WQ0003626_SOC_20090424

Shields,_Joel
From: Hope Walters [Hope Walters@campbellsoup:com]
Sent: Wednesday, August 25;-2010 1:01 PM
To: Shields, Joel.
Cc: Barnhardt, Art; Barber, Jim; John Talton; Jamie Collins; Greg Westb'rook
Subject: SOC - Change in Date
In the- SOC 'doeum' ent dated 'November 23-, 2009: on Page 2''of .the SOC ; '2 '(b),' 2Y it states that, "-
spray, irrigation system improvements are completed by September 1, 2010".
All of the spray irrigation system improvements will'.not-be completed by September.1';,2010: The,
original scope of the project has changed 'and an equalization tank has been added aS,part of the
improvements.
All Valley Pro2 Pivot Panels are installed and controlling locally (panel is set to local control). 'Dry=
walk Zones have been programmed. End gun operational zones have been programmed:` The Valley
Base, Station that controls all the pivots has also been installed in the Spray Field. -Building (office).
The sprinkler heads for all the fields (both pivots and stationary sprinklers) have been "replaced.
Actuator Upgrades for the Pivot Control Valves is:90% complete. All actuators were installed. Power
and control is not in place at this time: The actuators are being hand.operated. Control and Power
Trenching is in process. Trenching is 100% complete, with boring pending. approval of the NCDOT
right=a-way-encroachment. This is expected to be completed by December 1, 2010 or sooner. This
will. be complete, but it is designed to work in concert with the equalization tank, and therefore will. not
function completely until the installation of the tank. The system will continue to operate with as. much
functionality as possible, until installation is complete.
One Million Gallon Equalization Tank —.Engineering Design has been Stamped by PE. Design.
drawings that are being developed by Construction Resource Group have been received, reviewed
and approvedfor construction. Construction Resource Group has ordered materials to begin
fabrication of the tank. The installation of the Equalization Tank is expected to be completed by
January 1, 2011.
If you .have any questions, or need additional information please let Me know.
Thanks,
Hope
Hope A.` Walters
Environmental Manager
Campbell Soup Supply Company
2120 INC 7-1 Hwy. N.
Maxton, NC.28364
[phone] Office
(01`0) 374-5195 Cell
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4T6

4
MCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Mark T. Cacciatore
Campbell Soup Supply Company
2120 NC 71 "Highway North
Maxton, NC 28364
Division of Water Quality
Coleen H. Sullins
Director _
RE AWED
September 21, 2009 FSEP 2 3 2009
SUBJECT: SPECIAL ORDER BY CONSENT
EMC SOC S09-008
Maxton Plant and Silgan Can Company WWTP
Robeson County
PERMIT NO: WQ0003626
Dear Mr. Cacciatore:
DENR - FAYEFf EUI LLE REGIONAL OFFICE
Dee Freeman
Secretary
This letter is to acknowledge receipt of the signed Special Order by Consent (SOC) and check No. 3040
in the amount of $5,000.00 for the upfront penalty in section 2.(a) of the SOC, received from you on
September 18, 2009.
A public notice of the SOC will be published in a newspaper having circulation within Robeson County.
If there are no comments or if the comments received do. not support a public meeting, as determined by
the Director of the Division of Water Quality, the. Director will review the SOC 45 days after the public
notice.
If you have any questions concerning this Special Order by Consent, you may contact me at the Aquifer
Protection Section Central Office at [phone] or the Aquifer Protection Section staff of our
Fayetteville Regional Office at [phone].
Sincerely,
E. D. Hardee
Aquifer Protection Section
cc: Bob -Branch, -Branch Residuals & Soils LLC
a,eet�-fiV®fA
509=squ>fer.Rrotectisonection
`-
Permit File WQ0003626
AQUIFER, PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] \ FAX 1: 919-715-0588 FAX 2: 919-715-6048 \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal opportunity \ Affirmative Action Employer
Nne
OrthCarolina
tetra

13
ENFORCEMENT PAYMENTS JOURNAL
RECEIVED
SEP 2 3 2009
09/21/09 4
Page: 1
Payment IDENR—FAYEf NLLEREGIONALOFRCE_p
Fee Type Check Number Case Number Received Pay -r . Account Cost Center Company Amount County NC Statute Number
Civil Penalties 3040 S09008 09/18/2009 Campbell Soup Supply Company L.L.0 435500026 16906923 1601 $5,000.00 Robeson
Total Amount: $5,000.00
Grand Total Amount: $5,000.00
CAMPBELL SOUP COMPANY 3040
U. 55-7765/2360
k DATE 9/10/2009
PAY Payable; ... ' Originally Drawn
TO THE Dept. of Envir�i�a
ORDER OF •t'Y 5,000.00
Five thousand and 00/100 ****i *** *** *****************************
Features
r-� DOLIARaS a omaueon
4 • !i . 9ack.
ACH RrP 236077658 ACCT. 99999996
GIed*Union rP
FOR Attn:. Dir, -.Div of Water Quality •
1:2360776SEW7`523599 9611' 30L.0

WDENR
North Carolina Department of Environment and Natural Resources
Division 'of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 23, 2009
Mark T. Cacciatore
Campbell Soup Supply Company
2120 NC 71 Highway North.
Maxton, NC 28364 '
Subject: Special Order by Consent
EMC SOC WQ S09-008
Campbell Soup Supply Company
Permit WQ0003626
Roberson County
Dear Mr. Cacciatore:
Dee Freeman
Secretary
Attached for your records is your copy of the signed Special Order by Consent (SOC) approved
by the Environmental Management Commission.
The terms and conditions of the Order are in full effect, and you are reminded that all final
permit limits contained in the subject permits must be met.excent those modified by the
conditions of the Order. The -Order also contains an upfront penalty of $5,000.00, which was
paid by check No. 3040, on September 18, 2009. This payment satisfied the requirements of
SOC paragraph 2.(a).
Please note the reporting requirements in the SOC. Paragraph 2.(e) specifies when monthly
reports are to be submitted to the Fayetteville Regional Office. Additionally as specified in
paragraph 2.(d) of the Order, submittal of written notice of compliance or non-compliance with
any schedule date is required to be submitted to this office.
Pursuant to North Carolina General Statute 143-215.3D, there is an annual SOC administrative
fee of $500.00. while the Facility is under this SOC. This fee is in addition to the annual permit
fee. The Company will be billed for this at a later date.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604_ `TOne
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748 I V �I th 'aid �
Internet: vnpo .unity k Affirmative
a tine c �t ��J�
An Equal Opportunity 1 Affirmaii�s Action Employer a �,

If you have any questions concerning this matter, please contact Ed Hardee at [phone].
Sincerely,
n' Coleen H. Sullins
CHS/edh U
Attachment
cc: Bob Branch, Branch Residuals &-Soils, LLC
4LgUi�fer Protection Section. .ettev�i a Regional ©� ce w/,attar en
ermit File WQ0003626 w/attachment
SOC File w/attachment

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
RECOVER
,NOV 15 2009
DENR-FA`(tIT UILLEREGIONXURCE
IN THE MATTER OF )
NORTH CAROLINA ) SPECIAL ORDER'BY CONSENT
PERMIT ' NUMBER ) EMC SOC WQ No.S09-008
WQ0003626 HELD BY )
CAMPBELL SOUP SUPPLY )
COMPANY LLC )
Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2, this Special Order
by Consent is entered into by Campbell Soup Supply Company LLC, hereinafter referred to as
Permittee; Sand the North - Carolina Environmental Management Commission, an agency of the
State of North- Carolina created by G.S. 14313-282, and hereinafter referred to as the
Commission:
1. Permittee and the Commission hereby stipulate the following:
(a) Permittee holds North Carolina Non -Discharge permit Number WQ0003626 for operation of
an existing wastewater spray irrigation system adjacent to tributaries of the Lumber River. The
currently permitted spray system is not capable of effectively managing wastewater generated by
Campbell Soup Company LLC. Permittee, is occasionally unable to comply with limitations for
flow, and routinely hydraulically overloads spray fields resulting in excessive, ponding and
runoff in violation of Permit Number WQ0003626 conditions. Compliance will require
preparation of plans and specifications, construction and operation of additional treatment
structures, equipment and spray irrigation area.
(b) Noncompliance with the permit constitutes causing and contributing to pollution of the
waters of this State named above, and Permittee is within the jurisdiction of the Commission as
set forth in G.S. Chapter 143, Article 21.
(c) Permittee has the financial and engineering resources to determine the causes of and
solutions to permit violations and is in. the process of design and construction of new structures,
equipment and spray irrigation area, which once constructed, should be sufficient to adequately
handle and distribute wastewater in compliance with permit limitations.
(d) Since this Special Order is by Consent, neither part' will file a petition for a contested case
or for judicial review concerning its, terms.

