WQ0003626_Renewal (Application)_20090903

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NCDENIZ
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue - Coleen H. Sullins
Governor Director
September 3, 2009_ IFC EnT.
MARK T. CACCIATORE —SENIOR DIRECTOR OF OPERATIONS
SEF•: 0-8 2
CAMPBELL SOUP SUPPLY COMPANY
2120NC7:1HIGHWAY NORTH • . ;DENR=FAYETIEVLLEREGIONALOFFICE
MAXTON, NORTH CAROLINA 2836,4
Dear Mr. Cacciatore:;
The Central and Regional Aquifer Protection -Section Reviewers have completed their review of the
subject permit application package. . Additional` information is require& before we .may complete our
review. Please address the following items no later thanthe close of business on October 3, 2009.
Please areresponsible aware that you arresponsible' for' meeting all requirements set forth in North Carolina rules and
regulations. 'Any oversights that occurred in the review of the. subject application package are still the
responsibility of the applicant: In addition, any:omissions made in responding to the above items shall
result in future requests for additional information:
Subject: T p ee'dho iANto W 0 0004 .4=
Additional Information Request
tro b sm Su ply eu
Land Application Program
Ro eson. G�'oun y
Dee Freeman
Secretary
•
Please reference the subject application number when providing the requested information._ Three (3)
copies of all revised and/or additional documentation shall be signed, sealed and dated by the proper
North Carolina licensed professional and shall be submitted to my attention at: 1636 Mail Service Center,
Raleigh, North Carolina 27699-1636. Please note that failure to provide this additional information on or
before the aboverequested date may result in your application being returned as incomplete.
If you have any questions regarding this request, please do not hesitate contact me at [phone].
Thank you for your cooperation. y -
Sincerely,
Nathaniel D: Thornburg
Environmental Engineer II
Fa- etteville',Regienabeffce, Aquifer Protection Seefion :
Robert .: ranc e S - Branch Residuals &'Soils, LL `'
Permit Application File WQ0004893
Phone: [phone] FAX 1: 919-715-0588; FAX 2: 919-715-604 -1
81 Customer Service: 1-877-623 E
AQUIFER PROTECTION SECTION •
1636 Mail Service Center, Raleigh, North Carolina 27699-1636
Location: 2728 Capital. Boulevard, Raleigh, North Carolina 27604
An Equal Opportunity 1 Affirmative Action Employer
One
N mtlmCamp.j
1a�11,1�
at1iiQji

•Mr. Mark Cacciatore
September 3, 2009
Page 2 of 2
General:
1. Per 15A NCAC 02T .1104(c)(1), amend the provided buffer maps in Attachment Order 3-e to include
the following information:
a. Amend Buffer Maps 1 and 2 to include all property boundaries within 500 feet of the land
application, sites. Review of the Robeson County GIS shows' a property line near the onsite
wetland that is not indicated on the current Buffer Maps (see photograph below).
b. ExpaiidBuffer Maps 2 and 3 to show all required features within 500 fe
et of the proposed land
application sites.
' . Amend -Buffer Maps 1, 2 and 3 to include the delineation of the review and co
mplice
boundaries for the land application sites. The compliance boundary shall be 250 feet from
waste application boundary or 50 feet within the property boundary,from the
waste application bowl Whichever is closest to the
bound y. The review boundary shall be midway between the compliance
ary and the waste -application boundary:
t
2, Please note per the attached document from the Attorney General's Office, all property and/or parcel
lilies, regardless if the adjoining owner(s) is the same as the Applicant/Perm'ittee, shall be buffered
® ��® � �ppv ble setbacks listed in 15A NCAC 02T .1108. Therefore, the parcel line near
the onsite wetland betwe7;1 Sites I and 2 (see photo above) shall be included on the buffer map, and
be onsi a wetl n ao feet eitheside for surface application by vehicle and injection/incorporation
oP
150 feet on either side for sine application by irrigation.

