WQ0035595_NOV-2019-PC-0223_20190329

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary 0
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
April 3,2019
CERTIFIED MAIL 7016 3560 0000 4428 5171
RETURN RECEIPT REQUESTED
Jason Smith, Vice President
Granville Farms, Inc.
PO Box 1396
Oxford,NC 27565-1396
Subject: Compliance Evaluation inspection-Notice of Violation
NOV-2019-PC-0223
GFI RLAP
Land Application of Class B Residuals
Permit Numbers W0000838&W00035595
Granville&Edgecombe Counties
Mr. Smith,
On March 26, 2019, Rick Trone and Gary Kreiser of the Raleigh Regional Office of the Division of
Water Resources conducted a compliance evaluation inspection for permits W00000838 and
W00035595 at Granville Farms.The purpose of this inspection was to ensure compliance with the
subject permits. On the day of the inspection,GFI was not land applying residuals on any fields due to
heavy rains the night prior. During the inspection,your cooperation was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of Operation and Maintenance Plans;
• Review of the 2018 Residuals Annual Summary Reports and;
• On-site inspection of application fields
The current permits were issued in October 2016 and expire on September 30,2021.
Under permit WQ0000838,Granville Farms land applied 2,211.92 dry tons of residuals on 1,023.16
permitted acres in 2018.That year,65 fields were utilized out of 203 permitted. Residuals were sourced
from 47 sources out of 56 permitted. Dry tons applied from each source were below permit limits.
North Carolina Department of Environmental Quality I Division of Water Resources
_ Raleigh Regional Office 1 3800 Barrett Drive I Raleigh.North Carolina 27609
�� /'� 919.791.4200

Mr.Jason Smith
Granville Farms Inc.
Page 2 of 3
3/29/19
Residuals monitoring and TCLP were conducted in accordance with the current permit and were analyzed
by multiple labs(i.e., Meritech, Environment 1, Waypoint Analytical).
Field summary forms were reviewed and indicated loadings less than permitted amounts. Pathogen and
Vector Attraction Reduction forms were reviewed and indicated compliance with the permit for residuals.
Most sources met PARNAR through fecal demonstration and 30-day bench tests.A few exceptions were
Willowbrook WWTP(Lime-Stabilized),Neuse River WWTP(38%reduction) and SGWSA(SOUR test).
Soil analyses were submitted for all fields that received application of residuals. Soil analyses were
conducted by Waypoint Analytical. Soil pH was below 6 s.u. on 49 of 65 fields utilized and lime was
recommended for those fields. Field summary forms indicate lime applied where recommended.
Under permit WQ0035595 in 2018 Granville Farms land applied 884.76 dry tons of residuals on 22 fields
out of a permitted 32 fields.Residuals from 31 source facilities were applied on a total of 286.42 acres.
Residuals monitoring and TCLP were conducted in accordance with the current permit and were analyzed
by multiple labs(i.e, Meritech,Environment 1, Waypoint Analytical).
Field summary forms were reviewed and indicated loadings less than permitted amounts. Pathogen and
Vector Attraction Reduction forms were reviewed and indicated compliance with the permit for residuals.
Sources met PARNAR through fecal demonstration and 30-day bench tests.
Soil analyses were submitted for all fields that received application of residuals. Soil analyses were
conducted by Waypoint Analytical. Soil pH was below 6 s.u. on 18 fields and lime was recommended for
those fields.Field summary forms indicate lime applied where recommended.
During drive-arounds of fields permitted under WQ0035595 on March 25, Granville Farms was actively
land applying residuals to field JBS-17. While the application operation appeared to be compliant, 5
storage tanks were observed to be located on the northern end of field JBS-15. Mr. Smith explained these
tanks were for the"day storage"of residuals so that trucks could unload on site and return.Land
application equipment could then load from the tanks until empty.Mr. Smith further explained any
residuals offloaded in this manner would not remain stored on site, all residuals would be land applied the
same day. Class B residuals should not be stored at any land application site.
The following permit condition violations were noted during the March 26,2019 compliance
inspection and records review:
11.Performance Standards (WO0000838.&WO0035595)
Condition 3,which states that,"Only those Class B residuals generated by the facilities listed in
Attachment A are approved for land application in accordance with this permit."Granville Farms is
currently accepting residuals from Birchwood RV Park(Permit NC0042803). Birchwood RV Park is not
a permitted residual source for Granville Farms. Mr. Smith explained that Granville Farms is contracted
by facilities to move residuals between permitted facilities. Granville Farms indicates residuals from

Mr.Jason Smith
Granville Farms Inc.
Page 3 of 3
3/29/19
Birchwood RV Park were not land applied in 2018. Please explain in your response the disposition of
residuals from facilities such as Birchwood RV Park and any other facilities not listed as approved
residual sources.If Granville Farms is storing waste at other permitted residuals sources for land
application, this waste must be listed as a source in the storage facility's permit.
Please explain how Granville Farms is ensuring this requirement is being met when you are storing
waste at other facilities.
M.Ooemtion and Maintenance Requirements(WO0035595)
Condition 8.which states that, "Class B residuals listed in the most recently approved Attachment A of
this permit shall not be stored at any land application site,unless written approval has been requested and
received from the Division" 5 storage tanks were observed to be located on the northern end of field JBS-
15. Mr. Smith explained these tanks were for the"day storage"of residuals so that trucks could unload on
site and return. Land application equipment could then load from the tanks until empty. Mr. Smith further
explained any residuals offloaded in this manner would not remain stored on site, all residuals would be
land applied the same day. Class B residuals should not be stored at any land application site.
Please explain how these on-site waste storage tanks are utilized,how long waste is stored in them,
and how Granville Farms is ensuring permit compliance during residuals applications for each
source stored in these waste storage tanks.
This office requests that you respond to this letter in writing within 30 days of receipt.
Your response should be sent to this office at the letterhead address. Your response should
address the following items as noted above. Please include in your response all corrective actions
already taken and a schedule for completion of any corrective actions not addressed.
If you have any questions about this inspection or this letter, please contact Rick Trone at
[e-mail] or 919-791-4257.
Since ely,
ck Bolich L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files