NCGNE1236_NOI Application_20170831

-t::>DUNCKLEE
& DUNHAM
August 31, 2017
Mr. William Vinson, Jr., P.E.
Chief, Program Operations
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
512 Salisbury Street
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Reference: No Exposure Certification
Southern States Cooperative, Incorporated
Farmville Agronomy Center
Farmville, Pitt County, North Carolina
Dear Mr. Vinson:
ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DUNCKLEEDUNHAM.COM
AtJG 31 2017
LAND QUALITY SECTIOi4
RECEIVED
AUG 31 2% d
DENR-LAND QUALITY
STORMWATER PERMITTING
Duncklee & Dunham, P.C. (Duncklee & Dunham), on behalf of Southern States Cooperative,
Incorporated (SSC) submits this No Exposure Certification (NEC) for SSC's Farmville Agronomy Center
in Farmville, Pitt County, North Carolina. SSC currently is a leasee on a portion of property owned by
Butterball, Inc. (Butterball). SSC is submitting the NEC pursuant to discussions with Thom Edgerton and
Bill Moore of the North Carolina Division of Energy, Minerals, and Land Resources (NC DEMLR),
Washington Regional Office (WaRO) during a site meeting on May 24, 2017, and subsequent meeting
between Duncklee & Dunham and Messrs. Edgerton, Moore and Samir Dumpor at the WaRO on August
28, 2017.
SSC intends to conduct the following activities at the site to achieve NEC. These measures are depicted
on the figure that is included in this submittal:
• construct a 25-foot vegetative filter on the north side of the ditch located on the southern border
of the property, between the ditch and the truck parking area, in order to create a better buffer,
promote dispersive sheet flow from this area and provide a degree of runoff treatment;
• fill in the existing drop inlet in the center of the gravel truck parking area on the west side of the
property;
• cap/plug the pipe that discharges from this inlet into the ditch;
• survey the gravel truck parking area, fill and grade the area accordingly with gravel or crusher run
to promote sheet flow of storm water runoff from this area over the grassy vegetative filter before
entering the ditch as sheet flow;
• construct free-standing roofs/covers over both the railcar and truck unloading areas on the
northern and western sides of the fertilizer storage building, next to the hopper and conveyor,
where bulk fertilizers are off-loaded into the building;
MAILING ADDRESS — POST OFFICE BOX 639 — CARY, NORTH CAROLINA 27512
NORTH CAROLINA BOARD OF EXAMINERS FOR ENGINEERS AND SURVEYORS LICENSE C-3559
NORTH CAROLINA BOARD FOR LICENSING OF GEOLOGISTS LICENSE C-261
NC DEQ REGISTERED ENVIRONMENTAL CONSULTANT NUMBER 00061

No Exposure Certification
SSC-Farmville Agronomy Center
Farmville North Carolina
August 31, 2017
Page 2 of 2
• pour concrete pads beneath the roof structures to make it easier to implement housekeeping
measures in these areas;
• construct an earthen diversion berm along the south side of the ditch located on the north side of
the property, adjacent to the rail spur, and grade this area to divert stormwater runoff flow away
from the ditch and toward the south;
• move the lime pile storage from its current location on the western side of the property to a
location closer to the fertilizer storage building, south of the earthen diversion berm described
above;
• construct a 50-foot vegetative (grassed) buffer along the east side of the ditch located on the
western side of the property. The buffer will extend to the south ditch line, and tie -into the 25-ft
buffer constructed along the southern ditch line;
• construct an earthen diversion berm on the south side of the stormwater drop inlet, east of the
former fertilizer storage warehouse (between the former warehouse and drop inlet) and grade this
area to divert stormwater runoff to the south and west, and eliminate future stormwater runoff
flow associated with SSC's activities into this drop inlet; and
• remove the equipment and fill the rail car unloading pit on the east side of the former fertilizer
storage building that is no longer in service.
Butterball has been apprised of the foregoing plans and agrees with the activities proposed by SSC for the
site to achieve NEC.
During our meeting with WaRO staff on August 28, 2017, we discussed the requirement to collect
stormwater samples as listed in NC DEMLR's August 10, 2017, letter. Based on our discussion, NC
DEMLR agreed to suspend this requirement pending further internal discussions within the Division.
Attached to this cover letter is a completed NEC package, including a site map depicting the
aforementioned measures that SSC will implement as part of the certification. If you have any questions
on this submittal, please contact us at [phone] or [e-mail].
Sincerely,
Duncklee & Dunham, P.C.
6ax_'o' "L_
Andrew M. Rodak, P.E.
Senior Engineer
Cc: WaRo/Thom Edgerton
John Madden, SSC
Suzanne Griffin, Butterball
Senior Peer Review:
Thomas S. Dunham, L.G.
Vice President
Attachments: NEC form
Site Maps
P:\Southern States\201783-Env. Srvs_Compl Assist_Oversight\Corresp\NCDEQ\Farmville\NEC Letter-1741 Ldocx.doc
DUNCKLEE & DUNHAM, P.C.

