NCG060374_Final Report EPA ACO CWA-04-2017-4752_20180212

III
mm
} L11
I.
August 31, 2017
LCDR Tara Houda
Stormwater and Residuals Enforcement Section
NPDES Permitting & Enforcement Branch
Atlanta Federal Center
61 Forsyth Street
Atlanta, Ga 30303-8960
Mr. William Vinson
Stormwater Permitting Program
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
SEP 0 5 X417
Subject: Final Report, Administrative Compliance Order on Consent No.: CWA-04-2017-4752
Mt. Olive Pickle Company, Mount Olive, North Carolina
Dear Ms. Houda and Mr. Vinson:
As of August 4, 2017, Mt. Olive Pickle Company has completed the requirements of the
Administrative Compliance Order on Consent: CWA-04-2017-4752. In reference to the
requirements of paragraph 23 of the Consent Order the following actions were taken to comply
with each part.
Part A. A copy of the Certificate of Coverage (COC) for General Permit NCG060374 issued
October 14, 2016 to Mt. Olive Pickle Company was provided to LCDR Tara Houda on
April 6, 2017 via e-mail. The semi-annual sampling of stormwater Discharge Outfall
(SDO) 002 required by the COC was completed on May 23, 2017 and the results were
less than 229 mg/l. A copy of the COC is included in. appendix Part A.
Part B. During the month of May 2017 a rope fence was constructed to provide a visual
boundary for the twenty five foot vegetative buffer for Drainage Area 2a. Two Rhotos
were provided each month to LCDR Tara Houda via e-mail on April 6th, May 5' , June
7th, July 7th, and August 4th. Natural vegetation established over most of the area except
for the southern most corner due to soil compaction. Sod was professionally installed in
this area to complete the vegetative buffer on June 28, 2017. The sod permanently
established itself in late July 2017. All pictures submitted of drainage area 2a along with
final pictures taken on August 27th of Drainage area 2a are included in appendix Part B.
Mount Olive Pickle Company, Inc. • Corner of Cucumber & Vine • One Cucumber Boulevard • P.O. Box 669 • Mount Olive, NC 28365
Phone: [phone] • Fax: [phone] • www.mtolivepickles.com

Part C. Grab samples of SD O's 001, 002 and 003 taken during three measurable storm events
were analyzed for chlorides on April 24th, June 20th and July 3rd. The monitoring results
and monthly rain logs were reported to LCDR Tara Houda via e-mail on April 6th, May
5th, June 70, July 7th and August 0h. The rain logs included the date of every rain event
for the month, time rain began, method of measuring rain event and the measured amount
of rain received. The monitoring results were included on the rain log and included the
time discharge began, time sample was collected, chloride concentration for each sample
and the methodology used for measuring chlorides. No additional sampling is required
because no sample exceeded the 229 mg/l benchmark. A copy of the rain log and
monitoring results are included in Appendix Part C. The rain log also includes the
chloride measurement for the semi-annual monitoring requirement performed in May.
Part D. The final draft of the Stormwater Pollution Prevention Plan (SPPP) was provided to
LCDR Tara Houda on April 6, 2017 via e-mail. The final daft included monthly self
inspection language required by the Consent Order. A final executed SPPP was provided
to LCDR Tara Houda on May 1, 2017. A copy of the final executed SPPP is included in
Appendix Part D.
Mt. Olive Pickle Company submits this Final Report for EPA's review, approval, and
determination that all requirements of the Consent Order have been completed and implemented
in accordance with the terms of the Consent Order and that Administrative Compliance Order on
Consent No.: CWA-04-2017-4752 be terminated.
"I certify under the 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 gather and evaluate 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 submitting false information,
including the possibility of fine and imprisonment for knowing violations."
Very truly yours,
William H. Bryan
Executive Chairman
Amy P. Wang

Appendix Part A

11YIHC�`-:{,4L`W:;tt, l�r:,1t ITY
Mr. Fletcher Arritt
Mt. Olive Pickle Company
P.O. Box 609
Mount Olive, NC 28365
Dear Mr. Arritt:
PAT MCCRORY
DONALD R. VAN DER VAART
.:r• rcv"
October 14, 2016 TRACY DAVIS
Subject. General Permit No. NCG060000
Mt. Olive Pickle Company
NPDES Stormwater Permit Issuance
COC No. NCGO60374
Wayne County
In accordance with your application for a discharge permit received on July 6, 2016, we are
„4"MN forwarding herewith the subject certificate of coverage (CDC) to discharge under the subject state —
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except upon approval of the
Division of Energy, Mineral, and Land Resources (DEMLR). The Division may require modification
or revocation and reissuance of the certificate of coverage.
Coverage under this General Permit is granted with the condition that: the permittee performs
additional sampling requirements as outlined in the amended conditions to the COC. This COC
requires you to sample SDO 002 semi-annually for chloride, in addition to the other parameters
required at all outfalls. No benchmark applies, but levels above 860 mgll should prompt the facility
to evaluate the area for potential exposed sources, implement Best Management Practices (BMPs) to
reduce chloride concentrations, and document actions in the facility's Stormwater Pollution
Prevention Plan (SPPP).
Chloride is a pollutant of concern resulting from the activities at this plant. The Division will
consider the data upon renewal of coverage under this General Permit to determine if coverage under
a different General .Permit or an individual permit is more appropriate.
State ofNwlh Carolina j Ernvironmental Quality { Enargy, Mineral and land Rcsourecs
1612 Mail Service Center 512 N, Salisbury St. j Ralsigh. NC 27699
919 707 9200 T

The Washington Regional Office visited the site on September 13, 2016. DEM LR Stormwater
Program staff confirmed that the following three stormwater discharge outfalls should be sampled:
001 (Drainage Area 7 — laydown yard in the western corner of the property)
002 (Drainage Area S — loading/unloading area at front of the property at the drop inlet also
used for cooling water sample collection, with ability to sample stormwater-only prior to
commingling with any wastewater). Ultimately this stormwater joins wastewater discharges;
however, this isolated sample point is important to characterizing stormwater from the
drainage area and achieving effective pollution prevention goals under NCG060000.
003 (Drainage Area 6 — corner of administrative parking lot on southern portion of property,
at drop inlet where discharge from vinegar and alum unloading area can be collected)
Two other drainage areas/potential outfalls were in question: Drainage Areas 2a and 2b. The
Regional Office determined that the outfall draining area 2b (northwest portion of the site with
storage building and gravel parking) does not have any current regulated activity or materials from
past activities, and therefore the outfall does not discharge stornnwater associated with industrial
activity. As long as regulated activities or materials storage do not resume in this area, stormwater
discharges from Drainage Area 2b are not subject to the NPDES General Permit.
Drainage Area 2a (bone yard at the back of the property, just south of Drainage Area 3 with
stormwater and wastewater treatment ponds) has mostly sheet clow across a significant distance to
surface waters. However, Regional Office staff determined that the vegetative buffer along the fence
line needs work in order to remove the potential for a point source discharge. Per the Regional staffs
recommendation, Mount Olive has agreed to establish and maintain a minimum 25 -foot
vegetated buffer from the fence line that will remain free of stored materials. Once this buffer is
established, and the potential for a point source discharge has been removed, stormwater from this
drainage area is not subject to the NPDES General Permit. Until then, the discharge is subject to the
permit.
This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Energy, Mineral, and Land Resources, the Division of Water Resources, the Coastal
Area Management Act, or any other federal or local government permit that may be required.
State of Nurlh Caroli" I Fnvironmenlal (pWiry I Energy, Millett! and Land Resources
1612 Mail Service Cen(er 1 512 N. Salisbury st.. Raleigh, NC 27694
919 707 9200 T