Page 2
Campbell SOC
2. , Permittee desiring to comply .with the Permit identified in paragraph l (a) above, hereby
agrees to do the following: .
(a) As. settlement of previous violations for applying wastewater to excessively wet site
conditions, wastewater -discharges and cover crop ' deficiencies the permittee agrees to pay
$5,000.00 dollars. A certified check must be made payable to the Department of
Environment and Natural Resources and forwarded to the Director- of the Division of Water
Quality at 1617 Mail Service Center, -Raleigh, North Carolina 27699-1617 by no later than
fifteen (15) days following the date on which this Order is approved and executed by the
Commission and received by the Permittee.
(b) Undertake. the following activities in accordance with the indicated time schedule:
1) On -or before December 1,, 2009 provide NC .'DWQ with complete functional
specifications of the improved wastewater spray irrigation system.
2) On or before . January 1, 2010, provide NC DWQ with a Standard -Operating
Proceduremanual that will outline how the Permittee will manage the wastewater spray
irrigation system, spray irrigation fields and any wastewater ponding or runoff events
until the spray irrigation system improvements are completed by September 1, 2010.
3). On or before November 1, 2009, return field `B" to the original storage capacity of 6.2
million gallons.
4) .On or before December 1, 2009,, add a pivot and begin utilizing field "H" as a spray
irrigation field.
5) On or before June 1, 2010, complete trenching around field "J".
6) On or. before December 1, 2011, achieve compliance with all permit conditions.
(c) Permittee shall comply with all terms and conditions of the permit. The Permittee may also
be required -to monitor for other parameters as deemed necessary by the Director in future
permits or administrative letters.
(d) No later than thirty (30) calendar days after any date identified for accomplishment of any
activity listed in'2(b) above, submit to the Director of DWQ written notice -of compliance or
noncompliance therewith. In the case of noncompliance, the notice shall include a statement of
the reason(s) for noncompliance; remedial action(s) taken, and a statement identifying the extent
to which subsequent dates or times for accomplishment of listed activities may be affected.

Page 3
Campbell SOC
(e) The Permittee shall provide the Fayetteville Regional Office with monthly progress reports
regarding construction and upgrades pertaining to the spray irrigation system and spray irrigation
fields beginning September 7, 2009, and by the'7tt' day of each month thereafter. These
reports will outline progress' in equipment purchase and installation, and progress with field
restoration.
(f) Operate the existing waste treatment spray irrigation system to the best of the Permittee's
ability in order to stop ponding and runoff from spray irrigation fields.
(g) Prior to the completion of wastewater irrigation system improvements and in the event that
irrigation activities result in excessive ponding and/or runoff, the Permittee is expected, to
immediately take all necessary proactive steps to manage..the wastewater irrigation system by all
means necessary to minimize and limit ponding and/or runoff impact. This can include shutting
down portions of the irrigation system, installation of temporary earthen dikes to prevent
wastewater from exiting the application site, wastewater runoff collection and pumping back into
the permitted application area, increased frequency of site monitoring by personnel to list a few
examples. Each noncompliance event should be reported to the Fayetteville Regional Office
(910-433-3300) within 24 hours of discovery or the next business day following the event.
(h) If after completing the actions detailed in this Special Order by Consent, and all other
supporting documentation, permit noncompliance remains a routine occurrence, Campbell will
commit to pursue and institute additional solutions to the waste water system deficiencies by one
or more of the following: (1) adding additional application area (2) add additional waste water
storage capacity (7-30 day volume) (3) Seek other permitted waste water options.
3. Permittee agrees that unless excused under paragraph four (4), Permittee will pay the
Director of DWQ, by check payable to the North Carolina Department of Environment and
Natural Resources, stipulated penalties according to the following schedule for failure to meet,
deadlines set out in paragraphs 2(b), 2(d) and 2(e).
Failure to meet a schedule date.
Failure to maintain compliance with
any specified action contained in the SOC
or the specified actions required by documents"
subsequently produced as a part of this SOC.
Failure to achieve compliance with final
effluent management at final compliance deadline.
Failure to submit progress reports
$1000/day for the first 7 days;
$2000/day thereafter
$5000/violation,.
$5000.00
$1000.00/ per violation for first
violation; penalty doubles with each
subsequent violation

Page 4
Campbell SOC
4. Permittee and the Commission agree stipulated penalties are not due if Permittee satisfies the
Division of Water Quality noncompliance was caused solely by:
(a) An act. of God;
(b) An act of war;
(c) An intentional act or omission of a third party; but this defense shall not be available if the
act or omission is that of an employee or agent of the defendant or if the act or omission
.occurs in connection with a contractual relationship with the Permittee;
(d) An extraordinary event beyond the Permittee's control. Contractor delays or failure to obtain
funding will not be considered as events beyond the Permittee's control; or
(e) Any combination of the above causes.
Failure within thirty (30) days of receipt of written demand to pay the penalties, or challenge
them by a contested case petition pursuant to G.S. 150B-23, will be grounds for a collection
action, which the Attorney" General is hereby authorized to initiate. The only issue in such an
action will be whether the thirty (30) days has elapsed.
5. Noncompliance with the terms -of this Special- Order by Consent are subject to enforcement
action in addition to the above stipulated penalties, including injunctive relief pursuant to G.S.
143-215.6.C.
6. The Permittee upon signature of this Special Order by Consent will be expected to comply
with all schedule dates, terms, and conditions of this document.
7. This Special Order by Consent shall expire December 1, 2011.
For Campbell Soup Supply Company LLC
Print Name and Title of Signin Official
Date
Signa ure of 'Signing Official "
For the North Carolina Environmental Management Commission:
Date l 7
Chairman of the ommission

Shields, Joel,
From: Barnhardt, Art
Sent: Thursday, August 27, 2009 9:50 AM
To: Shields, Joel
Subject: RE: SOC Response
Yes I will
From: Shields, Joel
Sent: Thursday, August 27, 2009 9:40 AM
To: Barnhardt, Art
Subject: RE: SOC Response -
Art:
This looks fine to me. - Are you sending the SOC draft with the changes back to Hope and John?
From: Barnhardt, Art
Sent: Wednesday, August 26, 2009 2:27 PM
To: Shields, Joel
Subject: RE: SOC Response
How's this in your opinion for substitute language.....
If after completing theactions detailed in this Special Order by Consent, and all other
supporting documentation, permit noncompliance remains a routine occurrence, Campbell will
commit to pursue and institute. additional solutions to the waste water system deficiencies by
one or more of the following: (1) adding additional application area (2) add additional waste
water storage capacity (7-30 day volume) (3) Seek other permitted waste water options. -
From: John Talton[Tailto:[e-mail]]
Sent: Tuesday, August 25, 2009 3:55 PM
To: Barnhardt, Art
Cc: Hope Walters
Subject: RE: SOC Response
I tried to reach you this afternoon. I will try tomorrow.
Here is where I see this: we are spending over $2 million to expand our sprayfield by 20%, put in a pond so we can divert when we
have excessive rain, andiput a system in to accurately control the water applied to the fields on the fields. As discussed earlier, we are
more than 95% sure that this is going to solve'our issues with runnoff.
We are in alignment with you all that we will not have runnoff - we will meet the letter of the permit. 'If after doing all of the above,
we have issues with runnoff, we are proposing that we sit down and-develop,another plan. As I see it, there will be 3 possible solution_ s
and the DENR on listed one. The three solutions: put in more acreage (suggested in your limitation of water applied), put in a bigger
pond (a week to 30 day pond) or put in a direct discharge system for peaks in the winter months,(this is what our plant in Ohio does).
John

