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Home My WebLink AboutWQ0017321_Compliance Evaluation Inspection_20210929ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Mr. Doug Burns, EHS Manager Cargill Incorporated 5000 South Boulevard Charlotte, North Carolina 28217 Dear Mr. Burns: NORTH CAROLINA Environmental Quality September 29, 2021 via Email Subject: Non -Discharge Permit Inspection Report Cargill, Inc. - Permit WQ0017321 Distribution for Processing of Residual Solids (503 Exempt) System Mecklenburg County Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on September 15tn 2021, for the referenced Non -Discharge permit. The residuals processing, storage and records were reviewed and additional information requested was received in your September 23rd, 2021 email. The following items were noted to maintain overall compliance: At the time of inspection, the clarifier appeared to have floating residuals and there was sludge present along the outside wall, potentially indicating overflow or foaming conditions at some point. These observations may indicate that fats/oils are making it into the plant and/or the clarifier solids are not being wasted routinely enough to allow for proper settling (see photos below). NODE M, Depaenl or Environmental Owllly North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115 704.663.1699 While technically not a violation of this Distribution permit, inconsistent residuals processing may cause other issues with your pretreatment, discharge permit and lead to belt -press issues with poorly pressed cake. Per onsite conversation, there are plans to replace the current clarifier; in the meantime, should you need assistance with plant operations, it is recommended you discuss with your pretreatment contact at Charlotte Water or you may contact Wes.Bell@ncdenr.gov with the MRO. All plant repairs and residuals hauling records are well documented in separate databases. For simplicity, a notebook log was recommended to be kept in the Belt -Press building to document dates/times of all related operation and maintenance. Pressed residuals continue to be hauled by Waste Management for composting at Wallace Farms in Mecklenburg County. Cargill currently is not distributing residuals under this permit. You also noted concern of potential, future odor complaints with new apartment construction in the vicinity. You may inform the MRO, should such occasions arise. The MRO would like to thank you for your time during the inspection. The inspection report is attached, should you have any questions please contact Maria Schutte by phone at (704) 235-2184 or email at maria.schutte@ncdenr.gov. Sincerely, DocuSigned by: [t.11414V H P444.61FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment(s): WQ0017321 Inspection Report CC: Mr. Daniel Imoudu, Facility Superintendent (Email) Compliance Inspection Report Permit: WO0017321 Effective: 03/01/19 Expiration: 05/31/24 Owner : Cargill Incorporated SOC: Effective: Expiration: Facility: Cargill DCAR County: Mecklenburg 5000 South Blvd Region: Mooresville Contact Person: Frank Persinger Directions to Facility: Charlotte NC 282172700 Title: Phone: 704-523-0414 System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NCG060036 Cargill Incorporated - Cargill - Charlotte Facility Inspection Date: 09/15/2021 Entry Time 01:25PM Exit Time: 03:20PM Primary Inspector: Maria Schutte Phone: 704-663-1699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Distribution of Residual Solids (503 Exempt) Facility Status: Compliant ❑ Not Compliant Question Areas: ▪ Miscellaneous Questions Record Keeping Treatment ▪ Pathogen and Vector Attraction Storage (See attachment summary) Page 1 of 4 Permit: WQ0017321 Owner - Facility: Cargill Incorporated Inspection Date: 09/15/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on September 15th, 2021, for the referenced Non -Discharge permit. The residuals processing, storage and records were reviewed and additional information requested was received in your September 23rd, 2021 email. The following items were noted to maintain overall compliance: At the time of inspection, the clarifier appeared to have floating residuals and there was sludge present along the outside wall, potentially indicating overflow or foaming conditions at some point. These observations may indicate that fats/oils are making it into the plant and/or the clarifier solids are not being wasted routinely enough to allow for proper settling (see photos in Cover Letter). While technically not a violation of this Distribution permit, inconsistent residuals processing may cause other issues with your pretreatment, discharge permit and lead to belt -press issues with poorly pressed cake. Per onsite conversation, there are plans to replace the current clarifier; in the meantime, should you need assistance with plant operations, it is recommended you