ROY COOPER
Attorney General
• State of Nortla, Carolina.
Department of 'Justice,
Pb 'Box 629
•Raleigh, North :Cprolina
27662 " •
August 27, 20.09
MEMORANDUM
•
TO: ,: Jon Risgaard, Supervisor
.DWQ.Land ApPlication :Unit /
FROM: . Kathryn Jones Cooper -
•
SpecialDeputy Attorney General
SUBJECT: :ResidualsManagement Setbacks ;
. : Kattityri Jones Cooper
Environmental Division
• .
AVa.ter end.Land Section
• Telephone.[phone] -
Fax [phone]
lccooneriibcrioj Amy '
You asked whether the setbaoks:inN:c.,ADMIN.:tODEtitl 5A, T.,2T.1108 apply
to.thesapplication Of residuals to., contiguous mon-declicatedli elds:owned.:by,a single individual
but divided by parcel (property) lines. We havexeyiewed-.:the.`_!wastemot-dischargedlo :surface
waters" rules found in N..C. ADMIN. CODE tit:15A,:Subchapter2T-,-..partictilarlyEthe TeSiduals
management rules found:in N.C. ADMIN. CODE tit 15A,i 2T r o'o; et ,s;e4:, and the general -
rules found in 2t0100, :and:for the reasons set forth below.haVedetermined.the.setbabks in N.C.
ADMIN: - CODE tit 15A, r.:2T.I1 08 '.do apply to:the:application ofreSidualsi'to contiguous non- ,
dedicatedlields'DWned-by Sirigle'indiVidtiaPbUtfdiVitled (15.=OPtifyyTinet:' _
In some:Of the setback proVisions in ...MC: ADMIN.
distinctions are made for habitable residences or places ,:ofpublic..assembly under -separate
ownership or not to be -maintained as part of the -project_ -site,-. asopposed t6thabitable residences
oi placeS ofpublic,asSembly ciwnedby theTerinittee,--the owner. of thelandor the -IeWe/operator
of the land to be maintained as part of the project site -See:MC. ADMIN. CODE tit.15A.; rules
2t11.08 (a) [forresiduals treatment -and- storage:facilities], 2T 1 1,08(b)(2) [for land onto Which
bulk residuals are applied or stockpiled and the bulk residuals -that don't meet tlie requirements
1-This informal -opinion has not beenTeviewed and approved in accordance with -the Attorney General's
policy for, issuing formal opinions.

Jon Risgaard
August 27, 2009
Page 2
ofrul es .1105(c), .1106(b):and„11 07] „and 2T.1108(c):{constructionand• operation of,surface
disposal units]: For :exartiPle,,inN.-C. ADAK:tODE:tit.15A, ;r..2T.1108,(b)(2),.there. are• -
setback requirements forbalk residuals :that don!tmeet-theTequireinerits•Of rules .1:105(c),
• .1 1•06(b) and .11 07, for-habitable.residences or plans of piiblie ass en-ihlyunder.sep arate
ownership .or not to bentaintainedas part ofthe-project site f.o-17 'surface.-appl i cation :by vehicle,
surface application by irrigation, -and, injectiotiiincorpdratiorOioweVer, there_ are no setback
:requirements forbulkteSidualsThatdon't-meet-the7eqUirements °flail es' .1 1:05(c), 111 06(b).:and
...11 07, for habitable residences or places of pnblicassenibly,own edby the permittee, the owner
of the land:or:thelessee/operator :of -the land.Ao' b e maintain ed -as_part.of the project ,sitefor
• surface :apPlicati on.by vehicle, or inj ection/incorporati on.*
--There:are:property line setbacks in :N.C. ADMT.N1!:CODE lit :1:5A ;;rhles.' 2T: 1.10 (b)(2) and . •
2T.1.108(c) as well; :however, there are no-ovsr.ner0ip,distinctionsTtnade.fouroperty. line -setbacks _
. .
iri
ariy•oftheseprevisionS. • • •
•
Consequently, it is our legal therules do mot make,auy .distinctions::for;property line
setbacks, •therefore, - no exceptions to the ,prOpertOin e setbaCka:Canlbelmade'for,contiguous--but
•separate parcels:ofland oWnedl.by one 'il*Envirohniefital:Iflanagement;ComniisSion
had intended to carve out an for prppeqylines; it would have Sc) as it did for
habitable residences under separate - ownerghiRes;ioppoSedqo :Ow.iierShipby••„-the:.perntitee: or owner
-:ofland certainprovisions. •
•
We also looked- at N.C. ADMDST,CODEAit :15A;,;:r,..2T:.0105 (ri) to d eterrnin e whether:the:director
COUldmaive or :Eillow•a •variancefrom-thesetbadkzeqUirementS, Aftef-ourreView•ofthattule, we
determiriedthatthe: setbaCkiscnotaDesigir•Criteria,suelt that:it would he alloWable:as:•an
•ahem atiVe . •
Thus Aveli el i eve thAtthe propertyajner setbaoles;:amollg-,othersidn'NE: ADMIN t5 A,
r. 2T.1108, do apply to the,application of-re§iiduai0o,contiguous-,uon,dedicated.'fields Owned:by
a single individual but divided:by:parcel
Ifyouneed .furthersteseardhplease let us know, •

