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HomeMy WebLinkAboutWQ0035595_Staff Report_20150814Divlslon of Water Resources State of North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Regional Operations Section Staff Report August 14,2015 To: Non -.Discharge Pennitting Unit Application No.: WQ0035595 Attn: Troy Doby Facility: Granville Farms Land Application Program g� #� County: Edgeeombe From: Cory Larsen REGEI� r �IDENRIQ��.' Raleigh Regional Office ; L GENERAL SITE VISIT INFORMATION water,Quality 1. Was a site visit conducted? ® Yes or ❑ No Per+ril 1111 Section a. Date of site visit: March 26, 2015 and April 15, 2015 b. Site visit conducted by: 3/26: Cory Larsen William Miller. 4115: CoEy Larsen Danny Smith William Miller Erin Deck c. Inspection report attached? ® Yes or ❑ No d. Person contacted: Jason Smith and their contact information: (919) 690 - 8000 ext. e. Driving directions: Fields are located at 21.80 Shiloh Farm Rd, Tarboro, NC 27886 II. ROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS I . cility Classification: (Please attach completed rating sheet to be attached to issued permit) 2. Are th ew treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No If no, exp 3. Are site conditio {soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A If no, please explain: 4. Do the plans and site map resent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A If no, please explain: 5. Is the proposed residuals manageme Ian adequate? ❑ Yes ❑ No ❑ N/A If no, please explain: 6. Are the proposed application rates (e.g., hydra , nutrient) acceptable? ❑ Yes ❑ No ❑ NIA If no, please explain: 7. Are there any setback conflicts for proposed treatment, s ge and disposal sites? ❑Yes or ❑ No If yes, attach a map showing conflict areas. 8. Is the proposed or existing groundwater monitoring program adequ ? ❑ Yes ❑ No ❑ NIA If no, explain and recommend any changes to the groundwater monitors program: 9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No NIA If yes, attach list of sites with restrictions (Certification. B) FORM: WQROSSR 02-14 Pagel of4 111. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ® No ❑ NIA ORC: Certificate ##: Backup ORC: Certificate #: 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ® No If no, please explain: Operation and maintenace of the land a lication fields has not been compliant with permit requirements. 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? ❑ Yes or ® No If no, please explain: Some fields had excessive residuals application and were not assimilating the waste. Application to saturated fields was observed. Depth to water table not currently monitored. 4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? ❑ Yes or ® No If yes, please explain: 5. Is the residuals management plan adequate? ❑ Yes or ❑ No ® N/A If no, please explain: 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No ® N/E If no, please explain: Observed application rates appear excessive although reported application rates appear com liant with realistic yield rates. No determination of whether current rates are protective of GW/SW can be made without father data and resource monitoring 7. Is the existing groundwater monitoring program adequate? ❑ Yes ® No ❑ N/A If no, explain and recommend any changes to the groundwater monitoring program: The facility does not currently monitor GW. Recommend installation of piezometers and monitoring wells for measurement of groundwater elevation levels and quality at select locations. 8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No If yes, attach a map showing conflict areas. 9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No If no, please explain. 10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no, please explain: 11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A If no. please complete the following (expand table if necessary): Monitoring Well Latitude Longitude O , Il 0 , rl 0 r If 0 r It O r rr o r rr 0 1 If a r I7 12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW)? ® Yes or ❑ No Please summarize any findings resulting from this review: Inspection Summary: Review of the 2014 Residuals Annual Summ RAS re ort for W 00035595 was performed by W ROS staff on Mgy 19 2015. Note that this inspection evaluated compliance of the annual report submittal only, and not of the land