applications that are receiving a lot of attention today are the
removal of perchlorate and technicium, both of which can pose serious health threats by contaminating groundwaters.
Perchlorate is a byproduct of rocket propellant manufacturing and has been detected in the groundwater in more than
30 states. Technicium is a radioactive isotope that appears in the wastewater from some nuclear operations.
Nitrate Dumping
The Type 1 and Type 2 resins are considered non -selective because of their greater affinity for sulfates. If a normal
Type 1 or Type 2 resin is run past the end of the normal nitrate removal service cycle, sulfates can continue to load
onto the resin bed, pushing the nitrates off and causing dumping. (See Figure la.)
When dumping occurs, the concentration of nitrates in the treated water can approach the sum of the concentrations of
both the sulfates and nitrates in the raw water. In a water containing 80 ppm of nitrates as calcium carbonate and 85
ppm of sulfates as calcium carbonate, overrunning the unit will cause nitrate levels to rise until they approach 165 ppm
as calcium carbonate. Nitrate selective resins prevent this from occurring. (See Figures 1b and lc.) In the event of a
service overrun with the nitrate selective resin, the highest nitrate level that can appear in the effluent is equal to the
nitrate level in the influent.
Resin Certification
The standard Type 1 and Type 2 resins are listed by the U.S. Food and Drug Administration (FDA) for potable water
applications in the USA.
Although both the tributylamine and triethylamine resins are approved by the equivalent of the FDA organizations in
essentially all European countries for potable water applications, they are not currently listed by the United States FDA.
Only one or more brands of nitrate selective resin (triethylamine functionality) have been certified by the Water Quality
Association's (WQA) Gold Seal Program. Ask your resin supplier to provide you with copies of the certification.
Operation
The ion exchange process for the removal of nitrates is both simple and effective. It operates in the same manner as a
common water softener and easily can remove much more than 90 percent of the nitrates. The process uses a strong
base anion exchange resin, which is regenerated with common salt. The chloride (CI) ion of the salt molecule is utilized
by the anion exchange site, the sodium (Na) ion passes right through the resin bed and does not affect the process.
Operational Guidelines
The anion resins used in nitrate removal applications are regenerated with ten percent brine at a dosage of about ten
pounds per cubic foot. The service flow rate can be between two and four gallons per minute per cubic foot. A
minimum resin bed depth of 30 inches is recommended, 36 inches is preferred.
In many respects, the operation of a nitrate removal unit is similar to an ordinary softener. The biggest difference during
regeneration is the backwash rate. The anion resins are less dense and require a backwash flowrate about half that of
softening resin.
In some household applications, nitrate removal is used solely for drinking and cooking purposes. This reduces the
volume demand substantially, in some cases to the point that small POU throwaway filter cartridges can be used
instead of the larger regenerable systems. Cartridges always should be filled with the nitrate selective resins to avoid
nitrate dumping.
Type 1 and Type 2 strongly basic anion resins have high affinities for nitrates and are easily regenerated with common
salt All of the anions found in potable water have varying affinities for the resin. Therefore, they consume varying
amounts of the resin's capacity. The amount of a particular ion that the resin will hold varies directly with its affinity and
its relative concentration with respect to the other ions in the influent. At the concentration levels involved in drinking
water, sulfate has a higher affinity for the Type 1 and Type 2 strong base resins than nitrate, while nitrate is more
strongly held than chloride and bicarbonate.
Safety Guidelines
It is essential that the unit not be overrun during service, especially when standard anion resins are used, to prevent
nitrate dumping.
• Use automatic regeneration controls on the ion exchange unit
- Meter initiated (gallonage)
- Timeclock controlled (time in service)
• Downgrade the system to operate at 80 percent of the total capacity.
Also worth noting is the fact that nitrate -bearing water should never be boiled. Boiling concentrates the water and the
relative level of nitrates would actually increase.
Waste Brine Concerns
The discharge of a salt regenerated nitrate unit is typically sent to the on -site septic system. Some denitrification takes
place in the septic tank from anaerobic bacteria, where bacteria break down nitrate to nitrogen and oxygen. Additional
denitrification can take place during percolation.
Pretreatment
Nitrate removal systems usually require only prefiltration and dechlorination (if chlorine is present) as pretreatment
These two steps are necessary to protect the anion bed from oxidation and physical fouling. Softening ahead of the
nitrate removal resin is not necessary except in cases of high pH and high -hardness waters (four grains or higher)
where the concentration of carbonates and hydroxides in the resin bed could cause precipitation of calcium or
magnesium.
pH Effects
Anion resin in the chloride fore removes not only nitrates, but also sulfate and alkalinity. The removal of alkalinity can
lead to a reduction in pH of the product water in the beginning of the run. To minimize this effect and add some
buffering ability back to the water, soda ash (Na2 CO3) can be added to the brine tank. This will convert a portion of
11/1Cl/111G

Nitrate Removal by Ion Exchange I The Solutions Source of the Water & Wastewater Ind... Page 3 of 4
the resin to the bicarbonate form during regeneration. A ratio of one lb./cu. ft. of soda ash mixed with nine lbs./cu. ft. of
salt can be used.
Comparing Resins
1n standard resins, when' sulfates are relatively low, the nitrate takes up most of the resin's capacity, to about the same
degree as in the nitrate selective resins. Therefore, the higher total capacity of the standard resins provides
significantly higher operating capacities in all but those cases where sulfates are present in large amounts.
Nitrate selective resins are best used in applications that may not be monitored closely and an overrun may occur. The
resins give effective nitrate removal and prevent nitrate dumping. They can cost about 50 percent more than standard
resins.
Operating Comparisons
Figures la, 1 b and lc show the performances of three resins (a standard Type 2 resin, triethylamine-based nitrate -
selective resin and tributylamine-based nitrate selective resin) on the same water supply after being regenerated at 20
pounds of NaCI per cubic foot. These graphs show the effluent concentrations of bicarbonates, sulfates and nitrates .
during the service (exhaustion) cycle. The service cycles were allowed to run past the nitrate breakthrough until the
effluent and influent concentrations for each ion were equal.
As an example in Figure la, the nitrate breaks through from the bed of ResinTech SBG2 at about two-thirds of the run
length before the sulfates breakthrough. This is typical performance on this type of water for either Type 1 or Type 2
resins. You also can see that the nitrate concentration reaches a peak concentration of about twice the raw water
concentration and that the sulfate leakage occurs gradually, starting at about the time that the nitrate begins to reach
its peak level and that the sulfate never exceeds the raw water value.
As another example, Figure lb shows the sulfate breaks through from the ResinTech SIR-100 bed 20 percent before
the nitrate begins to leak. This is typical performance for the triethylamine type resins. Notice how gradual the
breakthrough curve for nitrate is and that it never exceeds its influent value. Also, you can see that the sulfate
concentration reaches a value of about 50 percent above its influent water concentration.
In Figure 1 c, the sulfate begins leaking almost immediately from the tributylamine type resin due to its very weak
affinity for this type of resin. You also can see in Figure 1 c that the nitrate leakage also occurs gradually, just like in
Figure lb.
Figures 2a, 2b and 2c show operating capacity curves for a standard Type 2 anion resin and a triethylamine type
nitrate selective anion resin on waters containing 100 ppm each of bicarbonates, chlorides and nitrates but with sulfate
levels of 0, 100 and 300 ppm (0 percent, 25 percent and 50 percent, respectively). It can be seen that the standard
resins have higher operating capacities at sulfate levels up to 25 percent and that the selective resin has a higher
,operating capacity when sulfate levels are above 50 percent
Nitrate removal by ion exchange is the preferred technology for whole house treatment. It is a low-cost method,
operated in much the same manner as a common water softener. Regeneration is simple and accomplished with
softener salt, the chloride ion from the salt being the reactive ion. Nitrate selective resin is the logical choice to prevent
any nitrate dumping. Cartridge applications mandate the use of nitrate selective resins.
The future will find other applications for these selective resins such as we are already are seeing with the removal of
perchlorate and technicium.
More like this
• Ion Exchange Resins and Processes for Industrial Water Treatment
• Just the Facts: Knowing Strong Base Anion Resin Types
• Controlling Mechanisms of Contaminant Ion Leakage in Condensate Polishing Systems
• St. Cloud's Ascent
• Portable Exchange D.1., Operating Primer, Part I
ACF30FD.pdf
eave A Comment
Subject:
Comment: *
Web page addresses and e-mail addresses turn into links automatically.
Allowed HTML tags: <a> <em> <strong> <dte> <code> <ul> <ol> <lie <dt> <dt> <dd>
Lines and paragraphs break automatically.
More information about formatting options
By submittinci this form, you accept the Moltom privacy policy.
SAVE PREVIEW
Isearch...
Supmt
• Newsletters
1.4- I/*..w.,....,rev ..7w ,rn ....", by ;+«.,+o «o,......,1 ;.,,, o.,.,l..,..,eves
1 1 /1 A/')f11 C

Nitrate Removal by Ion Exchange The Solutions Source of the Water & Wastewater Ind... Page 4 of 4
o Subscribe
o Advertise
o Contact
Buyer's Guide
Products + Services
Events Calendar
Top Projects
Magazine
o Current Issue
o Archive
o Subscribe
o About Us
o Contact
Zones
o Membrane Technology
o Pump Source
o Energy Efficiency
o Meter Source
o Rural + Small Systems
o Pipe + Distribution Systems
o Industrial
Continuing Education
o Webinars
o White Papers
o Events
14 Media Press Studios
:mi;mi31"dl
E L �iCGittt0i3
© 2015 Scranton Gillette Communications. All Rights Reserved. Sitemap 1 Privacy Policy 1 Terms ii Conditions
h#n•//xxnxnxr'xnxrrimaa r•nm/rtifra -fa _ram nva1 /1 nihni c

Report of Annual Groundwater Monitoring and
Treatment System Effectiveness
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
November 9, 2015
Page 5 of 6
5 Recommendations
Based on the information presented above, Duncklee & Dunham recommends the following:
• Operate the groundwater -treatment system in accordance with the CAP and NPDES permit.
• Test groundwater samples collected from the three recovery wells for nitrate and ammonia on an
annual basis.
• Continue with the annual groundwater -monitoring program and conduct the next sampling event in
May 2016.
6 Bibliography
The following is a partial list of the literature reviewed:
Agriculture's Clean Water Alliance, 2010, Bioreactor Basics.
http://www.acwa-rrws.org/bioreactorbasics.html
Alvarez, Pedro J., 1998, USGS Water Resources Research Grant Proposal - Treatment of Nitrate -
Contaminated Groundwater Using Zero-Valent Iron and Autotrophic Denitrification.
http://water.usgs.gov/wrri/98grants/Iowa.htm
Calgon Carbon Corporation, 2012, Ion Exchange Technologies.
http://www.calgoncarbon.com/ion_exchange/media.html
Christianson, Laura, Ph.D. and Helmers, Matthew, Ph.D., 2011, Woodchip Bioreactors for Nitrate in
Agricultural Drainage. Iowa State University.
http://www.leopold. iastate.edu/sites/default/files/pubs-and-papers/2011-11-woodchip-
bioreactors-nitrate-agricultural-drainage.pdf
DeSilva, Francis, J., 2003, Nitrate Removal by Ion Exchange. Water & Wastes Digest.
http://www.wwdmag.com/nitrate-removal-ion-exchange
http://www.enviroalternatives.com/waternitrate.html
Environmental Protection Agency, Website: Basic Information about Nitrate in Drinking Water.
http://water.epa. gov/drink/contaminants/basicinformation/nitrate. cfm
Environmental Protection Agency (EPA/600/R-07/139), 2007, Monitored Natural Attenuation of
Inorganic Contaminants in Ground Water, Volume 2, Assessment for Non -Radionuclides
Including Arsenic, Cadmium, Chromium, Cooper Lead, Nickel, Nitrate, Perchlorate, and
Selenium. http://nepis.epa.gov
Foundation for Water Research, 2004, The feasibility of IN SITU groundwater remediation as robust low-
cost water treatment option. http://www.fwr.org/wresa/1325104.htm
DUNCKLEE & DUNI-IAM, P.C.

