WQ0003626_NOV-2009-PC-0144_20090227

2120 NC 71 Highway North
Maxton, NC 28364
March 12, 2009
Aquifer Protection Section
225 Green Street, Suite 714
Fayetteville, NC 28301
Dear Mr.. Barnhardt,
Per your request for additional documentation of the Sprayfield's hydraulic capacity
stated in the February 27, 2009 letter, Notice of Violation, Violation (NOV-2009-PC-
0144) please find the enclosed documents.
A. Statement of Design, Land Treatment of Canned Food Plant Wastewater from
Campbell Soup Company, dated April 23, 1980 — Sites A, C and D.
B. Additional information to supplement the April 23, 1980 Statement of Design
to Mr. A. C. Turnage from R. C. Locke dated July 28, 1980.
C. Document to Mr. H. Dale Crisp from Mr. Robert Shober sharing 1980 design
data for Site E.
D. Wastewater Treatment System Expansion, Sites F, G and I dated April, 1990.
An additional formal response to the Notice Of Violation — NOV-2009-PC-0144 will be
provided by March 20, 2009.
Sincerely,
A. rs
Environmental Manager
Enclosures

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MARK T. CACCIATORE
2120 NC HWY 71 NORTH
MAXTON, NC 28364
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NC DEPT OF ENVIRONMENT & NATURAL RESOURCES
DWQ-AP SECTION
ATTN: ART BARNHARDT ' :(r' �R
225 GREEN ST, SUITE 714
FAYETTEVILLE NC 28301-5043
MAR 9 2 2009

7A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality 1
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 27, 2009
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mark T. Cacciatore - Senior Director of Operations - Maxton
2120 NC Hwy 71 North
Maxton, North Carolina, 28364
Subject: Notice of Violation/Notice of Intention to Enforce
NOV-2009-PC-0144
Campbell Soup Supply Company, LLC.
Permit No. WQ0003626
Robeson County
Dear Mr. Cacciatore:
You are hereby notified that, having been issued a permit for wastewater disposal for the subject facility,
Campbell Soup Supply Company was found to be in violation of permit conditions.
Violation I: Failure to meet the Operation .& Maintenance Requirements within Section II (3).
"Inclement weather shall not affect, the spray irrigation of wastewater"unless the ground is in a condition that will cause
runoff on Fields, A, B, C, D, E, F, G, H, I and J.
On Thursday February 19, 2009 the NC DWQ during a routnine field inspection observed wastewater runoff from field(s)
G & F caused by rainfall, ground saturation, and wastewater ponding due to spray irrigation on ponded wastewater. The
runnoff from field(s)'G & F flowed together and created a large stream that ran into a wooded area between F & H fields.
Both G & H field(s) were being spray irrigated atthe.time of inspection.
NC DWQ also observed wastewater runoff from fields D & E caused by rainfall, ground saturation, and wastewater
ponding. Campbell Soup had. installed a coragated pipe to remove the rainfall from the low areas between field(s) D & E
but the pipe channeled ponded wastewater from both D & E field(s) into an open drainage ditch that runs by Oxendine
School Road. The same violation was found during a previous inspection(s) on ,January 30, and February 04, 2009 in
which Campbell Soup' -received anNOV with Inent to Enforce. D field was bieng spray irrigated during my inspection.
AQUIFER PROTECTION SECTION
225 Green St, Ste. 714
Fayetteville, North Carolina 28301
Phone: [phone] FAX : [phone] Customer Service: 1-877-623-6748
Internet www.h20.enr.state.nc.us
An Equal Opportunity \ Affirmative Action Employer
NorthCarolina
Naturally