If you have any questions concerning this permit, please contact Bethany Georgoulias at telephone
number [phone] or by email bethany.izeomoulias ft4fflLm.
Sincerely,
Original signed by Bradley Bennett
for Tracy E. Davis, P. E., CPM, Director
Division of Energy, Mineral, and Land Resources
cc; Carl W. Scharfe, P.E, / The Wooten Company
Washington Regional Office / DEMLR / BiIl Moore
Washington Regional Office / DWR / Scott Vinson
DWR Central Office / NPDES Permitting Program / Julie Gryzb
U.S. EPA Region 4 / NPDES Permitting & Enforcement Branch / LCDR Tara Houda
Stormwater Program Files
Central Files
StWt! of Nona Carolina ' Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1 512 N. Salisbury St. l Raleigh. NC 27699
919 707 9200 7

Appendix Part B

Bone yard, from top of the bone yard looking toward the fence, submitted on April 6, 2017
Bone yard, Facing west along the fence line, submitted on April 6, 2017

Bone yard, from top of the bone yard looking toward the fence, submitted on May 5, 2017
Bone yard, Facing west along the fence line, submitted on May 5, 2017

tsone yard, trom top of the bone yard looking toward the fence, submitted on June 7, 2017
Bone yard, Facing west along the fence line, submitted on June 7, 2017

II
t r �-
- P'

W
Bone yard, from top of the bone yard looking toward the fence, submitted on August 4, 2017
Bone yard, Facing west along the fence line, submitted on August 4, 2017

'Y Y
Bone yard, from top of the bone yard looking toward the fence, August 27, 2017
Bone yard, Facing west along the fence line, August 27, 2017

Appendix Part C

Measured
time
March
rain by
5D0
rain
Time
discharge
Time
chlorides
concentration
test
rain
event
began
g
sampled
m l
g/
method
guage
began
3/1/17
0.2"
after
no sample collected / no coverage
17:00
3/13/17
0.3"
after
no sample collected / no coverage
4/17/17
0.5"
a 00
no sample collected / no coverage
3/19/17
0.2"
after
no sample collectEcoverage
4/23/17
0.51,
17:00
no sample collected / no coverage
3/21/17
0.1"
1� 00
no sample collect
El
4/24/17
1.6"
001
7:30
9:00
3/29/17
0.2"
SM 4500 -
10:00
no sample collected / no discharge
3/31/17
0.3"
8:00
no sample collected / no coverage / no production
Measured
time
April
rain by
5D0
rain
Time
discharge
Time
chlorides
concentration
test
rain
event
began
sampled
mg/I
method
guage
began
4/3/17
0.11,
after
no sample collected / no coverage
17:00
4/5/17
0.1"
after
17:0D
no sample collected / no coverage
4/17/17
0.5"
a 00
no sample collected / no coverage
4/23/17
0.51,
after
no sample collected / no coverage
13:00
4/24/17
1.6"
001
7:30
9:00
9:25
18
SM 4500 -
Cl B.
4/24/17
1.6"
002
7:30
9:00
9:10
17
SM 4500 -
CI B.
4/24/17
1.6"
003
7:30
9:00
9:15
16
SM 4500-
CI B.
4/25/17
0.211
after
no sample collected / no coverage
17:00

Measured
time
Time
chlorides
June
rain by
SDC
rain
Time
Time
chlorides
test
May
rain
50O
event
discharge
sampled
Concentration
method
rain
event
began
sampled
mg/I
method
6/5/17
guage
began
no sample collected / no coverage
5/1/17
0.3"
after
no sample collected / no coverage
after
no sample collected / no coverage
6/14/17
17:00
5/4/17
0.3"
after
fter17:00
no sample collected / no coverage
after
no sample collected / no coverage
6/17/17
17:00
5/9/17
0.2"
after
no sample collected / no coverage
17.00
SM 4500-
5/22/17
0.8"
001
6:30
7:00
7:25
12.9
SM 4500 -
CI B.
5/22/17
0.8"
002
6:30
7:00
7:15
1
SM 4500 -
003
7:00
12:30
12:45
15.5
CI B.
5/22/17
0.8"
003
6:30
7:00
7:10
7.5
SM 4500 -
6/21/17
0.2
continued from previous day
CI B.
5/23/17
0.7"
0.3
continued from previous day
5/29/17
0.4"
after
no sample collected / no coverage
after
no sample collected / no coverage
6/30/17
17:00
5/31/17
0.2"
after
fter17:00
no sample collected / no coverage
17:00
Measured
time
Time
chlorides
June
rain by
SDC
rain
discharge
Time
concentration
test
rain
event
began
sampled
mg/I
method
guage
began
6/5/17
0.6"
after
no sample collected / no coverage
17:00
after
no sample collected / no coverage
6/14/17
0.2"
17:00
after
no sample collected / no coverage
6/17/17
0 2"
17.00
SM 4500-
6/20/17
0.5"
001
7:00
12:30
12:35
20.9
Cl B.
SM 4500-
6/20/17
0.5„
002
7:00
12:30
12:55
3.5
Cl B.
003
7:00
12:30
12:45
15.5
SM 4500-
6/20/17
0.5”
1
Cl B.
6/21/17
0.2
continued from previous day
after
no sample collected / no coverage
6/24/17
0.3
17:00er
after
no sample collected / no coverage
6/30/17
0.2
It

The rain guage is checked at 8:00 every morning. Any rain measured at that time will be counted
toward the previous days rain total.
Measured
time
July
rain b y
SDO
rain
e
7discharge
Time
chlorides
concentration
test
rain
event
began
sampled
mg/i
method
guage
began
7/3/17
0.7
001
15:30
15:40
16:00
15.5
SM 4500 -
Cl B.
7/3/17
0.7
002
15:30
15:40
16:10
5.5
SM 4500 -
CI B.
7/3/17
0,7003
15:30
15:40
16:20
12.5
SM 4500-
Cl B.5
after
7/5/17
0.2
17.00
no sample collected / no coverage
after
7/7/17
0.2
17.00
coverage
no sample collectet/no
after
7/9/17
0.1
14:00
no sample collectecoverage
after
7'/10/17
0.3
17:00
no sample collected / no coverage
after
7/15/17
0.3
17:00
no sample collected / no coverage
after
7/16/17
0.5
17:00
no sample collected / no coverage
The rain guage is checked at 8:00 every morning. Any rain measured at that time will be counted
toward the previous days rain total.