application sites. See the April 2015 compliance inspection and NOV-2015-PC-0082 letter for details on observed site conditions. The submitted annual land application certification form was complete and indicated program compliance with permit conditions. The Permittee land applied approximately 247 dry tons on 15 of 34 fields (245 acres) during FORM: WQROSSR 02-15 Page 2 of 4 the 2014 calendar year in Edgecombe and Martin counties from W WTP sources including Ahoskie, Contentnea MSD, Neuse River, Stantonsburg, Tarboro, and Williamston. Residuals nutrient and metals monitoring was conducted at least once for each source and TCLP was conducted one time in accordance with permit requirements. All results appeared compliant with applicable concentration Iimits. Field summary forms were provided and indicated acceptable loadings based on reported cover crop type. Pathogen and Vector Attraction Reduction forms were submitted and indicated compliance with the permit. Fecal coliform demonstration was utilized to show compliance with pathogen reduction requirements for all sources. Various vector attraction reduction methods were performed for different sources including volatile solids reduction, 30 -day bench scale test, and SOUR testing. All results appeared compiaint with PR/VAR demonstration requirements. Soil tests were performed on all fields and A r_g_onomic Division soil reports showed many fields with pH below 6.0 and included lime recommendation. Since the residual sources were not lime stabilized, and the permit requires maintenance of soil pH of 6 or above for land application sites, the permittee must apply lime in accordance with soil report recommendations. This was cited in NOV-2015-PC-0082. 13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No If yes, please explain: 14. Check all that apply: ❑ No compliance issues ® Current enforcement action(s) ❑ Currently under JOC ® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) 15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A If no, please explain: Following NOV-2015-PC-0082, the permittee has complied with signage requirement schedule condition (I.4), and it should be removed fromep rmit. 16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? ❑ Yes ®No❑N/A If yes, please explain: N. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ❑ No If yes, please explain: 2. List any items that you would like APS Central Office to obtain through an additional information request: Item Reason 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason Conditions 1.3, I.4, and 1.5 Compliance dates have passed and permittee is expected to comply with reference permit conditions. Monthly Application loading summary forms (modified by NDPU and customized for Granville 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason Request that the permittee submit monthly application reports on modified field Monthly Application loading summary forms (modified by NDPU and customized for Granville Reports Farms) to account for application and loading of all nutrient sources including Class A residuals, Class B residuals, animal waste, andsynthetic fertilizers to FORM: WQROSSR 02-15 Page 3 of 4 5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office ® Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ❑ Issue ■ N b. Signature of report preparer: Signature of Regional supervi Date: V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS FORM: WQROSSR 02-15 Page 4 of 4 ensure proper reporting of all nutrient sources and tracking of nutrient load. Application of non -Class B sources has not been reported in previous residual annual summary reports reviewed by the Division for at least the last two years. This reporting form should be incorporated into the permit with enforceable permit conditions. Recommend installation of shallow groundwater monitoring network on portions of the review boundary for select fields at the site as well as installation of piezometers to measure depth to water table. Basis for recommendation: Shallow depth to groundwater across site; Add GW Monitoring / Operation as dedicated fields evidenced by land application in consecutive Attachment C years on many fields (see attachment -- note it only accounts for Class B residual application — Class A application is largely unknown); - Water quality data collected in April suggests impacts (see Sample Points map with results - attached). Schedule condition to submit paperwork to designate ORC within 30 days of Schedule permit issuance. Jason Smith has not been designated as of the date of this staff report. 