LUUL-AeW-SL LU
SAMPLER NAME AND SIGNATURE
PRINT Name of SAMPLER: . 1A4.5
SIGNATURE of SAMPLER 4 DATE Signed t
ADDmONAL COMMENTS
c
o
m
m
m
in
a
w
ro
ITEM 1!
IRoquestod Duo Date/TAT: Sr4rYjai6
r;
m
o
i
rr
N
F
Section A Section B Section C
Required Client InformatIon: Required Project Information:
Invoice Information:
T
Section D Matrix Codos
noquGodclont IntomuGen MATRIX / CODE
Drinking Water DW
Water WT
Waste Wator WW
Product P
SoiL/Solid SL
SAMPLE ID al OL
Wipe WP
(A-Z. 0-9 / :) Air AR
Sample IDs MUST BE UNIQUE Tissue TS
Other OT
s
z
c
z
or
vi
V\
VI
3.-
t�
!Purchase Order No.:
8
i
R
73
1
-i
P.
/.'
it
\
RELINQUISHED BY / AFFILIATION
fC.
-
—
—f
i
MATRIX CODE (sea va'A cal^a to taq)
t
".--
—
"—"
0,
SAMPLE TYPE (G=GRAB CrCOMP)
\may///rrl
Dg
m
COLLECTED
/
`
N
J.
!
V1
1
—
a
N
t-
N
Vi
F
m
m n
O
la
V.
`
a�\\
s
. H
rt1
I
P
w
Al
Q+
_
NI
(7
_
a�
alb
m
6 m
SAMPLE TEMP AT COLLECTION
3
--
-
�
�
�
1{ OF CONTAINERS
la
p
8'
..
Ni
-N
)
g
91
Pm
._h
k
Company Name:
a'
Rm
`
—
—
--
x
Unpreserved
—
----
—_
•(
H,SO4
ilk
O
v
0
oi
HNO3
HCI
m
NaOH
Na2S2O3
y
Methanol
Other
'Analysis Test 1
YIN
I Requested Analysis Filtered (Y/N)
4t!f�rKe�tl�
cn
V 8
rr, O
r NPDES n% GROUND WATER r DRINKING WATER
r UST 7 RCRA r OTHER
REGULATORY AGENCY
�,
1
d
A
m
I-- S
-Q
CO
0
e
P.
Pa
Temp in 'C
SAMPLE CONDITIONS
Residual Chlorine (Y/N)
Received on
Ice (YIN)
G
0
4j
O
0
Cr'
el
0
V\L
6
0
0
IN
O
a
jam►
C
O
^—
9'2?el265
Pace Project NoJ Lab I.D.
Custody
Sealed Cooler
(YIN)
Samples Intact
(YIN)
e 17 of 17

QUALITY CONTROL DATA CROSS REFERENCE TABLE
Project: SS -Statesville
Pace Project No.: 92251265
Pace Analytical Services, Inc.
9800 KinceyAve. Suite 100
Huntersville, NC 28078
[phone]
Lab ID Sample ID
QC Batch Method
Analytical
QC Batch Analytical Method Batch
92251265001 K65W6N EPA 350.1 WETA/23059
92251265002 K65W6B EPA350.1 WETA/23059
92251265003 K65W7K EPA350.1 WETA/23059
92251265004 K65W7L EPA 350.1 WETA/23059
92251265005 K65W7J EPA 350.1 WETA/23060
92251265006 K65W6A EPA 350.1 WETA/23060
92251265007 K65W6E EPA350.1 WETA/23060
92251265001 K65W6N EPA 353.2 WETA/23040
92251265002 K65W6B EPA 353.2 WETA/23040
92251265003 K65W7K EPA353.2 WETA/23040
92251265004 K65W7L EPA353.2 WETA/23040
92251265005 K651N7J EPA 353.2 WETA/23040
92251265006 K65W6A EPA 353.2 WETA/23040
92251265007 K65W6E EPA353.2 WETA/23040
Date: 06/08/2015 02:12 PM
REPORT OF LABORATORY ANALYSIS
This report shall not be reproduced, except in full,
without the written consent of Pace Analytical Services, Inc.. Page 15 of 17

100.0% 100.0%
100.0%
90.0%
80.0%
70.0%
0 60.0%
•
a 50.0%
a) 40.0%
30.0%
• 20.0%
10.0%
0.0%
' Ppt\\2�ti� Oec. 2�1q Ua\\yea,
)ar' NoJ' P�`r
)al‘
.
System Operation Efficiency - 2014-2018
100.0% 100.O%
Ppt�\ -° sec.
No`l •
Converted to Annual
System Operation
lots\
2Oti1.�
201$ '(ot2'
at
P`i
Notes:
2014 to 2015 - system off between April and November, as approved by DEQ.
2018 data is as current as June 20, 2018

%\.v'^, • '� 11 \ = %��I �1 (- �� \4�`41�`:.;'t11 ''`'(``__
`. JltiI `I'' yj 1 == \ • -� t\\ ` •r r%: % � .' I 1 :� `\((t', � ��1{ tti `\ � ((
J j�'\1 �,I`tl\.. `'t��} ,�1 J7. �„ l J � Ij/ �J 1 1 l 1
i f f
(•N
. 55� II
\\tl'+Ilil4 ' L' i'l!'S ` '-.. I.,,,,\`
' I'`t\ i /° y Jj.tt11,% f •-f f1,' �! }', �� i �,.. ,.`\ />
'r:flL Ill\' , `j}I Orj7 it j 1 . r
\ \�s \�
/1 /-Li' 1i �3_ .1 i�j`F:` `Jl i�r''' ? i •/'1l \'��''aBJ11 l I I `I l�'•`L}'t
•
1
>\ \\"�-�
Bcro ',
i ; `._,
100'
Contour Interval = 10'
200'
IDUNCKLEE & DUNHAM
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
1 I Keisler Drive Suite 102
Cary, North Carolina 27518
NC Eng. License No. C-3559
[phone]
w,v,v.dunckleedunham.com
NC Geo. License No. C-261
Site Topographic Map
Statesville Fertilizer Plant
Statesville, North Carolina
Drawn By:
baj
Checked By:
'%a+
Project Number:
50200
Date:
July 2016
References:
MapCvd: StaLcsvilIc East. 1995; Field Noes
Scale:
1"=2000'
Size:
8.5"x11"
Layers:
0,1
Filename:
P:Southem StarcASnlesvillc Fcnili c,- 5O200 \Figs•Photosmcpon Figures
Figure
1

- SURFACE WATER SAMPLING PLAN FOR SOUTHERN STATES FERTILIZER
This sampling plan is established for collecting surface water sample near the Southern States
Fertilizer Plant in Salisbury, Iredell County.
The facility has National Pollution Discharge Elimination System (NPDES) permit: NC0082821.
The permit was issued in agreement with a Corrective Action Plan (CAP) that was established in
January of 1994. The NCDEQ, DWR, WQROS, has concerns regarding discharge from this facility
that may be causing elevated nutrient impacts to surface water(SW).
The continued increase of nutrients reported in the onsite monitoring wells and the
observations made of algae on the ground, spilled fertilizer at the loading area algae covered
pond on the west side of the property present concerns for DWR. Also, the appearance of a lack
of benthic life present in near site surface water, provides the basis for the concerns that the
nutrient plume has surpassed the permittee's ability to maintain control of the plume. It is
possible that further assessment of the nutrient plume may be warranted. MRO will use.
topographic, site and road maps to determine locations for sample collection and help to
determine location and access areas for the purposes of SW sample collection. Initial
remediatlon efforts were to include surface water sampling of the stream located to the west
the of the site. The onsite wells display a history of drying up during seasonal low water table
cycles.
During a reconnaissance drive by of the area on June 1, 2017, it was noted that there are several
properties located to the south of the facility that are receiving waterprivate water supply
wells. Additional assessments may be requested by NCDEQ, DWR regarding these wells to
determine if any of these wells have been impacted by nutrients generated at the Southern
State facility.
The objective of the CAP was to remediate groundwater and to prevent off -site migration of the
contaminant plume. The plan was submitted by environmental consultant, Canonie. In May
1995, a pH adjustment system was added to the permit on order to meet the discharge
requirement for the permit. The system includes the addition of a 25%.Sodium Hydroxide
solution to raise the pH in the wet well sump to the permitted range of between 6.0 and 9.0.
From May of 1995 to the present date, the system has remained largely unchanged. Monitoring
sampling frequency has been adjusted as needed. Currently, no discharge occurs during the
summer months due to high pH concentration and low water table conditions.
During the December 2015 meeting between Southern States and DEQ, sampling frequency has
been increased to bi-annual sampling from the three on -site recovery wells. The samples are
collected from spigots located near the wellheads and tested for nitrate nitrogen per EPA
Method 300.0 and ammonia nitrogen per EPA Method SM4500-NH3-G. For the past three years,
onsite nutrients have displayed an increasing trend.
Recently, the system treatment wells have continuously failed resulting in the issuance of two
NOD violations and one NOV violation sent to the permittee on May 23, 2017.
Annual reports from 2104, 2015, and 2016 display increasing Nitrates/Nitrites in the
groundwater wells on site. The southernmost well reports nitrates above 100mg/L. The 15A

NCAC 02C..GW standard. for Nitrate/Nitrite. is 10mg/L,.with well K65W7F reporting the highest. .
concentration. This well is located near RW-2.
The system has a discharge point that empties into 4th Creek the discharge line runs along
Buckbee Road.
1. Order sample regents/preservatives for surface water samples. (25% H2SO4, 6N Sodium
Hydroxide, 1:1 HNO3)
2. Select sample sites.
3. Collect GPS locations of the proposed sampling locations.
4. Mark sample location access points.
5. Collect samples after or during a rain event.
6. Collect samples during a dry event.
7. Make sample labels for the 50mL sample bottles are completed.
8. Plot sample location upstream and downstream of the facility.
9. Collect samples from the discharge point at fourth creek.
10. Try to collect surface water samples of near site water bodies.
11. Submit samples for analysis for Phosphate, Nutrients, NH3, NO4NO3, TKN, Sulfide._
12. Collect field measurements, Temp., DO, SP Conductance, pH, turbidity, etc.
13. Plan sample dates. The dates need to concur with lab receiving dates.
14. Perform a benthic animal study in the near site surface waters.

111 McNess Rd = Google Maps
Page 1 of 2
gl Maps111 McNess Rd
Southern States and Ferti Technologies overhead map
jinni Lac nli
Man agemenP
111 McNess Rd
Statesville, NC 28677
Disnibutetl,.
or:, Rd
Co
Cho
ain nand
Mess Ttif:'n
Map data ©2018 Google 200 ft
https://www.google.ca/maps/place/ 111+McNess+Rd,+Statesville,+NC+28677/@35.75719... 7/18/2018

111 McNess Rd - Google Maps Page 2 of 2
At this location
Ferti Technologies
5.0 (1)
Manufacturer • 111 McNess Rd
https://www.google.calmaps/place/ 111+McNess+Rd,+Statesville,+NC+28677/@3 5.75719... 7/18/2018

b
DUNCKLEE
& DUNHAM
July 9, 2018
North Carolina Department of Environmental Quality
Division of Water Resources - Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Notification of Non-compliance
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NC0082821
To Whom It May Concern:
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DUNCKLEEDUNHAM. CON1
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee &
Dunham) submits this notification of non-compliance for the treatment system at the referenced site.
On May 7, 2018, a leak was discovered in the pipe connected to recovery well RW-2. The pump to the
well was immediately shut off by Duncklee & Dunham personnel and the pipe was repaired by facility
personnel. During this time, RW-5r and RW-6 remained active. Duncklee & Dunham personnel
reactivated the pump to RW-2 on May 9, 2018.
Water samples were collected from the effluent during this monitoring period on May 7, and 21, 2018. The
monthly average concentration for ammonia on the May 2018 eDMR was calculated to be 9.95 mg/L,
which is above the April to October Monthly Average Limit of 7.8 mg/L. However, the daily maximum
reading from the May 7, 2018, sample was 17 mg/L, which is below the April to October Daily Maximum
Limit of 35 mg/L. The eDMR sheet calculates the monthly average by adding the listed concentrations and
dividing the sum by the number listed. Based on historical effluent data for ammonia and recent June 2018
effluent results, ammonia is consistently below the monthly average when the three recovery wells are
operating. With recovery well RW-2 being off for less than 48 hours, we believe the elevated ammonia
concentration from the May 7, 2018, sample does not accurately represent the concentration discharged
over the course of the month. Based on the May 21, 2018, and June 2018 laboratory data, we do not believe
additional corrective actions are necessary and will continue normal treatment system operations in
accordance with the permit.
MAILING ADDRI::. ,s - POST OFFICE BOX 639 - CARY, NOfR11-1 CAROLINA 27512
NORTH CAROLINA Bo.iw oi' ExAMINERS FOIR ENGINFEs:S AND SURVEYORS L10ENsli. C.. 559
NORTH CAROLINA BOARD FOR LICENSING OF GEVLOCAS S LICENSE C-26
NC DEQ REGIS'EIRE _r ENVIR NMENTAL. CONSULTANT NUMBER 00061

Notification ofNon-compliance
Southern States Fertilizer Plant
Statesville, North Carolina
July 9, 2018
Page 2of2
Please contact Jayson Kilcoyne at jayson@,dunckleedunhatn.com or [phone], ext. 108, if you have
any questions or require additional information.
Sincerely,
Duncklee & Dunham, P.C.
Jayson A. Kilcoyne
Project Manager
Senior Peer Review:
Thomas S. Dunham, L.G.
Vice President/Senior Geologist
ec: Jennifer Bunting — Southern States Cooperative, Inc.
Edward Watson — DEQ-DWR-Mooresville Regional Office
Attachments: May 2018 Discharge Monitoring Report
P:\Southem States\Statesville Fertilizer - 50200\Forms-Corresp\NOV_NCDEQ Corres\2018\Notice-5-18_DMR.docx
D1. NCKL[E & DUNHAM. P.C.