Appendix Part

STOR.MWATER POLLUTION PREVENTION PLAN
FOR
MAIN PRODUCTION PLANT
One Cucumber Blvd.
THE MT. OLIVE PICKLE COMPANY
MOUNT OLIVE, NORTH CAROLINA
DECEMBER 2016
PREPARED BY CARL W. SCHARFE, P.E. & PETER W. GALAN, E.I.
TV
THE WOOtEN COMPANY
License No. F-4115
TWC Project 2395-0

TABLE OF CONTENTS
Executive Summary............................................
Stormwater Pollution Prevention Pian F........................................................................... 3
aciii_y Overview & Signatures.
1.0 Site Overview......... .......................... 4
1.1, Location/Site map.......'................................................................................................. 6
1.2. Narrative Description .............................................................................. b
1.3. Spill and Leak Lisi... ..................... ..................................... 8
1.4. Certification of rmwater Dischar......
ge...............................................................
Outfalls SDOs f l
Discharges...................to } or Non-Stormwater
2.0 Stormwater Management StrategyY......................_.....................,............................... 20
2.1. Feasibility Study.................................................................................. 23
2.2. Secondary Containment...................................................................... ..................... 27
2.3. BMF Summary ............................................................................................................................... 31
3.0 Spill Prevention/Response Plan.'.............................,....'.'.. ................. 35
4.0 Preventative Maintenance and GoodHousekeeping ............. 38
5.0 Facility Inspections.... eping Program_........... .......................... 42
6.0
7.0 Employee Training.................... ...............* ............... 45
Responsible Party....... ........................, ................ 47
8.0 Plan Amendments and Annual Update................,................'._."............................ 50
9.0 Plan implementation ...... 52
Stormwater Discharges: Analytical Monitoring ......................................... 54
Stormwater Discharges: On-site Vehicle/Equipment Maintenance Monitorin 54
9.3. Storm%,ater Discharges: Qualitative Monitoring ............................ $ .. . 5
9.2. 6
....... 57
FIGURES
FIGURE 1.1 -- GENERAL LOCATION MAP
FIGURE 1.2 — MAIN PRODUCTION PLANT SITE MAP
APPENDICES
APPENDIX A — NC GENERAL STORM WATER PERMIT NCG060000 AND CERTIFCATE
OF COVERAGE NCO060374 WITH COVER LETTER
APPENDIX B — SITE PHOTOS
APPENDIX C —EPA COMPLIANCE STORMWATER EVACUATION INSPECTION
LETTER
APPENDIX D —SPILL PREVENTION/RESPONSE PLAN
APPENDIX E — POTENTIAL STORMWATER PROTECTION DEVICES
The Mt. Olive Pickle Company
Stonnwater Pollution Prevention Plan — Main Production Plant
Page 2

Executive Summary
The Mt. Olive Pickle Company has developed this Stormwater Pollution Prevention Plan (SPPP)
for the Main Production Plant to meet the requirements of North Carolina General Permit No.
NCO060000 for storm water discharge under the Food and Kindred category (SIC code 2035).
A copy of the general permit is provided in Appendix A. The permit was issued to The Mt.
Olive Pickle Company effective October 14, 2016, and their Certificate of Coverage number is
NCG060374; this certificate is attached in Appendix A as well. The purpose of this plan is to
identify areas with industrial activity that may be in contact with storm water during rain events
and minimize or eliminate the impact of industrial activity occurring in these areas on
stormwater that runs off to freshwater streams and other bodies of water. This also includes
minimizing impacts of spills of materials that have the potential of reaching nearby waterways,
and this plan establishes procedures that will improve the protection of those waterways. The
plan outlines Best Management Practices to be implemented and includes proposed structural
changes to the site.
Each section of this document describes a different portion of the Stormwater Pollution
Prevention Plan, The first section is a general site overview, with maps and descriptions of day-
to-day activities, potential pollutants, and a list of spills and leaks that have occurred in the past
three years. Subsequent sections include description of present and future stormwater
management strategy, with explanations regarding secondary containment and existing BMPs;
spill response, preventative maintenance, and facility inspections; sections on employee training
and the organizational structure of the stormwater pollution prevention team; and sections
explaining how The Mt. Olive Pickle Company will implement, amend, and update this plan.
The Mt. Olive Pickle Company shall implement this Storrnwater Pollution Prevention Plan to
safeguard against the pollution of stormwater runoff and to establish procedures to be followed
to minimize contact of stormwater with industrial activities. Additionally, The Mt. Olive Pickle
Company staff will now track the quality of the stormwater leaving the property
through
monitoring procedures established in this plan, Sampling will occur at three stormwater
discharge outfalls (SDOs); more about these SDOs can be found later in the document.
The Mt. Olive Pickle Company
Stortnwater Pollution Prevention Plan — Main Production Plant
Page �

Stormwater Pollution Prevention Plan Facility Overview & Signatures
FACILITY INFORMATION Facility Name: Mt. Olive Pickle Co. Main Production Plant
Owner: Fletcher Arritt
Type Facility: Pickle Production Facilit
Address: One Cocum Blvd.
P.D. Box 609 Mount Olive. NC 28365
Phone No. / Fax No.: 9I9-658-2535/919-581-4769
E-mail: farritt(a'jmtolive ickles.com
CONTACT INFORMATION Responsible Party.: Fletcher Arritt
Phone No.: 419-658-2535
Mobile No.:
Pager No..
PERMIT INFORMATION General Permit No.: NCG060000
Certificate of Coverage No.: NCG0603 74
Effective Date of Coverage: I0114/2016
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Pale 4

NI VKMWATER POLLUTION PLAN (SPPP) DETAILS
Date Implemented (within 12 months of effective date of coverage):
SPPP must be updated annually after date implemented. Owner shall review/u data Sppp
in the first part of April of each year to comply, SPPP shall be kept on-site of facility and
be readily accessible.
Date of Annual Update:
Date of Annual Update:
Date of Annual Update:_
Date of Annual Update:
Date of Annual Update:
Parts Updated:
Parts Updated:
Parts Updated:
Parts Updated:
Parts Updated:
"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 a ualified
ersonnel
properly gather,and evaluate 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 knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations.''
Signature:
Print Name:
F
MAR
Title: f LI f tot S i�.rtA3
Date:,
The Mt. Olive Pickle Cornpany— Stormwater Pollution Prevention Plan
Page 5

1.0 Site Overview
1.1. Location/Site map
The Mt. Olive Pickle Company Main Production Plant facility is located an an approximate 50 -
acre parcel in Mount Olive, NC. This is the main production facility for The Mt. Olive Pickle
Company. It houses the majority of The Mt. Olive Pickle Company's production equipment and
corporate offices, as well as a retail store. Pickle production takes place in the main building.
There are other small buildings on-site, such as a pump house, storage shelters, and headworks
building, among other things. The central portion of the site is dedicated to large vats in which
the pickling process occurs.
Figure 1.1 is a general location map (see Figures). This map is a USGS quadrangle map of the
town of Mount Olive, with a highlighted footprint of The Mt. Olive Company's Main Production
facility. Barlow Branch is the receiving water for both storm water flows and existing permitted
NPDES discharges (non-stormwater related) from the Main Production Plant. This water body is
a 303D impaired stream that is monitored for chlorides and mercury content. The three accepted
SDOs (and their approximate locations) are shown on Figure 1.1.
Figure 1.2 is a large site map for the Main Production Plant (see Figures). This map shows the
building footprints; the site drainage areas, impervious surface percentages; flow direction of
stormwater both on the ground surface and in the existing storm drain piping, existing NPDES
discharge points (see discussion below); the locations of the three accepted SDOs;' and EPA
areas of concern (see Section 1.2).
The Mt. Olive Pickle Company has an existing NPDES discharge permit (Permit #NC0001074)
to discharge treated wastewater (at Outfall 01) and non -contact cooling water (Outfalls 02 and
03)• A permit application to renew the NPDES permit was submitted in February 2016 and is
still under review by the North Carolina Department of Environmental Quality (NCDEQ),
Outfall 03 (non -contact cooling water) is currently being added to the NPDES permit. Water
quality in Outfall 02 and Outfall 03 is essentially the same (non -contact cooling water is split in
two directions). There is a lagoon -based wastewater treatment plant (WWTP) located on-site that
treats both process wastewater and the majority of the stormwater run-off generated from
industrial activities on-site (primarily the open brine tanks areas). As shown on Figure 1.2, the
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 6

