NC0082821_Compliance Evaluation Inspection_20180727

Water R esources
ENVIRONMENTAL QUALITY
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPPER
Interim Director
July 27, 2018
Ms. Jennifer Bunting (via email)
Manager, Environmental Programs
Southern States Fertilizer
P.O. Box 26234
Richmond, VA 23260-6234
Subject: Southern States Fertilizer Plant
Compliance Inspection Report
NPDES Permit NCO082821
Statesville, Iredell County
Dear Ms. Bunting,
The Mooresville Regional Office (MRO) of the Division of Water Resources (DWR) would like to thank
you, Mr. John Madden, and Bruce Gray, for taking time to meet with us regarding the Southern States
Fertilizer manufacturing facility in Statesville. The MRO also extends its thanks to Tom Dunham and
Jason Kilcoyne of Duncklee and Dunham for their assistance and input during the July 16, 2018, site visit.
A Notice of Regulatory Requirements letter addressing the groundwater incident is currently being
drafted and will be sent separately from this compliance inspection report.
The current NPDES permit will expire on March 31, 2019. Your permit renewal application should be
submitted 180 days prior to the permit expiration date and this is also a good time to update contact
information.
Since January 2016, three Notice of Violations (NOVs) and two Notice of Deficiencies (NODS) have been
issued for limit violations associated with low pH and elevated TSS.
A system operations review performed by the MRO and Duncklee and Dunham has revealed that since
2014, the system has operated around 64% of the time. The MRO acknowledges that during a portion of
this time period, the system was only scheduled to operate a portion of the year. Operation efficiency
has increased in 2018 largely due to a treatment system overhaul. Flows from the various recovery
wells have also been optimized.
The MRO has concerns regarding the notification of system failures as specified under Section E of the
permit, which requires notification within 24 hours of occurrence. On multiple occasions in 2017,
system failures were not reported to the MRO within the 24-hour notification period. In 2018, there are
conflicting dates associated with separate reports of cracked piping at RW -2. The permittee is reminded
that notification of system failures should follow this permit condition. The MRO would also like to
impress upon Southern States that coordinated activity between on-site maintenance and Duncklee and
Dunham will aid with proper reporting of system failure issues.
State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations
Mooresville Regional Officel 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115
704 663 1699

All of this being said, the MRO would like to acknowledge that significant steps have been taken at the
site to overhaul the treatment system and, in particular, that site housekeeping has dramatically
improved since the last inspection. Plant operations moving away from loading/unloading and storage
of liquid fertilizer are also anticipated to improve site conditions.
Should you have questions regarding this letter, or the attached inspection report, you may contact
Edward Watson by phone at [phone] or email ([e-mail]).
Sincerely,
DocuSigned by:
A"uw H P44.,e4
F161FB69A2D84A3...
Andrew H. Pitner, P.G.
Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources
Attachment: Compliance Inspection Report
cc: Tom Dunham & Jayson Kilcoyne, Duncklee and Dunham (via email)
John Madden, Southern States