5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office ® Hold, pending review of draft permit by regional office ❑ Issue upon receipt of needed additional information ❑ Issue ■ N b. Signature of report preparer: Signature of Regional supervi Date: V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS FORM: WQROSSR 02-15 Page 4 of 4 GRANVILLE FARMS WQ0035595 FIELDS RECEIVING CLASS B RESIDUALS APPLICATION 2012-2014 (PER SUBMITTED RESIDUALS ANNUAL REPORTS) Field EB SBS 2012 EB fieids permitted during 2012 10 11 12 13 14 17 18 19 20 21 22 32 2013 1 21 31 1 2 3 4 6 7 8 11 12 13 14 16 17 18 19 20 21 22 32 2014 21 21 31 4 5 2 31 6 11 121 13 17 21 22 32 Sample G SampEe.G Fecal Coliform 2100 (CFU/ML) . Dissolved Oxygen 7.68 (mgfL) Sample Sec. Conductance 81.7 u cm ecal Coliform 420 (CFU/mL) y Sample F TDS 1 m )Ived Oxygen 10.82 (mgfL ? TKN 0.92 m !L as N Conductance 182.5 u crnt Ammonia 0.05 mgiLas N TDS m !L _ TKN 1.9 (mgfL as N} NitratefNitrite 0.02 (rrkglL -� � Ammonia 4 Chloride 11 mg 27 (mgfL as N} H 5.87 IS.U. NitratefNitrite 3.3 (mgfL) ti� :. Temperature 17.4 ecMs Chloride 11 (mg Ll H 6.68 S -U- rr Temperature 17.3 Uelciu& r, Sample D Sample E \Sample E Sample D; d Fecal Coliform 1200 ( FUlmL) ecal Coliform 490 (CFU/mL) Dissolved Oxygen 6.52 (mgfL) )Ived Oxygen 9.88 (mgfL)5 ec. Conductance 189.3 u crn Conductance 194.7 u cm TDS 154 m TDS m _ �` TKN 1.1 m 1L as N TKN1(mg/L) s N [ ` 1+ Ammonia 0.26 (mgfL as N) Ammonias N) +a NitratefNitrite 4 (rng1L) NitratefNitrite Chloride 6 mgfL) rChlorideH6.56 S.UH Tem erature 17.3 a aus Tem erature r Sarriple C' Np r LF. i 1 A Y� ��t • c� Sant le C r ecal Coliform 720 U mL) )Ived Oxygen 7.66 (mg ) Conductance 215.8 u cm TDS 200 m L TKN 1-7 m /Las N N�� ~ Ammonia 0.3 (m 9ILas-- �� Nitrate/Nitrite 9 (mg/L) Chloride 8.2 (mg L) pH 8.26 S.U.=a Temperature 17.2 lUeiUus )nia 0.54 m L as N) trite 25 (mg ) ride 17 rn IL H 5,63 S.U. ure 14.8 a cws Legend ® Sample_Sites >v Suffers Buffered area Map provided by NCDENR Division of Water Resources locations are approkma#ions and : are provided for reference only :: Atnr"52 0.36 " as N) NitratefNitrite 33 (mgfL) Sample Points Granville Farms WQ0035595 Edgecombe County, NC As collected on: 4/15/15 r Wk M6F_ NCD North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary April 28, 2015 CERTIFIED MAIN RETURN RECEIPT'REOUESTED RECEIPT #7010 1870,0001 34230919 JASON B. SMITH — VICE PRESIDENT GRANviLLE FARMS, INC. P.O. Box 139.5 OXFORD, NORTH CAROLINA 27565 Subject: Notice of Violation and 10-Day Notice of Intenfto Enforce NOV-2015-K-00Sk Permit No., WQ0.03559$ . Land Application ofClass.B Residual Solids (503) Program Edgecombe County Dear Mr. Smith: Staff from the Division of Water Resources, Water Quality Regional Operations Section (WQROS). conducted .a compliance inspection on March 26, 2015 as part of transfer fields JBS-11 and Jl purpose of the visit was to " conditions of each field, B` A- 519natura U agent inspection, a more com rehens , ■Complete items 1 2, and 3. Also oornp►ete X p Addressee p p item 4 if Restricted Delivery is desired. on April 15, 2015 to assess ova C Date of Delivery � Print your name and address on the reverse s � calved b Pnn#ems � rti photos document permit conduit So that we can return the card to YOU- photos y i n ■ Attach this card to the back of the malOece, D Is delivery address different from item 17 �-, or on the front if space permits. p No if YES, enter delivery address below, I. SCHEDULES 1. Article Addressed to: 1. Condition 1: "The permi JASON $. SMITH, VICE PRESIDENT in Condition 11I.13. withi GRANVILLE FARMS, INC- Po BOX 1396 3. service Type OXFORD NC 27565 ib.Gertified Mail ❑ F-xpress Mail The permit for land a 1' ❑ Registered Q3-Return Receipt for Merctiandle p pp NOV AND 10-DAY NO ENF.INOV-2015-PC-008 required pasting of signx Wgo035595.EDGFC_0W e� couNTY p Insured Mail ❑ c.o.D. 4128115.MAILED.4129115.APS. TARSEN ©`fes signage was observed duf. 4 Restricted Deliveryxire Fee)' to post a sign at the entrap 2 Article Number y 11. PERFORMANCE STANDA>r nfrorserofce febef �. Domestic ic Return eturn Receipdt PS Form 3811, Febuary 2004 � f t iozs9a