Shields, Joel
From; Barnhardt, Art
Sent: Monday, August 24, 2009 3:28 PM
To: Barnhardt, Art; Hope Walters; Shields, Joel; Barber; Jim; Hardee, Ed
Cc: John Talton; Robert Shober; Robert Zimmerman
Subject: RE: SOC Response
Hope/John:
One area we would like to get a more definitive response is the 2.H paragraph, specifics need to stated: Bottom line is
we are concerned. that some of the acreage is being expected (by original design) to perform water assimilation at rates
too high. We want this type evaluation/system adjustment outcome if the improvements do not satisfactorily correct
the problems. Campbell's other comments seem to be more easily accommodated.
ArtB.
From: Barnhardt, Art
Sent: Monday, August 24, 2009 11:26 AM
To: 'Hope Walters'; Shields, Joel; Barber, Jim; Hardee, Ed
Cc: John Talton; Robert Shober; Robert Zimmerman
Subject: RE: SOC Response
John/Hope:
I was away on Friday. Sorry I missed your call. Having a look at Campbell's'comments presently, and getting feedback
from all DWQ stakeholders. Campbell should hear back soon.
Thanks
ArtB.
From: Hope Walters.[mailto:[e-mail]]
Sent: Friday, August 21, 2009 2:28 FM
To: Barnhardt, Art; Shields, Joel; Barber, Jim
Cc: John Talton; Robert Shober; Robert Zimmerman
Subject: SOC Response
Please find our comments in the SOC Response attached below. If you should have any questions or need additional -information
please give me a call.
Thanks,
Hope,
Hope A. Walters
Environmental Manager.
Campbell Soup Supply Company
2120 NC 71 Hwy. N.
Maxton, NC 28364
[phone] Office
[phone] Cell
(See attached file: SOC Response. doc)

Y "Barnhardt, Art"---08/24/2009 03:28:07 PM---Hope/John: One area we would like to get a more definitive response is the 2.1-1
paragraph, specifics
From.: "Barnhardt, Art" <[e-mail]>
To: "Barnhardt, Art" <[e-mail]>, Hope Walters/US/CAMPSOUP/CSC@CSC, "Shields, Joel"
<[e-mail]>, "Barber, Jim" <[e-mail]>, "Hardee, Ed" <[e-mail]>
Cc: John Talton/US/CAMPSOUP/CSC@CSC, Robert Shober/US/CAMPSOUP/CSC@CSC, Robert
Zimmerman/US/CAMPSOUP/CSC@CSC
Date: 08/24/2009 03:28 PM
Subject: RE: SOC Response
Hope/John:
One area we would like to get a more definitive response is the 2.H paragraph, specifics need to stated.
Bottom line is we are concerned that some of the acreage is being expected (by original design) to perform
water assimilation at rates too high. We want this type evaluation/system adjustment outcome if the
improvements do not satisfactorily correct the problems. Campbell's other comments seem to be more easily
accommodated.
ArtB.
From: Barnhardt, Art
Sent: Monday, August 24, 2009 11:26 AM
To: 'Hope Walters'; Shields, Joel; Barber, Jim; Hardee, Ed
Cc: John Talton; Robert Shober; Robert Zimmerman
Subject: RE: SOC Response
John/Hope:
I was away on Friday. Sorry I missed your call. Having a look at Campbell's comments presently, and getting
feedback from all DWQ stakeholders. Campbell should hear back soon..
Thanks
ArtB.
From: Hope Walters [mailto:Hope Walters(c campbellsoup.com]
Sent: Friday, August 21, 2009 2:28 PM
To: Barnhardt, Art; Shields, Joel; Barber, Jim
Cc: John Talton; Robert Shober; Robert Zimmerman
Subject: SOC Response
Please find our comments in the SOC Response attached below. If you should have any questions or need additional information
please give me a call.
Thanks,
Hope
Hope A. Walters
2

Campbell Soup -field under'drains` '
Subject: Campbell Soup field under drains '
From: Jim Barber [e-mail]
'Pate: Tue, 03 Mar 2009.17:44:34-0500
To: Bob Branch <[e-mail]>, [e-mail], Art Barnhardt <Art,[e-mail]>, Joel Shields [e-mail]>
Bob;
After speaking with folks in Raleigh,,.,it appears that any under -drain type structure would be viewed as a "Subsurface groundwater••lowei•i'n -
drainage .system" and would require a 100' buffer per 15ANCAC 2T .0506 (a) on page 29 of the 2T rules. Hence, burying a,drainage system beneath -
the spray fields and irrigating over the top would not be allowed. It appears that the least intrusive way to deal 'with surface water drainage'
at Fields D & E, F & G and the low area in Field H would,be to have surface water diversions (i.e. ditches, page 28) that would.be buffered
- 25'. As with -recent events at the facility this would seem to be problematic at best. The ditching option may become plausible once the new '
pivots are in place, as long as -the pivots can be programed to stop spraying (both end,gun and drops) 251,from the ditch ins talled'(Field H)
and the end guns programed not to spray in fields D&E/F&G as the pivot approaches the vicinity (minimum 251,, but may'need.a larger buffer due
to,slope of field, etc.) of the'ditch placed between the fields. -
With ;the proposed re -working of Field B and the removal of soil and organic accumulation, it would appear that this material may 'suffice for
fill material.in Field H'to alleviate the low area. Since Field H is a cultivated field and is currently disturbed with 'little••or'no-- ''
vegetation; has the idea of using a -land plane -'on Field H been considered to help with redistributing:soil within the field',to'Elatten-and .•• -
minimize/remove.the low area?? Just a thought.
I'm sure we will have more discussion in the future. Give me a call at your convenience. - •-
Jim Barber -
Jim Barber • is - - -
Environmental Engineer •I _ - -
NCDENR/Div.,of Water Quality; _
Fayetteville Regional Office
225 Green,St. Ste. 714 ,
Fayetteville, NC 28301
910-433-3340 phone
910-486-0707 fax •-
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Barber, Jim h%(L0_6 ) 6P
From:
Shields, Joel
Sent:
Thursday, May 07, 2009 3:20 PM
To:
Barber, Jim
Cc:
Barnhardt, Art
Subject:
Campbell Soup
Jim
FYI. Spoke with Hope today. She said that she still hasn't received a check from corporate but as soon as it comes she
will mail in the SOC. Field G continues to have a large ponding area. I have never seen this particular area in the field
dry and one of the workers at Campbell Soup informed me that they had never seen that part of the field dry. Again it
makes me question the hydraulic capacity that was and is assigned to this field.
Joel S. Shields
Environmental Specialist
North Carolina Division of Water Quality -Aquifer Protection
225 Green Street
Fayetteville, NC 28301
910-433-3332 phone
910-486-0707 fax
*************
E-mail':correspond ence to and from this address may be subject to the North Carolina Public Records Law and
may be disclosed to third parties.
*************
1'

Beverly Eaves Perdue,
Governor -
.w���®
NC®ENit
North Carolina Department of Environment and Natural Resources
Division of Water Quality �.
Coleen H, Sullins RKE
Director. MAY 2 8
May 26, 2009 L DENR - FAYUULLEREGIQNALOFHGE
Mark T. Cacciatore
Campbell Soup Supply Company
2120 NC 71 'Highway North
Maxton, NC 28364 "
SUBJECT: NON-REFUNDABLE PROCESSING FEE -
SPECIAL ORDER BY CONSENT
EMC SOC S09-008
Maxton Plant and Silgan Can:Company WWTP
Robeson County -
Permit No. WQ0003626
Dear Mr. Cacciatore:
Dee. Freeman
Secretary
This letter is to acknowledge receipt of your application for a Special Order by Consent (SOC) and. check
No. 200001944 in the amount of $400.00 received from you on May 14, 2009.
By copy of this letter we are forwarding your application to the Fayetteville Regional Office for review
and processing.
If you have any questions concerning this Special Order by Consent, you may contact me a `ihe Aquifer.
Protection Section Central Office at [phone] or the Aquifer Protection Section staff of our
Fayetteville Regional Office at 910-433-3300.
Sincerely,
E. D. Hardee
Aquifer Protection Section
cc: Bob Branch, Branch Residuals & Soils, LLC
Fayetteui!lle Regional Off ce
S09-008 Files
Aquifer Protection Central Files
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604 On,.e,1
Phone: [phone] FAX 1: 919-715-0588 FAX 2: 919-715-60481 Customer Service:1-877-623-6748 NOl iCar01111a,
Internet: www.ncwaterquali�.org
�J1 f/j� //
An Equal Opportunity IAffirmativeAction Employer �/ ►ate"alYff

sr -
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC),
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, other): Campbell Soup Supply Company, LLC
2. Print or Type Owner's or Signing Official's Name and Title: Mark T. Cacciatore, Senior
h Director of Operations
3. Facility Name (as shown on Permit): Campbell Soup Supply Company, LLC
4. Application Date: March 20, 2009
U•
1 5. NPDES Permit No. (if applicable): WQ0003626 (Spray Irrigation)
6. Name of the specific .wastewater treatment facility (if different from I.3 above):
same as above -
II. PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the
appropriate regional office staff to discuss whether or not an SOC is appropriate for this
situation. Please not the date this meeting occurred: March 12, 2009
III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government
may request additional flow. .
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that do not include failure to perform
proper maintenance on treatment systems. Collections systems or disposal systems.
When requesting additional flow, the facility must include its justification and supporting
documentation.
If the requested additional flow is non -domestic, the facility must be ableto demonstrate
the ability to effectively treat the waste and dispose of residuals. The applicant must
• provide a detailed analysis of the constituents in the proposed non -domestic wastewater.