:area
,a1e0 .
-� �5-1L)
VIA �. o
›.1-)S $ f ctY
(/ �.�N now t
�✓ 11f71 4o
/off, ry� j G i
u6!SJos!JuednS leuo!6ej
:M0 u6!S Jos!Aiedng
, idtaoi6ag! ;uelsissy
paieldwo0
rn 4,:
era /fp4 2.. ss% `�`^.(//7 :9i/' 4 1 /5
•
b /� vi•z .
sr)"' :$aewaj jJe;S/suo!;aIb!A ieq.o
uo!#o19`
suo!)eloR }o #
;min JeA0 %
. 1.!.taAO
6.GO 40:lee
Moi4W
papodej saw Aouenbaid.}!wlad
•Ocigelo!A:,Aouandaad .6uuo}!uoE I
5
.ta}auteaed ale®
enle/1 �j !Q aaAl }!woad .
suo! �lo!fl.AllealAppem
Uo
;en.IP;iiVNQ= <a!!!1:1!uuad
sUoleloIA ebwoAy.AI wow
:•0N edict
Zee
oIM.
Japweied
alga
JONWeJEd
"► `'S :A3!I!oed

May 26, 2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT:. NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-LV-0051
Permit No. NC0082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the December 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s) indicated below:
Limit Exceedance Deficiency(s):
Sample Limit Reported
Location - Parameter Date Value Value Type of Deficiency
001 Effluent pH (00400)
12/29/2016 6 5.88 Daily Minimum Not Reached
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State law. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State of North Carolina l Environmental Quality i Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

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

May 26, .2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-LV-0050
Permit No. NC0082821
Southern States Fertilizer Plant
Iredell County,
Dear Ms. Faulkner:
A review of the January 2017 .Discharge Monitoring Report (DMR) for the subject facility revealed the
deficiency(s)indicated below:
Limit Exceedance Deficiencv(s):
Sample Limit Reported
Location Parameter Date Value Value Type of Deficiency
001 Effluent pH (00400)
1/31/2017 6 5.88 Daily Minimum Not Reached
Please be aware that non-compliance with your permit could result in enforcement action by the Division of
Water Resources for these and any additional violations of State I.aw. The Mooresville Regional Office
encourages you to take all necessary actions to bring your facility into compliance.
State ofNorth Carolina l Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

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

Certified Mail # 7015 1520 0002 69.84 9362
Return Receipt Requested
May 26, 2017
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF VIOLATION
Tracking. Number: NOV-2017-LV-0287
Permit No. NC0082821
Southern States Fertilizer Plant
Iredell County
Dear Ms. Faulkner:
A review of the February 2017 Discharge Monitoring Report (DMR) for the subject facility revealed the
violation(s) indicated below:
Limit Exceedance Violation(s):
Sample Limit Reported
Location Parameter Date- Value Value Type of Violation
001 Effluent pH (00400) '
2/24/2017 6 5.69 Daily Minimum Not Reached
Remedial actions, if not already implemented, should be taken to correct any noted problems. The Division of
Water Resources may pursue enforcement actions for this and any additional violations. If the violations are of a
continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial
construction activities, then you may wish to consider applying for a Special Order by Consent (SOC).
State of North Carolina I , Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

A
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,
(-vat W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit = Enforcement File
State of North Carolina I Environmental Quality I Water Resources
610 East Center Avenue, Suite 301, Mooresville, NC 28115
704-663-1699

,.
AoOrd 6;
t�
Facility.: 50L411p ::
Parameter
Date Parameter
Date . Parameter
l f eviiew Record
r[n No A% o8 !`°.:::::.: _ : Pipe No.:
IVionthly Average Violations
t ' Permit limit :. 'Dfl�VR Value
WeeklvlDailv'Violations
Permit Limit . Limit Type DMR Value
Monitoring Frequencit Violations.
Permit Frequency • Values. Reported
Month/Year,/2Ci7
% Over Limit
% Over Limit
/466
# of Violations
Action
Action*
Action •
Other ViolationslStaff Remarks: i. /1
-A -o ..1)4t (H-1n1✓19vwz ,i . rt LQ
�-( '.CYG " ?o y ) H-LA N 6�'�Ge
s 3 (�+� KI �" C r�w0,6 33ck,
e 2q!! l u GclP )4 t (> Y(i I7Tdw\
(fz ca % SS b., dt /4CL. e
/vo. U: iss�c
ANc3 6s"..Ve . .
o.uu it et /COU 'r5(DJ'p
3 3>Jel.
3.5/ . c --d --°
roerki
s ue. ess
Supervisor Remarks:
Completed by: • -crei-1
Assistant Regional
Supervisor Sign Off:
. Date:
Date: -7S
Regional SupervisorSign

Facility: e,-G.,
Parameter
,efmit No inrc �c 8S8Z� Pipe No.: oo
Monthly Average Violations
Permit Limit'.: :DMRVaiue.
'6 0 z.9 ..
Date
Month/Year: G-2016
•
% Over Limit •
•
Action
Weekly/Daily'Violations
Parameter . Permit Limit . Limit Type DMR Value % Over Limit Action"
Monitoring Frequency Violations.
Date Parameter Permit'Frequencv Values Reported # of Violations Action •
Other Violations/Staff Remarks: ;e1,,--5e -to ,�
r�cecv'3 �L� evs 5i5,,i ots cewr4, 5uij6a�v�
• d3.:07-0G -F. z 1144, -
) /Gln.i iC^ N I S . d/ j c h.PCI-
1 oV-0016-- L
o 5S 7
Supervisor Remarks:
Assistant Regional
Supervisor Sign Off:
Regional SupervisorSign

DUNCKLEE
& DUNHAM
July 27, 2016
North Carolina Department of Environmental Quality
Point Source Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Notification of Non Compliance
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NC0082821
To Whom it May Concern:
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DUNCKLEEDIINHAM.COM
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C. (Duncklee
& Dunham) submits this notification of non compliance for the treatment system at the referenced site.
The operator in responsible charge (ORC) discovered the caustic solution tank to be empty on June 23,
2016, and measured the pH of the effluent to be 5.77 standard units. Due to the low pH reading, the
treatment system was shut down and more caustic solution was ordered. The ORC re -activated the
system on June. 27, 2016, after the caustic solution tank was refilled. Plant staff observed the peristaltic
pump that discharges the caustic solution into the wet well to be malfunctioning on June 29, 2016, and
halted operations until a replacement pump could be installed. The ORC installed a replacement pump on
July 19, 2016, and re -activated the sytem. We do not believe additional corrective actions are necessary
at this time and will continue normal treatment system operations in accordance with the permit.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to call Joshua Hanks at [phone].
Sincerely,
Duncklee & Dunham, P.C.
Joshua M. Hanks
Staff Geologist II
Senior Peer Review:
Thomas S. Dunham
Senior Geologist
e-copy: Lauren Faulkner — Southern States Cooperative, Inc.
Edward Watson — DEQ-DWR-Mooresville Regional Office
\\boss\files\Projects\Southem States\Statesville Fertilizer - 50200\Forms-Conesp\NOV_NCDENR Corres\2016Uune - 2016 - 16287.docx
MAILING ADDRESS — POST OFFICE BOX 639 — CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF ExAM1 tERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DEQ REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061 '

r
D
a
3
1
7
J
Li
r)
9
9
3
•.
CERTIFIED MA IL° RECEIPT
Domestic Mail Only
For delivery information, visit our website at www.usps.com®.
Certified Mail Fee / I /�
$ to
111
Extra Services & Fees (check box, add fee as appropriate)
❑ Retum Receipt (hardcopy) $
❑ Retum Receipt (electronic) $
❑ Certified Mall Restricted Delivery $
❑ Adult Signature Required $
❑ Adult Signature Restricted Delivery $
Postage
$
1
u
OCro t r 016 .
SOUTHERN STATES COOPERATIVE
PO BOX 26234
RICHMOND VA 23260-6234
ATTN: LAUREN FAULKNER
dwr/ew 10/13/16

c 1JI v ucC
our. wuvVru AU ucncuw.
A receipt (this portion of the Certified Mail label).
A unique identifier for your mailpiece.
Electronic verification of delivery or attempted
delivery.
A record of delivery (including the recipient's
signature) that is retained by the Postal Service'"
for a specified period.
nportant Reminders:
You may purchase Certified Mail service with
First -Class Mail°, First -Class Package Service°,
or Priority Mail® service.
Certified Mail service is notavailable for
intemational mail.
Insurance coverage is not available for purchase
with Certified Mail service. However, the purchase
of Certified Mall service does not change the ■
insurance coverage automatically included with
certain Priority Mail items.
For an additional fee, and with a proper
endorsement on the mailpiece, you may request
the following services:
- Retum receipt service, which provides a record
of delivery (including the recipient's signature).
You can request a hardcopy return receipt or an
electronic version. For a hardcopy retum receipt,
complete PS Form 3811, Domestic Return
Receipt; attach PS Form 3811 to your mailpiece;
for an electronic retum receipt, see a retail
associate for asslstance.To receive a duplicate
retum receipt for no additional fee, present this
LISPS® -postmarked Certified'Mail receipt to the
retail associate.
- Restricted delivery service, which provides
delivery to the addressee specified by name, or
to the addressee's authorized agent.
- Adult signature service, which requires the
signee to be at least 21 years of age (not
available at retail).
- Adult signature restricted delivery service, which
requires the signee to be at least 21 years of age
and provides delivery to the addressee specified
by name, or to the addressee's authorized agent
(not available at retail).
To ensure that your Certified Mail receipt is
accepted as legal proof of mailing, it should bear a
USPS postmark. If you would like a postmark on
this Certified Maii receipt, please present your
Certified Mail item at a Post Office'" for
postmarking. If you don't need a postmark on this
Certified Mail receipt, detach the barcoded portion
of this label, affix it to the mailpiece, apply -
appropriate postage, and deposit the mailpiece.
IMPORTANT: Save this receipt for your records.
5 Form 3800. Anril 2015 /Reverser PSI 7s2am-norr.nne7

Certified Mail # 7015 1520 0002:8386 8554
Return Receipt Requested
October 13, 2016
Lauren Faulkner
Southern States Cooperative :Inc.
P.O. Box 26234
Richmond, VA 23260-6234
SUBJECT: NOTICE OF VIOLATION.
Tracking Number: NOV-2016-LV-0557
Permit No. NC0082821
Southern States. Fertilizer Plant
Iredell County
Dear Permittee:
A review of the June 2016 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
Limit Exceedance Violation(s):
Sample
Location Parameter
Limit Reported
Date Value Value Type of Violation
001 Effluent pH (00400)
6/23/2016 6 5.77 Daily Minimum Not Reached
Remedial actions, if not already implemented, should be taken to correct any noted problems. .The Division of
Water. Resources may pursue enforcement actions for this and any additional violations. If the violations are of a
continuing nature, not related to operation and/or maintenance problems,and you anticipate remedial
construction activities, thenyou may wish to consider: applying. for a Special Order by Consent (SOC).
State of North Carolina I Environmental: Quality I Water Resources
'610 East Center Avenue; Suite301, Mooresville;'NC28115.'

