NCS000294_Fact sheet binder_20240327

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 3/22/2024
Permit Number NCS000294
Owner/Facility Name Southern States Cooperative, Inc./Southern States
Creedmoor-LouisburgAgronomy Plant
SIC AICS Code/Category 2875/Fertilizers,Mixing Only
Basin Name/Sub-basin number Neuse/03-04-01
Receiving Stream/HUC UT to Robertson Creek/030202010503
Stream Classification/Stream Segment WS-IV;NSW/27-12-1-(0.7)
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? No
New expiration date 4/30/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Southern States Creedmoor-Louisburg Agronomy Plant is a fertilizer storage facility. Dry bulk and
bagged fertilizer(inside), bulk lime (outside), and liquid nitrogen fertilizer(ASTs with secondary
containment) are stored onsite for the retail store just south of this facility. Per the previous permit fact
sheet, no fertilizer mixing or manufacturing occurs onsite (storage and distribution only) and there is
uncovered loading/unloading of materials.
Per the August 2022 DEMLR inspection, the fertilizer house located on the facility yard has nitrate,
phosphorus, and pot ash stored inside. Large aboveground tanks of liquid nitrates/phosphorus (bulk
liquid fertilizer), pallets, treated wood post, and an approximately 500 gallon double walled diesel tank
with a dispenser for fueling equipment are present outdoors. Located beside the fertilizer shed is a
container full of water with containers of Liquid Tank Cleaner inside.
Outfall SW001 (West drainage area
Discharge area contains the bulk fertilizer building, truck loading and unloading pads,bulk lime storage
pad, concrete pads, and 500 gallon diesel tank.
Outfall SWO03 (East drainage areal
Discharge area contains a parking lot, truck scale, office and fertilizer warehouse, ammonia nitrogen
storage tanks, and a structural product storage area.
Additional Outfalls:
Per the previous permit fact sheet, SWO02 was removed from the permit in 2008 as it was determined to
be sheet flow.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
Page 1 of 8

from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• Apil 2014 to September 2022, benchmarks exceeded for:
o SW001: Sulfate 8x, BOD 5x, COD 8x, Ammonia Nitrogen 22x,Nitrate-Nitrite 32x,
TKN 18x, TN 22x, TP 32x, TSS 6x
o SW003: Nitrate-nitrite 2x, TP 3x, TSS 5x
■ No data 2015-2018
■ Annual monitoring performed
■ Monitoring for SW003 ceased in 2020; Per a phone call with the permittee on
4/10/2023, there was an email from 2019 between the company and consultant
stating SW003 was not being sampled as the State determined the drainage
area/outfall was not representative of the facility's industrial activity. No further
documentation was provided regarding this agreement and the permittee stated
there is no agreement on Laserfiche.
• Per letter dated 5/3/2017, SW001 was in Tier II status for nitrate-nitrite, TN, ammonia nitrogen,
TP and TKN and SW003 was in Tier II status for nitrate-nitrite and TSS and Tier I status for TP
• Per letter dated 3/1/2017, SW001 was in Tier II status for nitrate-nitrite, TN, ammonia nitrogen,
TP and TKN and SW003 was in Tier I status for TP and Tier II status for nitrate-nitrite and TSS
• Per letter dated 7/14/2016, SW001 was in Tier II status for nitrate-nitrite, TN, ammonia nitrogen,
TP and TKN and SW003 was in Tier I status for TP and Tier II status for nitrate-nitrite and TSS
• Per letter dated 6/30/2016, SW001 was in Tier II status for nitrate-nitrite, TN, ammonia nitrogen,
TP and TKN and SW003 was in Tier I status for TP and Tier II status for nitrate-nitrite and TSS
• Per letter dated 10/11/2016, SW001 was in Tier II status for nitrate-nitrite, TN, ammonia
nitrogen, TP and TKN and SW003 was in Tier I status for TP and Tier II status for nitrate-nitrite
and TSS
• Per letter dated 11/19/2015, SW001 was in Tier I status for sulfate, BOD, and TSS and Tier II
status for ammonia nitrogen, nitrate-nitrite, TP, TKN, and TN; SW003 was in Tier II status for
nitrate-nitrite, TP and TSS
Page 2 of 8

• Per letter dated 11/17/2015, SW001 was in Tier I status for sulfate and Tier II status for BOD,
ammonia nitrogen, nitrate -nitrite, TP, TKN, TSS and TN; SW003 was in Tier II status for
nitrate-nitrite, TP and TSS
• Per letter dated 8/24/2015, SW001 was in Tier I status for sulfate and Tier II status for BOD,
ammonia nitrogen, nitrate-nitrite, TP, TKN, TSS, and TN; SW003 was in Tier II status for
nitrate-nitrite, TP and TSS
• Per letter dated 7/19/2015, SW001 was in Tier I status for sulfate and Tier II status for BOD,
ammonia nitrogen, nitrate-nitrite, TP, TKN, TSS and TN; SW003 was in Tier II status for
nitrate-nitrite, TP, and TSS
• Per letter dated 1/6/2015, SW001 was in Tier II status for sulfate, BOD, COD, ammonia
nitrogen, nitrate-nitrite, TKN, TSS, TP, and TN; SW003 was in Tier II status for nitrate-nitrite
and TP and Tier I status for TSS
• Per letter dated 10/27/2014, SW001 was in Tier II status for sulfate, BOD, COD, ammonia
nitrogen, nitrate-nitrite, TKN, TSS, TP, and TN; SW003 was in Tier II status for nitrate-nitrite
and TP, and Tier I status for TSS
• Per letter dated 8/19/2014, SW001 was in Tier I status for sulfate, ammonia, TKN, TSS, and TN
and SW003 was in Tier I status for TP
• NOD-2014-PC-0189 was issued in September 2014 for failure to perform qualitative monitoring
(discovered during inspection)
Per the August 2022 DEMLR inspection report:
• The majority of required permit documents were not available. From the information available,
the facility is probably in Tier III status.
• A spill from an aboveground storage tank was not documented in the spill response plan. It was
captured in the secondary concrete dike and pumped out according to the Plant Manager, but
there is no documentation to backup what happened, how much was spilled, what was spilled,
who cleaned up the spill and how it disposed/dealt with.
• The fertilizer house located on the facility yard has nitrate,phosphorus and pot ash stored in it
that is being tracked out one end of the building on the equipment tires and out the other end of
the building around the silo and conveyor system used to load trucks. Those chemicals are spread
around on the ground from the loading process and are a major contamination factor.
• There is a dumpster for miscellaneous trash with a missing lid and numerous buckets,barrels and
misc. containers around the facility yard that should be inside and covered.
• Beside the fertilizer shed is a container full of water with containers of Liquid Tank Cleaner
stored in the water outside on the ground.
• The facility has a double walled diesel tank of approximately 500-gallon capacity with a
dispenser for fueling equipment that has no covering or containment for spills when fueling.
Threatened/Endangered Species:
There are no threatened/endangered species at the discharge location, however, there are species of
concern in the vicinity. These include Southern Skullcap (Scutellaria australis; NC status: E), Carolina
Birdfoot-trefoil (Acmispon helleri; NC status: T), Rufous Bulrush (Scirpus pendulus;NC status: SR-O),
and American Barberry(Berberis canadensis; NC status: SC-V).
Page 3 of 8

Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for Apil 2014 to September 2022. Quantitative sampling included pH, TSS, sulfate, BOD,
COD, ammonia nitrogen, nitrate-nitrite, total phosphorus, TKN, and total nitrogen.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Southern States Creedmoor-Louisburg Agronomy Plant site.
Outfalls SWO01 and SWO03
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
Conductivity BASIS: Discharge potential indicator
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Quarterly monitoring
Ammonia Nitrogen BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Sulfate BASIS: Potential pollutant from drainage area
Page 4 of 8

Quarterly monitoring
Total Potassium BASIS: Potential pollutant from drainage area
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Page 5 of 8

Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
g 133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN+Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 mg/L BPJ; Based on wastewater permit limits for NSW waters
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(Summer) 5.6 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from Wasteload
(winter)
15 mg/L Allocation document for the coastal plain region(worst-case
scenario
Sulfate Total 3,500 mg/L '/2 FAV
Total Potassium 17.14 mg/L '/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology(BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
Page 6 of 8