The total domestic additional flow requested:
The total non -domestic additional flow requested:
The total additional flow (sum of the above):
N/A
N/A
N/A
gallons per day.
gallons per day.
gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Please be advised that any
additional flow allowed by this requested SOC will be determined by a complete analysis of
any projected adverse impact to wastewater treatment facilities and surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding
the necessity of the proposed SOC. Include the following issues:
• Existing and/or unavoidable future violation(s) of permit conditions or limit(s),
• The existing treatment process and any modifications that have been made to
date,
• Collection system rehabilitation work completed or scheduled (including dates),
• Identify any non -compliant significant industrial users and measure(s) proposed
or taken to bring the pretreatment facilities back into compliance. If any
industrial facilities are currently under consent agreements, please attach these
agreements.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with
expertise in wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and
recommendations as to how the efficiencies of these facilities can be maximized.
• A certification that these facilities could not be operated in a manner that would
achieve compliance with final permit limits.
• The effluent limits that the facility could he expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider
interim construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone
dates for beginning construction, ending construction, and achieving final compliance.
In determining the milestone dates, the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to
DWQ for review and approval.
• Occurrence of major construction activities that are likely to affect facility
performance (units out of service, diversion of flows, etc.)
• Infiltration/Inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if
applicable.
• Toxicity Reduction Evaluations(TRE), if necessary.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to
bring the facility into compliance. Possible funding sources include but are not limited
to loan commitments, bonds, letters of credit, block grants and cash reserves. The
applicant must show that the funds are available, or can be secured in time to meet the
schedule outlined as part of this application.
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION
OF WATER QUALITY UNLESS ALL OF THE APPLICABLE ITEMS ARE
INCLUDED WITH THE SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed
application form, along with all required attachments.
• If the SOC is for a City/Town, the person signing the SOC must be a
ranking elected official or other duly authorized employee.
• If the SOC is for a Corporation/Company/Industry/Other, the person
signing the SOC must be a principal executive officer of at least the
level of vice president, of his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be
the Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the
North Carolina Administrative Code [T15A NCAC 2H.1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00.
A check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)

APPLICANT'S CERTIFICATION:
I, Mark T. Cacciatore, attest this application, for a Special Order by Consent (SOC) has been
reviewed by me and is accurate and complete to the best of mu knowledge. I understand if all
required parts of this application are not completed and if all required supporting information and
attachments are not included, this application package may be returned as incomplete.
Furthermore, I attest by my signature that I fully understand that an upfront penalty,
which may satisfy as a full settlement for past violations, may be imposed. {Note: Reference
to upfront penalties in Special Orders by Consent may be found in the North Carolina
Administrative Code[T15A NCAC 2H.1206©(3)].}
Sig ture of Signing Official
/Ad T : (acc,g f-c
Printed Name of Signing Official
Date Oi‘/ef
THIS COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS; SHOULD BE SENT
TO FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER QUALITY
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636

IV. NECESSITY NARRATIVE:
NOV-2009-PC-0085
NOV-2009-PC-0144
Sections of the existing infiltration fields experience ponding, and rainfall runoff problems during
high soup season (October— February) and during extended periods of rain. Field H is already
included in the current permit and a capital project has been developed to prepare it for
utilization. The addition of Field H will allow greater flexibility during times of harvesting,
repair, maintenance and extended periods of rain.
In addition, the control system at the spray fields has proven,to be unreliable. The equipment
that was installed in 2004 has experienced repeated failures and is not operating automatically,
requiring the system to be operated manually. Campbell intends to resolve the following
equipment system issues: automatic and reliable valves feeding the pivots/spray fields;, automatic
capability to turn the pivot drives on/off; the system must operate within a consistent pressure
range - i'.e. 60 to 90 psi, and the spray field pumps must operate within a normal duty cycle and
not cycle on and off.
Field B was originally designed as a high rate infiltration area to be used during emergency
situations such as electrical, mechanical or pump failures. Over the years, sedimentation and
berm erosion have decreased the overall capacity of this area. Current thinking by both
Campbell and DENR is to utilize Site B during periods of extreme weather (tropical storms,
heavy rains, hurricanes, etc.) in addition to the other emergency situations. Excavation of the
infiltration basin and improvement of the basin berms will return Site B to its original
configuration and capacity to accommodate this operational change..
Campbell Soup Supply Company intends to install management systems to allow the operator to
respond quickly to areas of the sprayfields which are holding wastewater and/or could potentially
allow run off. The operator will have the control to avoid application on specific sections of the
sprayfields and additional acreage to divert the wastewater away from any problematic sections'
of the sprayfield. To ensure that the system is operated per design, a Daily Management
Systems (DMS) will be developed and enforced by the operator of record.

V. CERTIFICATION
Based on my review of Campbell Soup Supply Company's spray irrigation infiltration
treatment system, the following changes will be made to achieve permit compliance:
• Increase acreage for application of wastewater
• Implement control systems to allow the operators to manage efficiently the
application .of wastewater on current and new acreage, and
• Manage distribution of the application of wastewater over the entire infiltration
system, maintain the equipment necessary to pre -treat and distribute the
wastewater and manage the soils and crops of each field to ensure the proper
treatment of the applied wastewater.
Currently there is sufficient land to handle the hydraulic load. However, during peak
production periods this land must be available to receive wastewater. Equipment
breakdown, soil wetness, crop needs, routine maintenance or unforeseen events during
peak production periods could lead to poor distribution of the wastewater. If one spray
field is unavailable, more pressure is placed on the remaining irrigation fields.
Additional land to allow operational flexibility would help eliminate the cause of the
issued NOV's.
The current control system, while designed to grant the operator the necessary flexibility,
does not provide a reliable mechanism to distribute the amount of effluent sprayed over
specific portions of the infiltration fields. Problematic areas include the valve, control
system, spray head, end gun, and flow metering systems. Replacements with a proven
and reliable system will help in addressing the issues noted in the NOV's issued by the
regional office.
Management is perhaps the most critical component for any spray irrigation system.
Without proper management, even the best designed system will suffer failure. The
Operator will emphasize crop management, irrigation scheduling, metering calibration,
hay harvesting, equipm - 015 a - employee training, and field oversight.
Date

VI. PREDICTED COMPLIANCE SCHEDULE:
Campbell Soup Supply Company — Maxton, NC
Sprayfield Expansion Project
Description
Completion Date
"B" Field (return to original storage capacity of 6.2 MG)
September 1, 2009
"H" Field (add pivot and utilize as sprayfield)
September 1, 2009
September 1, 2009
Additional Ditching Around "J" Field
Control System Project Upgrade
Description
Completion Date
Total Project
Complete Sept/2010
Timelines for Control System Upgrade
Evaluate current conditions of control equipment
March 31, 2009
Develop long term plan
June 1, 2009
Install and Startup A, C, D, E, F, G, I, J (include control for H)
August 31, 2009 —
September 1, 2010

VII. FUNDING SOURCES IDENTIFICATION:
Currently Campbell Soup Supply Company is in the process of installing two new
DAF (Dissolved Air Floatation) units. This capital project was funded and
approved for $2.6 million and demonstrates Campbell's commitment to
improvement and sustainability. -
A project has been written and funded ($700,000) for Field H (utilizing as a spray
field), Field B (returning it to original storage capacity of 6.2 MG) and additional
ditching around Field H & J. -
Engineering is working to develop a scope of work for the Control System
Project, after which the anticipated funds will be available after June 30, 2009.