Barber, Jim
From: Thornburg, Nathaniel[[e-mail]]
Sent: Wednesday, April 29, 2009 9:28 AM
To: [e-mail]
Subject: FW: Comments concerning draft permit WQ0003626
Attachments: Draft NPDES Comments cover letter 2009.doc
Jim,
Please read the following response from Campbell Soup regarding the two outstanding issues with the draft. Please let
me know if FRO wants to address these issues, or move forward with issuing the permit.
Thank you,
Nathaniel
i<•dFi(••Y.••Y.• X�dtiEa:-i<•� •fi%•Y,• X•ii#i:-i(•#iF X�•Y.• X�X'k�C •X•-k�i<• Y••Y.• X••a �••7Fi(••%•Y,-3E•Y.• k•%•X-dF ib-%.y,-%.y,.%�:..H.
Nathaniel D. Thornburg — Environmental Engineer II
Aquifer Protection Section — Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
919-715-6r6o
919-715-6048 FAX
http://h20.enr.state.nc.us/lau/main.html
DISCLAIMER: Per Executive Order No.150, all a -mails sent to and from this account are subject to the North Carolina
Public Records Law and maybe disclosed to third parties.
From: Robert Zimmerman [mailto:robert [e-mail]]
Sent: Monday, April 27, 2009 4:42 PM
To: [e-mail]
Cc: Risgaard, Jon; Hope Walters
Subject: Comments concerning draft permit WQ0003626
Nathaniel,
Attached please find my comments concerning the draft permit. I am sorry that I did not get these to you on Friday as promised. I had
two details I was tracking down and felt they should be included in my letter. I will send the letter to your office this week.
(See attached file: Draft NPDES Comments cover letter 2009. doc)
=1GIOM17-1-
Bob Zimmerman I Campbell Soup Company I Environmental Project Manager 1 Global Engineering Systems
One Campbell Place I Mail Stop 222 1 Camden, NJ 08103-1759 1 Ofiicia UW968.4436 I Fax [phone] Call 61
M robart_ximmermanicampbellsoup,com
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April 27, 2009
Nathaniel Thornburg, Supervisor
Environmental Engineer II.
Aquifer Protection Section
North Carolina Department of Environment and Natural Resources
1636 MSC, Raleigh, NC 27699-1636
Re: Permit No.: WQ0003626
Facility Name: Campbell Soup Supply Company
Dear,Mr. Thornburg:
In accordance with the extension your office graciously provided, Campbell Soup
Company would like to respond to the March 23, 2009 draft permit. Attached please
find the comments compiled based upon the draft permit and the associated e-mails from
the Fayetteville Regional Office (dated 4/3/09 and 4/7/09).
Campbell Soup Company looks forward to the opportunity to discuss with the
NCDENR the attached comments and to develop a consensus of the appropriate permit
language to ensure the protection of the waters of the State.
Sincerely,
Robert Zimmerman
cc: Hope Walters, Campbell Soup Company
Jon Risgaard, NCDENR