M 2. Condition 1: "The subjec voiuudis management program shall be effectively. maintained and operated at all times so there is no discharge to surface waters, nor any contravention of groundwater or surface water standards..," Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http://portal.ncdenr.org/web/wqlaps 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone: (919) 791-4200 Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax: (919) 788-7159 An Equal Opportunity 1 Affirmative Action Employer - Made in part by recycled paper Mr. Jason B. Smith 471 Page 2 of 6 , Application of residuals within setback distances to surface waters and groundwater lowering ditches appears to have resulted in discharges of waste to surface waters over extended portions of the land application site including Fields 11, 17, 19, 21, and 22. See Figure 1 below and attached map for specific locations and reference photos. 3. Condition 8: "Setbacks for land application sites shall be as follows: a M Application of residuals was observed within setbacks/buffers to surface waters (100 ft), surface water diversion and groundwater lowering ditches (25 ft), water supply wells (100 ft). Setback distance to surface waters may be reduced to 50 ft if the residual is injected or incorporated within 24 hours of application, however, even this buffer distance was observed to be in violation. See the enclosed reference map for specific locations and photos. Setback by application type (feet) Setback Description Vehicular Irrigation Surface Surface Injection 1 Application Application corporation Private or public water supply 100 100 100 Surface waters (streams — intermittent and perennial, perennial waterbodies and wetlands 100 100 50 Surface water diversions (ephemeral streams, waterways, ditches 25 100 25 Groundwater lowering ditches (where the bottom of the ditch intersects the SHWT 25 100 25 Subsurface groundwater lowering system 0 100 0 Wells with exception to monitoring wells 100 100 10 Application of residuals was observed within setbacks/buffers to surface waters (100 ft), surface water diversion and groundwater lowering ditches (25 ft), water supply wells (100 ft). Setback distance to surface waters may be reduced to 50 ft if the residual is injected or incorporated within 24 hours of application, however, even this buffer distance was observed to be in violation. See the enclosed reference map for specific locations and photos. 7 r` Mr. Jason B. Smith NOV-2015-PC-0082 April 28, 2015 ' Page 3 of 6 4. Condition 9: "Land application areas shall be clearly marked on each site prior to and during any residuals application event." Land application was being conducted as WQROS staff arrived on April 15, 2015, however, buffers were not flagged prior to application or otherwise marked until staff instructed land application personnel to cease activities until, fields could .be' flagged. Flags were not available onsite immediately and were later brought to the site. Only a few flags froth previous application events were observed as staff walked the majority of the fields. In some cases, residuals were applied within flagged buffers or flags were placed following application activities. The permittee must clearly mark land application field areas suitable for residuals application prior to and during application events.` 1111. OPERATION AND MAINTENANCE REOUMEMENTS 5. Condition 1: "The residuals management program shad be properly maintained and. operated at 411 times. The program shall be effectively maintained and operated as a non -discharge system to prevent any contravention of surface water or groundwater standards." Visual observations of onsite ditches and surfacc waters including the presence of .f lamentous algae, turbidity and chlorophyll -induced color indicate that -the land application program is not being effectively managed to prevent waste discharges and exceedence.s .of groundwater and surface -'water standards. Field sampling results indicated' that surface waters and associated ditches have been impacted by residuals. application and contain. water quality parameters consistent with wastewater characteristics. WQROS.also observed improper storage And -apparent disposal of hay bales along field edges in Fields 17 and 22 (see photos). Decaying bales return harvested nutrients back to the soil, and does not constitute good crop management practice as it effectively reduces realistic yield nitrogen rates for crops, and concentrates nutrients in the soil with the potential to impact surface water and groundwater. Harvested crops must be removed from all land application sites for their intended purpose within a reasonable timeframe following harvest. Additionally fields north of Shiloh Farm Road were found to be heavily rutted and compacted (see photos) by vehicle traffic and are unsuitable for land application in their existing state. 