SOC Pre -Application Certification
Special Order by Consent Pre -Application Certification:
On March -12, 2009 , DWQ regional office staff met with
(pre -application meeting date),
Campbell Soup Supply Company, LLC / WQ0003626 to discuss the needs
(facility, name/permit number)
and merits of applying for a Special Order by Consent (SOC),. Based on the Information .
presented during this meeting and -the facility's non -compliant status with permit conditions
and/or other state rules and regulation, I support this facility's application submittal.
Date_ 'J — 1.
It
Sign a Me Office Supervisor
L
DWQ R gional Office

.1t7.130/2009 20:25 an-715-0588 NODEMR/WATER OUAL PAGE 02
6.
NORTE CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF ROBESON
IN THE MATTER OF
NORTH CAROLINA
PERMIT NUMBER
WQ0003626 HELD BY
CAMPBELL SOUP SUPPLY
• COMPANY LLC
SPECIAL ORDER BY CONSENT
EMC SOC 1,y,',Q•sNo.S09-008
--&:• -
Pursuant to provisions of North 'Carolina General,,SWites .(G.S.) 143-21 ... 41fthis Special Order
by Consent is entered into by Campbell Soup $0g--i Company LLC, hereinkk:referred to as
Permittee, and the North Carolina Environmenia.4ganagementommission, aii-H4gency of the
State of North Carolina • created. by G.S. 143t-'..m2, aiiihereinafter referred to as the
. .
Commission: • .s"...nz.c.
• .-::::17..i::,:„....
1. Permittee and the Commission here15Stkf ,te the follov4g;.
.....
.:;,:,,:.;•
(a) Permittee holds North Carolina Non-Di;•gp'harge ...*::::(..,....umbeMiQ000.3626 for operation of
an existing wastewater siga.:5.ka,tion sysiaLadi4nt t-'64,%taries of the Lumber River. The
currently permitted sprg*stexxisi4ot capab1igi7afectively managing wastewater generated by
Campbell Soup Co10*.., LLC. Pk3#iittee is eficasionall3r unable to comply with limitations for
flow, and rotiinelyAydraulically,M.Nieloads spray fields resulting in excessive pontliEg and
runoff in violation :.;"4'..,ermit.,-V*IS44*-W.Q0001:626 conditions. Compliance will require
...:•-f•••::,,•::.• --t:,•-•:-..?7•• • •••,4..:,•<.*:..,-;:::,;.,• ...,..- .
preparation,,,,A•Oans atitl$ii,,44.fications-;'4'*i#1,16tion and operation of. additional treatment
structuresAgiiiiiittiwid sPegiirrigation area.
,,,,,,:•c..:4]-- ,*:•:,,.:•. -,!•,::;•,...:•..
- ...;:,8:::,:.-7. '°:::i;:::;E:::-:.. '''''.ii':Ni•-;• .
..:-:::;:-:-::::' ,;,:.-7.•:.::•. :•.u.;.,
(b) INTOComplia.nce with,, ..,...e per.i.:,ng...tKoonstitutes causing and contributing to pollution of the
raters*this State narnedliiove, anV ermittee is within the jurisdiction, of the Commission as
set forth ik..,,,S. Chapter 14il*t..... icle 21.
"?.,,,f-,;-..,..:.•:,,.:.,..,
!•:-..-:.:
p....,,:,.
(c) P ermittee*s,,the fi446ial and engineering resources to determine the causes of and
solutions to permiRiklpiga and is in the process of design and contraction of new structures,
equipment and .spraY";AiTigation, area, which once constructed, will be sufficient to adequately
. handle and distribute wastewater in compliance with permit limitations. \__. 4i--;i---•,...„;,...s,„%:;7••••_=
_ .
(d) Since this. Special Order is by Consent, neither party will file a petition for a 6bn:tested Case
or for judicial review concerning its terms. d -

07/30/2009 20:25 919-715-0588
NODE&NR/WATER QUAL PAGE 03
2. Permittee desiring to Comply with the Permit identified in paragraph 1(a) above; hereby
agrees to do the following:
(a) As settlement of previous violations for applying wastewater to excessively wet site
conditions, wastewater discharges, and cover crop deficiencies/ the perrittee agrees to pay
$12 O'0.0 00 dollars: A certified check must be made payable to the Department of
Environment and Natural Resources and forwarded to the Director of the Division of Water
Quality at 1617 Mail Service Center, Raleigh, North Carolina 7699-1617 by no later than
fifteen (15) days following the date on which this Order is:a,•oved and executedby the
Commission and received by the Permittee.
(b) Undertake the following activities in accordance with_th:%ndicate:ne schedule:
1) On or before Jiiiiiy' : 0 , provide NC DWi/Vith complete functia ial.specifications of
the improved wastewater spray irtigation,s; stem.
2) On or before JuIy 1 2009, provide NC DWQ with a; dard Operating Procedure
manual that will outline how the Permittee wiltiLetii ge the wastewater spray irrigation
system, spray irrigation fields and an ? .wastewater lion:Zino- or runoff events until the spray
irrigation. system improvements are a mp1 d-by Septet er.,1, 2010,
3) On or before September 1, 2009 tdurn field In. thetg nal storage capacity of 6.2
million gallons. .;
4) On or before eptember 10009, add-JaLpivot and begin utilizing field "H" as a spray
irrigation
• 5) On or before Se p't` . - "J„ -
����,ex;�Y, •20•4� eoiap��te trenching around field
n or before Si i
10, achieve compliance with all.
permit conditions.
•
(c) PemiitigLihall comply v all terms• and conditions of the permit. The .Permittee May also
be required to i monitor *Other parameters as deemed necessary by the Director in future
permits or adrninis tw letters.
(d) No later than thirty (301 calendar days after any date identified for accomplishment of any
activity listed in2(b) above, submit to the Director of DWQ written notice of compliance or
noncompliance therewith., In the case of noncompliance. the notice shall include a statement of
the reason(s) for noncompliance- remedial action s) taken, and a statement identifying the extent
to which subsequent dates or times for accomplishment of listed activities may be affected.

07/3012009 20:25 919-715-0588
NCDE&NR/WATER QUAL - PAGE 04
(e) The Permittee shall provide the Fayetteville Regional. Office with monthly progress reports
regarding construction and upgrades pertaining to the spray irrigation system and spray irrigation
fields beginning ; °illy3140:0:9. These reports will outline progress in equipment purchase and
installation and progress with field restoration. at'c3{ 4
(f) Operate the existing waste treatment spray in-igation system to the best of the Permittee's •
ability in order to stop ponding and runoff from spray irrigation fields.
(g) Prior to. the completion of wastewater irrigation system improyeni�eiits and in the event that
- irrigation activities result in excessive ponding and/or runoff, the;Pezmittee is expected to '
' .immediately take all necessary proactive steps to manage -the wastewater irrigation, system by all
.means necessary to 'minimize and limit pending and/or runofann.paCe is 'can include shutting
down portions of the irrigation system, installation of temporary earthen` ikes to prevent -
wastewater from ,exiting the application site, wastewatqizurioff collection`thi.,pumping back into
the,pennitted application area, increased frequenoy4,r Bite monitoring by personnel to list a few
•
examples. Each noncompliance event should be reported to the Fayetteville Regional Office
(910-43 3 -3300) within 24 hours of disco' ery'or The next business -day following fhieOent.
(h) In the e ent that wastewater ruzibff continues to ocr;ar'he wastewater irrigation system
improvements are made due to the site' nability to assim late the wastewater volume, the
• Permittee will conduct a thorough hp*R.rlpgic assessrent of the spray irrigation facility that
will determine the suitable hydraulic Cap oit Res*ates for e .:.,,3ndividual spray irrigation site.
Adjustments to the volume of wastewater<applied-`t >:each site woailxi be required and possibly
result in the need to modify the permit. r .` .. •;; r` ` •
3. Perrittee agrees thati n1ess .e c. sed under pariiigraph four "(4), Permittee will pay the.
Director of DWQ, byw &ck payableto, the North Carolina Department of Environment and
Natural. Resotirces,‹stpulated penalties according to, the following schedule for failure to meet
deadlines set out in hs 2.(b 2 ,d) ..and 2.(e)- '
dule 4ate,
Failure to meet~0.
Failur : naintain compliance with`
any speor€ted:action contained:zn the SOC
or the specifie'aactions requiki4.by documents
subsequentlypro aced as aOt of this SOC.
Failure to achieve coinp'lt-ance with final
effluent management at''final compliance deadline.
Failure to submit progress reports •
$1000/day for the first 7. days;
S2000/day thereafter
$5000/violation
$5000.00 -
"$1000.00/ per violation for, first
• violation; penalty doubles with each .
. subsequent violation