The regulatory authority to issue permits comes from the Environmental Management
Commission (EMC) consistent with General Statutes created by the legislature. The EMC
delegates the authority to the DWQ Director to issue permits. Permits are issued
consistent with the 2T rules. Specific to the re4uest made by Campbell Soup, the
proposed conditions in the draft permit are allowed consistent with I5A NCAC 02T . 0108
(b)(1): "The Director may issue a permit containing such conditions as are necessary to
effectuate the purposes of Article 21, Chapter 143 of the General Statutes".
Fayetteville Regional Office
Chapter 143, Article 21, Part 1, Section 211 - Declaration of public
policy..
§ 143-211. Decla "ration of public policy.
(a) It is hereby declared to be the public policy of this State to provide for the
conservation of its water and air resources. Furthermore, it is the intent of the
General Assembly, within the context of this Article and Articles 21A and 21 B of
this Chapter, to achieve and to maintain for the citizens of the State a total
environment of superior quality. Recognizing that the water and air resources of
the State belong to the people, the General Assembly affirms the State's ultimate
responsibility for the preservation and development of these resources in the
best interest of all its citizens and declares the prudent utilization of these
resources to be essential to the general welfare.
(b) It is the public policy of the State, to maintain, protect, and enhance water
quality within North Carolina. Further, it is the public policy of the State that the
cumulative impact of transfers from a source river basin shall not result in a
violation of the antidegradation policy set out in 40 Code of Federal Regulations
§ 131.12 (1 July 1997 Edition) and the statewide antidegradation policy adopted_
pursuant thereto.
(c) It is the purpose of this Article to create an agency which shall administer a
program of water and air pollution control and water resource management. It is
the intent of the General Assembly, through the duties and powers defined
herein, to confer such authority upon the Department of Environment and Natural
Resources as shall be necessary to administer a complete program of water and
air conservation, pollution abatement and, control and to achieve a coordinated
effort of pollution abatement and control with other jurisdictions. Standards of
water and air purity shall be designed to protect human health, to prevent injury
to plant and animal life, to prevent damage to public and private property, to
insure the continued enjoyment of the natural attractions of the State, to
encourage the expansion of employment opportunities, to provide a permanent
foundation for healthy industrial development and to secure for the people of
North Carolina, now and in the future, the beneficial uses of these great natural

resources. It is the intent of the General Assembly that the powers and duties of
the Environmental Management Commission and the Department of
Environment and Natural Resources be construed so as to enable the
Department and the Commission to qualify to administer federally mandated
programs of environmental management and to qualify to accept and administer
funds from the federal government for such programs. (1951, c. 606; 1967, c.
892, s. 1; 1973, c. 1262, s. 23; 1977, c. 771, s. 4; 1979, 2nd Sess., c. 1158, s. 2;
1989, c. 135, s. 1; c. 727, s. 218(102); 1997-443, s. 11A.119(a); 1998-168, s. 1.)
Issue 1
Condition II.1. — This condition requires that land application sites be inspected and a
record maintained as often as necessary, but in no case shall the time between inspections
be more than 120 minutes during the application of wastewater to the permitted fields.
Condition H..1: Operator's shouldn't be driving "in" the application fields day or night,
unless maintenance activities are being performed or the crop that is currently being
managed is being harvested (per permit condition II.9 that is in all permits). The fields at
Campbell Soup have typical dirt/soil roads around the fields and in some cases the roads
are only partially around fields (A, G, H). I'm not sure what the obstacles are that
prevents Campbell Soup employees from observing the fields during spray irrigation
activities. Campbell Soup has recently installed 8' high security fences and lockable gates
to secure their spray fields. Safety of Campbell Soup employees at the site at night has
been brought up in past meetings, but I would assume that the recent installation offence
and lockable gates would mitigate safety issues at the site. "
"As far as the holidays and non production weekends, I think the permit condition is self
explanatory that when the facility is generating wastewater for irrigation, that
inspections be made, i.e. "but in no case shall the time between inspections be more than
120 minutes during the application of wastewater to the permitted fields". If the plant is
not generating wastewater and conveying such to the pump house for irrigation, then no
inspection is necessary. "
Fayetteville Regional Office
Campbell Soup Company does not believe that the inclusion of the condition above is
necessary to satisfy the purposes of the General Statutes. The permit, as written without
this condition, will satisfy the purposes of the General Statutes. North Carolina
regulation, 15A NCAC 08G.0204 specifies visitation times for spray irrigation systems as
to visit as often as necessary to insure the proper operation of the system but in no case
less frequently than specified below (weekl for surface irrigation systems) or unless .
otherwise defined in the permit. , e 12© nl�inutes vjisitai�an sc e Lt e matches lanuae