W,0_ P-10
Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
Division of Energy, Mineral and Land Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
FOR AGENCY USE ONLY
Date Received
Year
I MonthT
Day
Certificate of Coverage
NCGNE
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling, and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
Please look for information about re -certification under the No Exposure section on this page:
https://deg. nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-permits/stormwater-
Permits/npdes-industrial-sw
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Southern States Cooperative, Incorporated
Contact John Madden, VP, Risk Management & Insurance Services
Street Address P.O. Box 26234
City Richmond State VA ZIP Code 23260
Telephone No. 804 281-1581 Fax:
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NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name
SSC-Farmville Agronomy Center
Facility Contact
Ben Gawron
Street Address
3648 South Fields St
City
Farmville State
County
Pitt
Telephone No.
[phone] Fax:
3) Physical location information:
VA ZIP Code 27828
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). Site is located off of South Fields Street approximately Yz
mile north of the intersection of Alternate US-264 in Farmville NC.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes X No
5) Is this a Federal facility? ❑ Yes X No
6) Latitude 350 35' 35" Longitude 770 35' 57" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
X Existing Date operation began 1986
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? X Yes ❑ No
If yes, what is the NPDES Permit Number? N/A
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 7 5
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Facility is a retail establishment for fertilizers and other crop enhancement products Liquid and solid fertilizers
are stored in bulk, mixed and loaded into tanker trucks and spreaders for off -site application
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
X No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes � No ❑ N/A
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes � No ❑ N/A
c. Materials or products from past industrial activity
❑ Yes � No ❑ N/A
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes � No ❑ N/A
e. Materials or products during loading/unloading or transporting activities
❑ Yes � No ❑ N/A
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes � No ❑ N/A
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑ Yes � No ❑ N/A
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes � No ❑ N/A
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes � No ❑ N/A
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes � No ❑ N/A
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes ❑ No � N/A
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes � No ❑ N/A
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes � No ❑ N/A
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or Yes ❑ No ❑ N/A
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any Yes ❑ No ❑ N/A
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
� Yes ❑ No ❑ N/A
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NCGNE0000 No Exposure Certification
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals*?
d. Is secondary containment provided for hazardous substances** designated in 40
CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
� Yes ❑ No ❑ N/A
� Yes ❑ No ❑ N/A
� Yes ❑ No ❑ N/A
� Yes ❑ No ❑ N/A
❑ Yes � No ❑ N/A
❑ Yes � No ❑ N/A
❑ Yes � No ❑ N/A
*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
**Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes � No ❑ N/A
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NCGNE0000 No Exposure Certification
b. Does your facility have coal piles on site?
c. Does your facility store other fuel sources outside in piles, such as wood chips,
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g.,
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality
Permit? Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
❑ Yes � No ❑ N/A
❑ Yes � No ❑ N/A
❑ Yes � No ❑ N/A
❑ Yes ❑ No � N/A
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NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertification form at least once
each year, and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or MS4 operator where the discharge is into the local MS4, to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand I
must keep a copy of annual re -certifications on file at the facility.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: John T Madden
Title: Vice President, Risk Management & Insurance Services
8/31 /2017
(S *,— r"Al ature of Applicant) (Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDEQ Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no fee for a No Exposure Exclusion.
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
�l This completed application and all supporting documentation.
A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Program
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...
[phone]
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........
[phone]
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ENVIRONMENTAL GEOLOGISTS & ENGINEERS
Farmvllle, North Carolina
511 Keis ter Drive Suite 102 [phone]
Cary, North Carolina 27518 —Aunckleedunhanrcom
Drawn BY:
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Project Numb
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