''k7/3012009 20:25 919-715-0588
NCDE&NR/WATER QUAL
PAGE..05
4. Permittee and the Commission agree stipulated penalties are not due if Permittee satisfies the
Division of Water Quality noncompliance was caused solely by:
:`(a) 'An act of God;
(b) An•act of war;
-.(c) An intentional act or omission of a third party, but this defense shafY;.not be available if the
act or.omission is that of an employee -or agent of the defendant .or if the act or omission
occurs m connection with a contractual relationship with the; "en nttee;
(d) An extraordinary event beyond the Pennittee's control, Contractor'd4ays or failure. to 'obtain .
funding, will not be 'considered, as events beyond thePnnittee's conti:St r:
(e) Any combination of the above causes.
Failure within thirty (30) days of receipt of written dei. land to p'ay. the penalties, or challenge
them by a contested case petition pursuant to G..S. 150B::`.2 twill be grounds for a collection
action, Which the Attorney General is hereby authorized tovitiate. The only issue in such an
-.•.,.ti: tip•
action will be whether the thirty (30) da%s;ha:s..tlapsed.
5. Noncompliance with the terms of this Special ;onseiiti'ar'e subject to enforcement
action in addition to the abo?etistxpulated peira ti s; i cludin r motiye:reliefpursuant:to G.S.
6. The Permittee, 'Upon, siEenature dfTis Special Order by Consent, will be expected to ;comply
with all schedule dates terns an 1 Ci iiditions of tlii ` iocwnent.
7. Thisecia1 1 rVby Gainsent shall expire D
,Specember,:1, 2011. •
143-215.6.C.
For Campbe11 Soup Supply Company LC
Print - Crn...lr S. -..:g Official
Date
Signature of Signing Official
For the North Carolina Environmental Management Commission:
• *Date
Chairman of the Commission

November 6, 2009
Mr. Joel Shields
NCDENR
Division ofWater Quality
225 Green Street
Suite 714
Fayetteville, NC 283-01-5043
Dear Mr. Shields:
Attached is the.monthly progress report for Campbell Soup Supply Company.:
The monthly progress report summarizes construction and upgrades pertaining
to the spray irrigation system and spray irrigation fields.
Field E3,'
• Field B has been dug out, graded and the field hes been returned to the
,
original design capacity of 6.2 million gallons. The project for Field B has
been completed.
Field H
• Seeding &field H was:connpleted mid October and the addition of lime
and fertilizer was completed the last week of October.
• Floyd Construction installed an 8 inch manual cut off valve that can
isolate Field,H and Field J, so they both don't have to operate at the same
time. This manual cut off was installed near the Field J loop_where the 12
inch lines reduces down to an 8 inch line. This was installed on October
30th.
• Field H Pivot was started up on Tuesday, NoVember 3rd,it ran only about
an hour to ensure proper operation and then it was stopped until the flow
meter, installation and calibration was competed:
• CAROTEK completed installation and calibration of the flow meter on
Thursday, November 5th.
• Field H Pivot was started again on Thursday (November 5th) afternoon at
1:00 PM. It was in operation four hours and then a pipe feeding the pivot
from the flow meter blew loose and operation had to be stopped for
repair. Anticipating putting the pivot back in service on Monday,
November 9, 2009.
Field J
• Installation Of 2100 LF of piping in Field J has been completed (September
2009). The 'piping was placed in a herringbone pattern in the field and
drains to the adjacent L Ditch.

• Installation of 750 LF of 15 inch pipe with manhole and installation of 1025
LF of 18 inch pipe with manhole began in mid October and is currently
85% complete, it should be completed by mid November.
Timber Project (Land Application Site)
• Project is complete and ready to receive residuals for land application
(October 5, 2009).
• The rows have been cut out in the timber to be used for land application,
and all the mulching of the rows to remove debris and tall stumps has
been completed.
• The permit modification for land application to include the timber acres
and new acres at the spray fields was received by Campbell Soup on
October 9, 2009. Timber acres and new acres at the spray fields can now
beutilized..
•
Spray Field Controls Project
• The project was approved on October 8, 2009.
• The kick off meeting between the Maxton Plant and World Head Quarters
to start mapping out the path of the project was held on October 28, 2009.
• Guess Irrigation to quote and install the Valley panels and controls for
each pivot.
• South East Farm Equipment to quote and install replacement sprinkler
heads for all the pivots and stationary sprinklers:
• Field F — Grading work and filling in of low areas and large holes.
Surveying work began the first week of November.
• Field G - Installation of 300 LF of 18 inch pipe and 770 LF of 13.inch pipe,
a 15 inch x 18 inch "T" and 400 ton of #57 was stone. This to alleviate
ponding issues on the back side of Field G (edge of Field H borders this
area). Surveying has been completed and work is anticipated to begin
mid November.
Please let me know if you need any additional information, or have any
questions.
Sincerely.
Hope A. Walters
Environmental Manager
Campbell Soup Supply Company
2120 NC 71 Hwy. N.
Maxton, NC 28364
[phone] Office
[phone] Fax

C4I—PaSCL -90-0 /0
1nl 6L 6-0
Barber, Jim,
/RJZ 64T104J
From: Hope Walters [Hope_Walters@campbellsoup:com]
i
Sent: Friday, September 04, 2009 2:55 PM
To: Shields, Joel; Barnhardt, Art; Barber, Jim
Cc: John Talton
Subject: Monthly Progress Report - September
Attachments: Monthly Progrss Report - September.doc
Attached is the monthly progress report. Please let me know if you need any additional informations
Have a safe and happy Labor Day Holiday!
Thanks,
Hope
(See attached file: Monthly Progrss Report - September.doc)
This e-mail and.any files transmitted with.it may contain -
confidential information and is intended solely for use by
the individual to whom it is addressed. If you received
this e-mail in error, please notify the sender, do not
disclose its contents to others and delete it from your
system.
f

September 4, 2009
Mr. Joel Shields
NCDENR
Division of Water Quality
225 Green Street
Suite 714
Fayetteville, NC 28301-5043
Dear Mr. Shields:
Attached is the monthly progress report for Campbell Soup Supply Company.
The monthly progress report summarizes construction and upgrades pertaining
to the spray irrigation system and spray irrigation fields.
Field B
• Field B has been dug out, graded and the field has been returned to it's
original design capacity of 6.2 million gallons.
• A six inch pipe to return water from Field B backs to the pump house was
installed.
• Permanent six inch hook up -flanges were installed for the portable pump.
• Field B has been reseeded with a combination of Bermuda, Fescue and
Rye grasses.
• A 10 ft. x 14 ft. concrete pad with one inch I -bolts and six inch curbs on
two sides for the portable pump is scheduled to be poured by September
15th. The sidewalk at the pump house will be replaced and a splash pad
down in the base of Field B will be poured 'at the same time.
• Powers Surveying is currently working on as built drawings for Field B.
Field H
• The pivot mechanical assembly has been completed.
■ Installed the new style tracks on the wheels on the new pivot.
These must be properly set up when the pivot operates.
• 970 LF of 8 inch water line to supply wastewater to the pivot has been
installed.
• Floyd Construction is currently working on cutting (sloping) a flat area on
the west side of the field to the west retention pond. Anticipates being
finished with all grading by September 11, 2009.
• Pipe connection at pivot base and the plug valve installation is expected to
be completed by Tuesday, 9/8/09.
• Floyd Construction is scheduled to install the Dezurik plug valve install in
the valve vault Tuesday, September 8th. The Manual valve will remain in
place following installation.

