WQ0000701_Amendment Request_19901221

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State of North Carolina
Department of Environment, Health and Natural Resources
Division of Environmental Management
51.2 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
Mr. Lawrence R. Sampson,
N.C. Division Engineer
Holly Farms Foods, Incorporated
Post Office Box. 88
Wilkesboro, North Carolina 28697
Dear Mr. Sampson:
George T. Everett, Ph.D.
Director
December 21, 1990
Subject Permit No. WQ0000701 Amendment
Holly Farms Foods, Incorporated
Harmony and Wilkesboro Facilities
Land Application of Sludge
Rowan County
This is in response to your letter received August 16, 1990, concerning various
comments and amendment requests for the subject permit. When your letter was received by the
Permits and Engineering Unit, it was reviewed and copies of the subject letter were sent to the
Mooresville Regional Office and the Groundwater Section for review and comment. Based on the
review and comments of Mooresville Regional Office, the Groundwater Section and the Permits
and Engineering Unit, some of the requested permit amendments can be made. The other requested
permit amendments cannot be made at this time. The following is an item by item response.
Item 1 Condition 11.3 of the existing permit is amended to conform to the current
standard condition, as it specifically details PAN requirements for specific
crops. No justification to amend this condition, as requested in your letter,
has been provided, therefore, it should remain.
Item 2 Condition II.5 of the existing permit shall be amended to correct the error
concerning the permit number for the Wilkesboro Facility. In response to your
question, additional sources of sludge, of a poultry rendering nature, can be
added to this permit. However, a formal permit amendment request must be
made for each additional source or group of sources which must include the
appropriate analysis. In response to your request for the land application of
tailings water from the sludge rendering process, a formal permit amendment
request must be made.
Item 3 The existing permit condition shall not be amended to reduce the sludge
analysis from quarterly to annually. After two years worth of analysis the
Penxnitee may request that the frequency be changed to annually. This
condition, IIIA, shall also include an annual TCLP analysis which replaces
EP Toxicity, in accordance with the Division of Environmental Management
procedure and March 29, 1990 Federal Register Final Rule for TCLP.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Item 4 Condition IV.1 of the existing permit requires two (2) new monitoring wells so
that in conjunction with the one (1) existing monitoring well, application :Fields
F, Q, and L would be adequately monitored for 2L Standard violations beyond
the perimeter of compliance.
Item 5 All monitoring wells must be surveyed in order to provide relative elevations.
Condition N.2 requiring the survey is necessary in order that a determination
may be made of groundwater flow direction across the site. The existing permit
shall be amended to require all monitoring wells be surveyed relative to
common elevation. The expense of performing a survey is not needless or
excessive in view of the value of the information provided.
The Division hopes that this response adequately addresses your concerns. Please
review the attached permit and if it is unacceptable to Holly Farms, Inc., you should proceed to file
a formal petition to the Office of Administrative Hearing as directed by the enclosed permit.
If you have any questions regarding this matter, please contact Mr. John Seymour at 919/
733-5083.
cc: Mooresville Regional Office
Groundwater Section