Mark Cacciatore
Page 2
February 27, 2009
Required Corrective action for Violation I:
Campbell Soup Supply Company, LLC shall insure their spray irrigation fields are not applied upon when they
are not capable of absorbing wastewater.
Violation II: Failure to meet the Operation & Maintenance Requirements within Section II (3).
Inclement weather shall not effect the spray irrigation of wastewater unless the the ground is in a
condition that will cause runoff on fields A, C, D, E, F, G, H, I and J. During such events wastewater
shall be diverted to Field B until the remaining fields are suitable for irrigation.
On Thursday February 19, 2009 during a routine field audit inspection field(s) G, F, D & E were found to
have runoff occurring.
Required Corrective action for Violation II:
During periods when the ground will not assimilate the wastewater for spray irrigation the wastewater
shall be diverted to Field B until the remaining fields are suitable for irrigation.
Violation III: Failure to meet the Operation & Maintenance Requirements within Section II (5).
"A suitable year round vegetative crop shall be maintained."
On Friday January 30, 2009 during a routine field inspection the NC DWQ observed that fields G & F did
not have an acceptable vegetative crop.
Required Corrective action for Violation III:
If you have not already done so, immediately take adequate measures to ensure an acceptable year round
vegetative crop is established on all spray irrigation fields.
ViolationlV: Failure to meet the Operation & Maintenance Requirements within Section II (6).
"Adequate measures shall be taken to prevent runoff from the irrigation field."
On Thursday February 19,. 2009 the NC DWQ during a routnine field inspection an area of wastewater
runoff runoff from field(s) G & F, and D & E.
Required Corrective action for Violation for Violation IV:
r Adequate measures to prevent runoff must be taken. Inspection of the spray irrigation fields before spray
irrigation begins, several times during the spray irrigation event, and after spray irrigation is completed is
suggested.
AQUIFER PROTECTION SECTION
225 Green St., Ste. 714
Fayetteville, North Carolina 28301
Phone: [phone] FAX : [phone] Customer Service: 1-877-623-6748
Internet: www.h20.enr.state.nc.us
An Equal Opportunity \ Affirmative Action Employer -
Noe
rthCarolina
Naturally

Mark Cacciatore
Page 2
February 27, 2009
The Division of Water Quality requests that, in addition to the specified corrective action above, please
submit the following items on or before March 6, 2009:
1. Please respond with a written explanation as to how these violation(s) occurred.
2. Please respond with why Permit WQ0003626 Operations & Maintenance guidelines Section II (3)
were not followed and wastewater diverted to field B?
3. Due to the reoccurrence of ponding and runoff regarding 'the spray irrigation field(s) please provide
reports/documentation, (Le., modeling, water balance calculations, soil permeability values, etc.) that
validate the soils in field(s) A, C, D, E F, G, H,. I, & J can hydraulically accept 156" per year of
wastewater in combination with the 'normal rainfall for the Maxton area.
4. In your response, include the steps that are being taken to prevent these violation(s) from reoccurring
on all of Campbell Soup Supply,Company's spray irrigation fields.
Please be advised that this notice does not prevent the Division of Water Quality from taking enforcement
actions for this violation or any past or -future violation. Neither does this notice remove you fromthe
responsibility or liability for failure to comply with any State Rule,State Statue or permitting.
requirement. Furthermore, the Division of Water Quality has the authority to levy a civil penalty of not
more than $25,000.00 per day per violation.
If you have an explanation for these violations that you wish to present to this office, please forward a
detailed explanation, in writing, of the event noted and why"you feel that this office should not proceed
with recommendation for enforcement. This office should receive information in the time frame requested
within this letter. Information provided to this office will be reviewed and, if enforcement is still deemed
appropriate, your explanation will be forwarded to the Director with the enforcement package for her
consideration.
If you have any questions concerning this matter, please do not hesitate to contact either Joel S. Shields
(910-433-3332) or myself at (910- 433-3336).
cc: Hope Walters, ORC
APS Central Office File
APS FRO File
Sincerely,
Stephen Barnhardt, L.G. '
''Regional Aquifer Protection Supervisor
AQUIFER PROTECTION SECTION
225 Green St., Ste. 714 •
Fayetteville, North Carolina 28301
Phone: [phone] l FAX : [phone] Customer Service: 1-877-623-6748
Internet: www.h20.enr.state.nc.us
An Equal Opportunity \ Affirmative Action Employer
NorthCarolina
Vaturaff;