The addition of this condition is non -productive and a clear safety concern to our
employees. While CSC has installed fencing and gates to our spray fields, lighting has
not been installed. In addition, that there are not "roadways" that surround each field.
This condition would require that a CSC employee ride around the exterior of portions of
the sprayfields with the only area visible lit by the headlights of the vehicle. The ability
of an individual to detect flowing water in a grass field by headlight is nearly impossible.
Therefore the effectiveness of such an inspection would be very limited and dangerous
for the employee. Any condition that would lead to an over -land flow non-compliance
should be evident to the operators prior to the actual discharge and addressed prior to
allowing an actual discharge.
During weekends and holidays CSC does generate wastewater at a much lower rate than
during production. The source of the wastewater is varied and a focus of the sites water
conservation efforts. Regardless, requiring an operator to be present and inspecting the
sprayfields 24 hours a day 7 days a week is well beyond the published North Carolina
regulations. A complicated mechanical treatment system would only be required to have
an operator on site 24 hours per day if the systems capacity was beyond 5.0 million
gallons per day.
Please remove this clause from the draft permit.
Issue 2
Attachment A — A maximum daily flow limit of 4,311,206 gallons per day (GPD) has
been instituted due to recent compliance issues regarding ponding and runoff from the
irrigation fields. Once Field H has been constructed and the Engineering Certification
submitted, the maximum daily flow may increase to 5,039,515 GPD. In addition, per the
Aquifer Protection Sections Monitoring Policy, passive treatment systems disposing of
more than 500,000 GPD shall sample all effluent parameters at a minimum of 2 times per
month, unless noted otherwise. In addition, note that Lead has been removed from the
monitoring parameters.
"Attachment A: Its the opinion of the regional office that a hydraulic limit be instituted to
insure that repeated over application (greater than the calculated daily hydraulic limit of
the respective field annual loading rates) doesn't occur that leads to discharges from the
application fields (two recent discharges have been documented and NOV's/Enforcement
actions have been initiated). Since the facility has no way of equalizing flow to the spray
fields through the use of a storage lagoon or other structures; the option was to limit the
facility to a daily rate of 4 mgd instead of a 4 mgd monthly average. We understand that
the facility will have high flow days and low flow days and that averaging flows over a
month is more realistic than having to initiate compliance action for every day that
Campbell Soup exceeds 4 mgd (averaging over a 365 day year is typically done for

municipal wwtp). With the monthly average identified, it seemed appropriate to have a
maximum flow with respect to spray irrigation based upon recent discharges at the
facility. "
"At the present time FRO has not received confirmation that Campbell Soup will enter
into a SOC, nor has a time frame been given as to when a SOC decision will be made. We
have been informed by the Maxton plant that a 'SOC is being considered and that
information has been forwarded to Campbell Soup corporate and Campbell Soup legal
department. At this time the regional office is waiting for a formal reply as to the
direction Campbell Soup wishes to proceed with the pending enforcement. "
Fayetteville Regional Office
Campbell Soup Company will soon be submitting a SOC application to establish a plan
of action and schedule with the Fayetteville Regional Offices to address the discharge
from the application fields the week of 4/27/09. Several meetings have been held with
the regional office at which the issue of a maximum daily discharge has been discussed.
At the past two meetings the regional office has stated that the permit will not have a
daily maximum discharge limit but will have a 4.0 MGD monthly average limit. It is
disheartening to have a maximum daily limit reintroduced into this draft permit. The
addition of this permit condition is not necessary to satisfy the purposes of the General
Statutes. -This issue should be addressed in the SOC and not in the operating permit.
Please remove this clause from the draft permit.