The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Regulatory citations have been added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Feasibility study removed per updated stormwater program requirements
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall specific monitoring implemented
• Facility name updated based on information provided in the permit renewal application
• Monitoring for Total Kjeldahl Nitrogen(TKN) and Nitrite+Nitrate (NO3 +NO2) removed as
monitoring for total nitrogen is already required
• Outfall SW002 removed from the permit as it sheet flows (per information found in the permit
file history)
• Monitoring for conductivity added for all outfalls due to onsite industrial activity
• Monitoring for potassium added due to the presence of potash onsite
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• None
Page 7 of 8

Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 8/2/2022
• Initial contact with Regional Office: 8/2/2022
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 11/1/2023
• Final permit sent for supervisor signature: N/A
Section 7. Comments received on draft permit:
• Chris Bagley(synTerra; via email 11/20/2023): Neither SynTerra nor Southern States have
comments on the Draft NPDES stormwater permit for Southern Sates Cooperative, Inc.
Creedmoor-Louisburg Agronomy Plant (NCS000294).
• Shawn Guyer (via email 11/27/2023): We concur with the issuance of this permit provided the
facility is operated and maintained properly, the stated effluent limits are met prior to discharge,
and the discharge does not contravene the designated water quality standards.
Page 8 of 8

The Beaufort Gazette Durham I The Herald-Sun The Modesto Bee
The Belleville Newr-Democrat Fort Worth Star-Telegrun The Sun Netes-Mvrtle Beach
Bellingham Herald The Fresno Bee Raleigh News&Observer
M ' Centre Daily Times The Island packet Rock Hill I The Herald
Sun Herald The Kansu City Star Tite SRcramento Bee
atchy Idaho ton Statesman Lexing Herald-Leader San Luis Obispo Tribune
Bradenton Herald The Telegraph-Macon Tacoma I The Neas Tr-bane
The Clliarlotte Observer Merced Sun-Star Tri-City Herald
The State Miami Herold ThelWi Nita Eagle
Ledger-Eraryiret El Nuevo Herald The01%= an
AFFIDAVIT OF PUBLICATION
Account# Order Number IdenttRwtion Order PO Amount Cols Depth
38106 522762 Print legal Ad-IPL01606590-IPL0160659 $481.68 1
Attention: Joyce Sanford Clark STATE OF NORTH CAROLINA
NC DENR ENGERGY MINERAL&LAND RESOURCES COUNTY OF WAKE,COUNTY OF DURHAM
1612 MAIL SERVICE CENTER Before the undersigned,a Notary Public of Dallas
RALEIGH,NC 216991612 County,Texas,duly commissioned and authorized to
administer oaths,affirmations,etc.,personally
[e-mail] appeared Tara Pennington,who being duly sworn or
_ affirmed,according to law,cloth depose and say that he
NORTH CAROLINA ENVIRON- or she is Accounts Receivable Specialist of the News&
,
MENTAL MANAGEMENT COM- Observer Publishing Company,a corporation organized
MtSS16N INTENT TO ISSUE and doing business under the Laws of the State of North
NPDES STORMWATER DIS-
CHARGE PERMITS Carolina,and publishing a newspaper known as The
The North Carolina Environmental Management Commission proposes News&Observer,Wake and State aforesaid,the said
�
to issue NPDES stomiwater discharge newspaper in which such notice,paper,document,or
permit(s)to the person(s)listed below legal advertisement was published was,at the time of
Public comment or objection to the g
draft permits Is invited.Written com- each and every such publication,a newspaper meeting
meats regarding the proposed permit will be accepted until 30 days after the all of the requirements and qualifications of Section 1-
publish data of this notice and consid- ; 597 of the General Statutes of North Carolina and was a
ered in the final determination regard-
ing permit issuance and permit provi- qualified newspaper within the meaning of Section 1-597
sions.The Director of the NC Division of the General Statutes of North Carolina,and that as
of Energy,Mineral,and Land
es(DEMLR)may hold a publicc hearing earing such he or she makes this affidavit;and is familiar with
should there be a significant degree of the books,files and business of said corporation and by
public:Interest.please mail comments reference to the files of said publication the attached
and/or Information requests to DEMLR
at 1612 Mail Service Center,Raleigh, advertisement for NC DENR ENGERGY MINERAL&LAND
NC 27 12.
Southern states Cooperative, RESOURCES was inserted in the aforesaid newspaper on
• Southern
Inc.[6606 W Broad Street,Rich- dates as follows:
mond,VA 23260]has requested ;
renewal of permit NGS000294 insertion(s)published on:
for the Southern States Creed- 1 insert p
moor-Loulsburg Agronomy 02/21/24
Plant in Granville County.This ;
facility discharges to an un-
named tributary to Robertson
Creek in the Neuse River Basin. ;
Interested persons may visit DEMLR
at 512 N.Salisbury Street, Raleigh, , ;
NC 27604 to review information on
file. Additional Information on NP-
DES pemtlts and this notice may be
found on our website: httpsJ/deq. f,, ��'�y `���A ; �,.._--••
nc.gov/abouVdivisions/energy-min- ,
eral-and-land-resources/starliwater/ .j
sfotmwater-program/stom►water-pub- e�
tic-notices,or by contacting Brianna certifyor declare)under penalty o perjury that the
Young at or919 707-3647�'young®deq.nc.gov �L��� ?� foregoing is true and correct.
IPLO160659 r�O
Feb 212024
i
Notary Public in and for the state of Texas,resi ins in
Dallas County
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Extra charge for lost orduplimte affidavits.
Legal document please do not destroy!

Young, Brianna A
From: Guyer, Shawn
Sent: Monday, November 27, 2023 11:41 AM
To: Young, Brianna A
Subject: NCS000294 FW: Draft stormwater permits
Attachments: Draft NPDES Permit NCS000294.pdf
We concur with the issuance of this permit provided the facility is operated and maintained properly, the
stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water
quality standards.
Shawn F. Guyer, P.E.
Deputy Section Chief- Technical Services Branch Head
Division of Water Resources, Public Water Supply Section
North Carolina Department of Environmental Quality
Office: [phone] 1 Mobile: [phone]
[e-mail]
D 0
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tjp�
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, November 1, 2023 4:07 PM
To: Guyer, Shawn <[e-mail]>
Subject: Draft stormwater permits
Good afternoon,
Please find attached the draft stormwater permits for Southern Sates Cooperative, Inc. (NCS000294) and SpecGx, LLC
(NCS000136), which have been submitted for public notice.These facilities discharge to class WS-IV; NSW and WS-IV;
NSW, CA waters. Please provide any comments by December 1, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Chris Bagley <[e-mail]>
Sent: Monday, November 20, 2023 9:47 AM
To: Young, Brianna A
Cc: Jennifer Bunting; David McIntyre
Subject: [External] RE: Draft NPDES stormwater permit NCS000294
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Neither SynTerra nor Southern States have comments on the Draft NPDES stormwater permit for Southern Sates
Cooperative, Inc. Creed moor-Louisburg Agronomy Plant (NCS000294). Thank you for providing a copy of the draft for
review.
Will you please Email us a copy of the final when issued?
Thank you,
Chris Bagley, P.E.*, CIH, CHMM, QEP
Senior Engineer/Senior Industrial Hygienist
16VT
synTerm
511 Keisler Drive, Suite 102
Raleigh, North Carolina 27518
Main: 919.858.9898
Direct: 984.308.8621
Mobile: [phone]
Email: [e-mail]
www.synterracorp.com
* Registered in NC, VA, and AR
Connect with us: Linkedln I Facebook Twitter
This email might contain privileged or confidential information.If the email was not intended for you,please:
(i) Delete the email and any attachments.
(ii) Destroy any copies that might have been made.
(iii) Do not use,copy,or distribute the contents in any form.
(iv) Notify me by return email or phone.
No privilege is waived by inadvertent transmission.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, November 1, 2023 4:04 PM

To:Jennifer Bunting<[e-mail]>
Cc: Zachary Garlick<[e-mail]>; Chris Bagley<[e-mail]>
Subject: Draft NPDES stormwater permit NCS000294
EXTERNAL: This Message originated outside your organization.
Good afternoon,
Please find attached a copy of the draft stormwater permit for Southern Sates Cooperative, Inc. Creedmoor-Louisburg
Agronomy Plant (NCS000294). A hard copy of this permit will be placed in the mail to Jennifer Bunting. Please provide
any comments on the draft permit by December 1, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Young, Brianna A
Sent: Thursday, May 4, 2023 10:05 AM
To: Clark, Timothy W
Subject: RE: Question regarding fertilizer storage facilities
Good morning,
I am following up on my previous email. I would appreciate if you could provide a response at your earliest convenience
as I'm waiting on this information to move forward with the draft permit.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent:Wednesday,April 12, 2023 4:14 PM
To: Clark,Timothy W<[e-mail]>
Subject: RE: Question regarding fertilizer storage facilities
Good afternoon,
I am following up on my previous email as I have not seen a response come through yet. Are you able to address the
questions?
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
1

