WQ0017321_Compliance Evaluation Inspection_20181203

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LINDA CULPEPPER
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December 3, 2018
Mr. Daniel Imoudu, Refinery Superintendent via Email
Cargill Incorporated
5000 South Boulevard
Charlotte, North Carolina 28217
Subject: Non -Discharge Permit Inspection
Cargill, Inc. - Permit No.: WQ0017321
Distribution for Processing of
Residual Solids (503 Exempt) System
Mecklenburg County
Dear Mr. Imoudu:
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on November 201"
2018, for the referenced Non -Discharge Distribution permit. The MRO would like to thank you and your
staff for your time during the site visit.
Issues noted during the 2017 inspection appear to have been addressed. Cargill researched and
emplaced use of a new flocculant, added a couple of "u" turns in the plumbing to increase contact
residence time and replaced the belt -press belt. The belt press was not in operation during the site visit,
but the area appeared clean and well maintained.
This inspection was conducted in conjunction with the permit renewal. The option to rescind this
permit was discussed; however, per your November 3011, 2018 email, Cargill management wishes
to retain the permit and proceed with the renewal. Specific questions related to permit renewal
should be directed to Troy. DobV(@_ncdenr.gov, with our Central Office permitting staff in Raleigh.
If you have any questions, comments, or need assistance with understanding any aspect of your permit
or the attached inspection report, please do not hesitate to contact Maria Schutte at [phone] or
maria.schutte(a-)ncdenr.gov.
Sincerely, DocuSigned by:
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Andrew H. I n�i�'I�A2Daaaa...
Assistant Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

Enclosure(s): Inspection Report November 2018
CC: Michael Mattingly, Facility Leader (Email)
Troy Doby, DWR CO -Raleigh (Email)

State of North Carolina Department of Environmental Quality
Division of Water Resources
Roy Cooper, Governor
Michael S. Regan, Secretary
Linda Culpepper, Director
NON -DISCHARGE COMPLIANCE INSPECTION
GENERAL INFORMATION
Owner: Cargill Incorporated County: Mecklenburg
Permit #: WQ0017321 (Non-503) Facility Name/Location: Cargill Inc., 5000 South Blvd., Charlotte
Issuance Date: 07/25/2013 Expiration Date: 02/28/2019
Permittee: Michael Mattingly, Facility Leader Phone: [phone] email: Michael _MattinglykCar ilg l.com
Facility Contact: EHS Manager (Vacant) Phone: To be determined Email: To be determined
Additional Contact: Daniel Imoudu, Refinery_ Superintendent Phone: [phone] Cell: 321-394-6075
Email: Daniel _Imoudu&Car ilg l.com
Reason for Inspection
X ROUTINE
Type of Inspection
Collection System
COMPLAINT FOLLOW-UP OTHER
Spray Irrigation X Sludge
Inspection Date(s): November 20, 2018
Inspection Summary: (additional comments may be included on attached pales)
Other
This inspection included a records review and tour of the WWTP residuals processing and storage areas.
Residuals are hauled for processing at the Wallace Farms Composting facility in Mecklenburg County. The
Waste Management group has replaced Republic Services as the hauling contractor. This facility is permitted
under the Charlotte Water pretreatment program IUP#0642.
Please note the following:
Continue with renewal process or request permit rescission as discussed on -site and noted in the
cover letter.
• The MRO should be informed of any changes to the contact information noted above.
Is a follow-up inspection necessary yes X no?
Inspector Name/Title: Maria Schutte, Environmental Specialist I; Edward Watson, Hydrogeologist
Telephone No.: 704-663-1699 Fax No. 704-663-6040
Date of Inspection: 11/20/2018

Residuals Inspection
Permit #WQ0017321 Cargill Incorporated — Mecklenburg County
pg. 2
Type of Residual
Land Application (class B — Non-503 Residuals)
Record Keeping
Y-yes N-no NE -not evaluated NA -not applicable
X Distribution for Processing (503 Exempt)
Y Copy of current permit available at residual generating site
NA Current metals and nutrient analysis (see permit for frequency)
NA TCLP analysis, NA SSFA (Standard Soil Fertility Analysis)
NA Nutrient and metals loading calculations (to determine most limiting parameter) YTD
Y Hauling records (# gal and/or ton hauled during calendar year to date)
NA Field loading records, NA Field site maps and information
NA Records of lime purchased
NA Pathogen & Vector Attraction Reduction
Comments: The residuals hauling records and receipts for composting at Wallace Farms appeared adequate at
the time of inspection. Waste Management has replaced Republic Services as the hauling contractor. There
are currently no analytical requirements under this permit.
Pathogen & Vector Attraction Reduction Records Not Applicable
Comments: Pathogen and Vector Attraction Reduction is not required as this is a 503 Exempt, industrial
process only, and they are not land applying or distributing the material.
Treatment
X Aerobic digestion Autothermal Thermophilic Aerobic Digestion
Anaerobic digestion Drying beds (may not meet 503's)
Alkaline Stabilization Lime X Other -describe (Dewater via belt filter press)
Comments: Cake residuals are placed in roll -off units and hauled by Waste Management to Wallace Farms,
Mecklenburg CounU for composting. Dewatering of residuals via belt press was inactive at the time of
inspection. Mr. Imoudu noted several improvements/repairs to address dewatering concerns noted in the 2017
report, including a change to the flocculant, slight Mplumbing to increase contact time, a new belt for the press
and pump repairs for the floor drain. Odors and vectors were not detected at the residuals processina areas
and odors (primarily from their food oils manufacturing) were minimal throughout the plant.
Transport No residuals hauling was taking place during this inspection.
Spill control plan in transport vehicle? NA
Does transport vehicle appear to be maintained? NA
Storage
Number of days/weeks/months of storage: NA — Per previous inspections, this facility stores residuals in a 30
cu. vd. roll -off which is removed from site within 24 hrs.
Describe storage: Per previous inspection reports, sludge residuals are moved to a thickening tank only as
wasting from the WWTP is required (�nproximately every 10 to 12 weeks). Residuals are dewatered via belt

Residuals Inspection
Permit #WQ0017321 Cargill Incorporated — Mecklenburg County
pg. 3
alter press and the resulting cake loaded directly in a roll -off unit, as noted above. The loading area is
adiacent to the dewatering building and under roof. No residuals dewatering, or loading was taking place at
time of inspection. A couple of plumbing "u " turns were installed after flocculant addition to increase contact
time/improve thickening; and, a new belt was recently installed on the press. The dewatering building
appeared clean and well maintained at the time of inspection.
Odors present N Vectors present N
Sampling
Describe Sampling: This permit currently does not have analytical requirements.
Is sampling adequate? NA Is sampling representative? NA
Field Sites (end use for class B biosolids)
Not applicable under the current permit. Roll -off delivery and hauling is now contracted with the Waste
Management company.
Monitoring well(s) Y/N: N
If yes, location of well(s):
Comment: This permit currently does not require groundwater monitoring_
Other noted conditions
Per previous inspection report, cleaning and disposal of grit/sludge from the 4 on -site retention basins is
handled by HEPCO.
Correspondence associated with this permit should be directed to Daniel Imoudu, until the new EHS contact is
named.