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
Director of Operations
3. Facility Name (as shown on Permit): Campbell Soup SwpllyCompany, LLC
4. Application Date: March 20, 2009
5. NPDES Permit No. (if applicable): WQ0003626 (Spray Irrigation)
6. Name of the specific wastewater treatment facility (if different from 1.3 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: N/A gallons per day.
The total non -domestic additional flow requested: N/A gallons per day.
The total additional flow (sum of the above): 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 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 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.

W
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)].)
Date / _7z 0�
of Signing Official
Al-1, T:
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 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,

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 s rayfield)
September 1, 2009
Additional Ditching Around "J" Field
September 1, 2009
Control System Project Upgrade
Description
Completion Date
Timelines for Control System Upgrade
Total Project
Complete Se t/2010
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.

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Re: WQ0P,03626 - Campbell Soup Supply Company Draft Permit
Subject: Re: WQ0003626 - Campbell Soup Supply Company Draft Permit
From: Robert Zimmerman <[e-mail]>
Date: Mon, 6 Apr 2009 09:57:29 -0400
To: [e-mail]
Nathaniel,
I am having trouble finding a regulatory basis for these conditions. Can you direct me to the regulations
that the Regional office are using to justify these clauses?
�; cKaoaasvc:taq,
Bob Zimmerman I Campbell Soup Company I Environmental Project Manager I Global Engineering Systems
One Campbell Place I Mail Stop 222 1 Camden, NJ 09103.1799 I Office 958.958.4438 I Fax.055.550,2809 1 Cali 809.504.2555
PRI'robert zlmmermangcampbellaoup.cam
"Nathaniel Thornburg ---04/03/2009 02:04:56 PM ---Bob, Here is the response from the Fayetteville
Regional Office regarding your questions about Cond
From: Nathaniel Thornburg<[e-mail]>
To: Robert Zimmerman/US/CAMPSOUP/CSC@CSC
Date: 04/03/2009 02:04 PM
Subject: Re: WQ0003626 - Campbell Soup Supply Company Draft Permit
an
Here is the response from the Fayetteville Regional Office regarding your questions about Condition
II.1. and Attachment A.
Condition II.1: Operator's shouldn't be driving ,"in" the application fields day or night, unless
maintenance activities are being performed or the crop that is currently being managed is being
harvested (per permit condition II.9 that is in all permits). The fields at Campbell Soup have typical
dirt/soil roads around the fields and in some cases the roads are only partially around fields (A, G, H).
I'm not sure what the obstacles are that prevents Campbell Soup employees from observing the fields
during spray irrigation activities. Campbell Soup has recently installed W high security fences and
lockable gates to secure their spray fields. Safety of Campbell Soup employees at the site at night has
been brought up in past meetings, but I would assume that the recent installation of fence and lockable
gates would mitigate safety issues at the site."
"As far as the holidays and non -production weekends, I think the permit condition is self explanatory
that when the facility is generating wastewater for irrigation, that inspections be made, i.e. "but in no
case shall the time between inspections be more than 120 minutes during the application of
wastewater to the permitted fields". If the plant is not generating wastewater and conveying such to the
pump house for irrigation, then no inspection is necessary."
"Attachment A: Its the opinion of the regional office that a hydraulic limit be instituted to insure that
1 of 4 4/7/2009 11:48 AM