919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Friday, March 3, 2023 9:27 AM
To: Clark,Timothy W<[e-mail]>
Subject: RE: Question regarding fertilizer storage facilities
Hello Tyler,
Would monitoring for Total Nitrogen and Total Phosphorus be sufficient for the concerns on phosphorus and nitrate? Or
are there other parameters you feel should be included?
This facility is located in the Neuse River Basin. Are there specific basins you feel we should pay attention to when
permitting these types of facilities? I know many basins have nutrient management plans. Monitoring wells are outside
the scope of stormwater permits, so that's not something we would add to our permits.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Clark,Timothy W<[e-mail]>
Sent:Thursday, March 2, 2023 2:01 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: Question regarding fertilizer storage facilities
Hi Brianna,
2

Sorry for the delayed response! I spoke to several of our staff members concerning your request. Overwhelmingly,the
highest priority concerns are phosphorus and nitrate monitoring. Both of these compounds can easy mobilize and
discharge to surface waters and groundwater, especially if some of the loading areas are uncovered.
Additionally, it sounds like this facility is located in the Tar-Pamlico watershed, which has special restrictions when it
comes to nutrient releases.
Are monitoring wells being considered for this permit?
Timothy"Tyler" Clark(he/him/his)
Hydrogeologist, Division of Water Resources
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
D_ E
�
NORTH CAROLINA tillo)
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, February 28, 2023 8:47 AM
To: Clark,Timothy W<[e-mail]>
Subject: RE: Question regarding fertilizer storage facilities
Good morning,
I am reaching out about my previous email. Are you able to assist with this request, or is there another staff member I
should reach out to?
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
3

as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Friday,January 27, 2023 3:17 PM
To: Clark,Timothy W<[e-mail]>
Subject: Question regarding fertilizer storage facilities
Good afternoon Tyler,
I am working on a stormwater permit renewal for a fertilizer storage facility. During the course of review, a discussion
around what should be included in the permit for monitoring came up and it was suggested I reach out to you.
The facility is the Southern States Cooperative, Inc. Creedmoor-Louisburg Agronomy Plant(stormwater permit
NCS000294).The fertilizer house located on the facility yard has nitrate, phosphorus, and pot ash stored inside. Bulk
lime and ASTs of liquid Nitrates/Phosphorus are outside. Located beside the fertilizer shed is a container full of water
with containers of Liquid Tank Cleaner inside.There is uncovered loading/unloading of materials.
Are there any pollutants you are aware of that we should be concerned about or monitor for with this facility, or
facilities like this?We would like to protect groundwater as well as surface waters from stormwater runoff and
infiltration. Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D_ E
NORTH CAROLINA ti ;
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
4

Compliance Inspection Report
Permit:NCS000294 Effective: 02/01/11 Expiration: 01/31/16 Owner: Southern States Cooperative Inc
SOC: Effective: Expiration: Facility: Southern States Coop-Creedmoo
County: Granville 2089 Sam Moss Rd
Region: Raleigh
Creedmoor NC 27522
Contact Person:Zach Garlick Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/10/2022 Entry Time 01:20PM Exit Time: 02:45PM
Primary Inspector:Thaddeus W Valentine Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000294 Owner-Facility:Southern States Cooperative Inc
Inspection Date: 08/10/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The majority of the required documents for the permit where no available. The sample data, employee training and outfall
inspections were from 2019.The most resent sample data I found in laserfiche is from February 2021 with samples taken on
the 15th and the 25th, both of which had exceedances of Nitrate/Nitrite and Phosphorus. From the information we do have
the facility is probably in Tier III
They had a spill from one of their aboveground storage tanks that was not documented in their spill response plan. It was
captured in the secondary concrete dike and pumped out according to Hoyt Self the Plant Manager, but there is no
documentation to backup what happened, how much was spilled, what was spilled, who cleaned up the spill and how it
disposed/dealt with.
The fertilizer house located on the facility yard has nitrate, phophorus and pot ash stored in it that is being tracked out one
end of the building on the equipement tires and out the other end of the building around the silo and conveyor system used
to load trucks. Those chemicals are spread around on the ground from the loading process and are a major contamination
factor. There is a dumpster for miscellaneous trash with a missing lid and numerous buckets, barrels and misc. containers
around the facility yard that should be inside and covered. Located beside the fertilizer shed is a container full of water with
containers of Liquid Tank Cleaner stored in the water outside on the ground that should be removed and stored correctly.
The facility has an double walled diesel tank of approximately 500 gallon capacity with a despenser for fueling equipment
that has no covering or containment for spills when fueling and the despenser and tank are located approximately 20 feet
from a stormwater drop inlet.
I would suggest a review of the stormwater permit so that all required documentation is available on site and that the site is
cleaned up and a system established that will prevent any and all chemicals to be stored loaded and despensed in a
manner in accordance with the individual stormwater permit held
Page 2 of 3

Permit: NCS000294 Owner-Facility:Southern States Cooperative Inc
Inspection Date: 08/10/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? ❑ 0 ❑ ❑
#Does the Plan include a list of Responsible Party(s)? ❑ 0 ❑ ❑
# Is the Plan reviewed and updated annually? ❑ 0 ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ 0 ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ 0 ❑ ❑
Comment: The _great majority of the SP3 was not available
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ 0 ❑ ❑
Comment: The sample data they had was from 2019.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ 0 ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ 0 ❑ ❑
Comment: The last test results they had available was from 2019. There is a possiblity that the need
samples for vehicle maintenance because of an outside diesel pump
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ 0 ❑ ❑
Comment: They are missing certificate of coverage and illicit discharge evaluation
Page 3 of 3

Young, Brianna A
From: Zachary Garlick <[e-mail]>
Sent: Tuesday, April 11, 2023 3:19 PM
To: Young, Brianna A
Cc: Jennifer Bunting; Chris Bagley
Subject: RE: [External] SW Permit Renewal Supplemental Information - SS Creedmoor,
NCS000294
Attachments: 2019-01-02 Lily Walker-Jennifer Bunting, Hoyt Self, East Outfall.pdf, Site
Map-Replacement 2023.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
The coordinates of the stormwater outfalls are:
Outfall 001: 36.136013, -78.680640
Outfall 003: 36.136049, -78.679964
Per our phone conversation yesterday afternoon, outfall 003 is not being monitored due to an understanding with DEQ
that outfall 003 is not representative of the facility's industrial activity. Please see the attached email from Lily Walker of
Duncklee & Dunham (now SynTerra)to Jennifer Bunting and Hoyt Self of Southern States Cooperative on January 2,
2019.The following statement is in the email and provides indication of the understanding between Southern States
Cooperative and DEQ.
"I learned we have not been sampling at this outfall since the State had determined this outfall was not representative
of industrial activity in the past."
An updated site map is attached as well.
Please let me know if you have any further questions.
Thank you,
Zach Garlick
Environmental Engineering Technician
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ternn��tM
s,q-
synTerm
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Direct: 984-308-8622
Mobile: [phone]
[e-mail]
www.synterracorp.com
Connect with us: Linkedln I Facebook Twitter
i

This email might contain privileged or confidential information. If the email was not intended for you,please:
(i) Delete the email and any attachments.
(ii) Destroy any copies that might have been made.
(iii) Do not use,copy,or distribute the contents in any form.
(iv) Notify me by return email or phone.
No privilege is waived by inadvertent transmission.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,April 5, 2023 3:32 PM
To:Zachary Garlick<[e-mail]>
Cc:Jennifer Bunting<[e-mail]>; Chris Bagley<[e-mail]>
Subject: RE: [External] SW Permit Renewal Supplemental Information -SS Creedmoor, NCS000294
EXTERNAL: This Message originated outside your organization.
Good afternoon Zach,
I received your voicemail from the other week and wanted to follow up as I had not heard anything further. Do you have
any questions about the additional information requested?
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Friday, March 3, 2023 9:50 AM
To: 'Zachary Garlick' <[e-mail]>
Cc: 'Jennifer Bunting' <[e-mail]>; 'Chris Bagley' <[e-mail]>
Subject: RE: [External] SW Permit Renewal Supplemental Information -SS Creedmoor, NCS000294
Good morning,
After reviewing all the information submitted, I have a couple follow-up questions.The site map you submitted indicates
there are two outfalls: 001 and 003. Can you please provide the coordinates for each outfall?Additionally,you state
Outfall 003 is not monitored. Can you please provide an explanation for why the outfall is not monitored?
2