If you have any questions concerning this m'atteror to apply for an SOC, please contact Edward Watson of
the Mooresville Regional Office at 704-663-1699.
Sincerely,
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
Cc: WQS Mooresville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
•
State of North Carolina 1• , Environmental ,Quality 1 Water Resources
610 East Center Avenue •Suite 301, Mooresville, NC 28115
'•704 663r1699 ` . "''

• Complete items 1, 2, and 3.
• Print your name and address on the reverse
sdthat we can return the card to you.
• Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
SOUTHERN STATES COOPERATIVE
PO BOX 26234
RICHMOND VA 23260-6234
ATTN: LAUREN FAULKNER
dwr/ew 10/13/16
111111111111111111111111111111111111111 III III
9590 9403i0891 5223 31.67 48
2. Article Number (Transfer_fromieniice.labell__'__.
7015 1520 0002 8386
COMPLETE THIS SECTION ON DELIVERY
D. Is delive
If Y
'3.
❑ At Signa
�❑ Adu • Signatur - :stricted Del
ertifi Mail®
❑ Certified it Res i'very: ..
i .❑ Coiled on D li4@r�y
O ColleGton Delivery �iestrcte, Delivery
itl
8 5 5.4 _. iil Restricted Delivery
❑Agent
0 :Addresse
C. Date
from item 1? IP Yes
elow: p No
of Deliver
OCT 7 2n1R
❑ Pr' ity Meil Express®
❑ gistered MailTM
❑registered Mail Restrict
Delivery
etum Receipt for
1Merchandise
DSignature Confirmations
❑ISignature Confirmation
Restricted Delivery
n R1I11 1. s benlii��n_ro_nriri_4nda
Domestic Return Receini

i
i
USE)S;,T DING#
•
I I
9590 9403 0891 5223 3]67 48
United States
Postal Service
First -Class Mail
Postage &:fees Paid
USPS
Permit No. G-10
n
• Sender: Please print your name, address, andfZlP+4® in this brc•
0
1 n d
NCDEQ/WQROS ni
610 CENTER AVE. �, o cg IT
SUITE 301 0 0,
MOORESVILLE NC 28115 a'
r
0
•Y1
1tll) 1111 Ft 1 1 11 111111 ij1i1 i 111 it lief i,iil t 11 1 f 1 i 111� i ttll�l1tl

PAT MCCRORY
'Water ter Resources
ENVIRONMENTAL DUALITY
August 25, 2016
Lauren Faulkner
Southern States Cooperative Inc
PO Box 26234
Richmond, VA 23260-6234
Subject: NPDES Electronic Reporting Requirements
Southern States Fertilizer Plant
NPDES Permit Number: NC0082821
Dear NPDES Permittee:
Governor
DONALD R. VAN DER VAART
Secretory
S. JAY ZIMMERMAN
Director
RECEIVEDINCDENRIDWR
AUG 2 9 2016
WQROS
MOORESVILLE REGIONAL. OFFICE
The U.S. Environmental Protection Agency (EPA) recently published the National Pollutant Discharge
Elimination System (NPDES) Electronic Reporting Rule. The rule requires NPDES regulated facilities to
report information electronically, instead of filing written paper reports. The rule does not change what
information is required from facilities. It only changes the method by which information is provided (i.e.,
electronic rather than paper -based).
EPA is phasing in the requirements of the rule over a 5-year period. The two phases of the rule, and their
key milestones, are:
• Phase 1—Starting on December21, 2016, regulated entities that are required to submit Discharge
Monitoring Reports (DMRs) will begin submitting these reports electronically. If you are currently
reporting your DMR data electronically using eDMR, then you simply need to continue reporting
in the same way as you are now. The key change is that, starting on December 21, 2016,
electronic reporting of DMRs will be required, instead of voluntary.
• Phase 2 —Starting on December 21, 2020, regulated entities that are required to submit certain
other NPDES reports will begin submitting these reports electronically. Reports covered in the
second phase include Notices of Intent to discharge in compliance with an NPDES general permit,
Sewer Overflow/Bypass Event Reports, and a number of other NPDES program reports.
Incorporating Electronic Reporting Requirements into NPDES Permits
The NPDES Electronic Reporting Rule requires authorized NPDES programs to incorporate electronic
reporting requirements into NPDES permits beginning December 21, 2015. Under the new rule, the
electronic reporting process supersedes the paper reporting process. According to our files, your NPDES
permit became effective after November 2013, and should contain the requirement to electronically
report your Discharge Monitoring Reports using NC DWR's eDMR system.
In addition to requiring permittees to report information electronically, the rule also requires permittees
to identify the initial recipient for the NPDES electronic reporting data [see 40 CFR 122.41(1)(9)]. Initial
State of North Carolina I Environmental Quality I Water Resources
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919 807 6300

recipient of electronic NPDES information from NPDES-regulated facilities (initial recipient) means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity
for receiving electronic NPDES Data [see 40 CFR 127.2(b)]. Permittees are required to electronically
submit the required NPDES information to the appropriate initial recipient, as determined by EPA. By July
18, 2016, EPA must identify and publish on its web site and in the Federal Register a listing of initial
recipients by state and by NPDES data group. Once available, you can use EPA's web site to find out or
determine the initial recipient of your electronic submission.
NC DWR has submitted a request to EPA to be the initial recipient for the following NPDES data groups:
1. Discharge Monitoring Reports;
2. General Permit Reports [Notices of Intent to discharge (NOIs); Notices of Termination (NOTs)];
3. Pretreatment Program Reports; and
4. Sewer Overflow/Bypass Event Reports
EPA's web site will also link to the appropriate electronic reporting tool for each type of electronic
submission for each state. Instructions on how to access and use the appropriate electronic reporting
tool will be available as well.
For more information on EPA's NPDES Electronic Reporting Rule, visit
http://www2.epa.gov/compliance/final-national-pollutant-discharge-elimination-system-npdes-
electronic-reporting-rule. For more information on electronic reporting to NC DWR, visit
http://deq.nc.gov/about/divisions/water-resources/edmr/npdes-electronic-reporting or contact Vanessa
Manuel at 919-807-6392 or via email at [e-mail].
Sincerely,
Je f fre t' O. Po. ptwI-
for S. Jay Zimmerman, P.G.
Cc: NPDES File
Central Files
t1Nloo1es_v_iII R'egional-OfficenVater-Quality-Frogr-a

$cheller, Roberto
From:
Sent:
To:
Subject:
Attachments:
Bell, Wes
Monday, June 13, 2016 2:48 PM
Scheller, Roberto
W`Stesville Fen ilizer Plant: Permit' #NC00828212016=0I NOV
2016-06 NOV7for 1=16-TSS.pdf`2016=01:PDF'
From: Josh [mailto:[e-mail]]
Sent: Monday, June 13, 2016 12:00 PM
To: Bell, Wes <[e-mail]>; Watson, Edward M <[e-mail]>
Cc:'Jayson Kilcoyne'<[e-mail]>; 'Tom Dunham' <[e-mail]>;'Vance)
Dann' <[e-mail]>; 'Lauren Faulkner' <[e-mail]>; 'Jim Wright'
<[e-mail]>
Subject: Statesville Fertilizer Plant Permit #NC0082821 2016-01 NOV
Edward and Wes,
I am emailing you today in regards to the attached NOV letter addressing the TSS exceedence during the January 2016
monitoring of the treatment system effluent at the Southern States Fertilizer Plant, permit #NC0082821. I submitted
the attached 2016-01 DMR with a notification letter to Edward and the Central Files Division that explained that the TSS
exceedence was believed to be a direct result of restarting one of the recovery wells approximately an hour prior to
sampling. Based on previous elevated TSS detections associated with this system, the TSS does not remain elevated for a
period longer than 24-hours past treatment system or well re -activation. Laboratory data showed the TSS concentration
decreased to below the minimum laboratory detection limit in our second effluent sample for the month of January.
If you have any questions or would like to discuss the matter any further please feel free to contact me at (919)-858-
9898 or Jayson Kilcoyne at [e-mail]. Thank you for your time.
Joshua Hanks
Joshua Hanks, GIT
Staff Geologist II
Duncklee & Dunham, P.C.
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Mobile: [phone]
Office: 919-858-9898 x212
www.dunckleedunham.com
1

DUNCKLEE
& DUNHAM
February. 10, 2016
North Carolina Department of Environmental Quality
Point Source. Compliance/Enforcement Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: Notification of Non -Compliance
Southern States Fertilizer Plant
Statesville, North Carolina
NPDES Permit Number: NC0082821
• To Whom it May Concern:
ENVIRONMENTAL GEOLOGISTS &.ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY. NORTH CAROLINA 2751E
OFFICE: (919) S5S-9898-
W W W.DUNCKI.E1 j)(' HAU COM
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & _Dunham, P.C. (Duncklee
& Dunham) submits this notification of non-compliance for the permitted daily effluent limit for total
suspended solids (TSS) at the referenced site.
TSS was detected by the laboratory above the permitted daily maximum allowance of 45 mg/L. The
sample was collected from the treatment system effluent on January 7, 2016, at a concentration of 87
mg/L. Recovery well RW-2 was shut off on December 22, 2015, to monitor the water -table elevations in
surrounding monitoring wells and restarted on January 7, 2016. We collected the sample approximately
one hour after the pump was restarted. The elevated TSS detected in the effluent sample is believed to be
a direct result of the recovery well having been off and restarted just prior to sample collection. We do
not anticipate elevated TSS to persist, and therefore no corrective actions are believed necessary at: this
time.
Duncklee & Dunham appreciates your time on this matter. If you have any questions or require any
additional information, please do not hesitate to call Joshua Hanks as [phone].
Sincerely,
Duncklee & Dunham, P.C.
Senior Peer Review:
v
Joshua M. Hanks Thomas S. Dunham
Staff Geologist II
Senior Geologist
e-copy: Vance Dann — Southern States Cooperative, Inc.
Edward Watson — DEQ-DWR-Mooresville Regional Office
P:1Southem States\Statesville Fertilizer - 502001Forms-Corresp\NOV_NCDENR Cones 12016 Jan - 2016.docz
MAILING ADDRESS — POST OFFICE Box 639 — CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DEQ REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061

t e I
NPDES PERMIT. NO.: NC0082821 PERMIT VERSION: 4.0
FACILITY NAME: Southern States Fertilizer Plant CLASS: PC -I
OWNER NAME: Southern States Cooperative Inc ORC: Joshua Michael Hanks
GRADE:PC-1 ORC HAS CHANGED: No
eDMR PERIOD: 01-2016 (January 2016) VERSION: 1.0 STATUS: Processed
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 NO DISCHARGE*: NO
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1001041
m
a"
6.
' d
E
tU
E•
,.
8
6 -
L
4
E
7,
<
`
O
Operator Timc On She
:.
it
G
No Reporting Reason
59050
00400
CO6ID
C0530
C0600
C0665
T11P3B
00620
00940
Continuous
2 X month
2 \ month
2-X month
Monthly
Monthly
Monthly
Monthly
%tenthly
Recorder
Grab
Grab
Gtah.
Grab
Grab
Grab
Grab,.
Grab
FLOW
PH
NII3-N-Ceoc
TSS-Cone
TOTAI.N-
TOT.\LP-
CER7DCHV
NO3=N'
CHLORIDE
2400,
lIrs
2400-
Hrs
Y0WN
.mgd
so
mg*
m9/1
m9JI
mr/l
Percent
m8,1
mg11
1-
0015
2
0.005
..
3
0.005
4
0.005
5
0.005
6
0.005
7
1045
4.25
Y
0.094 •
7.38
<0.0088
87
42
0.32
39
52
8
0,09-1 .
9
0.094
. .
ID
0.094
II
0.094
12
0.094
13
0.094
14
0.094
•
15
0.094 '
•
16
`
0.094
17
0.094
.
18
0.094 '
.
19
0.094
20
0.094- .
21
1145
2
Y
0.094'. '
8.61
1.2 ' -
<0,8
.22
0.094
•
23
0.094
24
0.094
25
-
0.094
-
..
26 '
0.094
27
0.094 .
28
-
0.094
'
29
-
0.094
-
30
0.094
.
31
-
0.094'
. .
`
Monthly A. erage LImit:
30
\Icnlhly Average:
0.076774
7.995
0.6
43.5
7
42
0.32
- 39
52
Daily Maximum:
0.094
8.61
1.2
87
42
0.32
-
39
52
Daily Mltatmum:
0.005
7.38
0 . -
0
- 42 -
0.32 •
- 39
52
Monthly Avg % Removal (85%)a