non -contact cooling water from the Main Production Plant is discharged separately from the
wastewater effluent from the WWTP. These discharges are currently sampled separately as part
of the NPDES permit_ The sampling locations are on the plant site property at the effluent
cascade aerator from the WWTP (Outfall 01), at an inlet near the main entrance to the Main
Building (Outfall 02), and at an inlet across from the existing sludge drying beds(ne NPDES
Outfall 03. pending approval). The NPDES discharges lead to a main trunk stormsewe
eventually discharges off Plant roe titch
15 P property rty at Barlow Branch. Thus, stormwater that does not
drain to the WWTp is mixed with the normal NPDES discharges in the main storm sewer piping
when it rains. A new sludge dewatering press was purchased (in 2015) and installed (in 2016)
under an outdoor roof/pad area across from the sludge drying beds. The location of this press is
also shown on Figure 1.2,
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan - Main Production Plant
Page 7

1.2. Narrative Description
The Mt. Olive Pickle Company's Main Production Plant site has been divided into eight drainage
areas based on topography and local knowledge of the site. These eight areas are shown on
Figure 1.2. Of the eight drainage areas on the site, Drainage Areas 1. 2b, 3, and 4 are not of
concern in this SPPP because stormwater does not leave the plant site or is not impacted by
industrial processes. A description of these drainage areas is provided below.
• Drainage Area I includes the paved area to the rear of the production plant and the
.majority of the main building roof. The paved area is contoured such that any stormwater
falling on the pavement will drain into drop inlets located throughout the drainage area. A
combination of collection pits and lift stations pump stormwater runoff from this drainage
area to the on-site WWTP where the stormwater is treated (along with process water) in
the treatment plant.
• Drainage Area 2b is composed of the storage building located at the northwest corner of
the property. This area is on a different lot than the Production Plant, but is part of The
Mt. Olive Pickle Company's overall parcel, so it is included in this study. However, it is
not part of the industrial process, so any stormwater generated here is considered normal
runoff not associated with industrial activity. It is separated from Drainage Area 2a by a
chain link fence; this fence is constructed such that it acts as a divide between Drainage
Areas 2a and 2b.
* Drainage Area 3 is composed of the area around the treatment lagoons for the WWTP
and the lagoons themselves. The terrain is contoured such that stormwater drains directly
into these lagoons from the top of the berms. Additionally, there are no identified
exposed industrial activities occurring in these areas.
• Drainage Area 4 is also composed of the area around a treatment Iagoon. but it also
includes the WWTP and all of the structures associated with it. Any stormwater failing in
this area is contained in the lagoons/tank or is sloped towards the lagoons. Like Drainage
Area 3, there are no exposed industrial activities occurring in this area, so stormwater
does not need to be managed. Prior to the EPA's visit, there were a number of open top
dumpsters located near the edge of the building in Drainage Area 5, and stormwater that
The Mt. Olive Pickle Company
Stonnwater Pollution Prevention Plan — Main Production Plant
Page 8

fell on these dumpsters drained to nearby storm grates. Since this concern was raised by
the EPA, these dumpsters have been moved to Drainage Area 4 so that any contaminated
runoff flows to the WWTP. Additionally, The Mt. Olive Pickle Company staff has stated
that they plan to end the practice of storing these dumpsters in Drainage Area 4
altogether.
Stormwater must be managed in the other drainage areas around The Mt. Olive Pickle
Company's Main Production Plant. Stonnwater can be exposed to a number of industrial
activities. The following list explains the pattern of stormwater runoff for each drainage area and
the industrial activities potentially exposed to rainfall.
• Drainage Area 2a is located on the northwest corner of the site property, southeast of
Drainage Area 2b. This is a grassy area used to store empty stacked plastic bins, wood
pallets, old process tanks (not currently in use), dumpsters used to store scrap wood, and
miscellaneous empty plastic drums (referred as the lay down yard or boneyard). Pictures
of this and other areas can be found in Appendix B. These items were typically used in
the production process. Because these items were once used in production, the EPA
views this as part of the industrial process. Water from this lay down yard flows in
general overland sheet flow to the south onto the property of the North Carolina National
Guard Armory. A portion of the National Guard Armory property that receives this
runoff has residual impacts from runoff generated prior to The Mt. Olive Pickle Company
re-routing stormwater flows from the paved area surrounding the pickle vats to the
WWTP. The iaydown yard continues to be a
potential source of stormwater
contamination as rain falls on the items stored in this area. To comply with the ruling of
the Washington Regional Office of the Land Quality Section of the North Carolina
Department of Environmental Quality (NCDEQ), The Mt. Olive Pickle Company will
construct and maintain a vegetative buffer with a minimum uridth of 25 feet between the
existing property line and any stored equipment. More description will follow in later
sections.
• Drainage Area 5 is the paved area south of the main entrance to the plant (including the
part of the main building roof sloped towards this area). Stormwater drains away from the
building via downspouts and is discharged into drop inlets located throughout the paved
The Mt, Olive Pickle Company
Stormwater Pollution Prevention Plan - Main Production Plant
Wage 9

Iot. Surface water runoff in Drainage Area 5 drains to the storm inlets in the area and then
to the main conveyance pipe running parallel to the Main Building. The main drainage
pipe also receives the non -contact cooling water from the production processes and the
effluent from the WWTP.
The plant receives high fructose corn syrup delivered by train car (at the end of the
railroad spur) and via tanker truck deliveries. The train car parks in this area to unload
via a pumping system and delivers approximately 18,000 gallons per delivery. The
unloading process is considered an industrial activity. Tanker trucks deliver
approximately 5,000 gallons per delivery. Currently. the plant receives three to five
tanker truck deliveries per week and one train car delivery per
week.
transferred from the train car or the trucks to a double -walled eceivin tank (labelled
syrup is
Figure 1.2). There is also a second double walled tank that is used as necessary ed on
so
Iabeled on Figure 1.2). Due to the viscosity of the corn syrup, it trust be heated to be
Pumped into the production plant. The railroad tracks and pump building are located
adjacent to the main parking lot east of the main production facility. Pictures of the train
car unloading area are in Appendix H.
There is a storm grate located adjacent to the railroad spur and in-between the tura double
walled tanks. Storm water or any spilled liquids (that flow) around the tracks and double
wall tanks will flow to this storm grate. For spill purposes, the con syrup can be
considered a semisolid as it will not really flow due to its viscosity. It can still reach
storm drainage and proper precautions (as explained later) should still be followed.
Drainage Area 5 also contains seven truck loading concrete pads that receive finished
goods for shipment; the handling of finished goods is considered an industrial activity.
However, the entrances to the loading doors in the rear of these trucks are covered such
that no product jars are exposed to rain water. An inspection of the area around the
loading dock does not show signs of truck fluid leaks or tracks of fluid leaks to the storm
drop inlets. The storm inlet off the east corner of the loading area (EPA #4) is discussed
later.
A portion of the WWTP operations is located east of the Main Building and in Drainage
Area 5. Historically, sludge from the WWTP is dewatered and stored uncovered in this
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 10