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Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent: Monday, October 24, 2022 2:12 PM
To:Zachary Garlick<[e-mail]>
Cc:Jennifer Bunting<[e-mail]>; Chris Bagley<[e-mail]>
Subject: RE: [External] SW Permit Renewal Supplemental Information -SS Creedmoor, NCS000294
Thank you for providing this information. I will reach out if I have any additional questions once I've had a chance to
review.
Brianna Young, MS(she/her/hers)
3

Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Zachary Garlick<[e-mail]>
Sent: Monday, October 24, 2022 2:01 PM
To:Young, Brianna A<[e-mail]>
Cc:Jennifer Bunting<[e-mail]>; Chris Bagley<[e-mail]>
Subject: [External] SW Permit Renewal Supplemental Information -SS Creedmoor, NCS000294
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
See the attached Supplemental Information for the Southern States Coop. Creedmoor Fertilizer Plant's Individual
Stormwater Permit Renewal, NCS000294.An electronic spreadsheet summarizing the analytical and visual monitoring
data 2017-present is included.
Let me know if you have any questions or concerns.
Thank you,
Zach Garlick
Environmental Engineering Technician
nc�.%cr:rer
synTerra
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898
Mobile: [phone]
[e-mail]
www.sVnterracorp.com
SynTerra, as always, is focused on the safety of our employees, clients, and communities.As our communities reopen,
we continue to monitor COVID-19 numbers. SynTerra has developed a three-phase return-to-office plan. While we
4

implement the plan,we remain flexible.Technology enables us to continue operations,collaborate freely,and provide
the same responsive service our clients deserve. For more information about our new safety precautions and return-
to-office plan, click here.
Connect with us: Linkedln I Facebook I Twitter
This email might contain privileged or confidential information.If the email was not intended for you,please:
(i) Delete the email and any attachments.
(ii) Destroy any copies that might have been made.
(iii) Do not use,copy,or distribute the contents in any form.
(iv) Notify me by return email or phone.
No privilege is waived by inadvertent transmission.
5

Lily Walker
From: Lily Walker
Sent: Wednesday, January 2, 2019 11:44 AM
To: 'Jennifer Bunting'; '[e-mail]'
Cc: Chris Bagley
Subject: December Creedmoor SW Results
Attachments: 2018-12 SDO Qualitative Monitoring Report.pdf; Lab Results Dec 2018 EAST.pdf;
2018-12 SDO Submittal.pdf
Hello Jennifer and Hoyt,
Attached is the stormwater monitoring report and qualitative report for the Creedmoor Fertilizer Plant for the month of
December. I have submitted the report to the appropriate state office.
The outfall looks much better this month,but it did still exceed the benchmark values for nitrate-nitrite and total
phosphorus. This is a significant improvement from exceedances in ammonia,nitrate-nitrite,total phosphorus, TKN,TSS
and total nitrogen when I sampled in October.
I also sampled at the East outfall as you asked and have attached the lab results for that outfall. It looks to be fairly clean—
the only benchmark it exceeded was TSS (value of 632 mg/L for a benchmark value of 100 mg/L). This value could be
due to significant corrosion of the buried pipe seeing as this outfall was actually discharging from a hole in the bottom of
the metal pipe. I learned we have not been sampling at this outfall since the State had determined this outfall was not
representative of industrial activity in the past.
The values for nitrate-nitrite and phosphorus were low for the East outfall(1.63 and 6.22,respectively). Therefore,I think
we can confidently say that the contamination problem is coming from somewhere on the west side of the site.
I hope I was able to explain the situation fairly well over email. Please feel free to call/email me if you have any
questions!
Thanks,
Lily R.Walker
Staff Engineer
Duncklee&Dunham,P.C.
511 Keisler Drive
Suite 102
Cary,North Carolina 27518
Office:[phone] ext. 105
Mobile:[phone]
lilygdunckleedunham.com
www.dunckleedunham.com
hiips://www.linkedin.com/in/tily-walker-umich/
DUNCKLFE&DUNIL M
A Professional Geologic and Engineering Corporation
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NDrawn By: Checked By: Project Number: Date: References: ENVIRONMENTAL GEOLOGISTS&ENGINEERS
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I"=50' 8.5"X 11° P:\_Cary\Southern States\Creedmoor Stormwater-201027WPDES Permit\Application\2022-Response to DEQ\Response\Fig=s.pdf

Terra Science & Engineering Consultants
synsynterracorp.com
October 24, 2022
Brianna Young
Industrial Individual Permits Coordinator
DEMLR Stormwater Program, 1612 MSC
Raleigh, North Carolina 27699-1612
SUBJECT: Stormwater Permit Renewal - Supplemental Information
Southern States Cooperative, Inc.
Creedmoor Fertilizer Plant
Creedmoor, North Carolina
Permit No. NCS000294
Dear Ms. Young:
On behalf of our client, Southern States Cooperative, Inc. (Southern States), SynTerra
Corporation (SynTerra) submits the following attached supplemental information you
requested for the renewal of Individual Stormwater Permit No. NCS000294:
• Table 1 —Analytical Monitoring Results 2017— present
• Table 2 —Visual Monitoring Results 2017— present
• Analytical Monitoring Results 2014—2016
• Visual Monitoring Results 2014—2016
• Figure 1 —Topographic Site Location Map
• Figure 2 —Site Map
• Best Management Practices (Section 4.3 of the SWPPP)
• SWPPP Certification (Section 11 of the SWPPP)
The online NPDES Stormwater Permit Summary has been revised to indicate Jennifer Bunting as
the Owner, Facility, and Permit Contact (replacing Lauren B. Faulkner). I, Zach Garlick, am
indicated as a Permit Contact. There have been no changes in industrial activities since the
permit renewal application was submitted. Outfall 001 West is the only outfall currently being
monitored.
Please contact Zach Garlick at [phone] ([e-mail]) or Jennifer Bunting
of Southern States at [phone] (men [e-mail]) if you have any questions
or require any additional information.
synterracorp.com

Stormwater Permit Renewal-Supplemental Information
Southern States Cooperative,Inc—Creedmoor Fertilizer Plant
October 24,2022 Page 2
Sincerely,
SynTerra
Zach Garlick
Environmental Engineering Technician
Senior Peer Review
Chris Bagley, C , CHMM, QEP
Senior Engineer/Senior Industrial Hygienist
Cc: Jennifer Bunting— Environmental Programs Manager, Southern States Cooperative, Inc.
synterracorp.com