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 15 I 3 I NCO082821 111 12 I 18/07/16 I17 18 I S J 19 LG] 201 I
211111 1 1 1 1 1 111 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 111 1 1 1 1 1 166
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
67 1.0 70 I, I 71 [L] JI 72 I I 73I I I74 751 I I I 1 1 1 I80
I—I I I i
Section B: FacilityDataI�
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
10:OOAM 18/07/16
14/05/01
Southern States Fertilizer Plant
2582 Salisbury Hwy
Exit Time/Date
Permit Expiration Date
Statesville NC 28677
12:30PM 18/07/16
19/03/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Danny Dillon,6606 W Broad St Richmond VA 232606234NP Crops/804-281-1000/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program 0 Facility Site Review Effluent/Receiving Waters Laboratory
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Edward Watson MRO GW/// /
107/27/2018
CA4CEBF8F85F415...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Docusigned by: Date
Andrew Pitner MRO WQ//704-663-1699 Ext.21 �'y'. n H Nuft 7/27/18
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
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NPDES yr/mo/day Inspection Type (Cont.)
NCO082821 111 121 18/07/16 1 17 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On July 16, 2018, MRO staff conducted a compliance inspection of the Sourthern States Fertilizer
Manufacturing facility operating under NPDES permit NC0082821.
Edward Watson and Andrew Pitner,of MRO, Tom Dunham and Jason Kilcoyne, of Duncklee and
Dunham, Jennifer Bunting, John Madden and Bruce Gray from Southern States,were present at the
meeting.
The recovery wells have been pumping year-round since 2016. RW -5r was observed to be operating
during the site visit. The area around RW -5r needs to be maintained so the well is easily accessible to
be able to perform routine work and sampling. Recovery well sampling will be performed in the months
of May and December of each year. The system has received considerable repairs since 2015 and
appears to be operating more efficiently.
Wet toxicity sampling results have reported to be passing for 2016, 2017,and thus far in 2018.
Southern States is reporting Discharge Monitoring Reports (DMRs)electronically as required by the
Permit. The eDMR's for 2016, 2017 and 2018 were reviewed prior to the site visit and the records were
complete. pH and TSS violations were noted in 2016 and 2017 resulting in the issuance of two NOD's
and three NOV's for Limt Violations from this office.
Most recently, RW -2 was shut down due to a cracked pipe at the well head. A January 11, 2018, email
from Adam Daniel appeared to indicate that the cracked pipe was scheduled to be repaired within 7 to
10 days of discovery. However, according to the email attachment dated July, 9, 2018, and received by
the MRO on July 11, 2018, states the RW -2 cracked pipe repair occurred on May 7, 2018. Apparent
conflicts with email notification regarding system failure is not in compliance with permit requirements
to notify the MRO.
The Permit condition that stipulates reporting requirements for Noncompliance Notification is found in,
Part II Standards and Conditions, Section E, Reporting Requirements, 9)Noncompliance
Notification(a).
The MRO would like to impress upon Southern States that coordinated activity between on-site
maintenance and Duncklee and Dunham personnel will aid with the proper reporting of system failuire
issues. As this is a permit requirement,on-site maintenance will need to play an active role in the 24 hr.
notification process. Future violations may result in an enforcement action.
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Permit: NCO082821 Owner - Facility: Southern States Fertilizer Plant
Inspection Date: 07/16/2018 Inspection Type: Compliance Evaluation
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Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
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0
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application?
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Is the facility as described in the permit?
0
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# Are there any special conditions for the permit?
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0
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Is access to the plant site restricted to the general public?
0
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Is the inspector granted access to all areas for inspection?
0
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Comment: The Permittee was informed that this permit will exDire on March 31. 2019. and that a new
application will need to be submitted with updated contact information.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ 0 ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The housekeeaina at the facilitv has improved sianificantly since the 2015 site visit. A
request was made by MRO to record repair activities and to record routine system
inspections performed by maintenance staff. This requirment is stipulated as a permit
requirement in Part II Standard Conditions for NPDES Permits, Section C. Operation and
Maintenance of Pollution Controls(2) Proper Operations and Maintenance:
"Properly and offically designated operators are fully responsible for all proper operations
and maintenance of the facilty and the documentation thereof, whether acting as a
contractor operator (subcontractor) or a member of the Permittee's staff."
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported CDCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
Yes No NA NE
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Permit: NCO082821 Owner - Facility: Southern States Fertilizer Plant
Inspection Date: 07/16/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ 0 ❑
on each shift?
Is the ORC visitation log available and current?
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0
Is the ORC certified at grade equal to or higher than the facility classification?
0
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Is the backup operator certified at one grade less or greater than the facility classification?
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0
Is a copy of the current NPDES permit available on site?
0
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Facility has copy of previous year's Annual Report on file for review?
0
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Comment: There have been multiple Limit Violations (LV) reported for this facilitiv. Since 1-2016, there
effluent discharge.
have been 3 NOV'S and 2 NOD's. The LV's have primarily been for pH below minimum limits
and elevated TSS.
On 02/24//17. there was a system failure which was not reported to the MRO. From 6/20/17
through 7/26/17, the system was down again. MRO did not receive notification for several
days after the shut down occurred and not within the 24 hr notification period. Also, between
the dates of 08/11 throuah 08/28/17. another system failure occurred. Aaain. the MRO was
not notified within the 24hr window.
ee additional comments in the summa
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
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0
Are the receiving water free of foam other than trace amounts and other debris?
M
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If effluent (diffuser pipes are required) are they operating properly?
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0
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Comment: Access to the outfall is challenging. Due the location of the outfall;
the outfall had to be
observed from across the stream. No foam, solids or coloration was observed in the
effluent discharge.
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