NCGNE1236_Letter from SSC RE Status_20180109

DUNCKLEE ENVIRONMENTAL GEOLOGISTS & ENGINEERS
511 KEISLER DRIVE - SUITE 102
& DUNHAM CARY, NORTH CAROLINA 27518
OFFICE: [phone]
W W W.DUNCKLEEDUNHAM.COM
VIA EMAIL TO: toby.vinson(a ncdenr.gov
December 14, 2017
Mr. Toby Vinson
Chief, Program Operations
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Reference: No Exposure Certification
Southern States Cooperative, Inc.
Farmville Agronomy Center
Farmville, Pitt County, North Carolina
Dear Mr. Vinson:
Duncklee & Dunham, on behalf of Southern States Cooperative (SSC), submits this letter to NC DEMLR
to provide a status update on the implementation of site improvements conducted to achieve stormwater
No Exposure Certification (NEC) at their Farmville Agronomy Center in Farmville, Pitt County, North
Carolina. SSC is a lessee of a portion of the property that is owned by Butterball. SSC submitted a NEC
application to NC DEMLR on A ugust 31, 20 17, which included an outline of specific construction
activities proposed for the site to prevent exposure of industrial activities to stormwater and eliminate
concentrated (point -source) stormwater runoff. In a response letter to SSC dated September 15, 2017,
NCDEMLR wrote that an NEC could not be considered until after completion of the proposed site
improvements, and imposed a deadline date of December 15, 2017 for completion of the work.
SSC commenced site improvement work in October. Essentially, the majority of the construction
activities have been completed at the site; specifically, all grading work has been completed and most site
stabilization activities have been completed (e.g., trees have been planted on the earthen berms
constructed on the northern and westerns portions of the property). Groundcover has been established in
the buffer area along the southern property line. SSC attempted to establish groundcover in the western
buffer area, but due to the time of year and soil conditions in this area, it was unsuccessful. In the spring,
they will re -attempt establishment of groundcover. Additionally, SSC removed the equipment on the
eastern side of the former fertilizer storage building that is no longer in service.
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
December 14, 2017
Page 2 of 2
Activities that have not been completed yet are: 1) construction of free-standing roofs/covers over both
the railcar and truck -unloading areas on the northern and western sides of the fertilizer storage building;
and 2) concrete pad construction beneath the roof structures. Construction activities on the roof and
concrete pad structures have not commenced due to a delay in acquisition of building permits from the
Town of Farmville. SSC submitted the permit application for this work in mid -November, and expected
a 1-2 day turnaround, based on conversations with the Town Planning Department. As of the date of this
letter, the permits have not been issued; permit issuance is anticipated within the next week. Work on
these structures will commence as soon as possible following permit acquisition.
Based on the delay in permit acquisition required for the roof construction, SSC will be unable to
complete all of the site improvements by the December 15 deadline, and hereby requests a 45-day
extension to January 31, 2018 to allow more time for completion of these activities, taking into account
the holidays and potential weather delays.
We appreciate the cooperation of NC DEMLR in allowing SSC additional time to complete the site
modifications for consideration of No Exposure Certification. If you have any questions, please contact
us at [phone] or at andygdunckleedunham.com.
Sincerely,
Duncklee & Dunham, P.C.
62.-4,117Z_
Andrew M. Rodak, P.E.
Senior Engineer
Senior Peer Review:
�' d A4 1
Richard A. Kolb, L.G.
Senior Geologist
Cc: WaRo/Thom Edgerton
John Madden, SSC
Suzanne Griffin, Butterball
Lankford Ruffin, Butterball
P:\Southern States\Farmville NC Feed Mill - 32600\Reports-Corr\NEC Status Letter-17613.doe
DUNCKLEE & DUNHAM, P.C.

Georgoulias, Bethany
From: Andy Rodak <[e-mail]>
Sent: Tuesday, January 09, 2018 11:46 AM
To: Georgoulias, Bethany
Subject: [External] FW: NEC Status Letter, Southern States Cooperative Farmville Agronomy
Center, Farmville, Pitt County, NC, Proj No. 32600
Attachments: NEC Status Letter-17613 ECOPY.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Copy of e-mail sent to Toby.
Regards,
Andrew M. Rodak, P.E.
Senior Engineer/Director of Engineering
511 Keisler Drive
Suite 102
Cary, North Carolina 27518
Office: [phone] ext. 118
Mobile: [phone] (m)
andy&dunckleedunham.com
www.dunckleedunham.com
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INV1RONMENTAL GEOLOGISTS d ENGINElxS
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