area. However, a new dewatering press and concrete pad were added in 2016. The
activities surrounding the dewatering press as well as the dumpsters are now located on
the new concrete pad under a new metal roof structure. Thus, the process is now under a
roof and sludge residuals are not in direct contact with rainfall. if these dumpsters cannot
be stored under the roof, they will be moved to Drainage Area 4 so that any contaminated
runoff flows to the WWTP.
• Drainage Area 6 comprises a number of employee parking lots and the roadways
employees drive on to enter and exit the property. There is also a gravel unloading area
where delivery trucks park to unload vinegar and alum into tanks located near the main
building. This area drains into drop inlets located in the gravel parking lot. Stormwater
runoff flows off the parking lot to storm ditches/inlets along Vine Street. The primary
industrial process in this area is unloading vinegar and alum into the storage tanks in this
area. The unloading stand has hosing and piping that extends over the gravel parking
area; this area is called out in Figure 1.2. Pictures of this area can be found in Appendix
B. The loading stand has a metal yellow railing to prevent trucks from backing up into
the unloading pipe connections. This unloadingis
area a potential spill area that could
impact storm water runoff.
+ Drainage Area 7 is located on the westernmost corner of the property_ There is both
gravel and grass in this area. Any stormwater that falls in this area drains to a drop inlet
that flows into off-site Town of Mount Olive -owned drop inlets and storm pipes. This
area is a lay down yard used by maintenance to store pipes and wood, and a number of
metal recycling durnpsters can be found in this area as well. There is a storm water drain
located near the property line that exits the property. This equipment and storm drainage
pipes are considered part of the industrial process and are in contact with rain that falls in
this area. Pictures for this area can be found in Appendix B.
On February 10. 2016, the United States Environmental Protection Agency (EPA) visited
production plant site to perform a routine inspection. During this visit, the EPA walked the
perimeter of site in an effort to identify locations where industrial activity was occurring and
where storrnwater run-off from these areas could be exposed to potential contaminants. On May
2, 2016 EPA issued a Compliance Stormwater Evaluation Inspection letter detailing areas of
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan .- Main Production Plant
Page 1 i

concern for potential storm water contamination. This report can be found in Appendix C of
this SPPP. The EPA visit prompted the need for a general stormwater permit at the facility and
this SPPP. The EPA identified following areas which could potentially have stormwater exposed
to industrial activities. These areas correspond with the callouts on Figure 1.2 (marked as EPA
#l, EPA #2, etc. on the map).
• EPA #1; This is at the lowest point of Drainage Area 2a. The EPA`s primary concern
along the entire western fence line was the quantity and type of equipment stored here
and the fact that surface runoff drains off the plant site to the west (to the National Guard
Armory property). This equipment stored was previously used in the manufacturing
process and EPA considers the area to be an industrial activity as these materials are
exposed to rainfall at present.
• EPA #2: This area, located in Drainage Area 2a, is next to the influent screenhouse for
the WWTP. There were a number of uncovered storage containers in this area that could
impact stormwater runoff quality. All but three of these containers have since been
removed.; these tanks are going to be used in the tank yard indefinitely.
• EPA #3; When the EPA .made their visit, there was an actively drip
ed
dumpster up -grade of the storm drain located at EPA #4; they deemed this should be
immediately addressed. Since the EPA's visit, The Mt. Olive Pickle Company has moved
these dumpsters to Drainage Area 4 so that any stormwater runoff that comes in contact
with the dumpsters flows to the WWTP for treatment. As a result, the dumpsters do not
impact Drainage Area 5 anymore. There are also a number of uncovered storage
containers that are considered part of the industrial process in this area. This spot is part
of Drainage Area 5.
• EPA 44: This is the inlet located off the northeast comer of the Main Building in
Drainage Area 5. There is a storm drain located in the vicinity that receives stormwater
from the. EPA #3 area. There are a number of dumpsters and other material storage
containers situated in this area that are currently uncovered and leaky during rain events,
These dumpsters have since been moved to Drainage Area 4 so that runoff coming in
contact with liquids pooling under the dumpsters can be treated by the WWTP and will
have no impact on stormwater runoff from Drainage Area 5. The EPA observed dirt in
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan _]Main Production Plant
Page 12

the bottom of the inlet. likely from the dried solids container near the WWTP. The solids
should be removed from this inlet.
• EPA #5: This is one of the inlets over the main storm drain pipe that was identified
during the EPA site visit. The water moving through this pipe is discharge from NPDES
permit Outfalls 01 and 03 (WWTp effluent and non -contact discharge water). This flow
is already known and is permitted.
• EPA #6: This area is where the train car is parked for transfer of corn syrup into the
factory. There is an inlet located close to the point at which the unloading pump hose is
connected to the train cars. Additionally, there is a corn syrup storage area upstream of
one of the drop inlets located in this area; there is nothing preventing spilled corn syrup
from reaching the outflowing stormwater. One concern is the train car itself, as
condensate from a steam jacket pools beneath the car and flows into the drain. The gravel
in this area under the tracks has become discolored as well. in addition, water currently
Pools around the drain indicating there may be subsidence around the storm drop inlet
itself
• EPA #7: This is a storm drain located in Drainage Area 5 that receives non -contact
cooling water (NPDES Outfall 02). EPA identified this inlet as they were unsure of what
was being discharged. This discharge is permitted and sampled, so it is not of concern.
• EPA #8: The storm drain located in Drainage Area 5 was of concern to EPA because they
noted steam at this inlet on the day of the site visit (a cold day). The M_. Olive Pickle
Company employees have investigated further and have indicated that this inlet is
upstream of the main storm sewer line and any steam from this inlet would be caused by
the non -contact water in the main line and not any other source. Thus, this area is not
considered an area in need of any future action in this SPPP.
• EPA #9: This is one of the gravel parking lots located in Drainage Area 6. More
specifically, this is where tanker trucks park to unload vinegar and alum into the tanks
located by the main building. There are four storm drains located in the parking lot_ The
primary concern of the EPA is the lack of spill containment present in this area — there is
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 13

a secondary containment wall (see Section 2.2) but there is no measure against a spill
from the truck as it is unloading. A solution to this problem is proposed in Section 2.1.
+ EPA #10: This area is in Drainage Area 1. There are a few oil tanks located near this
point, and they are outside of any secondary containment. The EPA noted an oil spill in
this area. Any stormwater passing through this area will be treated at the WWTP, but
measures should be put in place to minimize the amount of fluid exposed to rainfall.
• EPA #11: This area is also in Drainage Area 1. There are a number of oil and gas storage
tanks Iocated near this point; they are all behind a secondary containment wall, but oil
residue has escaped and is sitting untreated on the pavement. Any stormwater passing
through this area will be treated at the WWTP, but preventative measures should be put
in place to minimize spills and the quantity of fluid exposed to rainfall.
• EPA #12: This area is part of Drainage Area 7. As stated above, this area contains used
industrial equipment and other items associated with maintenance activities. The concern
of the EPA is the fact that storm water runoff from this area leaves the site untreated after
contacting the materials stored in this area.
+ EPA #I3: EPA identified this area as a ditch that may be draining runoff off-site from
Drainage Area 2a. However, according to a staff member of The Mt. Olive Pickle
Company, this ditch only drains runoff from the National Guard Armory site and there is
no direct storm conveyance connection to Drainage Area 2a. The paved area north of the
pickle vats also is sloped toward the pickle vat drain system and not off-site to the ditch
north of the paved area. Thus, the ditch does not receive any storm water associated with
industrial activity from The Mt. Olive Pickle Company Main Production site.
There are other areas around the Main Production Plant site that are exposed to stormwater that
have already been accounted for in The Mt. Olive Pickle Company's Spill Control Plan (see
Section 2.2). Many of these tanks have secondary containment (see Section 2.2) so stormwater
Pollution was not identified as problem areas during the EPA site visit.
In accordance with the authorization provided by the Certificate of Coverage, The Mount Olive
Pickle Company has established three SDOs on its site. These locations are noted on Figures 1.1
and I.2. SDO 001 is Iocated in Drainage Area 7, in the drop inlet closest to the chain link fence
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 14