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality .
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 20, 2009
Mark Cacciatore
Campbell Soup Supply Company L.L.C.
2120NC 71 Hwy N
Maxton NC 28364
SUBJECT: February 19, 2009/Field Audit Inspection Inspection
Campbell Soup Supply Company L.L.C.
Maxton Plant and Silgan Can Company WWTP
Permit No: WQ0003626
Robeson County
Dear Mr. Cacciatore:
Enclosed please find a copy of the Field Audit Inspection Inspection form from the inspection conducted on
February 19, 2009. The Field Audit Inspection Inspection was conducted by Joel S. S. Shields of the Fayetteville
Regional Office. The facility was found to be in Non -Compliance with permit WQ0003626.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff have
any questions, please call me at [phone].
Sincerely,
Joel S. Shields
cc: Hope Atkinson Walters, ORC
Central Files
Fayetteville Files
North Carolina DWQ/Aquifer Protection Section 225 Green St./ Suite 714 Fayetteville, NC 28301 Phone [phone]
FAX [phone] Internet: h2o.enr.state.nc.us Customer Service 1-877-623-6748
NorthCarolina
Naturally
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

Permit: WQ0003626
SOC:
County: Robeson
Region: Fayetteville
Compliance Inspection Report
Effective: 02/10/05 Expiration: 05/31/09 Owner: Campbell Soup Supply Company L.L.C.
Effective: Expiration: Facility: Maxton Plant and Silgan Can Company
WWTP
2120NC71 Hwy
Maxton NC 28364
Contact Person: A F George Title: Phone: [phone]
Directions to Facility:
The site is located on the east side of NC 71 at the intersection with SR 1312, approximately 3 miles east of Maxton.
System Classifications:
Primary ORC: Hope Atkinson Walters Certification: 28639 . Phone: [phone]
Secondary ORC(s): '
On -Site Representative(s):
Related Permits:
Inspection Date: 02/19/2009
Primary Inspector: Joel Shields
Secondary Inspector(s):
Entry Time: 10:00 AM Exit Time: 01:00 PM_
Reason for Inspection: Follow-up
Permit Inspection Type: Surface Irrigation
Facility Status: fl Compliant ■ Not Compliant
Question Areas:
Miscellaneous Questions IN End Use -Irrigation
(See attachment summary)
Phone:
Inspection Type: Field Audit Inspection
Page: 1

Permit: WQ0003626 Owner - Facility: Campbell Soup Supply Company L.L.C.
Inspection Date: 02/19/2009
Inspection Type: Field Audit Inspection Reason for Visit: Follow-up
Inspection Summary:
There were large amounts of ponding and runoff in fields D, E, F & G. Despite the ponding Campbell Soup was contiuing
to spray irrigate on these ponded areas in the before mentioned fields. Their permit requires Campbell Soup to divert all
wastewater to field B when the ground is in such a condition it cannot absorbe the wastewater. Campbell Soup has been
issued and NOV for runoff on fields D& E on runoff that was occurring on January 30 and February 4, 2009. I spoke with
Hope Walters representing Campbell Soup and stated that Campbell Soup had to do an better job of watching the fields
and preventing runoff. Field E has a cooragated pipe installed to drain the rainfall from the low areas outside the buffer
zone, but the wasewater from fields D & E.combine and follow the low point to the corragated pipe and ischarge into an
open drainage dithc by Oxendine School Road.
Campbell Soup was aware of the runoff in fields G & F because it weas evident sometime in the past Campbell Soup had
put in pipe and large•blocks of concrete to slow or stop the migration of wastewater off of these fields. In additon, fields
D & E were still running off via the corragted pipe.
Ms. Walters stated that Campbell Soup. would stop the current runoff in field D, E, F, & G, she shut down the pivots in
these fields, and stop the flow of wasewater to the cooragated pipe. I called Ms. Walters .Februury 20, 2009 and
reminded her that Campbell Soups permit required them to divert all wastewater to field B when the ground was in a
condition it could not assimilate wasewater and could cause runoff. Ms. Walters stated she was aware of that stipulation
in the permit.
Furthermore I stated that the coragated pipe is ok to use but it only to drain the rainfall in low areas outside the buffer
zone. Ms. Walters stated she understood and would make sure the pipe was set correctly and the ground graded
accordingly.
Ms. Walters further stated that Campbell Soup is in the progress of upgrading their spray irrigation system and how they
monitor it. I informed Ms. Walters that I would work with Campbell SOup to help them reach their goals pertaining to their
spray irrigation system but until the system is upgraded runoff would.not be tolerated. Ms. Walters stated she understood
and would keep closer management on the system.
Page: 2