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures,drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
�S 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Table 1-Analytical Monitoring Results 2017-Present
Date 24-hr pH Sulfate BOD COD Ammonia Nitrite+Nitrate Total TKN Total Suspended Total
Rainfall(in) Nitrogen Nitrogen Phosphorus Solids Nitrogen
Benchmark Values 6-9 250 30 120 7.2 10 2 20 100 30
Outfalls
2/15/2017 0.34 6.70 481 9.20 80.6 17.3 856 13.4 0.0657 398 856
7/30/2018 0.86 7.51 156 11.5 116 58.9 55.3 10.8 206 16.0 261
10/11/2018 2.14 7.28 96.3 6.45 91.6 18.4 26.2 12.2 39.3 133 65.5
12/14/2018 0.13 7.23 89.9 4.30 29.7 4.41 13.4 5.75 7.93 32.4 21.4
1/4/2019 0.11 7.15 87.6 7.35 441 3.26 20.1 4.86 3.58 24.3 23.7
2/27/2019 0.13 6.76 149 6.20 138.2 4.69 15.1 4.07 6.33 19.16 21.4
7/23/2019 0.97 6.78 57.9 6.10 42.0 5.60 16.0 4.89 6.58 13.4 22.5
12/13/2019 0.19 6.88 156 5.05 46.5 10.5 36.2 3.34 <1.75 8.00 36.2
2/6/2020 0.19 7.03 65.8 6.80 57.7 3.98 14.3 3.54 5.03 80.8 19.3
4/20/2020 0.58 6.34 230 9.17 77.5 30.5 45.3 23.1 34.3 11.9 79.6
Outfall 001 West 5/19/2020 0.11 6.01 709 17.2 124 85.1 179 71.2 78.8 20.9 258
6/6/2020 0.86 6.73 76.3 5.25 56.3 15.0 27.5 87.5 18.3 11.4 45.8
8/4/2020 3.49 6.45 119 5.90 54.3 5.91 45.2 9.20 <7.0 8.20 45.2
9/17/20201.26 6.75 242 9.40 59.7 20.2 55.5 18.7 26.6 47.5 82.1
11/12/2020 0.35 6.88 52.4 8.60 45.5 6.78 12.5 9.80 8.82 30.6 21.3
12/16/2020 0.02 6.72 20.3 3.00 19.6 2.34 7.27 2.67 3.73 59.5 11.0
1/26/20210.71 6.84 73.1 5.20 37.4 3.67 23.8 4.67 3.00 5.70 26.8
2/12/20210.94 7.09 55.6 3.90 149.4 17.4 12.8 13.4 25.0 19.80 37.8
6/22/2021 1.03 6.16 672 16.3 125 103 163 162 90.0 22.8 253
7/8/2021 2.52 7.52 380 11.2 77.2 70.8 132 18.3 70.0 6.00 202
9/9/2021 0.07 7.03 62.6 4.65 67.2 4.42 36.4 1.38 292 189 328
9/30/2022 0.20 6.63 163 7.90 59.1 60.3 62.4 88.0 59.0 35.8 121
12/14/2018 0.13 7.54 15.6 <10 30.0 0.135 6.22 1.63 1.75 632 7.97
Outfall 003 East 12/13/2019 0.19 7.07 28.0 4.60 45.5 0.342 5.42 0.711 0.796 35.3 6.22
2/6/2020 0.19 7.08 11.5 3.15 150.1 0.375 1.99 1.01 10.636 590 2.63
Notes:
1)All parameters with the exception of 24-hr Rainfall and pH are in units of mg/L.
2)Shaded values exceeded the corresponding benchmark.

Table 2-Visual Monitoring Results 2017-Present
Floating Suspended Signs of
Date Color Odor Clarity Foam Oil Sheen
Solids Solids Erosion
1-5 1-5 1-5 Yes/No Yes/No Yes/No
Outfalls
2/15/2017 Medium brown None 3 3 3 No No No
7/30/2018 Light brown None 3 2 3 No No No
10/11/2018 Light brown None 2 1 2 No No No
12/14/2018 Light brown-yellow None 2 1 1 No No No
1/4/2019 Very light brown-yellow None 2 1 1 No No No
2/27/2019 Light brown-yellow None 2 1 1 No No No
7/23/2019 Medium yellow Slight chlorine odor 3 1 1 No No No
12/13/2019 Light yellow-brown None 4 1 1 No No No
2/6/2020 Light yellow-brown None 2 1 2 No No No
4/20/2020 Light brown Strong dirt odor 3 2 2 No Yes No
Outfall 001 West 5/19/2020 Medium orange-brown Weak chlorine odor 4 2 2 No No No
6/6/2020 Light/medium yellow Slight chlorine/earthy odor 3 1 1 No No No
8/4/2020 Medium yellow-brown Weak earthy odor 1 2 2 No No No
9/17/2020 Light orange-brown Weak earthy odor 4 2 2 No No No
11/12/2020 Light brown None 3 2 2 No No No
12/16/2020 Light brown-orange None 4 1 1 No No No
1/26/2021 Light green-brown Weak earthy odor 1 1 1 No No No
2/12/2021 Light green None 2 11 1 No No No
6/22/2021 Light yellow-green None 2 2 2 No No No
7/8/2021 Light brown None 2 3 2 Yes Yes No
9/9/2021 Light brown None 3 2 2 No No No
9/30/2022 Light yellow-brown None 2 1 2 No No No
12/14/2018
Outfall 003 East 12/13/2019 Light yellow-brown INone 4 1 1 Yes,small No INo
2/6/2020 Medium yellow-brown INone 14 11 14 INo INo No
Note:The visual monitoring results for Outfall 003 East on 12/14/2018 are missing.

Creedmoor Storm Water Sample Results-2014-2016
Total
Ammonia total Suspended Total
Date pH Sulfate BOD COD Nitrogen Nitrate-Nitrite Phosphorus TKN Solids Nitrogen
Benchmark
Values 6.0-9.0 250 mg/L 30 mg/L 120 mg/L 7.2 mg/L 10.0 mg/L 2.0 mg/L 20 mg/L 100 mg/L 30 mg/L
Outfall1 West 4/15/2014 7.02 360 40 260 69 18.2 27 130 190 199
5/14/2014 7.02 360 40 260 ` 69 18.2 27 130 190 199
7/21/2014 6.64 240 52 ` 98 34` 100.5 12 40 86 74
9/24/2014 6.8 150 44 99 46i 111.3 15 46' 210 92
12/16/2014 6.53 98 6.7 49 7.2 17.13 4.1 9.7 67 16.9
3/27/2015 7.2 1200 42 61 200 49.6 14 220 100 420
11/2/2015 6.87 145 10.6 74.4 28.3 27.88 6.6 28.6 40 56.9
4/12/2016 6.64 524 16.5 41.9 119 77.94 92.2" 194 12 313
5/17/2016 6.5 351 ` 9.15 104 43` 72.7 29.82 41.5 5.8 84.5 1
6/28/2016 6.42 67.3 9.85 84.2 8 N 17.3 9.68I 10.6 18.3 18.8
9/19/2016 6.55 95.9 6.4 83.3 758 44 6.85` 8.7 10.5 16.3
Outfall 3 East 4/15/2014 7.03 25 10 71 3.2 4.6 3.2 t 6.7 35 9.9
5/14/2014 7.03 25 10 71 3.2 4.6 3.2 6.7 35 9.9
7/21/2014 7.5 47 5.7 50 2.7 14.22 2 <0.7 78 2.7
9/24/2014 6.76 45 5.5 47 2.2 14.09 2.6 4.6 ;ii% 6.8
12/16/2014 7.09 33 3.6 40 0.88 4 1.3 1.6 280 2.48
3/27/2015 6.55 17 5.9 24 0.24 3.34 1.1 1.9 210 2.14
t l
�.,lsttime exceeding benchmark
Tier H monitoring in effect exceeded benchmark value
Bold Increased from previous sampling event

Southern States Creed moor Fertilizer Plant Visual
Monitoring Results Permit#NCS000294
Date Color Odor Clarity Floating Solids Suspended Solids Foam Oil Sheen Signs of Erosion at Oufall
Outfalls
Outfall 1 West 7/21/2014 yellowish-brown None 3 1 3 No No No
9/24/2014 yellowish-brown None 3 1 3 No No No
12/16/2014 yellowish-brown None 3 1 2 No No No
3/27/2015 yellowish-brown None 3 1 3 No No No
11/2/2015 yellowish-brown None 3 1 1 3 No No No
12/22/2015 light brown None 2 1 2 No No No
4/12/2016 light brown None 2 1 2 No No No
5/17/2016 slight tint None 3 3 3 No No No
6/28/2016 slight tint None 2 2 2 No No Yes
9/19/2016 light yellow None 2 2 2 No No No
Outfall 3 East 7/21/2014 Yellowish brown None 3 2 3 yes No Yes
9/24/2014 Yellowish brown None 3 2 3 Yes No Yes
12/16/2014 Yellowish brown None 2 1 2 No No Yes
3/27/2015 Yellowish brown None 4 1 4 No No Yes

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Drawn By: Checked By: Project Number: Date: References: 1
511 Keisler Drive Suite 102 [phone] LRW 201027 November 2019 Sys:stem,NC(2019),C-dmoor,NC 1
Cary,North Carolina 27518 —.dunckleedunham.com 2019
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NDrawn By: Checked By: Project Number: Date: References: ENVIRONMENTAL GEOLOGISTS&ENGINEERS
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PASouthemStates\CreedmoorStormwater-201027\CAD\SWPPP Site Map.dwg