on the southwestern border of The Mt. Olive Pickle Company's property. Sam
pling will occur
from this drop inlet prior to the stormwater leaving the site through the outlet of this drain. SDO
002 is located in Drainage Area 6, at the same location as Outfall 02. This inlet receives
stormwater from the drop inlet located closest to the train car. Additionally, it receives cooling
water from the plant and wastewater effluent from the W WTP; samples should be collected from
the pipe receiving stormwater flow from the drop inlet near the train cars prior to mixing with the
cooling water and wastewater effluent. SDO 003 is located downstream from the vinegar and
alum storage tanks. This location was chosen because of the potential for spills from the tanker
trucks and the storage tanks themselves, as well as the possibility for leakage from the trucks
(and other vehicles that use the parking lot), SDO 003 is the inlet located at the southwest corner
of the administrative parking lot across from the gift shop. Sampling should be conducted from
the stormwater pipe that receives stormwater flow from the vinegar and alum storage area, and
should take place Prior to that water mingling with other stormwater.
The chart below lists the potential pollutant sources for product/chemicals stored at the site and
identifies the SDO to which spilled material could potentially reach if a spill occurs.
The Mt. Olive Pickle Company
5tormwater Pollution Prevention Plan — Main Production Plant
Pale 15

Potential Pollutant Sources
InstructionsUst areas that are potential sources of pollutants, e.g., wash down pad, fueling area,
loading and unloading activities, storage practices, process areas, waste disposal
activities, etc. and state which outfall, as identified on the site map, the pollutant
would drain to if there was a spill or leak, i.e., outfall 1.
P©tential Sources of PollutantsDrainage Area
Stormwater
Discharge Outfall
Decommissioned tanks, bins, and production equipment 2a
Spills in corn syrup unloading area (railroad tracks and
(SDOs)
**
truck deliveries)
Truck vinegar/alum unloading area spills 6
Vinegar/alum tank storage area (containment area) g
Decommissioned tanks and production equipment, other 7
002
003
003
maintenance -related materials
001
Metal recycling dumpster area 7
Gas/diesel tanks l
Vehicle fluid tanks 1
Cucumber storage tanks l
001
***
Active brine tanks l
Isomorose tanks l
***
***
Filtered/Used brine tanks l
***
Wastewater Tank
*A new inlet and drainage is proposed to be installed to direct stormwater flow from this area to
the W WTP
** A 25 -foot -wide vegetated buffer will be installed to establish vegetative cover prior to
stormwater leaving the site.
*** Stormwater from these areas already drains to the existing WWTP, thus no SDOs are
designated for these potential sources.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 16

1.3. Spill and Leak List
Listed below are any significant spills and leaks that have occurred at The Mt, Olive Pickle
Company's Main Production Plant within the last three years. Additionally, any preventative
measures taken to prevent a similar leak in the future are listed at the end of the chart. The table
should also he used to document arty significant spills and/or leaks if they occur in the future as
well as the action taken as a result of spill.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Pale 17

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1.4. Certification of Stormwater Discharge Outfalls (SDOs) for Non-Stormwater
Discharges
The Mt. Olive Pickle Company has three existing non-stormwater discharges at its plant. Outfall
Ol and 02 are permitted NPDES discharges and a NPDES permit modification for Outfall 43 has
been submitted. These flows are continuous and are monitored under the NPDES permit.
Additionally, domestic wastewater generated at the facility is discharged to the City of Mount
Olive's sanitary sewer system.
The Mt. Olive Pickle Company staff must certify that each identified SDO in this SPPP does not
have any non -storm water discharges. The attached table can be used to record the basis for the
non-stormwater discharge certification statement. The Mt. Olive Pickle Company is required to
monitor the SDOs during dry weather periods (minimum annual basis) to determine if
unpermitted non-stormwater discharges are reaching the SDO during dry weather periods. The
monitoring for non-stormwater discharges is to be performed 72 hours after a previous
measurable storm event (i.e. after a 3 -day dry period). The chart on the following page serves as
a future record for those monitored events.
Mt. Olive Pickle Company must recertify annually that the identified SDOs do not have
non-Stormwater discharges. The certification statement will need to be signed in accordance
with the requirements found in Part III, Standard Conditions, Section B, Paragraph S.d of the
general permit. This statement can be found on the page following the chart, and a signature will
be required for each certification event.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 20

Record of Stormwater Discharge Outfalls
Stormwater Discharges
Completed by:
Title.
(SDOs) for Non -
I
Instructions:Evaluate each outfall as shown on the site map for the presence of non-stormwater
flow and document in.the following table. This evaluation should be completed a
minimum of 72 hours after a: rainfa . The certification and signature above shall
serve as the certificati
true. On that the information contained in the table is accurate and
Stormwater
Date ofDischarge
Evaluation Outfall
Identifier
SDO 001
SDO 002
SDO 003
SDO 001
SDO 002
SDO 003
SDO 001
SDO 002
SDO 003
Hours Since Presence of if now is present,
Last Flow Source of Flow? Is
Precipitation (yeslNo) this N011-Stormwater
es/No)
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 21

Certification of Stormwater Discharge Outfalls (SDOs) for Non-
Stormwater Discharges
In accordance with the table filled in above, The Mt. Olive Pickle Company must certify the
results of each evaluation event. Each signed instance below reflects the text of the following
statement:
V 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 gather and evaluate 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 niy knowledge and belief,' true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations. "
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
Printed Name Signed
Date
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 22

2.0 Stormwater Management Strategy
Currently, the primary stormwater management practice utilized by The Mt. Olive Pickle
Company is to treat the stormwater generated on-site as though it is wastewater — a large portion
of the site's storm drainage flows directly into the company's W WTp There are inlets located
throughout the brine vat yard that flow to a common point and subsequently are pumped by force
main to the WWTP. Any paved surface behind the plant will flow into those inlets. Additionally,
the swales and ditches located behind the plant receive the stormwater that does not reach (or
flows past) the inlets will drain into pipes, and they are also routed to the WWTP. As this
stormwater is being treated by the WWTP, it does not factor into this plan.
The stormwater that does not drain into the WWTP is currently managed by way of the existing
spill Prevention plan. The area around the trucks and railroad car where loading and unloading
takes place is unprotected from stormwater pollution with the exception of the measures taken in
the spill prevention plan (see Section 2.2). The same can be said for the area around the vinegar
and alum tanks where trucks park to unload into the tanks currently situated in that area. The
spill prevention plan is not sufficient to manage the stormwater exiting the facility, so this SPPP
has been developed to supplement the spill control plan. The SPPP incorporates both structural
measures (like BMPs) and non-structural measures (like procedure changes) into The Mt. Olive
Pickle Company's maintenance routines and plant operations. Implementing both types of
strategies will help minimize the impact of industrial activity on the quality of the stormwater
discharged from the site, and will help keep the plant in compliance with the general stormwater
Permit. Proposed BMPs are listed in the table below under the "Description of Best Management
Practices" header. These items are proposals and are not finalized, once The Mt. Olive Pickle
Company`s staff agrees to the feasibility of these BMPs, they can be implemented. Until then,
they are listed here as proposed solutions.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Pian — Main Production Plant
Page 23