6. Condition 5: "Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the facility, the Permittee shall designate and employ a certified operator in responsible charge (ORC) and one or more certified operators as back-up. ORCs in accordance with ISA NCAC 08G .0201..," To date, an ORC has not been designated for this facility according to Division, records. See the. enclosed Water Pollution Control System Operator. Designation Form and return a completed form prior to conducting further land. application activities. 7. Condition 8: "Residuals shall not.be stored at any land application site, unless written approval has been requested and received from the Division." Mr. Jason B. Smith NOV-2015-PC-0082 April 28, 2015 Page 4of6 WQROS staff observed multiple product storage piles in fields 18 and. 20 of. various age and type including pelletized solids, lime stabilized solids, and cake residuals. Two piles were overgrown with vegetation and appeared to have been onsite during multiple growing seasons. The permit prohibits storage of residuals onsite without written Division approval, and does not allow long- term storage or disposal of stockpiles onsite. 8. Condition 9: "When the Permittee land applies bulk residuals, adequate measures shall be taken to prevent wind erosion and surface runoff from conveying residuals from the land application sites onto adjacent properties or into surface waters." Residuals .appeared to have been conveyed by surface runoff into groundwater lowering ditches hydraulically connected to surface waters, most notably in fields 11 and 17 at the time of inspection (see. photos). 9. Condition 10: "When the, Permittee land applies bulk residuals, a suitable vegetative cover shall be maintained on land application sites onto which residuals are applied..." Extensive portions of active land application areas were either un -vegetated or weed covered, conflicting with cover crops reported in the 2014 residuals annual summary report for the site. A July 2013 inspection by Division staff also noted lack of cover crop on application fields. Residuals shall.not be applied to any fields without a suitable and maintained cover crop. 10.. Condition J 1: `Bulls residuals shall not be land applied under the following conditions... c. If the land'fails to assimilate the bulk residuals... f ...within 24 hours following a rainfall event of 0.5 inches or greater in a 24-hour period. h. If the soil.pH is not maintained at 6.0 or greater... j.. If the vertical separation between the seasonal high water table and the depth of residuals application is less than one foot." 11.c violations were noted in areas of excessive application as shown. on`the enclosed map and in photos. All fields that were land applied on during the April 15., 2015 visit were in violation of l 1.f as 0.72 inches and 0.83 inches of rainfall were recorded at nearby weather stations on April 14, 2015. Numerous portions of fields with residuals application did not meet vertical separation to -groundwater requirements under Condition 11 j (see map). Finally, soil reports from. the 2014 residuals annual summary also indicated that fields 1-12, 14, 17-21, 26, 32 did not have soil pH of 6.0 or greater, as required by Condition l l.h and NCDA&CS recommended lime application to each field. Many of the fields have been land applied on since those results were available in violation of Condition I Lh. These fields shall not receive further residuals application if soil pH is below 6.0 unless the residual is lime stabilized product. 