Stormwater Pollution Prevention Plan
Creedmoor Fertilizer Plant
Creedmoor,North Carolina
November 26,2019
Page 6 of 16
4.3 Best Management Practices
The Creedmoor Fertilizer Plant implements both structural and non-structural control measures to reduce
potential stormwater contamination. This summary of best management practices is reviewed and updated
annually with the SWPPP review.
4.3.1 Structural Control Measures
Structural control measures in place at the Creedmoor Fertilizer plant include:
• ASTs are equipped with secondary containment
• Truck loading/unloading operations are performed on concrete pads that are regularly swept
• Dry fertilizer is stored inside the warehouse and the bulk fertilizer building to limit contact with
stormwater
• The exterior walls of the bulk fertilizer building are reinforced with wooden braces to withstand
the pressure from loading bulk fertilizer into the bays and prevent leakage from the building's
side
4.3.2 Non-Structural Control Measures
Non-structural control measures at the Creedmoor Fertilizer Plant include the good housekeeping and
preventative maintenance programs. The following-non-structural control measures are also implemented
at the facility:
• Designated employees routinely inspect the ASTs to check the valves, fittings,and hoses for signs
of leaks or damage and make repairs as needed.
• The concrete containment dike is inspected regularly for signs of deterioration.
• Spills at the facility are cleaned up and reported as described in Section 5.3.
• Periodic safety meetings are held to review safe work practices that include spill prevention and
response procedures so that employees know where the spill response equipment and emergency
response numbers are located.
• Facility employees observe customers and delivery drivers while they are onsite to ensure that
material is properly handled, and spilled material is contained and promptly cleaned up following
loading/unloading activities.
• Routine inspections and dry sweeping of mobile equipment used for bulk dry fertilizer transfer(i.e.
front loaders, fork lifts, etc.) are performed to prevent the spread of dry fertilizer onto ground
surfaces where it can contact precipitation or vehicle wheels; loose fertilizer is either placed in a
container for off-site disposal or recycled back to fertilizer storage.
4.3.3 Good Housekeeping
The following housekeeping measures are followed to minimize contact of stormwater with potential
sources of pollutants:
• Visible,loose fertilizer is removed from exposed surfaces in material-loading and-unloading areas,
and from transfer and distribution vehicles.

Stormwater Pollution Prevention Plan
Creedmoor Fertilizer Plant
Creedmoor,North Carolina
November 26,2019
Page 7 of 16
• Fertilizer spills on indoor floor surfaces are removed daily to prevent fertilizer from being
transferred outdoors on vehicles such as fork lifts or on employees'shoes.
• Building concrete floors are swept or scraped daily to prevent stormwater contamination from
fertilizer tracked outside on shoes or tires.
• The concrete containment dike is kept as empty and clean as possible between storm events;
following storm events, standing water is inspected for signs of contamination prior to discharge.
• Exposed concrete surfaces used in the fertilizer operations are swept clean at the end of each day
and recovered product is reused when possible.
• Drip pans are placed under the fittings of the hose connections at the diked area when material is
being loaded or unloaded onto trucks or tanks.
• Debris and trash is picked up throughout the day.
• Spill response supplies are stored at the facility. Employees know where these materials are located
and are familiar with proper spill response procedures.
• Spills and leaks are promptly contained and cleaned up. Refer to Section 5 for Spill Prevention
and Response Procedures in place at the facility.
• Vehicle maintenance is conducted off-site.
All employees working at the fertilizer plant are trained on the importance of good housekeeping practices.
The manager will perform regular inspections during operating hours to assure that the appropriate
measures are being taken.
4.3.4 Preventive Maintenance
The Creedmoor Fertilizer Plant implements a preventive maintenance program to minimize the potential
for leaks, spills,and other releases of pollutants to stormwater from equipment stored and used on-site. All
equipment kept onsite will be inspected on a regular basis in order to detect any leaks or unsafe conditions.
This includes the forklift, a front-end loader,two nurse tanks, a sprayer buggy, a flatbed truck, a spreader
truck and tandem trailer used to deliver bulk fertilizer. The program ensures control measures, stormwater
discharge outfalls, industrial activity areas, drainage features and structures, and existing structural BMPs
are properly maintained. Preventative maintenance activities are performed by trained personnel and
corrective actions are documented on maintenance logs.
These logs include:
1. the date and places of maintenance activity;
2. individual performing maintenance activity; and
3. description of areas in need of repair or replacement;
Maintenance logs are prepared by the personnel conducting the maintenance and maintained by the Plant
Manager. The routine inspections described in Section 8 are part of the preventive maintenance program.

Stormwater Pollution Prevention Plan
Creedmoor Fertilizer Plant
Creedmoor,North Carolina
November 26,2019
Page 16 of 16
11 SWPPP Certification
I certify, under penalty of law, that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gathered
and evaluated the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,
to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submittingfalse information, including the possibility offine and imprisonment for knowing
violations.
P&Nnf-j
Name: ! ` Title: N0-ecdA,K44*q
Signature: Date: i

Young, Brianna A
From: Zachary Garlick <[e-mail]>
Sent: Monday, October 24, 2022 2:01 PM
To: Young, Brianna A
Cc: Jennifer Bunting; Chris Bagley
Subject: [External] SW Permit Renewal Supplemental Information - SS Creedmoor, NCS000294
Attachments: SW Permit Renewal Supplemental Info.pdf,Analytical and Qualitative Data.xlsx
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
See the attached Supplemental Information for the Southern States Coop. Creedmoor Fertilizer Plant's Individual
Stormwater Permit Renewal, NCS000294.An electronic spreadsheet summarizing the analytical and visual monitoring
data 2017-present is included.
Let me know if you have any questions or concerns.
Thank you,
Zach Garlick
Environmental Engineering Technician
nnn[xr.vx ren7
r-nIrnM
ow
synTerra
511 Keisler Drive, Suite 102
Cary, North Carolina 27518
Office: 919-858-9898
Mobile: [phone]
[e-mail]
www.synterracorp.com
SynTerra, as always, is focused on the safety of our employees,clients, and communities.As our communities reopen,
we continue to monitor COVID-19 numbers. SynTerra has developed a three-phase return-to-office plan. While we
implement the plan,we remain flexible.Technology enables us to continue operations,collaborate freely,and provide
the same responsive service our clients deserve. For more information about our new safety precautions and return-
to-office plan, click here.
Connect with us: Linkedln I Facebook I Twitter
This email might contain privileged or confidential information.If the email was not intended for you,please:
(i) Delete the email and any attachments.
(ii) Destroy any copies that might have been made.
(iii) Do not use,copy,or distribute the contents in any form.
(iv) Notify me by return email or phone.
No privilege is waived by inadvertent transmission.
1

Table 1-Analytical Monitoring Results 2017-Present
Date 24-hr pH Sulfate BOD COD Ammonia Nitrite+Nitrate Total TKN Total Suspended Total
Rainfall(in) Nitrogen Nitrogen Phosphorus Solids Nitrogen
Benchmark Values 6-9 250 30 120 7.2 10 2 20 100 30
Outfalls
2/15/2017 0.34 6.70 481 9.20 80.6 17.3 856 13.4 0.0657 398 856
7/30/2018 0.86 7.51 156 11.5 116 58.9 55.3 10.8 206 16.0 261
10/11/2018 2.14 7.28 96.3 6.45 91.6 18.4 26.2 12.2 39.3 133 65.5
12/14/2018 0.13 7.23 89.9 4.30 29.7 4.41 13.4 5.75 7.93 32.4 21.4
1/4/2019 0.11 7.15 87.6 7.35 441 3.26 20.1 4.86 3.58 24.3 23.7
2/27/2019 0.13 6.76 149 6.20 38.2 4.69 15.1 4.07 6.33 9.16 21.4
7/23/2019 0.97 6.78 57.9 6.10 42.0 5.60 16.0 4.89 6.58 13.4 22.5
12/13/2019 0.19 6.88 156 5.05 46.5 10.5 36.2 3.34 <1.75 8.00 36.2
2/6/2020 0.19 7.03 65.8 6.80 57.7 3.98 14.3 3.54 5.03 80.8 19.3
4/20/2020 0.58 6.34 230 9.17 77.5 30.5 45.3 23.1 34.3 11.9 79.6
Outfall 001 West 5/19/2020 0.11 6.01 709 17.2 124 85.1 179 71.2 78.8 20.9 258
6/6/2020 0.86 6.73 76.3 5.25 56.3 15.0 27.5 87.5 18.3 11.4 45.8
8/4/2020 3.49 6.45 119 5.90 54.3 5.91 45.2 9.20 <7.0 8.20 45.2
9/17/20201.26 6.75 242 9.40 59.7 20.2 55.5 18.7 26.6 47.5 82.1
11/12/2020 0.35 6.88 52.4 8.60 45.5 6.78 12.5 9.80 8.82 30.6 21.3
12/16/2020 0.02 6.72 20.3 3.00 19.6 2.34 7.27 2.67 3.73 59.5 11.0
1/26/2021K2.52
6.84 73.1 5.20 37.4 3.67 23.8 4.67 3.00 5.70 26.8
2/12/2021 7.09 55.6 3.90 49.4 17.4 12.8 13.4 25.0 9.80 37.8
6/22/2021 6.16 672 16.3 125 103 163 162 90.0 22.8 253
7/8/2021 7.52 380 11.2 77.2 70.8 132 18.3 70.0 6.00 202
9/9/2021 7.03 62.6 4.65 67.2 4.42 36.4 1.38 292 189 328
9/30/2022 6.63 1163 17.90 159.1 160.3 162.4 188.0 159.0 135.8 121
12/14/2018 0.13 7.54 15.6 <10 30.0 0.135 6.22 1.63 1.75 632 7.97
Outfall 003 East 12/13/2019 0.19 7.07 28.0 4.60 45.5 0.342 5.42 0.711 0.796 35.3 6.22
2/6/2020 0.19 7.08 11.5 3.15 150.1 0.375 1.99 1.01 0.636 590 2.63
Notes:
1)All parameters with the exception of 24-hr Rainfall and pH are in units of mg/L.
2)Shaded values exceeded the corresponding benchmark