NPDES PERMIT NO.: NC0082821
FACILITY NAME: Southern States Fertilizer Plant
OWNER NAME: Southern States Cooperative Inc
GRADE:PC-1
eDMR PERIOD: 01-2016 (January 2016)
PERMIT VERSION: 4.0
CLASS: PC-1
ORC: Joshua Michael Flanks
ORC HASCf1ANGED: No
VERSION: 1.0
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.:.001
PERMIT STATUS: Active
COUNTY: Iredell
ORC CERT NUMBER: 1001041
STATUS: Processed
NO DISCHARGE*: NO (Continue)
a'
.)
a
:5
5
F
9
o
n
4
Operator Arrival Time
Operator Time On Site
11
7;
e
V
O
c
0
z
01042
If
•.
a
Monthly
Grab
COPPER
2400
fin
2400
ltn
Y!DQI
mall
1
3
a
5
6
7
1011
425
Y
<O0021
8
9
10
1I
12
13
14
15
16
IT
IN
19
SU
21
1145
2
Y
22
23
24
25
.
26
27
28
29
30
31
Monthly A. ern Limit:
Monthly Aveiaee:
0
• Daily Maximum:
0
Daily Minimum:
0
Moothiy Avg % Removal (85::1:

NPDES PERMIT NO.: NC0082821
FACILiTYNAME: Southern States Fertilizer Plant
OWNER NAME: Southern States'Cooperative Inc
GRADE: PC -I
eDMR PERIOD: 01-2016 (January 2016)
COMPLIANCE: Non -Compliant
PERMIT VERSION:4.0
CLASS: PC-1.
ORC: Joshua Michael Hanks
ORC HAS CHANGED: No
VERSION: 1.0
CONTACT PHONE ti: 9198589898
. PERMIT STATUS: Active
COUNTY: iredcll
ORC. CERT NUMBER: 1001041
STATUS: Processed
SUBMISSION DATE: 02/09/2016
02/09/2016
ORC/Ccrtific Signature: Joshua M Hanks E-Mail:[e-mail] Phone #:919=858-9898 Date
By this signature, I certify that this report is accurate and complete to the best of my lrnotvledge.
The perntittee shall report to the Director or the appropriate Regional Office any noncompliance'that potentially threatens public health or the environinent.
Any infornation shall be provided orally within 24 hours, from the time the pennittee became aware ofthe circumstances. A written. submission shall also be
provided within 5 days of the time the perntittce becomes aware of the circumstances.
1f the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for improvements to be made as required by part 11.E.6 of
the NPDES permit.
COMMENTS: TSS from the sample collected on January 7, 2016 above daily maximum allowance. Believe it to:be a direct result of the recovery well, RW-2, having been off
and'restarted just prior to sample collcction. Do not antieipate elevated TSS' to persist..
02/09/2016
Permittee/Submitter Si ature:** Joshua M Hanks E-Mail:[e-mail] Phone #:91,9-858-9898. Date
Pcnnittce Address: 2582 Salisbury Hwy Statesville NC 28677 Permit Expiration Date: 03/31/2019
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gatherand evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system. or those persons directly responsible for gathering the -information, the information submitted is, to the best of my knowledge and belief. true, •
accurate', and complete. 1 am aware that there are significant penalties for submitting false infonnation, including the possibility of fines and imprisonment for
knowing violations.
CERTIFIED LABORATORIES
LAB NAME: Duncktee & Dunham. PC
CERTIFIED LAB 0: 5484
PERSON(s) COLLECTING SAMPLES: Joshua Hanks
PARAMETER CODES
Parameter Code assistance may be obtained by calling the NPDES Unit [phone] or by visiting.http://portal.ncdenr.org/web/wq/swp/ps/npdes/fonns.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be entered for all of the•parameters.on the DMR
for entire monitoring period.
"'• ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
s«. Signature of Permittea if signed by other than the permiuce, thendelegation of the signatory authority must be on file with the'statc.per 15A'NCAC 2B •
.0506(b)(2)(D).

Nitrates Page 1 of 4
HOME
WATER
ISSUES
WATER
TREATMENT
GREY WATER
GREEN
PRODUCTS
GREEN
LIFESTYLE
RELATED
INFORMATION
CONTACT
Nitrate Removal
Environmental Alternatives
[phone]
petrich(c�whidbey.corn
N itrates
Removing Nitrate by Ion Exchange
Removal is Essential for Excess Nitrate
Five Nitrate Removal Methods
Understanding the Different Nitrate Units
Aqua Alternatives
[phone]
Removing Nitrate by Ion Exchange
DESCRIPTION
Nitrate is a common contaminant in water supplies, and especially prevalent in surface water supplies and shallow wells. However, it can
be found in any water source.
Nitrate contamination of drinking water is generally a manmade problem rtilizer i th largest contrit ufof to nitrate'poll_ tron. Some
sources say that poorly managed crops may only utilize 10% of the nitrate that is actually spread on the field. The runoff from these fields
ends up in surface water sources. Nitrate can also percolate down through the soil and end up in the drinking water aquifers. Other sources
of nitrate pollution are sewage treatment plants, septic systems, feed lots and industrial waste, both gas and liquid.
ANALYSIS
It is very important to know how nitrate is expressed in a water analysis so a water treatment system can be sized properly. The IUS
Environmental Protection Agency (EPA) has set a primary drinking water standard for nitrate. The maximum contaminant level (MCL) is 10
parts per million (ppm) nitrate as nitrogen (NO3 as N). A laboratory may also choose to express nitrate as nitrate (NO3as NO3) in the water
analysis, and in this case, the EPA MCL would be 44.2 pm (10ppm as N is equivalent to 44.2 ppm as NO3).
A good accurate water analysis is especially critical in this application, since a health issue is being addressed. The water analysis must
include nitrate and sulfate. Nitrate and sulfate levels are needed to calculate the operating capacity of the nitrate removal unit.
These parameters will have to be converted to their calcium carbonate equivalent. The conversion factor when nitrate is expressed as N is
3.57, and 0.81 when it is expressed as NO3. Typically sulfate is expressed as SO4 in a water analysis. Sulfate must also be converted to its
calcium carbonate equivalent by multiplying by 1.04. By converting to the calcium carbonate equivalent, the nitrate and the sulfate can be
compared as equals. It is also important to know the hardness, iron, total alkalinity, total dissolved solids (TDS) and pH.
ANION vs. CATION RESINS
Nitrate has a negative charge in water. It can be removed from the water with a strong -base anion resin. The resin can be regenerated
with salt (NaCI) and works similarly to a water softener. Anion resin is less dense than cation softening resin, so the backwash flow rate must
be reduced as compared to a softening resin. Check manufactures product data sheets for details.
Typical type 1 and type 2 strong -base anions will remove nitrate from water. Standard anion resins have an affinity for sulfate over nitrate.
The order of affinity is as follows: Sulfate-2>Nitrate-1>Chloride-1>Bicarbonate-1. These are the exhaustion bands in order of preference as
a unit exhausts. Sulfate has two negative charges (the valence) that give it a greater affinity to standard strong -base anion resin than nitrate
with one negative charge.
This is important since nitrate can be "dumped" from these types of resin. Dumping is defined as the elevation of nitrates in the treated
water over the level of nitrates in the raw (influent) water. As the nitrate system reaches exhaustion, sulfates will displace nitrates, causing a
significant increase in nitrate leakage corresponding to the nitrate and sulfate levels in the raw water.
When the raw water sulfates are high, nitrates in the treated water can be significantly higher that the raw water. This can be
compensated for when sizing the system. It is also best to use a standard anion resin when the system is monitored and/or the sulfate
concentration is low.
There are selective nitrate resins on the market. These resins have a different exchange group that makes it possible for nitrates to be
removed from water without the potential for dumping. Typical nitrate -selective functional groups include triethylamine, tripropylamine and
tributylamine.
With these types of resins the nitrate is held preferentially over sulfate. It should be noted that even though these resins are selective to
nitrates they still remove other negatively charged ions, like bicarbonate alkalinity and sulfate, from the water.
Whether a standard anion resin or a selective nitrate resin is used, sodium chloride or potassium chloride is typically used to regenerate the
system. A high concentration of brine is used to strip nitrate from the anion resin. Care must be taken, as with any anion resin, to set an
appropriate backwash flow rate to prevent resin loss.
The backwash flow rate of an anion resin is considerably lower than a cation softening resin's, so check with the manufacturers'
specifications. The use of a screen or upper basket in the valve will help to prevent resin loss during the backwash.
l,++r,•//nninar tarry 7irnbl+nrna+i,rno nesvrt 1m4ferni+rn+e 1,+n,1
1 1 /1 A/')111 C