• McCarter started pulling cable on Tuesday, 9/01/09 for the one on two
multi -conductor cables that run from the pump house to the valve vault.
Anticipates finishing by week ending 9/11/09.
• McCarter's Electric Division is constructing the Isolation Relay and
Metering Panel and the Valve Vault Terminal Box, both must be
constructed to complete the electrical install.
• . CAROTEK is on scheduled to install the actuator for week -ending Friday,
September 18th. . .
• Seeding of Field H is scheduled for the week of September 28, 2009.
Field J
• Installation of 2100. LF of piping in Field J has been completed. The piping
was. placed in a herringbone pattern in the field and drains to the adjacent
L Ditch. r
• Installation of 750 LF of 15 inch pipe with manhole and installation of 1025
LF of 18 inch pipe with -manhole (this is included in the Spray Field
Controls Project — this project is currently circulating for signatures
for approval)
Timber Project (Land Application Site)
• Rows have been cut out in the timber to be used for land application.
• Mulching of the rows to remove debris and tall stumps is on -going.
• The permit modification for.land application to include the timber acres
and new acres at the spray fields has been submitted. Jim Barber has
completed the site review and Raleigh has requested some additional
information (requested on'9/3/09). Working on completing the request for
additional information.
Spray Field Controls Project
• The project has been written and is currently circulating for signatures for
approval.
Please let me know if you need any additional information, or have any
questions.
Sincerely.
Hope A. Walters
Environmental Manager
Campbell Soup Supply Company
2120 NC 71 Hwy. N.
Maxton, NC 28364
[phone] Office
[phone] Fax

aid p�� WORLD HEADQUARTERS
1 Campbell Place
Camden, New Jersey 08103-1799
May 21, 2009
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Aquifer'Protection Section
1636 Mail Service Center
Raleigh, NC 27690-1636
Subject: Signatory Authorization
To Whom It May Concern:
I, Dave Biegger, Vice President, North American Supply Chain designate, Mark T.
Cacciatore, Senior Director of Operations for Campbell Soup Supply Company,
LLC, Maxton Plant as the duly 'authorized representative in all facility- signatory
matters. He is responsible'for the overall operation of the-Maxton Facility from
which' all permitted requirements originate. He has signatory authority in all
matters relating to the Maxton Facility.
Please ' don't hesitate to contact me if you should need additional- information
[phone].
Sincerely,
Dg
David B. Biegger
Vice President, North American Supply Chain
cc: Mark' T. Cacciatore

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DOCUMENT INVOICE INVOICE
NUMBER NUMBER DATE AMOUNT. DISCOUNT
Nglife'r proter.tion Serf, on
MAY 1-4 2009
MENT'HAS, MULTIPLE, SECURITY -FEATIJ
J§upply Co.,
2009/05104
WACHOVIA BANK, N.A.,.
PAY Fo�r. hundred, and,00/100"Doll�rs
To The
Orderof NCDENR-DIVOF WATER QUALITY
AUTHORIZED SIGNATURE
lie 2[]000 L944no 1:03 L LOD 2 2So: 20?99S LOPiR11I?On8
|---- |---- |---- |---- |---- |---,- |---- ----1 '----
L___. L___|
SEE REVERSE SIDE FOR OPENING INSTRUCTIONS
Campbell Soup Supply Co.
Campbell Soup Company
Campbell Place
NCOENR'DNDFWATER QUALITY
1G17MAIL SVCCTR
RALBGH'NC27GQQ'1617
�
'
'
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MENT'HAS, MULTIPLE, SECURITY -FEATIJ
J§upply Co.,
2009/05104
WACHOVIA BANK, N.A.,.
PAY Fo�r. hundred, and,00/100"Doll�rs
To The
Orderof NCDENR-DIVOF WATER QUALITY
AUTHORIZED SIGNATURE
lie 2[]000 L944no 1:03 L LOD 2 2So: 20?99S LOPiR11I?On8
|---- |---- |---- |---- |---- |---,- |---- ----1 '----
L___. L___|
SEE REVERSE SIDE FOR OPENING INSTRUCTIONS
Campbell Soup Supply Co.
Campbell Soup Company
Campbell Place
NCOENR'DNDFWATER QUALITY
1G17MAIL SVCCTR
RALBGH'NC27GQQ'1617
�
'
'
�
�
lie 2[]000 L944no 1:03 L LOD 2 2So: 20?99S LOPiR11I?On8
|---- |---- |---- |---- |---- |---,- |---- ----1 '----
L___. L___|
SEE REVERSE SIDE FOR OPENING INSTRUCTIONS
Campbell Soup Supply Co.
Campbell Soup Company
Campbell Place
NCOENR'DNDFWATER QUALITY
1G17MAIL SVCCTR
RALBGH'NC27GQQ'1617
�
'
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ENFORCEMENT PAYMENTS JOURNAL 05/26/09
Page:'I J
Payment
Fee Type Check Number Case Number Received Payor- Account Cost Center Company Amount County NC Statute Number
SOC Application Fee 200001944 S09008 05/14/2009 Campbell Soup Supply. Company 435100095 2341 1602 $400.00 Robeson
Total Amount: $400.00
Grand Total Amount: $400.00
r

-Beverly Eaves Perdue
'Governor
NCD�NR
North -Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins . 4JR`_ M
Director
May 26, 2069. S�E� � r F',t�"tTi tilt t 8 0:rJf lt£ai t;r �lGl
V' K.
Mark T. Cacciatore d� `
Campbell Soup Supply Company (,Y0,�
2120 NC' 71 Highway North �oP
Maxton, NC 28364 e 5��a
SUBJECT: NON-REFUNDABLE PROCESSING FEE ,
Ga
SPECIAL ORDER BY CONSENT V p
EMC SOC S09-008
Maxton Plant and Silgan Can Company WWTP
Robeson County
Permit No. WQ0003626
Dee Freeman
Secretary
Dear Mr. Cacciatore:
This letter is to acknowledge receipt of -your application for a Special Order by Consent (SOC) and check '
No. 200001944 in the amount of $400.00 received from you on May 14' 2009.
By copy of this letter we are forwarding your application to the Fayetteville Regional Office'for review
and processing.
If you have any questions concerning this Special Order by Consent, you may contact me at the Aquifer .
Protection Section Central Office at [phone] or the Aquifer Protection Section staff of our
Fayetteville Regional Office at 910-433-3300.
Sincerely,
B. D. Hardee
Aquifer Protection Section
cc: Bob Branch, Branch Residuals & Soils, LLC
Fayetteville Regional Office
S09-008 Files
Aquifer Protection Central Files
AQUIFER PROTECTION SECTION
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital Boulevard, Raleigh, North Carolina 27604
Phone: [phone] FAX 1: 919-715-0588 FAX 2: 919-715-60481 Customer Service:1-877-623-6748
Internet: www.ncwaterqualit .org . , '
An Equal Opportunity% Affirmative Action Employei
Nor iCarolilia
Naturoilt�
r

STATE OF NORTH CAROLINA .
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY.
APPLICATION FORA SPECIAL ORDER -BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1.. Applicant (coMoration,,individual, other): Campbell Soup Supply Company LLC
2.., Print or Type .Owner's or Signing Official'.s Name and Title: Mark T. Cacciatore Senior
Director of Operations
3. Facility Name (as shown on'Permit): Campbell Soup Supply Company LLC
4. Application Date: March 20.2009
5. NPDES Permit No. (if applicable): WQ0003626 (Spray Irri atio
-6. Name of the specific wastewater treatment facility (if different from I.3 above): -
same as above
II; PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the
appropriate regional office staff to discuss -whether or not an SOC is
`appropriate for this
situation. Please not the date this meeting occurred: March 12 2009
III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government
may request additional flow:
Additional flow may be allowed .under'an SOC only: in specific circumstances. These
circumstances may include eliminating discharges that do not include failure to perform
proper. maintenance on treatment systems. ;Collections systems or disposal systems.
When requesting additional flow, the facility must include its justification and supporting
documentation.
If the requested additional flow is non -domestic, the facility must be able to demonstrate
the ability to effectively treat the waste and dispose of residuals. The applicant must
provide, a detailed analysis of the constituents in the proposed non -domestic wastewater.

The. total domestic additional flow requested:
The total non -domestic additional flow requested:
The total additional flow (sum of the above):
N/A gallons per day.
N/A gallons per day.
N/A gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Please be advised that any
additional flow allowed by this requested` SOC will be determined by'a complete' analysis of
any projected adverse impact to wastewater treatment facilities and surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding
the necessity of the proposed SOC. Include the following issues' -
Existing and/or unavoidable future violation(s) of permit conditions or.limit(s),
•_ The existing treatment process and any modifications that have been made to
date
• Collection system rehabilitation work completed or scheduled (including dates),
• Identify any non -compliant significant industrial users and measures) proposed
or taken to bring the pretreatment facilities back into compliance. If any
industrial facilities are currently under consent agreements, please attach these
agreements.
V. CERTIFICATION:
The applicant.must submit a report prepared by an independent professional with
expertise in wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and
recommendations as .to how the efficiencies of these facilities can be maximized.
• A certification that these .facilities could not be operated in a manner that would
achieve compliance with final permit limits.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency. during the term of the requested SOC (be sure to consider
interim construction phases).
• Any other actions taken. to correct problems prior to requesting the SOC.