Table 2-Visual Monitoring Results 2017-Present
Floating Suspended Signs of
Date Color Odor Clarity Foam Oil Sheen
Solids Solids Erosion
1-5 1-5 1-5 Yes/No Yes/No Yes/No
Outfalls
2/15/2017 Medium brown None 3 3 3 No No No
7/30/2018 Light brown None 3 2 3 No No No
10/11/2018 Light brown None 2 1 2 No No No
12/14/2018 Light brown-yellow None 2 1 1 No No No
1/4/2019 Very light brown-yellow None 2 1 1 No No No
2/27/2019 Light brown-yellow None 2 1 1 No No No
7/23/2019 Medium yellow Slight chlorine odor 3 1 1 No No No
12/13/2019 Light yellow-brown None 4 1 1 No No No
2/6/2020 Light yellow-brown None 2 1 2 No No No
4/20/2020 Light brown Strong dirt odor 3 2 2 No Yes No
5/19/2020 Medium orange-brown Weak chlorine odor 4 2 2 No No No
Outfall 001 West 6/6/2020 Light/medium yellow Slight chlorine/earthy odor 3 1 1 No No No
8/4/2020 Medium yellow-brown Weak earthy odor 1 2 2 No No No
9/17/2020 Light orange-brown Weak earthy odor 4 2 2 No No No
11/12/2020 Light brown None 3 2 2 No No No
12/16/2020 Light brown-orange None 4 1 1 No No No
1/26/2021 Light green-brown Weak earthy odor 1 1 1 No No No
2/12/2021 Light green None 2 1 1 No No No
6/22/2021 Light yellow-green None 2 2 2 No No No
7/8/2021 Light brown None 2 3 2 Yes Yes No
9/9/2021 Light brown None 3 2 2 No No No
9/30/2022 Light yellow-brown lNone 12 11 12 lNo lNo No
12/14/2018
Outfall 003 East 12/13/2019 Light yellow-brown None 4 1 1 Yes,small No No
amount
2/6/2020 Medium yellow-brown None 4 1 4 No No No
Note:The visual monitoring results for Outfall 003 East on 12/14/2018 are missing.

Young, Brianna A
From: Young, Brianna A
Sent: Tuesday,August 2, 2022 10:38 AM
To: [e-mail]
Cc: [e-mail]
Subject: Southern States Creedmoor-Louisburg Agronomy Plant (NCS000294) stormwater
permit renewal
Good morning,
I am working on renewing the individual stormwater permit for the Southern States Creedmoor-Louisburg
Agronomy Plant(NCS000294). I need additional information in order to 1) confirm that the information I have
is correct and 2) make sure the permit adequately serves the needs of the facility. Please provide the following:
• Supplemental Information Form(available online here);
• Statement of any significant changes in industrial activities (could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage practices, and/or
changes in the raw materials used by the facility);
• Description of industrial activities in each drainage area;
• Confirmation on the number of outfalls and associated coordinates;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s) for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePgMent website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
1

Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
2

8/2/22,8:50 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
Southern States Cooperative, Incorporated
Information
Sosld: 0137894
Status: Current-Active O
Date Formed: 1/13/1965
Citizenship: Foreign
State of Incorporation: VA
Fiscal Month: June
Annual Report Due Date: October 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
Reg Office Reg Mailing
2626 Glenwood Avenue, Suite 550 2626 Glenwood Avenue, Suite 550
Raleigh, NC 27608-1370 Raleigh, NC 27608-1370
Mailing Principal Office
6606 West Broad Street 6606 West Broad Street
Richmond, VA 23230-1717 Richmond, VA 23230-1717
Officers
President Secretary Treasurer
Steve Becraft CHARLES W. PAYNE, JR. William Thomas Didlake , Jr
6606 West Broad Street 6606 WEST BROAD STREET 6606 West Broad Street
Richmond VA 23230 RICHMOND VA 23230 Richmond VA 23230
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

8/2/22,8:50 AM North Carolina Secretary of State Search Results
Stock
Class: 99 SEE CERT
Shares: 0
Par Value 0
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Southern States Cooperative,Inc.
6606 West Broad Street
Richmond,Va.23230.1717
Mall Address:P.O.Box 26234
Richmond,Va 23260-6234
Telephone[phone]
so October 21", 2016
SOUTHERN North Carolina Department of Environmental Quality
STAStormwater Program, Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh,North Carolina 27699-1612
Attention: Permitting
RE: Southern States Creedmoor facility (NPDES #NCS000294) located at
2089 Sam Moss Road in Creedmoor,NC
Dear whom it may concern,
As a requirement of the National Pollutant Discharge and Elimination System
(NPDES)permit that was issued by the North Carolina Department of Environmental
Quality (NCDEQ), the Southern States (SSC) Creedmoor Plant is submitting this
permit renewal package. This facility is located at 2089 Sam Moss Road in
Creedmoor, North Carolina and is covered under NPDES storm water permit
#NCS000294. Contained within this package are two copies of a site map, storm
water analytical data, storm water visual data, a list of current Best Management
Practices and a signed Certification form for the facility's Storm Water Pollution
Prevention Plan.
Thank you for your assistance and cooperation with this and if you need any
additional information, please let me at (804) 281-1189 or via email at
lauren.faulknerQsscoop.com.
Sincerely, RECEIVED
OCT 312016
-
DEIVR-LAND QUALITY
Lauren B. Faulkner STORhMATER PERMITTING
Environmental Project Manager
Cc: Mr. Samuel Anderson-General Manager of the Creedmoor Plant
Mr. Lucas Householder-SSC District Manager

A Permit Coverage
Renewal Application Form NPDES Permit Number
N�DENR National Pollutant Discharge Elimination System NC5000
Stormwater Individual Permit
294
Please provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/Organization Name: Southern States Cooperative,Inc.
Owner Contact: Lauren B. Faulkner
Mailing Address: PO Box 26234
Richmond, Virginia 23260
Phone Number: 804-281-1189
Fax Number: 804-281-1396
E-mail address: Lauren.faulknemosssc000.com
Facility Information
Facility Name: Southern States Creedmoor-Louisburg Agronomy Plant
Facility Physical Address: 2089 Sam Moss Hayes Road
Creedmoor, North Carolina 27522
Facility Contact: Lauren B. Faulkner
Mailing Address: PO Box 26234
Richmond,Virginia 23260
Phone Number: 804-281-1189
Fax Number: 804-281-1396
E-mail address: [e-mail]
Permit Information
Permit Contact: Lauren B. Faulkner
Mailing Address: PO Box 26234
Richmond,Virginia 23260
Phone Number: 804-281-1189
Fax Number: 804-281-1396
E-mail address: [e-mail]
Discharge Information RECEIVED
Receiving Stream: Unnamed tributary to Robertson Creek
Stream Class: WS-IV NSW OCT 3 12016
Basin: Neuse River Basin
Sub-Basin: n NR-LAND QUALITY
Number of Outfalls: 2 gTORMWATER PERMITTING
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
/NoA.e
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is true, c plete and..accucate
Signature Date
Lac�izn feu ll%�P/ E17v1ronmr1716?1 AWC/
Print or type name of person signing above Title
Please return this completed application form SW Individual Permit Coverage Renewal
Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources -Stormwater Permitting
Facility Name: Ct S60. s Crl�r no —L'OLtI-sbur o,� Janf
Permit Number: N/C s 000aq �f
Location Address: aosq Say,,,; MOSS
LC 2_p
County: Gran�i 2
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering the information, the
information gathered is, to the best of my knowledge and belief, true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been
fully implemented at this facility location in accordance with the terms and conditions of the stormwater discharge
permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date
�Gt,�tren �. l�ncr Cnvr i-01)m" Pr(! er
Print or type name of person signing above Title
SPPP Certification 10/13