Nitrates
Page 2 of 4
BE AWARE OF Ph CHANGES
All nitrate removal resins will remove alkalinity, including nitrate -selective resins. When alkalinity is removed from water, the pH will
decrease. The degree to which the pH will drop is dependent on the amount of alkalinity and carbon dioxide (CO2) in the water. The
decrease in pH occurs until the resin's capacity for alkalinity is reached; at that point the pH will start to return to the influent level. Generally,
on low total dissolved solids (TDS) water the pH drop will be more significant than on higher TDS water. Nitrates will be exchanged onto the
resin, and chlorides will be released into the water. This reaction will cause the chloride content of the treated water to increase. If the TDS
of the water is high, a salty taste may be detected.
SYSTEM COMBINATIONS
Caution must be taken when a single unit utilizes both cation and anion for softening and nitrate removal. During the regeneration,high
levels of hardness and high alkalinity may exist, causing calcium carbonate precipitation. This precipitation can foul the resin bed and/or plug
the drain line. Separate softening and nitrate removal units will prevent the precipitation from occurring.
Demand -initiated valves should be used as the brains of the system. These valves will monitor the amount of water treated and
regenerate the resin before the capacity is exhausted. •
Nitrate -selective resins should be used in point -of -use cartridges where the tendency to overrun the system exists. The selective resins
should be used on water with high sulfate concentrations. They should also be used when the system is not monitored. If the brine tank is not
filled or the valve fails, nitrate dumping will not occur when using a selective resin.
Standard anion resins should be used on systems that are monitored. Standard nitrate removal resins will generally have a higher operating
capacity than the nitrate -selective resins. They should be used on fee -lot applications where sulfate and nitrate removal is important.
It is beneficial to soften the water prior to nitrate removal. Softening will help to protect the nitrate removal system from fouling with metals
like iron. Nitrate removal by ion exchange is set up similar to softening, with some modifications. This type of water treatment is not difficult
and is within the expertise of most water treatment professionals....
SOURCE
Water Technology, Volume 23, Number 11, November 2000, "Removing Nitrate by Ion Exchange"
AUTHOR
Mike Keller is marketing specialist, domestic water services, for Sybron Chemicals, Inc. in Birmingham, N.J.
REFERENCES
1) Margaret McCasland, et al, "Nitrate: Health effects in Drinking Water," Natural Resources Cornell cooperative Extension, Comell University,
p m e p. cce. co rn e l I. e d u /facts-slides-self/facts/nit-h eef-g rw 85. h tm I
2) Stan Ziarkowski, "Nitrate Removal by Ion Exchange" Internal Paper at Sybron Chemicals, Inc.
Removal is Essential for Excess Nitrate
Too much of this is common, natural ion poses health risks.
by Ellen R. Campbell
Water Technology, September 2006, p.32
Nitrate is a simple ion that can occur naturally in mineral deposits or as a major end -product of biological degradation. All living things
contain nitrogen in their proteins and DNZ, and microbes in soild and water tend to convert nitrogen compounds into nitrate, which is the
preferred nitrogen source for plants. All living things and their waste products will produce nitrate as they decompose. You can expect to
find elevate nitrate levels in agrigultural regions, areas of high population (human or animal) where there is poorly treated or untreated
sewage, and in industrial areas where metals, munitions, paper and other products are manufactured.
A very stable ion
Nitrate is extremely soluble in water. It is also very stable -- it tends to remain as nitrate, rarely combining with other compounds to
become more benign. It does not bind to soil particles, as many water contaminants do. This means it will move around with groundwater,
you may find a sudden nitrate problem miles away from a potential source, or years after a farm or factory is gone.
The term "nitrates" is often used when talking about nitrate. Nitrates refers to combined nitrate and nitrite. Nitrite (NO2) is a very reactive
ion and rarely lasts long — it will quickly react with other chemicals, or become nitrate or ammonia. Most nitrate detection methods actually
measure combined nitrate and nitrite. Nitrate (NO3) is colorless, odorless, and tasteless. Because it is so unreactive, it is not removed from
water by standard water treatment dquipments such as carbon filters or softeners.
Nitrate and health
When humans (and most animals) take up nitrate in food or water, most of it is quickly eliminated from the body through the urine. Nitrate
does not accumulate in body fat, as most herbicieds and psticides can do. It is not irritating to the skin or to mucous membranes. However,
if there is a constant intake of nitrate — as might be the case if drinking water contains high nitrate levels -- there wil always be some nitrate
present in the body, and this is when health problems may occur.
Consumption of excess nitrate can cause "blue baby syndrome," or methemoglobinemia, in infants by interering with the ability of the blood
to carry oxygen. Infants never should be given water containing more than the US Environmental Protection Agency (EPA) maximuym
contaminant limit of 10 parts per milion (ppm) nitrate-N (as nitrogen). Long-term consumption of excess nitrate may increase the risk for
cancer of the stomach and bladder, and non -Hodgkin's lymphoma. High nitrate levels may increase the chance for miscarriage, childhood
asthma, and even juvenile diabetes. The elderly and those with reduced stomach acidity (such as people taking antacids) may also have
problems with reduced oxygen in the blood. Livestock and pets are also affected by high nitrate levels in water.
1,++„.//„r.,r.,r o,,.r,«..r,1+o,.«r,+:.resei es's..,..icy ,,+...:+. + 1 +. 1 1 1 11 nin1\1 e

Nitrates
Page 3 of 4
Because of the nitrate's adverse effects on human health, the EPA has set the MCL for nitrate at 10ppm nitrate-N (45 ppm nitrate, or 0.71
millimolar nitrate) under the Clean Water Act and the Safe Drinking Water Act. Nitrate is a primary contaminant, meaning that all potable
water in public supplies must be tested at least yearly for nitrate. Nitrate is also monitored in groundwater by state and federal agencies.
Background nitrate levels rarely exceed 2 ppm nitrate-N.
The problem of drought
Because nitrate is unreactive and water-soluble, it will remain in a well or aquifer unles it is flushed out by water containing lower nitrate
levels. Crought — where the same quantity of nitrate is present, but in less water -- can dramatically increase the nitrate concentration of a
water source. Water that had been safe might, under drought conditions, exceed the EPA safe drinking water limit.
Conversely, sudden increases in groundwater following flooding or excessive rain can also cause nitrate levels to rise in wells by flushing
nitrate into a new area from a contaminated site. Large areas of the US are under drought conditions in the summers. If your business is
locate in an agricultrual region and drought conditions are present, new nitrate problems will start to show up.
Testing and removal
There are many methods for testing water for nitrate, from test strips to sending samples to a certified testing lab. Test methods vary
widely in accuracy and reliability, so choose the most reliable method available to you. On -site testing is always helpful, allowing you to
demonstrate directly that there is a problem. Test strips and test kits are manufactured by a number of companies. Enzyme -based nitrate
analysis has been used in biomedical research for many years and is now available in simplified test kit formats for on -site water testing.
Test kits based on this method can provide reliable data even when ther eare other contaminants in the water.
Because nitrate is so soulble and non -reactive, it can be very difficult to remove from water. Under some conditions, for example, ion
exchange media can actually increase the danger for nitrate: the media will have a higher attraction for less soluble ions such as sulfate, and
will release the cound nitrate ions to make room for the others, causing nitrate breakthrough. All nitrate treatments require careful monitoring
and maintenance.
i oilizor l$
Various biological systems are also on the horizon in the technology of nitrate; remoara for ,crgbes that„use nitrate as an energy source can
be contained in a clomyun or tank s stemwater treatment ore soph.�1ticated'gp ach�pruifiesrth&enzgries vulfbir�;,ttlesemorganisCn'41
eduction reacts • sPs the eriayme lone.formtrate`removaL. The advantage of biological systems is that the
i ra _ a.conv , e safeni tregeriigas„ a s=irot ntribufe Celtic cjreeritio is'e effect. But it may be some years before these new
methods hurdle the technological, regulatory, and customer -perception barriers to make their way into common practice.
Ellen R. Campbell is vice president of The Nitrate Elimination Co., In, Lake Linden, MI, an environmental biotechnology company that develops enzyme -based
technologies for water testing and treatment. More information about the company is available at http://www.nitrate.com. Campbell can be reached at:
ellenr(anitrate.com. A.J. Kemppainen is a production/chemical engineer at the company.
Five Nitrate Removal Methods
by A.J. Kamppainen
Nitrate removal includes biodentrification, distillation, electrodialysis, ion exchange and reverse osmosis:
• Distillation boils water, leaving the nitrate behind, and then condensesand collects the steam/condensate. This process requires
relatively higher amounts of energy than other methods and is typically used when virtually complete removal of nitrate is desired.
. Electrodialysis uses an electrical current to move the nitrate threough a series of anoin and cation selective membranes. The
consecutive membranes concentrate the ions in a waste stream and away from the water. Electrodialysis may not be sot -effective for
small-scale production.
• Ion exchange uses a nitrate -selective resin to remove nitrate from water. Care must be used: as the resin exchange sites fill with
nitrate, nitrate breakthrough can occur as the resin reaches full nitrate capacity. Ion exchange is economical for large-scale nitrate
removal.
. Reverse osmosis (RO) traps the nitrate in a selctive membrane and allows the water to pass through. RO is the most common method
of nit te, removaL_and 'scost ffec ive when a small amount of water needs to be purified (5 to 10 gallons daily).
.JE1sde5 ii c do process that 'tsitypical 4y=assoclat d vwtdtlacg fsca a wastewate t �atment � generaI;,the strates are_[edire d'fg
bt�ogejAustngda_aetena>Inianranaercibic,envsronme'n .
Distillation, electrodialysis and reverse osmosis are very effective at removing nitrate from water. However, the high nitrate waste must still
be sidposed of properly or contamination of groundwater can occur.
Sources:
1. Scott Harmon, "Nitrate removal: Searching for the ideal in an imperfect world," Water Technology, November 2002.
2. David Elyanow and Janet Persechino, Advances in Nitrate Removal, GE WAter & Process Technologies, 2005
Understanding the Different Nitrate Units
by Ellen Campbell
Nitrate is reported in different terms (units) depending on where you live and your field of use. For example, 2 parts per million (ppm) nitrate-
N in New YOrk would be reported as 9 ppm nitrate in California.
. To convert from ppm nitrate-N to nitrate, multiply the nitrate-N value by 4.4 (10ppm nitrate-Nx4i4=44 ppm nitrate).
. To convert from ppm nitrate to ppm nitrate-N, multiply the nitrate value by 0.23 (50 ppm nitratex0.23=11.5 ppm nitrate-N).

Nitrates
Page 4 of 4
US EPA Units
2 ppm nitrate-N
(NO3N, nitrate -nitrogen)
10 ppm nitrate-N
California, Europe
9-10 ppm nitrate (NO3)
45 or 50 ppm nitrate
Chemical Units
140 micromolar nitrate
710 micromolar nitrate
Retum to WATER DETAILS
Return to main page on WATER
Return to HOME page
1 1 /1 A 41A 1 e

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
MA
Donald van der Vaart
Secretary
June 10, 2015
Ms. Lauren B. Faulkner
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Virginia 23260-1717
Subject: Compliance Evaluation Inspection
Southern States Fertilizer Plant
NPDES Permit NC0082821
Iredell County, North Carolina
Dear Ms. Faulkner:
Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on May 29, 2015, by Ms. Marcia Allocco of this office. I wish to thank
Mr. Jason Kilcoyne of Duncklee & Dunham for his assistance regarding the inspection.
Please review the comments in the Recordkeeping section of the report regarding Operator -in -
Responsible charge visitation requirements.
The inspection report should be self-explanatory; however, should you have any questions
concerning the report, please do not hesitate to contact Mr. Wes Bell at [phone] or
[e-mail] as my last day with the Division of Water Resources will be June 12, 2015.
Sincerely,
J
Marcia Allocco, MS
Environmental Senior Specialist
Water Quality Regional Operations
Division of Water Resources
Enclosure: Inspection Report
cc: Wastewater Branch
MSC 1617 — Central files basement
Jason Kilcoyne, back-up ORC (e-copy)
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http:l/portaincdenr.org/web/wq
An Equal Opportunity \ Affirmative Action Employer — 30% Recycled/10% Post Consumer paper

United States Environmental Protection Agency
E PA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No..2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection
1 H 2 I I 3 I NC0082821 111 121 15/05/29 117
Type
18 I ,, i
111111l11
Inspector Fac Type
19 I G I 2011
l66
180
21[1111I IIlIII11111III Ili' 11I1111
11
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67I1.o I 701d l:� I 71 IN I 72 I N LJ I
Reserved
731 I V 751
I I I
1 1 1 1 1 1
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Southern States Fertilizer Plant
2582 Salisbury Hwy
Statesville NC 26677
Entry Time/Date
10:30AM 15/05/29
Permit Effective Date
14/05/01
Exit Time/Date
11:55AM 15/05/29
Permit Expiration Date
19/03/31
Name(s) of Onsite Representative(s)ITitles(s)/Phone and Fax Number(s)
///
Joshua Michael Hanks/ORC/919-858-9898/
Other Facility Data
.
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Danny Dillon,6606 W Broad St Richmond VA 232606234NP Crops/804-281-1000/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement - Operations & Maintenance Records/Reports
Self -Monitoring Program Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
Marcia Ailocco MRO WQ/R04-663-1699 Ext2204/
Date
CU 4
/ 1 j6
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPDES yr/molday Inspection Type
31 NC0082821 111 121 15/05/29 117 18
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NC0082821
Inspection Date: 05/29/2015
Owner - Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is theinspector granted access to all areas for inspection?
Yes No NA NE
❑ ❑ � ❑
■ ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
IN ❑ ❑ ❑
Comment: NC0082821 was reissued by the Division on April 2, 2014, with an effective date of May 1,
2014. The permit is set to expire on March 31, 2019. The previous compliance evaluation
inspection was conducted on March 2, 2010. The reissued permit required electronic
submission of the monthly discharge monitoring reports by February 1, 2015. The permittee
began electronic DMR submission in October 2014.
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Yes No NA NE
• ❑ ❑ ❑
IN ❑ ❑ ❑
Comment: The groundwater treatment system is typically shutdown from April to November of each
year. Temperature and pH are monitored for process control.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Yes No NA NE
MI ❑ ❑ ❑
❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑
Comment: Totalizers are installed on each of the three extraction wells and averaged over the number
of days of discharge for reporting on the DMRs.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 ❑ • 0
Is sample collected below all treatment units? 1 ❑ 0 0
Is proper volume collected? ❑ 0 ❑
Is the tubing clean? ❑ ❑ � ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees • 0 ❑ ❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type • 0 0 ❑
representative)?
Page# 3