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit,a detailed listing of activities. along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone
dates for bekinnina construction ending construction and achieving final compliance
In determining the milestone dates, the following should be' considered:
• Time for submitting plans, specifications and appropriate engineering reports to
DWQ for review and approval.
• Occurrence of major construction activities that are likely to affect facility
performance (units out of service, diversion of flows, etc.)
• Infiltration/Inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if
applicable. .
• Toxicity Reduction Evaluations(TRE), if necessary. .
VII. FUNDING SOURCES IDENTIFICATION:
The, applicant must list the sources of funds utilized to complete the work needed to
bring the facility into compliance. Possible funding sources include- but are not limited
to loan commitments, bonds, letters of credit, block grants and cash reserves. The
applicant must show that the funds are available, or -'can be secured in time to meet the
schedule outlined as part of this application.
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION
OF WATER QUALITY UNLESS ALL OF THE APPLICABLE ITEMS ARE
INCLUDED WITH THE SUBMITTAL.
Required Items
a. One original and two copies of the completed .and appropriately executed
application form, along with all required attachments.
• If the SOC is for a City/Town, the person signing the SOC must be a
ranking elected official or other duly authorized- employee'
• If the SOC is for a Corporation/Company/Industry/Other, the person
signing the SOC must be a principal executive officer of at least the
-level of vice president, of his duly authorized representative.
• Jf the SOC is for a School District, the person, signing the SOC must be
the Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the
North Carolina Administrative Code, [Tl5A'NCAC 2H.1'206(a)(3)].
.b. { The non-refundable Special Order by Consent (SOC) processing fee of $400.00.
A check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation -report prepared -by an independent consultant with expertise in
wastewater. (in triplicate)

APPLICANT'S CERTIFICATION:
I, Mark T. Cacciatore, attest this application for a Special Order.by Consent.(SOC) has been
reviewed by me and is accurate'and complete to the best of mu knowledge. I.understand if all
required parts of this application are not completed and if all required supporting information and
attachments are not included, this application package may be, returned as incomplete.
Furthermore, I attest by my signature that I fully understand that an upfront penalty,
which may satisfy as a.full settlement for past violations may be imposed. (Note: Reference.
to upfront penalties in Special Orders by Consent may be found in the North Carolina
.Administrative Code[T15A NCAC 2H.1206©(3)].)
e / `_2
Date
Signature of Signing Official
Printed Name of Signing Official
THIS COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS .SHOULD BE SENT
TO FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER QUALITY
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION, SECTION
1636 MAIL SERVICE CENTER
'RALEIGH, NORTH CAROLINA 27699-1636

IV. NECESSITY NARRATIVE:
NOV-2009-PC-0085
NOV-2009-PC-0144
Sections of the existing infiltration. fields experience ponding and rainfall runoff problems during
high soup season (October — February) and during extended periods of rain. Field H is already
included in the current permit and a capital project has been developed to prepare it for
.utilization. The.addition of Field H will allow greater flexibility during times of harvesting,,
repair, maintenance and extended -periods of rain.
In addition, the control system- at the spray fields has proven to be unreliable. The equipment
that was installed in 2004 has experienced repeated failures and is not operating automatically,
requiring the system to be operated manually. Campbell intends to resolve the following
equipment system issues: automatic and reliable valves feeding the pivots/spray fields; automatic
capability to turn the,pivot drives on/off; the system must operate within a consistent pressure
range _ i.e.,60 to 90 psi, and the spray field pumps must operate within 'a normal duty cycle and
not cycle on and off -
Field
Campbell Soup Supply Company intends to install management systems to allow the operator to
respond quickly to, areas of the sprayfields which are holding wastewater. and/or could potentially
allow run off. The operator will have the control to avoid application on specific sections of the
sprayfields and additional acreage to divert the wastewater away from any problematic sections
of the sprayfield. To ensure that the -system is operated per design,,a Daily Management
Systems (DMS) will be developed and enforced by the operator of record.

V. CERTIFICATION "
Based on .my review of Campbell Soup Supply Company's spray irrigation infiltration
treatment system, the, following changes will be made:to achieve permit compliance:
Increase acreage for application of•wastewater.
• Implement control systems to allow the operators to. manage efficiently the_
application of wastewater on •current and new :acreage, and .
• Manage distribution- of the application of wastewater over the entire infiltration
system,,maiiitain the equipment necessary to, pre -treat and distribute the'
wastewater and manage the soils and=crops of each field to ensure. the proper
treatment of the applied wastewater. w
Currently there is sufficient land to handle the "hydraulic load. However; during. peak
production periods this land must be available to receive_ wastewater: Equipment
breakdown, soil wetness, crop needs, routine maintenance or unforeseen.events during
peak production periods could lead to poor distribution of the wastewater: If one spray
field,is unavailable, more pressure is".placed on the remainingimgation fields:
-Additional.land to allowoperational flexibility' would help eliminate'the cause of the
issued NOV's.
Tlie current control system, while designed to grant the operator the necessary flexibility,
does not provide a reliable mechanism to distribute the,amount of effluent -,sprayed over
specific portions ofahe infiltration fields. Problematic areas include the valve, control
system, spray head, end gun, and flow metering systems. Replacements with a proven
and reliable system will help in addressing the issues noted in the NOV's.issued,by the
regional office.
Management is perhaps the most critical component for any spray irrigation system:
Without proper management, even the best designed -system will suffer failure. The
Operator will emphasize cro t irrigation scheduling, metering calibration,
hay harvesting, equipm foyee training, and field oversight..', "
i
2 v
Robert T. Branch, ,fill" Date
ZZ - "

"" Description- .
Com letion '-I)ate
"B".Field.(return to 'ori inal storage ca�acit of 6.2 MG)" ..
--September 1,' 2009
"H" Field (addrpivot and utilize gas s rayfield)
Additional, Dit&ing Around "J" Field
September 1, 2009
September L 2009
Control System Project Upgrade
Description
Com letion Date
Timelines for Control System Upgrade
_
.Total Project
Complete Se t/2010
Evaluate current conditions_ of control e ui ment
March'3 1, 2009
Develo lorig'term pian. '
.June 1 2009
Install and Startup A, C, D, E, F_; G,,I, J (include control for H)
August31; 2009
September.1- 2010

SOC Pre -Application Certification
Special Order by Consent Pre -Application Certification:
On March -12, 2009 ; DWQ regional office staff met with
(pre -application meeting date)
Campbell Soup Supply Company, LLC l W00003626 to', discuss the needs
(facility name/permit number)
and merits of applying for a,Special Order by _Consent (SOC). Based on the Information, .
presented during this meeting and the facility's non=compliant status witl'permit conditions
and/or other state rules and regulation,l support this facility's application submittal.
Date.
Signatu f Regional Office Supervisor
DWQ R „gional Office

/
T m.
�m
WORLD HEADQUARTER' uR Q, Jt�
!�
CM
1' Campbell Place.
Camden, New Jersey 08103-1799
ry
o
Z
May 21., 2009
North Carolina Department of Environment and�Natural Resources
Division_ of Water Quality
:Aquifer Protection. Section','.
1636,Mail Service Center,-.-'. .
Raleigh, NC 27699-1636
Subject: Signatory Authorization
To Whom It May Concern:
I, Dave Biegger, Vice President, North,, American Supply Chain designate Mark T.
Cacciatore,-Senior..Director of Operations for Campbell Soup Supply. Company,
LLC, Maxton Plant as the duly authorized representative- in .all' facility' signatory ,
matters. He is responsible,for the overall operation of'the. Maxton- Facility., from
which. all permitted requirements originate. - He. has signatory. authority in all
matters .relating to the Maxton Facility.
Please don't hesitate to contact me if you should need additional' information.
[phone].
Sincerely,
• zLJ�� i : •-
.-David B. Biegger .
= Vice President, North American Supply Chain
cc: Mark T. Cacciatore

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ENFORCEMENT PAYMENTS JOURNAL
05/26/09
Page: 1
payment ;
Fee Type - Check Number Case Number
Received payor' Account Cost Center Company
. Amount County. NC Statute Number
SOC Application Fee - 200001944 S09008 .,
05/14/2009 Campbell Soup Supply Company 435100095 2341 1602
$400.00 Robeson
Total Amount:
$400.60
Grand Total Amount:
$400.00