Permit: WQ0003626 Owner - Facility: Campbell Soup Supply Company L.L.C.
Inspection Date: 02/19/2009
Inspection Type: Field Audit Inspection Reason for Visit: Follow-up
Type Yes No NA NE
Single Family Drip 0 -
Recycle/Reuse ❑
Activated Sludge Drip, LR 0
Infiltration System 0
Reuse (Quality) 0
Single Family Spray, LR ❑
Activated Sludge Spray, HR 0
Activated Sludge Spray, LR 0
Lagoon Spray, LR ■
End Use -Irrigation Yes No NA NE
Are buffers adequate? ❑ ■ ❑ ❑
Is the cover crop type specified in permit? ❑ ■ ❑ 0
Is the crop cover acceptable? _ ❑ ■ ❑ ❑
Is the site condition adequate? 0 • 0 0
Is the site free of runoff / ponding? ■ ❑ ❑ ❑
Is the acreage specified in the permit being utilized? ■ ❑ ❑ ❑
Is the application equipment present? ■ ❑ ❑ ❑
Is the application equipment operational? ■ ❑ ❑ ❑
Is the disposal field free of limiting slopes? 0 • 0 ❑
Is access restricted and/or signs posted during active site use? 0 0 0 ■
Are any supply wells within the CB? ❑ ❑ ❑ ■
Are any supply wells within 250' of the CB? . 0 ❑ 0 ■
How close is the closest water supply well? ❑ ❑ ❑ ■
Is municipal water available in the area? ■ ❑ ❑ ❑
# Info only: Does the permit call for monitoring wells? ■ ❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB? 0 0 0 •
Are GW monitoring wells properly constructed, including screened interval? ❑ ❑ ❑ ■
Are monitoring wells damaged? 0 0 0 •
Comment: See summary.
Page: 3

FACT & FINDINGS
February 20,:2009
Campbell Soup Supply Company, LLC
2120 NC Hwy,.71 North
Maxton, North Carolina 28364
Subject: Facts & Findings
NOV-2009-0185
NOV-2009-0144
Allen Canning Inc.
Permit No. WQ0004268
Robeson County
On January 30, 2009 after meeting with Campbell Soup to discuss their permit renewal
and upgrades to their wastewater and spray irrigation system Bob Branch a consultant for
Campbell Soup Jim Barber, Tony Honeycutt, and I conducted a field audit of their spray
irrigation fields. Mr. Honeycutt and I observed a metal pipe sticking out of the side of a
ditch embankment with a heavy flow of wastewater running out into an open ditch. This
ditch runs along Oxendine School Road. Mr. Branch, Mr. Barber, Mr. Honeycutt and
myself went to further investigate where this wastewater originated. Mr. Branch stated
that Campbell Soup was trying to drain water from a low area in field(s) D & E. Upon
further investigation it was discovered that field(s) D & E had large areas of ponded
wastewater that was in the process of being spray irrigated on. The wastewater from
field(s) D & E were combining, running on top of the ground and had made a channel to
the pipe in the side of the ditch embankment and discharging into an open ditch. The top
of the pipe was visible and no filtration through the soil was apparent. Mr. Branch stated
he would call Ms. Walters and have the pivots shut off and the runoff stopped. I took
note that the vegetative growth on field(s) D & E were unacceptable and large areas of
vegetation had been killed by ponding and washed off by runoff.
Tony Honeycutt and myself went to Campbell Soup on February 4, 2009 for a follow-up
field audit inspection of field(s) D & E to observe whether the runoff problem had been
stopped. When we arrived both D & E field(s) were spray irrigating and Campbell Soup
had replaced the metal pipe with a plastic corrugated pipe. In addition, Campbell Soup
had set at an angle with one end of the pipe was sitting on the bottom of the ditch and one
end was 6-8" from ground surface causing water to be diverted stronger to the drainage
ditch. Mr. Honeycutt and myself observed both field(s) being spray irrigated, a larger
area of combined wastewater from field(s) D & E running off more than during our
previous inspection. I called Hope Walters and had her come out to the field to show her
my findings. She came out and had the pivots turned off and stated she would have the
runoff stopped. The end gun on the pivot of field D was spraying into the open drainage
ditch. Ms. Walters stated she would have the end guns plugged.