NCGNE1236_DEMLR Response RE No Exposure Disapproval_20170915

Energy, Mineral &
Land Resources
ENVIRONMENTAL OVALITY
September 15, 2017
Mr. John Madden
Southern States Cooperative
P.O. Box 26234
Richmond, Virginia 23260
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
Subject: NPDES No Exposure Application
Southern States Cooperative (SSC) -
Farmville Agronomy Center
Pitt County
Dear Mr. Madden:
On August 31, 2017, we received the application for a No Exposure Certification for
Southern States Cooperative's (SSC's) Farmville Agronomy Center, submitted on behalf
of the company by Duncklee & Dunham. The submittal letter outlined several
modifications to the site that SSC intends to implement to achieve No Exposure
Conditions. A No Exposure Certification approval would mean an NPDES stormwater
discharge permit is not necessary.
The DEMLR Stormwater Program cannot approve a No Exposure Certification (NCGNE)
until exposures of industrial activities have been eliminated. The company must
complete the proposed modifications and resubmit the NCGNE application within 90
days of receipt of this letter. Consideration of the No Exposure application will be
contingent upon stormwater sampling being completed as advised in DEMLR's letter
dated August 10, 2017. The Washington Regional Office will evaluate the site to
confirm that no exposure conditions are achieved and/or identify remaining concerns.
An exclusion from NPDES stormwater permitting based on No Exposure requires that
no industrial materials or activities are exposed to rainfall and subsequent runoff
discharge to surface waters. Be advised that any modifications intended to remove
stormwater discharges but not exposure of industrial materials or activities must
succeed in eliminating any potential point source discharge. Otherwise these areas
will be regulated areas that are subject to an NPDES stormwater discharge permit.
Nothing Compares---�-
State of North Carolina Environmental Quality Energy, Mineral and Land Resources
512 N. Salisbury Street 11612 Mail Service Center j Raleigh, North Carolina 27699-1612
919 707 9200

If you have any questions or need further information, please contact Bethany
Georgoulias at [phone] or via e-mail at bethanv.georgouliasOncdenr.gov.
Sincerely,
Original signed by Annette Lucas
Annette Lucas, P.E.
Supervisor, Stormwater Program
Division of Energy, Mineral, and Land
Resources
cc: Ben Gawron / SSC Farmville Agronomy Center / 3648 South Fields St / Farmville,
NC 27828
Andrew Rodak, P.E. / Duncklee & Dunham, P.C. / S11 Keisler Dr, Suite 102, Cary,
NC 27S18
Suzanne Griffin, Butterball
Washington Regional Office
Stormwater Program Files
Nothing Compares_-_�_
State of North Carolina Environmental Quality Energy, Mineral and Land Resources
512 N. Salisbury Street 11612 Mail Service Center j Raleigh, North Carolina 27699-1612
919 707 9200