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Home My WebLink AboutNCS000594_Review Document_20181129Last updated 11129118 NC Division of Energy, Mineral and Land Resources Review of Permit Application— NCS000594 SePRO Research & Technology Campus - Whitakers SIC 2879 — Pesticides and Agricultural Chemicals. Facility is a 410 acre site whose main focus is herbicide and algaecide manufacturing along with scientific studies and lab assays. Facility has land area used for laboratory activities, manufacturing and packaging of chemicals, research pond system for testing chemicals and row crop production. Backgound — SePro Corporation researches, develops, manufactures and packages a variety of aquatic, agricultural, turf and ornamental herbicides and other chemicals. This facility has a lab area on the eastern portion of the site where they do the development and testing of specialty chemical products. Near the lab there are also areas where plants are grown in greenhouses and open containers for testing. This area also has open containers where developed chemicals are tested on plants and water areas. The eastern part of the site also includes a large pond system in a grid network where plants are grown and developed products are tested. The pond system is interconnected with pipes and they can adjust water level within the pond system, etc. Facility says the ponds are lined and don't discharge? The facility was utilizing the lower ponds in the grid to dump water produced in the laboratory process from time to time. Water was allowed to set in the ponds for treatment. In 2015/2016 there were issues at the location due to this unpermitted treatment system and DWR issued NOVs and took enforcement actions. This led to a settlement agreement that required the facility to obtain coverage under the stormwater permit. The facility now collects the lab wastewater and periodically pumps and hauls to Rock Mount. The western portion of the site has a manufacturing/blending and packaging building were the chemicals are produced and packaged for shipment. The area includes outside tanks with secondary containment for storage of chemicals. The western area also has a maintenance shop/ warehouse area where bulk chemicals are stored along with some biproducts and wash water. Some storage is under roof but with open walls for totes that contain wash water. This building also handles regular maintenance of farm equipment and has outside storage of equipment, laydown area, used oil in containment area, etc. (DWR inspection reports that are included in the LF files include a detailed description of the facility activities) Monitoring — The facility provided data for one sampling event as part of their Form 2F submittal for general parameters in the form (0&G, BOD, COD, TSS TN, TP, pH). Also provided data for Total Cu. None of the monitoring results were at levels about the benchmark values. Monitoring conducted by DWR during the 205/2016 investigation showed potential issues with metals values and their investigation has also lead to other potential pollutants of concern. Working with DWR DEMLR has established monitoring requirements in the permit that will allow us to collect data that will help characterize the potential impacts from this facility and the chemicals and processes that they have ongoing at the facility. Parameters that are included in monitoring requirements — ammonia nitrogen, TKN, nitrate/nitrite nitrogen, Cl, TSS, Al, Ar, Cd, Ca, Cu, Pb, Mn, Mg, Ni, TP, K, Na, Zn, hardness and pH. At a site visit on October 23, 2018 staff pointed out monitoring locations for the facility rep onsite (Ben Willis). There are four outfalls and one in -ditch location that staff requested monitoring for. The first two outfalls (001 and 002) are on the west side of the property near the shop area. Outfall 003 is along the access road leading to the laboratory area where the lab area drains back into a conveyance. Outfall 004 is the discharge point from the riser below the pond system. The in -ditch location is below the last outfall from the pond system and will help assess the overall impacts from the facility for DEMLR and DWR. There may be some groundwater issues that these results could help to assess. The monitoring locations are roughly shown in the aerial views in this document along with notes on location of activities and potential pollutant sources from the site visit. Two parameters did not have benchmarks established. Worked with Chris Ventaloro in DWR on benchmarks for Potassium and Calcium. For Potasium he looked at the FAV from EPA information and % FAV is 17.14 mg/L. For Calcium he reviewed information in ECOTOX and found a number of old studies but could not find the references. Found a good reference from 1997 study. Using ceriodaphnia they developed an LC50 of 1,830. For benchmark we would use %: LC50 of 915 mg/L. • Facility drains to UT to Fishing Creek [28-79-(29)] in the Tar -Pamlico River Basin, a class C; NSW stream. 2016 Assessment Report shows no impairment of concern for this facility in this area. Last updated 11129118 • NC National Heritage review — NHP report shows no aquatic resources in the project area. In the one mile radius around the facility there are a few species noted, but there is insufficient information to establish the viability and accuracy of data is not high. No Federally listed species. • RRO — Site visit was conducted on October 23, 2018. Bradley Bennett, Thad Valentine and Danny Smith participated in the visit and onsite rep was Ben Willis. After a brief overview discussion staff reviewed the outdoor areas of the site but did not tour any of the indoor activities. Site was found to be generally clean and well maintained. There were some secondary containment structures that did not have locked valves. One containment area had oil stored in open buckets and staff noted the need for different handling of used oil. There were empty totes stored onsite and a dumpster behind the maintenance/warehouse building that looked to have more than just office type trash. The laboratory area had very little outside material, but there were open containers adjacent to the lab that contain the chemicals being tested or materials that have been used and are now being held for sunlight treatment prior to being used for irrigation in the greenhouse. These materials could overflow during rain events. During the site visit the water level of the pond system was observed to be very low. The facility had indicated there was no discharge from the ponds and that the ponds were lined. It does not appear that there is the potential for evapotranspiration that would account for the low water level. Onsite staff offered that there were muskrats that bored holes that could explain some loss of volume? Need to continue to evaluate this process to determine where the water volume is going. Could create groundwater issues. Hopefully the monitoring requested and supplemental monitoring by DWR can assess any impact. DWR requested one monitoring timeframe in winter months. This has been addressed in the draft permit with 1st monitoring Dec -March. Areal Views with Notes and proposed outfalls from site visit: Tanks w/TEA (Triethanolamine). Secondary Western Portion of Site containment but valve not locked Tote storage- indicated that all where new totes waiting to be filled -------------------------------------------------- Under roof storage for totes containing wash water to be disposed and drums holding chemicals ------------------------------------------------ Juel and used all. Valves to containment were open, no locks, oil in open buckets. Last updated 11129118 Eastern Portion of Water from tests stored in open containers treated by sunlight until water is okay to be used for irrigation in greenhouse. • Outfall 003 — drains back from Lab area and discharges into conveyance ditch ponds on this side were very low. along road. Unsure whether there was some • Outfall 004 — discharge from riser leaking or infiltration ' • Outfall 005 — general location for in -ditch monitoring below riser outfall__________________________________________________