Permit: NC0082821
Inspection Date: 05/29/2015
Owner -Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: The permit requires grab samples for all required parameters. All effluent samples are kept
on ice in a cooler until transfer to a courier for delivery to the analytical laboratory.
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ ❑ •
❑ ❑ • ❑
Comment: There was no discharge of treated groundwater to the permitted outfall during the inspection.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
III ❑ ❑ ❑
III ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
Comment: On -site analyses are performed under field laboratory certification #5484, Duncklee &
Dunham,P.C. The permittee has also contracted Pace Analytical Services (laboratory
certification #12/40) and ESC Labs (toxicity) to provide the remaining testing requirements.
The fieldinstrumentation used on site appeared to be properly calibrated and documented.
Reagent tracking had been implemented for the pH buffers.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • 0 0 ❑
Is all required information readily available, complete and current? • ❑ 0 0
Are all records maintained for 3 years (lab. reg. required 5 years)? 11❑ ❑ 0
Are analytical results consistent with data reported on DMRs? • ❑ 0 ❑
Is the chain -of -custody complete? 1 0 ❑ 0
Dates, times and location of sampling •
Name of individual performing the sampling
Results of analysis and calibration •
Dates of analysis •
Name of person performing analyses •
Transported COCs
Are DMRs complete: do they include all permit parameters? • ❑ 0 ❑
Page# 4

4
. Permit: NC0082821
Inspection Date: 05/29/2015
Owner -Facility: Southern States Fertilizer Plant
Inspection Type: Compliance Evaluation
Record Keeping
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
❑ ❑ . ❑
❑ ❑•❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ � ❑
Comment: The permittee's records were organized and well maintained and records requested during
the inspection were readily retrievable. DMRs were reviewed for Jan 2014 through Mar 2015.
No limit violations were reported and all monitoring frequencies were correct.
The treatment system is currently classified as a physical -chemical grade I system (PC-1).
The standard conditions of NC0082821 and 15A NCAC 08G .0204 require weekly visitation
of PC-1 classified systems and are separate from any sampling requirements specified in
an individual NPDES permit. Although, the permittee requested reduced visitation approval
from the Division in 2009, a formal declassification of the system was not made at that time.
It is only through declassification that operator visitations can be reduced. The permittee
should make a formal request to the Wastewater Operator Certification group to declassify
the system; otherwise the visitation frequency of the system will need to be increased to
weekly from the present twice per month.
Page# 5

ArA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory
Governor
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Post Office Box 26234
Richmond, VA 23260
Attention: Vance Dann
Dear Mr. Dann:
Donald R. van der Vaart
Secretary
March 25, 2015
RE: Acknowledgement
Annual Groundwater Monitoring Report — 2014
NPDES Permit No. WQ0001759
Iredell County, NC
The referenced report was received in this office on October 16, 2014. I have reviewed the
report and have placed it in the Division's permit files. The next report is due in this office
by October 12 2015.
Thank you for updating the site Receptor Survey in this report.
Duncklee and Dunn have recommended proceeding with the existing on site remediation
system. While the report addresses the comment on concentrations levels from the April
30, 2014 e-mail, it does not provide information as to other methods of remedial actions
that might be useful for onsite wells that continue to remain above 2L standards for Nitrate
and Ammonia.
Please provide a brief analysis of other treatment options that might be appropriate for this
site to reduce groundwater contamination levels and prevent migration of contaminants off
site or to surface waters. Otherwise, provide information supporting the continuation of the
current remediation system present on this site.
Mooresville Regional Office/ Division of Water Quality/Aquifer Protection Section
610 E. Center Ave., Mooresville, NC 28115
Phone: [phone] l FAX: [phone]
Internet www.newaterquality.orq
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
?idledlr

Addressee
Date
Page 2 of 2
Should you have any questions, feel free to call me at [phone].
Sincerely,
dward Watson.
Hydrogeologist

F'!:1 E:'t,%EO
AVA DIVISION OF WATER QUALITY
NCDENR SEP 9 2014
North Carolina Department of Environment and Natural Resources_ s`dki 3E.cTION
UIOORESVILLE REGIONAL OFFit,E
Pat McCrory John E. Skvarla, III
Governor - Secretary
September 8, 2014
CERTIFIED MAIL 7013-2630-0001-8998-0591
RETURN RECEIPT REQUESTED
Ms. Lauren B._Faulkner
Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, VA 23260-1717
Subject: NOTICE ,OF VIOLATION
Southern States Fertilizer Plant
NPDES Permit NC0082821
Iredell County
NOV-2014-LR-0041
Dear Ms. Faulkner:
This is to inform you that the Division of Water Resources did not receive your monthly monitoring report
for June 2014. This is in violation of Part II, condition D(2) of the NPDES permit, as well as 15A NCAC
2B .506(a), which requires the submittal of Discharge Monitoring Reports no later than the last calendar day
following the reporting period. Failure to submit reports as required will subject the violator to the
assessment of a civil penalty of up to $25,000 per violation. You will be considered noncompliant with the
self -monitoring requirements of your NPDES permit until the report has been submitted.
To prevent further action, please submit said report within fifteen (15) days of receipt of this notice.
Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if
future reports are not received within the required time frame during the next twelve (12) reporting months.
The Division must take these steps because timely submittal of discharge monitoring reports is essential to
the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you
have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6307 or
via e-mail at [e-mail].
✓LL.
Thomas A. Reeder
Division of Water Resources, NCDENR
cc: Derek Denard, Compliance& Expedited Permitting Unit
DWR Mooresville Regional Office Supervisor, Surface Water Protection Section
Central Files
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: [phone] Internet: http://www.ncwaterquality.orgl
An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper

Allocco, Marcia
From: Reid, Steve
Sent: Tuesday, June 09, 2015 1:06 PM
To: Allocco, Marcia
Cc: Sifford, Barbara; Parker, Michael; Bell, Wes
Subject: RE: Site visits for Southern States
Marcia -
This is an interesting issue. It appears as if the permittee is misinterpreting the permit monitoring requirements as the
ORC visitation schedule. Previous TACU staff may not have been clear in the discussion of ORC visitation being over-
ridden by requirements in the permit (which is actually how the Rule refers to this issue...), or the discussion may have
resulted in the permittee misinterpretation. Either way, here is the bottom Tine.
If the facility is classified as a Grade 1 PC system, the ORC visitation is weekly, as you have noted in your discussions with
the staff. Monitoring frequency is independent of ORC visitation and therefore has no bearing on it, as such. If the
permittee wishes to decrease the monitoring frequency, that is what should be requested. If they wish to decrease ORC
visitation, the only way to do that would be for us (Central and RO Staff) to agree the facility does not warrant
classification and change it to "PCNC" (PC - Not Classified). I am not certain that is what you are looking for as the end
result in all of this, but felt it should be mentioned.
Hope this helps clear up some of the issue. Please let me know if there are additional questions. And if I completely
missed something (or anything) on this, help me understand better.
BTW — Where ya headed after DWR? Hate to see you go...
Thanks!
Steve Reid -
Supervisor, NC Operator Certification Program
NCDENR / Division of Water Resources
PH: 919.707.9108 FX:919.715.2726
[e-mail]
http://portal.ncdenr.org/web/wq/admin/tacu or ncwater.org/wwcert
Office: 1209 - K (Archdale Bldg)
Mail: 1618 Mail Service Ctr, Raleigh NC 27699-1618
Physical address: 512 N. Salisbury St., Raleigh NC 27601
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third
parties unless the content is exempt by statute or other regulation.
From: Allocco, Marcia
Sent: Monday, June 08, 2015 10:57 AM
To: Reid, Steve
Cc: Sifford, Barbara; Parker, Michael; Bell, Wes
1

Subject: FW: Site visits for Southern States
Importance: High
Good morning Steve,
MRO inspection staff has always defaulted to the classification rules and associated ORC visitation requirements for all
classified groundwater treatment systems except those under the UST trust fund program. I recently inspected the
Southern States site and inquired why the site visits were less than weekly as required by the PC-1 classification of the
system. I was forwarded the attached information, which is unique to this site as MRO staff have never reverted back to
the monitoring requirements in a permit to drive the ORC visitation requirements (except trust fund sites).
Mike and I discussed the situation and we plan to issue the inspection as compliant but request that the permittee
either formally request declassification of the system or increase the site visits to match those of the operator regs and
the standard conditions of the permit.
I have attached the permit description and also the standard conditions of the permit that state weekly visitation for PC-
1 facilities.
Are you in agreement with our plan?
I'll be leaving DWR at the end of the week so follow-up should occur (if after this time) with Wes or Mike.
Regards,
Marcia
From: Jayson Kilcoyne [mailto:[e-mail]]
Sent: Monday, June 01, 2015 1:53 PM
To: Allocco, Marcia
Subject: RE: Site visits for Southern States
Hi Marcia,
I did some digging in the project file and attached is an email I found regarding the change in frequency for ORC site
visits. No formal letter was issued to Southern States Cooperative for this change.
According to phone conversations and email between Tom Dunham and Mr. James Pugh of the North Carolina Division
of Water Quality, Technical Assistance and Certification Unit, the ORC does not have to visit the site any more frequently
than is specified in the NPDES permit and the NPDES permit monitoring schedule supersedes the waste water operator
rules. However, this is not specified in the NPDES permit and the NPDES permit writer (Mr. Charles Weaver) indicated
to Tom by phone on 9/10/2009, that they don't have any jurisdiction over the waste water operator rules and the ORC site
visit frequency. Mr. Pugh indicated in his email to Tom that the ORC requirements in Part II of the site's NPDES permit
is superseded by the NPDES monitoring schedule.
I hope this helps. Please let me know if you have any questions.
Regards,
Jayson
Jayson A. Kilcoyne
Project Manager
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898, ext. 208
[e-mail]
www.dunckleedunham.com
2

DUNCKLEE & DUNS
ENVIRONMENTAL AL GEOLOGISTS S E`G1NEERS
A Professional Geologic and Engineering Corporation
From: Allocco, Marcia[mailto:[e-mail]]
Sent: Friday, May 29, 2015 4:36 PM
To: [e-mail]
Subject: Site visits for Southern States
Hi Jason,
Thanks again for coordinating the inspection at the Southern States site in Iredell county. I checked our files and could
not find any older correspondence regarding the visitation requirements. Please check your files and let me know what
you find. I'll be in the office part of Monday then in the field Tuesday -Thursday fish shocking and then back in on Friday
if you need to contact me.
Marcia
DM ton of water Resources
Marcia Allocco, MS — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax: [phone]
[e-mail]
www.ncwaterqualitv.org
Please note that effective Oct. 15, 2013, the MRO copy fee is $0.05/page. This applies to all copies; the first 25 pages
are no longer free.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed.to third parties.
3

Allocco, Marcia
From: Jayson Kilcoyne <[e-mail]>
Sent: Monday, June 01, 2015 1:53 PM
To: Allocco, Marcia
Subject: RE: Site visits for Southern States
Attachments: System classification_modification to site visit frequency.pdf
Hi Marcia,
I did some digging in the project file and attached is an email I found regarding the change in frequency for ORC site
visits. No formal letter was issued to Southern States Cooperative for this change.
According to phone conversations and email between Tom Dunham and Mr. James Pugh of the North Carolina Division
of Water Quality, Technical Assistance and Certification Unit, the ORC does not have to visit the site any more frequently
than is specified in the NPDES permit and the NPDES permit monitoring schedule supersedes the waste water operator
rules. However, this is not specified in the NPDES permit and the NPDES permit writer (Mr. Charles Weaver) indicated
to Tom by phone on 9/10/2009, that they don't have any jurisdiction over the waste water operator rules and the ORC site
visit frequency. Mr. Pugh indicated in his email to Tom that the ORC requirements in Part II of the site's NPDES permit
is superseded by the NPDES monitoring schedule.
I hope this helps. Please let me know if you have any questions.
Regards,
Jayson
Jayson A. Kilcoyne
Project Manager
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898, ext. 208
[e-mail]
www.dunckleedunham.com
DUNCKLEE & DUNHAM
ENVIRo 1E:ITAL GEOLOGISTS & ENGINEERS
A Professional Geologic and Engineering Corporation
From: Allocco, Marcia[mailto:[e-mail]]
Sent: Friday, May 29, 2015 4:36 PM
To: [e-mail]
Subject: Site visits for Southern States
Hi Jason,
Thanks again for coordinating the inspection at the Southern States site in Iredell county. I checked our files and could
not find any older correspondence regarding the visitation requirements. Please check your files and let me know what
you find. I'll be in the office part of Monday then in the field Tuesday -Thursday fish shocking and then back in on Friday
if you need to contact me.
Marcia
1