discuss with your pretreatment contact at Charlotte Water or you may contact Wes.Bell@ncdenr.gov with the MRO. All plant repairs and residuals hauling records are well documented in separate databases. For simplicity, a notebook log was recommended to be kept in the Belt -Press building to document dates/times of all related operation and maintenance. Pressed residuals continue to be hauled by Waste Management for composting at Wallace Farms in Mecklenburg County. Cargill currently is not distributing residuals under this permit. You also noted concern of potential, future odor complaints with new apartment construction in the vicinity. You may inform the MRO, should such occasions arise. The MRO would like to thank you for your time during the inspection. The inspection report is attached, should you have any questions please contact Maria Schutte by phone at (704) 235-2184 or email at maria.schutte@ncdenr.gov. Page 2 of 4 Permit: WQ0017321 Owner - Facility: Cargill Incorporated Inspection Date: 09/15/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Land Application ❑ Distribution and Marketing Record Keeping Is GW monitoring being conducted, if required? Are GW samples from all MWs sampled for all required parameters? Are there any GW quality violations? Is GW-59A certification form completed for facility? Is a copy of current permit on -site? Are current metals and nutrient analysis available? Are nutrient and metal loading calculating most limiting parameters? a. TCLP analysis? b. SSFA (Standard Soil Fertility Analysis)? Are PAN balances being maintained? Are PAN balances within permit limits? Has land application equipment been calibrated? Are there pH records for alkaline stabilization? Are there pH records for the land application site? Are nutrient/crop removal practices in place? Do lab sheets support data reported on Residual Analysis Summary? Are hauling records available? Are hauling records maintained and up-to-date? # Has permittee been free of public complaints in last 12 months? Has application occurred during Seasonal Restriction window? Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑•❑ ❑ ❑•❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: This is a 503 exempt distribution permit that is currently not utilized. Belt -pressed residuals are hauled by Waste Management Services to Wallace Farms for composting. Any analyses conducted are to meet Wallace Farms requirements or for this permit renewal. Changes in management since the previous inspection may require update of Ownership or Signature Authority forms, which will be included in the email with this report. Pathogen and Vector Attraction a. Fecal coliform SM 9221 E (Class A or B) Class A, all test must be <1000 MPN/dry gram Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram Fecal coliform SM 9222 D (Class B only) Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram Yes No NA NE ❑ ❑•❑ ❑ ❑•❑ Page 3 of 4 Permit: WQ0017321 Owner - Facility: Cargill Incorporated Inspection Date: 09/15/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine b. pH records for alkaline stabilization (Class A) c. pH records for alkaline stabilization (Class B) Temperature corrected d. Salmonella (Class A, all test must be < 3MPN/4 gram day) e. Time/Temp on: Digester (MCRT) Compost Class A lime stabilization f. Volatile Solids Calculations g. Bench -top Aerobic/Anaerobic digestion results ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: This is a non 503 exempt distribution permit that is currently not utilized. The facility conducts analyses as needed for permit renewal and to meet their composting agreement with Wallace Farms. Mr. Burns noted nearby apartment building construction and expressed concern over potential odor complaints. Treatment Yes No NA NE Check all that apply Aerobic Digestion El Anaerobic Digestion ❑ Alkaline Pasteurization (Class A) ❑ Alkaline Stabilization (Class B) ❑ Compost ❑ Drying Beds ❑ Other Comment: The facility uses a "self -described" acidulation process to recapture food -grade oils that are sold. The remaining wastewater treatment process ends at a clarifier. Solids are moved directly from the clarifier to a belt -press (no additional storage or thickening). The resulting cake is housed in a roll -off container until removed by Waste Management and hauled to Wallace Farms. At the time of inspection, the clarifier exhibited signs of fats/oils and evidence of potential overflow or foaming that may be related to fats in the system or inconsistent residuals wasting. Cargill operates a pretreatment program with the Charlotte Water and has plans to install a new clarifier. See additional comments in the Summary section and Cover Letter. For this distribution permit, MRO staff recommended a notebook log be kept at the belt -press building to simplify documentation specific to residuals processing and maintenance. Page 4 of 4