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Creedmoor Storm Water Sample Results-2014-2016
Total
Ammonia total Suspended Total
Date PH Sulfate BOD COD Nitrogen Nitrate-Nitrite Phosphorus TKN Solids Nitrogen
Benchmark
Values 6.0-9.0 250 mg/L 30 mg/L 120 mg/L 7.2 mg/L 10.0 mg/L 2.0 mg/L 20 mg/L 100 mg/L 30 mg/L
Outfall1 West 4/15/2014 7.02 360 40 260 69 18.2 27 130 190 199
5/14/2014 7.02 360 40 260 69 18.2 27 130 190 199
7/21/2014 6.64 240 52 98 34 100.5 12 40 86 74
9/24/2014 6.8 150 44 99 46 111.3 15 46 210 92
12/16/2014 6.53 98 6.7 49 7.2 17.13 4.1 9.7 67 16.9
3/27/2015 7.2 1200 42 61 200 49.6 14 220 100 420
11/2/2015 6.87 145 10.6 74.4 28.3 27.88 6.6 28.6 40 56.9
4/12/2016 6.64 524 16.5 41.9 119 77.94 92.2 194 12 313
5/17/2016 6.5 351 9.15 104 43 72.7 29.8 41.5 5.8 84.5
6/28/2016 6.42 67.3 9.85 84.2 1 8.16 17.3 9.68 10.6 18.3 18.8
9/19/2016 6.55 95.9 6.4 83.3 7.58 44 HE 8.7 10.5 16.3
Outfall 3 East 4/15/2014 7.03 25 10 71 3.2 4.6 3.2 6.7 35 9.9
5/14/2014 7.03 25 10 71 3.2 4.6 3.2 6.7 35 9.9
7/21/2014 7.5 47 5.7 50 2.7 14.22 2 <0.7 78 2.7
9/24/2014 6.76 45 5.5 47 2.2 14.09 2.6 4.6 140 6.8
12/16/2014 7.09 33 3.6 40 0.88 4 1.3 1.6 280 2.48
3/27/2015 6.55 17 5.9 24 0.24 3.34 1.1 1.9 210 2.14
1st time exceeding benchmark
Tier 11 monitoring in effect exceeded benchmark value
Bold Increased from previous sampling event

Southern States Creedmoor Fertilizer Plant Visual
Monitoring Results Permit#NCS000294
Date Color Odor Clarity Floating Solids Suspended Solids Foam Oil Sheen Signs of Erosion at Oufall
Outfalls
Outfall 1 West 7/21/2014 yellowish-brown None 3 1 3 No No No
9/24/2014 yellowish-brown None 3 1 3 No No No
12/16/2014 yellowish-brown None 3 1 2 No No No
3/27/2015 yellowish-brown None 3 1 3 No No No
11/2/2015 yellowish-brown None 3 1 3 No No No
12/22/2015 light brown None 2 1 2 No No No
4/12/2016 light brown None 2 1 2 No No No
5/17/2016 slight tint None 3 3 3 No No No
6/28/2016 slight tint None 2 2 2 No No Yes
9/19/2016 light yellow None 2 2 2 No No No
Outfall 3 East 7/21/2014 Yellowish brown None 3 2 3
yes No Yes
9/24/2014 Yellowish brown None 3 2 3 Yes No Yes
12/16/2014 Yellowish brown None 2 1 2 No No Yes
3/27/2015 Yellowish brown None 4 1 1 1 4 No No Yes

P DUNCKLEE & DUNHAM
PHOTOGRAPHIC LOG
P:FYIROV4ENTAL GEOLOGISTS 8 ENGINEERS
Client Name: Site Location: Project No.
Southern States Creedmoor Fertilizer 201027
Photo# Date: -
j 6/24/14
Direction of Photo:
NA
Description:
West Outfall, inlet 3
stone filter excavation - -
Photo# Date:
2 1 6/24/14
Direction of Photo:
NA
Description:
West Outfall Inlet 3-
stone filter envelope

P DUNCKLEE & DUNHAM
PHOTOGRAPHIC LOG
ENVIRONMENTAL GEOLOGISTS ¢ ENGINEERS
Client Name: Site Location: Project No.
Southern States Creedmoor Fertilizer 201027
Photo# Date:
3 6/24/1a
Direction of Photo:
NA
V y
Description: 5 =
West Outfall Inlet 2- - s y I' -y " 4•
existing piping
Y
1
1
f .
Photo# Date:
[' r .ir -
4 6/24/14 :�- ":Ys- :� •�,�sr�`�3 � -• A>s`
Direction of Photo:
E
y
Description: .� '• "'
West Outfall Inlet 2-new . r 7i
piping
t7Y
,,-
Jyyr_
\r-

PHOTOGRAPHIC LOG DUNCKLEE & DUNHAM
I ENVIRONMENTAL GEOLOGISTS 8 ENGINEERS
Client Name: Site Location: Project No.
Southern States Creedmoor Fertilizer 201027
Photo# Date:
$ 6/24/14
Direction of Photo:
NA
Description:
West Outfall Inlet 2- ,, - z
stone filter envelope
ems. .y
Y
y'.
Photo# Date: - - -
6 6/10/14
Direction of Photo:
NA
Description: - -
West Outfall Pipe

P DUNCKLEE & DUNHAM
PHOTOGRAPHIC LOG
ENVIRONMENTAL GEOLOGISTS R ENGINEERS
Client Name: Site Location: Project No.
Southern States Creedmoor Fertilizer 201027
Photo# Date:
7 6/24/14
Direction of Photo:
NA
Description:
Lime pile stone filter

October 2016
Best Management Practices in place at the Southern States Creedmoor facility
NPDES#NCS000294
located at
2089 Sam Moss Road in Creedmoor,NC
Listed below are the recent structural Best Management Practices (BMPs) that were
installed at the Southern States (SSC) Creedmoor facility, NPDES storm water
permit#NCS000294.
• There are three drop inlets along the western side of the property that collect
storm water runoff that discharges through Outfall 1 West. Two years ago,
SSC placed silt sacks in each of these drop inlets to collect excess sediment
that might be flowing in from the gravel parking areas or the grassy areas
directly around the inlet. These silt sacks are checked each time a sample is
collected and any excess sediment that has collected in these silt sacks is
cleaned out. Outfall 3 East is fed by two drop inlets located in between the
fertilizer building and the main warehouse in grassy areas and both of these
have also had silt sacks installed.
• In 2014 the two most northern drop inlets that flow into Outfall 1 West had
stone filters installed to allow more sediment to settle out before entering the
drain. SSC had a contractor excavate 2-feet down and 3-4 feet wide around
the inlets and backfill with gravel to create any area where the sediments
could settle out of the runoff before entering the drain.
• During the installation of these stone filters for Outfall 1 West, the contractor
discovered that the corrugated underground pipe that connects the two
northern most inlets was severely corroded and needed to be replaced since
this was most likely allowing sediment into the pipe and contributing to the
elevated levels in recent storm water samples. The contractor came back at a
later date and excavated the old pipe and replaced it with a new corrugated
pipe which should dramatically help improve the sample results.
• A gravel lined trench was also installed next to the lime pile to prevent excess
lime and sediment from flowing into the ditch that feeds into Outfall 1 West.
Below are the procedural BMPs that are currently in place at the SSC Creedmoor
facility:
• Fertilizer that is spilled during the loading or unloading of trucks is swept up at
the end of each day to minimize the impact on storm water runoff.
• The silt sacks that were placed in each of the drop inlets are cleaned out
regularly to remove any excess sediment that has built up.
There have been no significant changes in industrial activity at this site over the last 4 years.