Dvi Ws#on of Water Resources
Marcia Allocco, MS — Senior Environmental Specialist
NC Dept. of Environment & Natural Resources (NCDENR)
Division of Water Resources - Water Quality Regional Operations
610 East Center Ave., Suite 301, Mooresville, NC 28115
Phone: [phone] Fax: [phone]
[e-mail]
www.ncwaterquality.orq
Please note that effective Oct. 15, 2013, the MRO copy fee is $0.05/page. This applies to all copies; the first 25 pages
are, no longer free.
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulation.
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
2

r
From:
Sent:
To:
Cc:
Subject:
Tom,
Just following up on our conversation today. The wastewater rules 15A NCAC 08G.0204 (2) "An Operator in Responsible
Charge (ORC) of a water pollution control system must: (2) visit the system as often as is necessary to insure the proper
operation of the system but in no case less frequently the following schedule, unless otherwise specified in
permit." Therefore if the NPDES permit states visit different from what the wastewater rule states, you are to follow
what is in the permit.
James
***Please note new email address: [e-mail]***
James L. Pugh, Extension Education & Training Specialist
NCDWQ, Technical Assistance and Certification Unit
1618 Mail Service Center.
Raleigh, NC 27699-1618
[phone] x341
[phone] Fax
[e-mail]
http://h2o.enr.state.nc.us/tacu/
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Tom Dunham [mailto:[e-mail]]
Sent: Thursday, September 10, 2009 5:03 PM
To: Pugh, James L.
Subject: Classification of Groundwater Treatment System
Dear Mr. Pugh,
I was given your name by Mr. Charles Weaver of the NPDES group. I left you a voice mail earlier today but though I
would follow up with an email.
We have a client that has a nitrate groundwater pump and treat remediation system in Statesville, NC (NPDES Permit #
NC0082821). In June 2004 the system was classified as a PC-1. Since that time there has been an ORC monitoring the
treatment system weekly. The treatment system consists of nothing more than metering in a caustic to adjust the pH prior
to discharge. I have spoken to the NPDES permit writer and the MRO and they will entertain a permit modification to
reduce the effluent sampling from twice per month to once per month. However, based on the system classification our
client still has to have an ORC conduct weekly site visits.
Is there a process such that we can either; 1) have the system reclassified such that an ORC does not have to visit the site
weekly or 2) reduce the ORC site visits to those required for NPDES permit effluent sampling?
Thank you for your time and I look forward to hearing from you.
1

r, a
Regards,
Tom
Thomas S. Dunham, P.G.
Senior Geologist
Duncklee & Dunham, P.C.
511-102 Keisler Drive
Cary, North Carolina 27518
Office: [phone]
Mobile: [phone]
tdunhanir dunckleedunham.com
2

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
September 25th, 2013
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
PO Box 26234
Richmond, VA 23260
Subject: Receipt of permit renewal application
NPDES Permit NC0082821
Iredell County
John E. Skvarla, III
Secretary
RECEIVED
DIVISION OF WATER QUALITY
OCT .8 2313
SVVP
MOORES I L.=. I:Et3iOwir"..L OFF D
Dear Ms. Lauren B. Faulkner,
The NPDES Unit received your permit renewal application on September 24th, 2013. This
permit renewal has been assigned Bob Sledge (91.9-807-6398) who will contact you if any
additional information is required to complete your permit renewal. Due to current backlog, you
should continue to operate under terms of your current permit, until a new permit is issued. If
you have any questions, please contact the assigned permit writer.
Sincerely,
Jeff Po 't art
Point Source Branch Program Supervisor IV
Cc: Central Files
Mooresville Regional Office
NPDES Unit
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] Internet: www.ncdenr.gov
An Equal Opportunity \ Affirmative Action Employer— 50% Recycled 110% Post Consumer Paper
NorthCarolina
Naturally

Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Va. 23230-1717
Mail Address: P.O.Box 26234
Richmond, Va 23260-6234
Telephone [phone]
September 19th, 2013
SOUTHERN
STATES North Carolina Department of Environment and Natural Resources
Division of Water Quality-NPDES Unit
Attention: Mr. Charles Weaver
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: NPDES Permit Renewal Application for the Southern States Statesville
Fertilizer Plant (Permit #NC0082821)
Dear Mr. Weaver,
The Southern States: Cooperative, Inc. (SSC) is submitting the completed Permit
Renewal .Application for the Statesville Fertilizer Plant is currently covered under
NDPES Permit #NC0082821 to : the North Carolina Department of Environment
and_ Natural Resources- Division of Water Quality. This permit expires on March
31st, 2014 and at this time there have been no changes to the groundwater treatment
system since the last permit was issued.
If you need any additional information, please contact me at [phone].
Sincerely,
Lauren B. Faulkner
Environmental Project Manager
Cc: Bruce Gray -Statesville Fertilizer Plant Manager
Tom Wheeler- Operations Manager for the SSC Fertilizer Division

Southern States Cooperative, Inc.
6606 West Broad Street.
Richmond, Va. 23230-1717
Mall Address: P.O.Box 26234
Richmond, Va 23260-6234
Telephone [phone]
September 19th, 2013
SOUTHERN
STATES
North Carolina Department of Environment and Natural Resources
Division of Water Quality-NPDES Unit
Attention: Mr. Charles Weaver
1617 Mail Service .Center
Raleigh, North Carolina 27699-1617
RE: NPDES Permit Renewal Application for the Southern States Statesville
Fertilizer Plant (Permit #NC0082821)- Sludge Management Narrative
Dear Mr. Weaver,
The Southern States Cooperative, Inc. (SSC) is submitting this brief explanation
regarding a sludge management plan on behalf of the Statesville Fertilizer Plant
that is currently covered under NDPES Permit #NC0082821 to the North Carolina
Department of Environment and Natural Resources- Division of Water Quality.
This permit is for the dischargethat is generated as a result of the groundwater
remediation system. There are no solids or sludge generated as a result of this
process and so this facility does not have a sludge management plan.
If you need any additional information, please contact me at [phone].
Sincerely,
Lauren B. Faulkner
Environmental Project Manager
Cc: Bruce Gray -Statesville Fertilizer Plant Manager
Tom Wheeler- Operations Manager for the SSC Fertilizer Division

DUNCKLEE
& DUNHAM
June 18, 2012
Mr. Bob Sledge
North Carolina Division of Water Quality
Surface Water Protection
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ENVIRONMENTAL CONSULTING & ENGINEERING
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W .DUNCKLEEDUNHAM.COM
Reference: Request to Place Permit on "Inactive" Status
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
Statesville, Iredell County, North Carolina
NPDES Permit NC0082821
Dear Mr. Sledge:
On behalf of Southern States Cooperative, Inc. (Southern States), Duncklee & Dunham, P.C.
(Duncklee & Dunham) submits this letter to inform you that the remediation system at the above
referenced site was shut off on June 7, 2012, and to request that the NPDES permit be placed on
"Inactive" status as of that date. The current NPDES permit is effective until March 31, 201'4, and covers
the discharge from a groundwater remediation system.
The groundwater remediation system consists of three groundwater extraction wells, a lift station with
wet well, a sodium hydroxide feed system to adjust the pH of the groundwater, and a surface water
discharge to Fourth Creek.
The remediation system has historically been shut down between April and October due to low water
table conditions and the extraction wells going dry. Therefore, Southern States is requesting the NPDES
permit be placed on "Inactive" status as of June 7, 2012, to reduce the costs associated with monthly
reporting of "no flow" and inspections.
MAILING ADDRESS - POST OFFICE Box 33366 - RALEIGH, NORTH CAROLINA 27636
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DENR REGISTERED ENVLRONMENTAL CONSULTANT NUMBER 00061

Request to Place Permit on "Inactive" Status
Southern States Cooperative, Inc.
Statesville Fertilizer Plant
NPDES Permit NC0082821
June 18, 2012
Page 2 of 2
Please contact Mr. Tom Dunham of Duncklee & Dunham at [phone]
(TDunham a,DunckleeDunham.com) or Mr. Vance Dann of Southern States at [phone]
([e-mail]) if you have any questions or require any additional information.
Sincerely,
Duncklee & Dunham, P.C.
Jayson A. Kilcoyne
Project Environmental Scientist II
Senior Peer Review:
Thomas S. Dunham, P.G.
Senior Geologist
Cc: Mr. Wes Bell — DWQ Surface Water Protection — Mooresville Regional Office (e-copy)
Mr. Vance Dann — Southern States Cooperative, Inc. (e-copy)
Mrs. Lauren Faulkner - Southern States Cooperative, Inc. (e-copy)
P:\Southern States\Statesville Fertilizer - 50200\Forms-Corresp\NPDES-Treatment System Docs\Inactive Status Requests\Inactive Status
Request-12222.doc
DUNCKLEE & DI.INHAM, P.C.

Bell, Wes
From: Jayson A. Kilcoyne [[e-mail]]
Sent: Monday, June 18, 2012 9:57 AM
To: 'Lauren Faulkner'
Cc: Bell, Wes
Subject: Inactive Status Request-12222 E-COPY.pdf (SECURED) - Adobe Acrobat Standard
Attachments: Inactive Status Request-12222 E-COPY.pdf
Attached is the Inactive Status Request for the Southern States -Statesville Fertilizer Plant for you to retain for your
records.
Regards,
Jayson
1

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Dee Freeman
Secretary
March 23, 2010
Mr. Vance Dann •
Manager of Environmental and Homeland Security
Southern States Cooperative, Inc.
Post Office Box 26234
Richmond,. Virginia 23260-6234
Subject: Notice of Violation
Violation of G.S. 143-215.1
Unpermitted Discharges of Stormwater
Southern States Fertilizer Plant
Iredell County, N.C.
Tracking.#: NOV-2010-OP-0014
Dear Mr. Dann:
Chapter 143, Article 21 of the North Carolina General Statutes (G.S.) authorizes and
directs the Environmental Management Commission of the Department of Environment &
Natural Resources to protect and preserve the water resources of the State. The Division of
Water Quality (DWQ) has the delegated authority to enforce adopted water pollution control
rules and regulations.
On March 2, 2010, Mooresville Regional Office (MRO) staff performed a Compliance
Evaluation Inspection (CEI) at the NPDES permitted facility (Permit No. NC0082821) located at
the Southern States Fertilizer Plant in Statesville, N.C. MRO Staff determined that the facility
had been discharging stormwater into an unnamed tributary to Third Creek without first
obtaining a permit.
Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not
more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars
($25,000.00) per day when the violation is of a continuing nature, against any person who is
required but fails to secure a permit required by G.S. 143-215.1. Penalties may also be assessed
for any damage to the surface waters of the State that may result from the unpermitted discharge.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
Internet: http:/lportal.ncdenr.orglweblwq
An Equal opportunity \ Affirmative Action Employer— 50%o Recycled/10%o Post Consumer paper
One
NorthCarolina
Naturally.

Mr. Vance Dann
Page Two
March 23, 2010
To comply with G.S. 143-215.1, you must submit a completed application form and
supporting fee to the Division for the stormwater discharge(s) at the Southern States Fertilizer
Plant in Statesville, N.C. The application form and supporting guidance information can also be
found at the following website address: http://portal.ncdenr.org/web/wq/ws/su/npdessw. The
application form (and supporting fee) should be completed and submitted within thirty (30) days
of this dated letter.
It is requested that a written response be submitted to this Office by April 13, 2010,
addressing the permitting of the stormwater discharge(s) at the Southern States Fertilizer Plant.
Should you have questions, please do not hesitate to contact Mr. Wes Bell at (704) 663-
1699.
cc: NPS-ACO Unit
Iredell County Health Department
Sincerely,
•
Robert B. Krebs
Surface Water Protection Regional Supervisor