11. Condition 12: "The following public access restrictions apply to residual land application sites... b. Public access to non-public contact sites shall be restricted for 30 days after a residuals land application event." Land application had been conducted prior to the March 26, 2015 visit, however, no method of restricting public access was in place when WQROS staff arrived and proceeded onto the site. Entrance gates were open and unlocked and no signage was present identifying the site as active land application fields. The permitee shall lock gates when not onsite or conducting land Mr. Jason -B, Smith NOV-2015-PC-0482 April 28, 2015 Page 5 of 6 application activities and for 30 days following application,events. in accordance with, Condition . 12. 12. Condition 13: "Public access controls shall include the. posting of signs with a minimum area of 3' square feet (e.g., 1,5'x 2'). Each sign shall indicate the activities conducted at:each site, permit number, and name and contact information, including the Per or applicator's telephone number. Signs shall be posted in a clearly visible.and'conspicuous.manner at the entrance to each land application site during a land application event, and for as long. as the public access restrictions required under 111.12 apply;,' As noted in the first violation above, the Permittee failed to comply. with signage requirements at the time of inspection until a makeshift sign could set up at the site entrance (see attached photo). A permanent sign shall be installed at each site entrance prior to conducting further land application activities As a result of the violations in this Notice: this Office is considering recommendation for the assessment of a civil penalty. Failure to comply with conditions in a permit may result in a recommendation of enforcement action, to the Director of the Division of Water Resources who may .issue a civil .penalty assessment of not more that twenty-five thousand ($25,000) dollars against .any "person" who violates or fails to act in accordance with the terms, conditions, or requirements of a permit under authority of G.S. 143-215.6A. By copy of this Notice of Violation with Notice of intent to Enforce a civil penalty, .this Office is requesting that you contact Rick Bolich or me at (919) 791-4200 within ten (10) days following receipt of this letter, so that we may schedule a time to meet to discuss these matters. Your written response to Violations J through 12 above must be, provided at the time of the meeting; and will be reviewed and taken intoconsideration prior to the assessment of any civil penalty. incerel , Danny Smith, Regional Supervisor Raleigh Regional Office, Water Quality Regional Operations Section, Division of Water Resources Enclosures: Violation Reference Map Select Violation Photos ORC Designation Form cc: Edgecombe County Environmental Health Department Scott Carpenter — Soils Plus Troy Lewis - Town of Tarboro (PO Box 220, Tarboro, NC 27886) Tim Woody — CORPUD (PO Box 590, Raleigh, NC 27602) Mr. Jason B. Smith NOV-201[5-PC-0082 April 28, 2015 Page 6 of 6 Bryan Lewis — Town of Ahoskie (PO Box 767, Ahoskie, NC' 27910 Gene Reed — Town of Williamston (PO Box 506, Williamston, NC 27892) Charles Smithwick — Contentnea MSD (PO Box 477, Grifton, NC 28530) Benjamin Smith --Town of Stantonsburg (PO Box 10, Stantonsburg, NC 27883) Kathie Fields — Town of Pikeville (PO Box 9; Pikeville, NC 27863) Elizabeth Jenkins -- Town of Robersonville (114 S Main St, Robersonville, NC 27871) Troy Doby Non -Discharge Permitting Unit Ed Hardee Non -Discharge Permitting Unit WQROS RRO Filos WQROS Central Files Violations cover Buffer Pond!ng/Separation �} Buffer and cover Signage Buffer and separation ® Storage Buffers Buffered area Map provided by NCDENR Division of Water Resources Locations are approximations and :: are provided for reference only :: Violation Reference Map Granville Farms WQ0035595 Edgecombe County, NC As observered on: 3/26/15 & 4/15/15 ,X 4 Violations cover Buffer Pond!ng/Separation �} Buffer and cover Signage Buffer and separation ® Storage Buffers Buffered area Map provided by NCDENR Division of Water Resources Locations are approximations and :: are provided for reference only :: Violation Reference Map Granville Farms WQ0035595 Edgecombe County, NC As observered on: 3/26/15 & 4/15/15 T- _ ;7 Granville Farms WQ0035595 Select Violation Photos Observed 3/26/15 & 4/15/15 Figure 3; Onsite residuals storage on Field 20. Granville Farms WQ0035595 Select Violation Photos Observed 3/26/15 & 4/15/15 w.= Granville Farms WQ0035595 Select Violation Photos Observed 3/26/15 & 4/15/15