Re: WQ00,03626 - Campbell Soup Supply Company Draft Permit
repeated over application (greater than the calculated daily hydraulic limit of the respective field annual
loading rates) doesn't occur that leads to discharges from the application fields (two recent discharges
have been documented and NOV's/Enforcement actions have been initiated). Since the facility has no
way of equalizing flow to the spray fields through the use of a storage lagoon or other structures; the
option was to limit the facility to a daily rate of 4 mgd instead of a 4 mgd monthly average. We
understand that the facility will have high flow days and low flow days and that averaging flows over a
month is more realistic than having to initiate compliance action for every day that Campbell Soup
exceeds 4 mgd (averaging over a 365 day year is typically done for municipal wwtp). With the monthly
average identified, it seemed appropriate to have a maximum flow with respect to spray irrigation based
upon recent discharges at the facility."
"At the present time FRO has not received confirmation that Campbell Soup will enter into a SOC, nor
has a time frame been given as to when a SOC decision will be made. We have been informed by the
Maxton plant that a SOC is being considered and that information has been forwarded to Campbell
Soup corporate and Campbell Soup legal department. At this time the regional office is waiting for a
formal reply as to the direction Campbell Soup wishes to proceed with the pending enforcement."
If you would like to discuss further, please contact me at your convenience.
Sincerely,
Nathaniel
Robert Zimmerman wrote:
Nathaniel,
A quick glance at the draft permit highlights two issues. Can you discuss what options are
available with respect to these items?
Condition II.1 - inspections every 120 minutes. - The permit condition does not address what
happens during the evening when an operator should not be driving in the application fields
and when there is no employees on duty at the wastewater treatment field (holidays/non
production weekends)
Attachment A - The inclusion of a daily hydraulic rate. We were told that there would only be
a monthly average hydraulic limit. We are planning to enter into a SOC with the State, which
addresses the recent compliance issues. Upon completion of field H, we should not have a
hydraulic daily limit.
Thanks,
Robert Zimmerman
Environmental Project Manager
,- Nathaniel Thornburg---03/26/2009 04:06:11 PM ---All, The draft permit for the subject
minor modification and renewal.
From: Nathaniel Thornburg<Nathaniel.ThornburgpNCMail.net>
2 of 4 4/7/2009 11:48 AM

Re: WQ00,03626 - Campbell Soup Supply Company Draft Permit
To: Robert Zimmerman/US/CAMPSOUP/CSC@CSC, Bob Branch
<bbranch(a,branchrs.com>, sreid(a reidengineering.com, Hope
W alters/U S /CAMPS OUP/CSC @ C S C
Cc: Jim Barber <Jim.Barber(-,ncmail.net>
Date: 03/26/2009 04:06 PM
Subject: WQ0003626 - Campbell Soup Supply Company Draft Permit
All,
The draft,permit for the subject minor modification and renewal
applications is attached for your review. This draft`differs
some from
the minor modification draft permit sent to Shane and Bob a few
weeks
back, so please re -review the attached draft.
If you have any questions, please contact me at your
convenience. Please
try and have comments back to me no later than the close of
business,
Friday, April 3.rd.
Please also note that Lead has been dropped from Attachment A
and Fecal °
Coliforms have been removed from Attachment C.
Sincerely,
Nathaniel
Nathaniel D. Thornburg - Environmental Engineer II
Aquifer Protection Section - Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
919-715-6160
919-715-6048 FAX
http://h2o.etr.state.nc.us/lau/main.html
DISCLAIMER: Per Executive Order No. 150, all e-mails sent to
and,from this account are subject to the North Carolina Public
Records Law and may be disclosed to third parties.
[attachment "WQ0003626dp090326.pdf" deleted by Robert
Zimmerman/US/CAMPSOUP/CSC]
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
3 of 4 4/7/2009 11:48 AM

Re: WQ0063626 - Campbell Soup Supply Company Draft Permit
n
this e-mail in error, please notify the sender, do not
disclose its contents to others and delete it from your
system.
Nathaniel D. Thornburg - Environmental Engineer -II
Aquifer Protection Section - Land Application Unit
1636 Mail Service Center
Raleigh, NC 27699-1636
919-715-6160
919-715-6048 FAX
http://h2o.enr.state.nc.us/lau/main.html
DISCLAIMER: Per Executive Order No. 150, all e-mails sent to and from
this account are subject to the North Carolina Public Records Law and
may be disclosed to third parties.
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.
4 of 4 4n12009 11:48 AM