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2.1. Feasibility Study
One strategy that could potentially reduce the stormwater pollution present at The Mt. Olive
Pickle Company's Main production Plant site is constructing a roof over the brine vats.
However, the fermentation process associated with the brine vat area requires UV light to work
correctly, so this strategy is completely infeasible. Instead, the stormwater runoff from these
areas was redirected to the WWTP.
Drainage Area 2a, on the northwest corner of the site where obsolete and unused equipment and
storage tanks are located, is another area of concern for stormwater pollution. This area is
considered part of the industrial process, and the stormwater in this area leaves the site and flows
onto the adjacent property. Installing a vegetative buffer, with a minimum width of 25 feet
between the existing chain link fence and any stored equipment, will improve the quality of the
stormwater leaving this area and minimize the amount of off-site flow of stormwater.
Changing the loading and unloading procedures for the Drainage Area 5 (specifically the train
car area) is a logical and reasonable method of improving the quality of runoff in this area. The
changes should be relatively easy to implement as they are already part of the spill control plan
and the employees in those areas should be familiar with the procedures. Rather than waiting
until a spill occurs, employees responsible for unloading the train car and truck tanks should
place storm drain mats over the top of the storm drains and spill containment berms or absorbent
booms on the ground prior to beginning the unloading process. This will minimize the amount of
spilled liquid that reaches the storm drains (in the event of a spill), as the spilled material can be
nearly completely cleaned up rather than only what is left after the employee places the mats
over the drains as the spill is occurring.
Stormwater quality concerns in Drainage Area 6 can be minimized by establishing new loading
and unloading procedures. The Mt. Olive Pickle Company staff should place drain mats, spill
containment berms. and absorbent booms in the appropriate locations before a Bruck: begins to
unload into the storage tanks.
Drainage Area 7 will undergo minimal changes; uncovered storage will be minimized in this
area, and care will be taken to keep recyclable goods in the dumpster and away from contacting
stormwater. No new structural modifications are planned.
The Mt, Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 27

The following page has a table showing stormwater management practices currently employed
by The Mt. Olive Pickle Company as well as those proposed above. The -Mt. Olive Pickle
Company may employ some or all of the proposed practices in their stormwater management
procedures in the future.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Pian — Main Production Plant Page 28

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2.2. Secondary Containment
The Mt. Olive Pickle Company's Main Production Plant has a number of bulk storage areas on
its site. A spill prevention and response plan has been created for the Main Production Plant, and
the full text of this plan is attached as Appendix D. The following list shows the liquid and
volume stored, and the containment designed.
• GasoIine. 1,000 gallons above ground, full containment, spills drain to WWTP
• Diesel fuel: 540 gallons above ground, full containment, spills drain to WWTP
• Used oil: 300 gallons above ground, partial containment (retaining wail), spills drain to
WWTP
• Hydraulic oil: 250 gallons aboveground, ,partial containment (retaining wall), spills drain
to WWTP
• Assorted vehicle maintenance fluids: multiple 55 gallon drums above ground, partial
containment (retaining wall), spills drain to WWTP
• Corn syrup: 17,696 gallon train car, no containment around train car, full containment
around storage tank (inside building)
• Cucumbers/Brine: No volume given, spills drain to WWTP
• Isomorose: 16,000 gallons above ground, spills drain to WWTP
• Vinegar: three 3,800 gallon tanks above ground, two 4,500 gallon tanks above ground,
spills drain to WWTP
• Alum: 3,800 gallons above ground, spills drain to WWTP
• Filtered/used brine: 5,600 gallons each above ground, 6,000 gallon total containment,
spills drain to WWTP
These storage areas are located at various points around the site; some are near storm drainage,
and some are not. Almost all of them are exposed to rainfall, so measures will be taken to
monitor any stormwater that leaves the site untreated for potential pollutants. As stormwater
gathers in the secondary containment area, it may accumulate spilled non-stormwater liquids in
the area. It is the understanding of The Mt. Olive Pickle Company that any liquid contained in
The Mt, Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 31

the secondary containment walls will flow into the W WTP, either by existing drainage or manual
pumping by The Mt. Olive Pickle Campany employees. There is a wall around the vinegar and
alum tanks that ,measures 15" tall; this wail height combined with the surface area contained
inside the walls of approximately 1,700 square feet means there is approximately 13,000 gallons
of containment for these tanks. This is a sufficient amount should a tank failure occur at the
bottom of one of the tanks. The following chart is for record-keeping purposes to track the
quality of the stormwater that accumulates in the containment areas; however, as none of the
stormwater that gathers in secondary containment areas currently discharge to stormwater
discharge outfalls, this chart does not need to be filled out.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant
Page 32

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2.3. BMP Summary
The Main Production Plant will incorporate a number of structural and non-structural BMPs into
their standard procedures. Potential examples of the structural BMPs can be found in Appendix
E. The table on the following page provides more detail for these and other BMPs that will be
implemented at the Production Plant. Found below is a step-by-step list of procedures that should
be followed at areas where loading and unloading takes place (in Drainage Areas 5 and 6).
1. Before a train car or transport truck unloads at the site, a protective, liquid -tight drain
cover mat shall be placed over any storm grates in the area to prevent spill from reaching
the storm drainage.
2. Place spill pallets between railroad tracks and under where trucks will park to catch liquid
draining from vehicles.
3. Place containment berms and absorbent booms between unloading area and storm drains
to contain any major spills
4. Should a spill occur, pump the spilled liquid away area before the storm mats are
removed; the liquid would likely be transported to the treatment plant. If corn syrup is
spilled, be sure to not use water to clean the spill (as this makes the corn syrup more
likely to flow into storm drainage). Instead, use absorbent material of an appropriate
nature.
5. If spill absorbent is used, properly dispose of this material once the spilled liquid is
gathered.
b. Record any spills that do occur, the amount spilled, and actions taken to counteract the
spill.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan - Main Production Plant Page 35

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3.0 Spill Prevention/Response Plan
The Mt. Olive Pickle Company has a spill response procedure in place for the liquids listed in
Section 2.2, The chart below shows the company's established response procedure in the event
of a spill at one of these Iocations. Appendix D contains the most recent Mt. alive Pickle
Company spill response plan. The Mt. Olive Pickle Company should modify the spill response
plan, as necessary, to include specific actions tailored to ft whatever liquid is spilled.
Additionally, the appropriate spill pallets, containment berms, and absorbent booms should be
added to the existing spill response kits (or put in place separate from the kits, as they will be
utilized every time a deliver occurs).
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant Mage 38

COMPICIcd b%.—
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rnstvuctioas:SpKcify ]nnwums for clewing up ypl)ts associated with all potCntia# po)Jutrultt sources Note: if f�
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4►0 Preventative Maintenance and Good Housekeeping Program
The Mt. Olive Pickle Company's staff will continue to employ good housekeeping procedures
throughout the Main Production Plant facility to better guard against stormwater pollution.
Following these procedures helps to minimize the amount of pollution that can be present in
stormwater flow by ensuring unwanted materials are not picked up by incoming stormwater.
Maintenance staff will also work to regularly inspect and fix equipment that may become leaky
and will take care to verify their maintenance activities do not contribute to stormwater pollution.
Any equipment and tools kept outdoors shall be regularly inspected and kept in an orderly
fashion; the new structural BMPs shall be checked to verify proper function; and the facility site
shall be monitored for potential new sources of stormwater pollution.
The Mt. Olive Picklc Company
Stormwater Pollution Prevention Plan —Main Production Plant Page 42

