NC0082821_Compliance Evaluation Inspection_20150610

Ar,
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
June 10, 2015
RECEI\IEDIDENRIDWR
Ms. Lauren B. Faulkner
iUN 1. 6 2015
Southern States Cooperative, Inc. Water Quality
6606 West Broad Street permitting Section
Richmond, Virginia 23260-1717
Subject: Compliance Evaluation Inspection
Southern States Fertilizer Plant
NPDES Permit NC0082821
Iredell County, North Carolina
Dear Ms. Faulkner:
Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on May 29, 2015, by Ms. Marcia Allocco of this office. I wish to thank
Mr. Jason Kilcoyne of Duncklee & Dunham for his assistance regarding the inspection.
Please review the comments in the Recordkeeping section of the report regarding Operator-in-
Responsible charge visitation requirements.
The inspection report should be self-explanatory; however, should you have any questions
concerning the report, please do not hesitate to contact Mr. Wes Bell at [phone] or
[e-mail] as my last day with the Division of Water Resources will be June 12, 2015.
Sincerely,
Marcia Allocco, MS
Environmental Senior Specialist
Water Quality Regional Operations
Division of Water Resources
Enclosure: Inspection Report
cc: Wastewater Branch
MSC 1617 — Central files basement
Jason Kilcoyne, back-up ORC (e-copy)
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone]\Customer Service:1-877-623-6748
Internet:http://portal.ncdenr.org/weblwq
An Equal Opportunity\Affirmative Acton Employer-30%Recycled/10%Post Consumer paper

United States Environmental Protection Agency Form Approved.
E PA Washington,D.C.20460 OMB No.2040-0057
Water Compliance Inspection Report Approval expires 8-31-98
Section A:National Data System Coding(i.e.,PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 Iu I 2 EI 3 I NC0082821 111 121 15/05n9
117
181,.1 191 G 201 I
21111111 111111111IIIIIIIIIIIIIIII Il1111111II (�
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67(1.0 1 70 1,1_1 J
71 �ti 72 1 ti J l 731 I 174 751 I I 1 1 1 1 180
Section B:Facility Data
L
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 10:30AM 15/05/29 14/05/01
Southern States Fertilizer Plant
2582 Salisbury Hwy Exit Time/Date Permit Expiration Date
Statesville NC 28877 11:55AM 15/05/29 19/03/31
Names)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Joshua Michael Hanks/ORC/919-858-9898/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Danny Dillon,6606 W Broad St Richmond VA 232606234NP Crops/804-281-1000/
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
POI Permit gl Flow Measurement • Operations 8i Maintenance • Records/Reports
ji Self-Monitoring Program IN Facility Site Review Effluent/Receiving Waters MI Laboratory
•
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
•
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Marcia Allocco MRO WQ//704-663-1699 Ext.2204/ �j I
.
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3580-3(Rev 9-94)Previous editions are obsolete.
Page# 1

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

Permit NC0082821 Owner-Facility: Southern States Fertilizer Plant
Inspection Date: 05/29/2015 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new 0 0 IN 0
application?
Is the facility as described in the permit? • 0 ❑ 0
#Are there any special conditions for the permit? U 0 0 0
Is access to the plant site restricted to the general public? • 0 0 0
Is the inspector granted access to all areas for inspection? • 0 0 0
Comment: NC0082821 was reissued by the Division on April 2,2014,with an effective date of May 1,
2014. The permit is set to expire on March 31,2019. The previous compliance evaluation
inspection was conducted on March 2, 2010. The reissued permit required electronic
submission of the monthly discharge monitoring reports by February 1, 2015. The permittee
began electronic DMR submission in October 2014.
Operations&Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • 0 0 0
Does the facility analyze process control parameters,for ex: MLSS, MCRT,Settleable • 0 0 0
Solids,pH, DO, Sludge Judge,and other that are applicable?
Comment: The groundwater treatment system is typically shutdown from April to November of each
year. Temperature and pH are monitored for process control.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? • 0 0 0
Is flow meter calibrated annually? 0 0 • 0
Is the flow meter operational? • 0 0 0
(If units are separated)Does the chart recorder match the flow meter? 0 0 • 0
Comment: Totalizers are installed on each of the three extraction wells and averaged over the number
of days of discharge for reporting on the DMRs.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 0 • 0
Is sample collected below all treatment units? • 0 0 0
Is proper volume collected? • 0 0 0
Is the tubing clean? 0 0 U ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0
representative)?
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Permit: NC0082821 Owner-Facility: Southern States Fertilizer Plant
Inspection Date: 05/29/2015 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: The permit requires arab samples for all required parameters.All effluent samples are kept
on ice in a cooler until transfer to a courier for delivery to the analytical laboratory.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? • 0 0 0
Are the receiving water free of foam other than trace amounts and other debris? 0 0 0 •
If effluent (diffuser pipes are required) are they operating properly? 0 0 MI 0
Comment: There was no discharge of treated groundwater to the permitted outfall during the inspection.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • 0 0 0
Are all other parameters(excluding field parameters)performed by a certified lab? • 0 0 0
#Is the facility using a contract lab? • ❑ 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • ❑ 0 0
Celsius)?
Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 I 0
Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 I 0
Comment: On-site analyses are performed under field laboratory certification#5484, Duncklee&
Dunham, P.C. The permittee has also contracted Pace Analytical Services(laboratory
certification#12/40)and ESC Labs(toxicity)to provide the remaining testing requirements.
The field instrumentation used on site appeared to be properly calibrated and documented.
Reagent tracking had been implemented for the pH buffers.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ 0 0
Is all required information readily available,complete and current? • 0 0 0
Are all records maintained for 3 years(lab. reg. required 5 years)? • 0 0 0
Are analytical results consistent with data reported on DMRs? • 0 0 0
Is the chain-of-custody complete? • 0 0 0
Dates,times and location of sampling •
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete:do they include all permit parameters? • 0 0 0
Page# 4

Permit NC0082821 Owner-Facility: Southern States Fertilizer Plant
Inspection Date: 05/29/2015 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Has the facility submitted its annual compliance report to users and DWQ? 0 0 U 0
(If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator 0 0 • 0
on each shift?
Is the ORC visitation log available and current? • 0 0 0
Is the ORC certified at grade equal to or higher than the facility classification? • 0 0 0
Is the backup operator certified at one grade less or greater than the facility classification? • 0 0 0
Is a copy of the current NPDES permit available on site? • 0 0 0
Facility has copy of previous year's Annual Report on file for review? 0 0 • 0
Comment: The permittee's records were organized and well maintained and records requested during
the inspection were readily retrievable. DMRs were reviewed for Jan 2014 through Mar 2015.
No limit violations were reported and all monitoring frequencies were correct.
The treatment system is currently classified as a physical-chemical grade I system (PC-1).
The standard conditions of NC0082821 and 15A NCAC 08G .0204 require weekly visitation
of PC-1 classified systems and are separate from any sampling requirements specified in
an individual NPDES permit. Although,the permittee requested reduced visitation approval
from the Division in 2009, a formal declassification of the system was not made at that time.
It is only through declassification that operator visitations can be reduced. The permittee
should make a formal request to the Wastewater Operator Certification group to declassify
the system;otherwise the visitation frequency of the system will need to be increased to
weekly from the present twice per month.
Page# 5