Preventative Maintenance & Good Housekeeping Procedures
Completed k%:
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Brief Description of
Maintenance Schedule for Starmwater
Identify Staff
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Page 43

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5.0 Facility Inspections
Similar to preventative maintenance and good housekeeping procedures, regular facility
inspections will help improve the quality of the stormwater Ieaving The Mt. alive Pickle
Company's Main Production Plant site. These inspections identify any malfunctioning
equipment that should be restored to its proper working order and minimizes the risk of said
equipment contributing to stormwater pollution (through a machine leaking oil on the ground, for
example). Additionally, with regular inspection, existing and new stormwater systems (such as
BMPs) will continue to function properly and will better treat the stormwater originating on the
site. Visual inspections of the facility will take place monthly.
The Mt, Olive Pickle Company
5tormwater Pollution Prevention Plan — Main Production Plant Page 45

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6.0 Employee Training
Mt. Olive Pickle Company will develop an employee training program for all employees with
responsibilities in areas where stormwater could be present are kept up-to-date on the correct
procedures to minimize stormwater pollution. An initial training session will be necessary for the
Stormwater Pollution Prevention Team (see section 7.0) to introduce the SPPP to the rest of The
Mt. Olive Pickle Company's staff and to inform them of the requirements and goals of the plan.
This training should be scheduled as soon as possible once the SPPP is certified by the team. The
chart below is to keep record of any training events that take place. In addition to the
introductory training, annual staff training must be performed to be in compliance with the
general stormwater permit requirements.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan —Main Production Plant page 47

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7.0 Responsible Party
The Mt. Olive Pickle Company's Stormwater Pollution Prevention Team shall be responsible for
ensuring the Stormwater Pollution Prevention Plan is implemented and updated correctly, This
team includes members of the executive staff, members of the operation staff, and members of
the maintenance and facility staff. The organizational chart showing the structure of the team is
on the following page. Their general responsibilities with regards to the plan presented here are
also shown. This is not the limit of their responsibility; rather, it is an outline of the more
significant aspects of what roles they will likely fill as the plan is implemented.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant Page 50

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8.0 Plan Amendments and Annual Update
The Stormwater Pollution Prevention Plan as presented above is a living document, and as The
Mt. Olive Pickle Company evolves, so too does its Stormwater Pollution Prevention PIan. This
section serves to track the changes made to the original plan, as well as to show evidence of data
accumulated over the life of the plan. Annual updates shall be made to the Stormwater Pollution
Prevention Plan to modify practices and procedures, as necessary, to make them more effective
or to adapt to changing operations at the main production plant.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant Page 52

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9,0 Platy Implementation
9.1. Stormwater Discharges; Analytical Monitoring
The Mt. Olive Pickle Company will perforin semi-annual monitoring (twice each year) of each
of its Stormwater discharge outfalls (SDOs). In the general storm water permit, the sampling
events are referred to as Period I and Period 2. Period I spans from January I" to June 30`x'
Period 2 spans from July 1s` to December 31". Each sampling event must be at least 60 days
apart and be taken during a measurable storm event. A measurable storm event is a storm event
that results in an actual discharge from the permitted site outfall. The previous measurable storm
event must have been at least 72 hours before the sampling event (i.e. no actual discharge in the
SDO 72 hours before sampling).
The analytical monitoring table below shows what must be measured and the table can be used to
record the results of each sampling event. All samples will be grab samples taken when flow is
occurring at the SDO. Per the Certificate of Coverage established by The Mt. Olive Pickle
Company and NCDEQ, chloride will be monitored in addition to the standard characteristics
designated by the permit, but only at SDO 002. As stated in the cover letter from NCDEQ
(which can be found in Appendix A), chloride is a pollutant of concern resulting from the
activities at this plant. Accordingly, a chloride benchmark value of less than 860 mg/L has been
established; should this value be exceeded, further action will be required. This action is detailed
below and in the Certificate of Coverage, Fecal coliforms and E. Coli samples are not included
because this sampling is only required for the meat processing industry. The table also shows
the benchmark values for each characteristic (italicized in the header) for comparison to the
results. Values above these levels must be addressed via the Tier 1, Tier 2, and Tier 3 responses
as listed in Part II of the general permit. Tier 1 involves evaluating causes of the exceedance and
what operational changes can be made to address the problem. Tier 2 is implemented if two
samples in a row are above the benchmark values; this tier triggers monthly sampling at each
SDO. If benchmark values are exceeded for four sampling occasions, Tier 3 is triggered and this
requires notification of the DWQ regional office supervisor upon which further actions would be
determined. If the benchmark value for chloride is exceeded, The Mt. OIive Pickle Company
must evaluate the area around the SDO for potential exposed sources, implement more effective
BMPs to reduce chloride concentrations, and document all actions taken in this SPPP.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main .Production Plant Page 54

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9.2. Stormwater Discharges: On-site Vehicle/Equipment Maintenance Monitoring
Independent from the above Qualitative Monitoring, stormwater discharge outfalls are typically
monitored for impacts from vehicle maintenance performed on-site. The permit requires
monitoring if the permittee uses more than 660 gallons of new motor oil and/or hydraulic oil on
this site in a year. The Mt. Olive Pickle Company does use more than this amount in their
maintenance facility, however vehicle maintenance is performed in a location where any
stormwater (and other liquids associated with the stormwater flow) is drained to the WWTP.
Accordingly, this monitoring is not required to meet the requirements of this permit.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant Page 56

9.3. Stormwater Discharges: Qualitative Monitoring
Qualitative monitoring will also be performed twice per year at each SDO during a measurable
storm event. The schedule will be during Periods 1 and 2 as defined for the analytical sampling
and qualitative monitoring is to be separated at least 50 days apart. It will be most efficient to
perforin the qualitative monitoring at tate same time as the quantitative sampling, as practical.
The table below lists the qualitative items to be visually inspected and provides a table to record
the results of the visual monitoring. The purpose of the qualitative monitoring is to gauge the
effectiveness of the Stormwater Pollut on Prevention Plan, assess new sources of stormwater
pollution, and. prompt The Mt. Olive Pickle Company to respond to any evidence of pollution.
Employees should be recording observations based on the color, smell, and clarity of the water,
and whether there are visible signs of pollution like particles suspended in the flowing water and
erosion at the outfalls.
Section II of the permit specifies what must be done if qualitative sampling reveals ineffective
BMPs or significant contamination is present then the permit outlines necessary responses. if
repeated "failures" occur, DWQ can require further actions (such as more monitoring,
implementing different BMPs, or sampling upstream and downstream to characterize impact on
receiving waters). Unlike quantitative sampling there is no tiered response; in the event an
atypical condition is noted at the SDO, The Mt. Olive Pickle Company staff shall document the
suspected cause of the condition and any actions taken in response to the discovery. This
documentation shall be maintained within this document.
The Mt. Olive Pickle Company
Stormwater Pollution Prevention Plan — Main Production Plant Page 57

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