NCGNE1236_Letter from SSC_20170808

Southern States Cooperative, Inc. w
6606 West Broad Street g
Richmond, Virginia 23230-1717 I v`
Mail Address: P.O. Box 26234
SOUTHERN Richmond, Virginia 23260-6234
STATES Telephone [phone] AUG 0 8 2017
Mr. Toby Vinson LAND QUALITY SECTIOiN
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
Dear Mr. Vinson:
Southern States Cooperative, Inc. (SSC) submits this letter in response to the April 10, 2017, NPDES
Stormwater Permit Requirement letter issued by the North Carolina Division of Energy, Mineral, and Land
Resources (NC DEMLR) regarding SSC's Farmville Agronomy Center in Farmville, Pitt County, North
Carolina. SSC is a lessee of a portion of the property, which is owned by Butterball, LLC. NC DEMLR
issued the letter following a site visit by staff from the Washington Regional Office on March 21, 2017.
The site visit was in response to an inquiry from Butterball to resolve questions regarding which areas of
the property are subject to stormwater permitting requirements under the NPDES program. In the letter,
NC DEMLR concluded that SSC's industrial activities are consistent with those described under the
Standard Industrial Classification (SIC) code associated with fertilizer mixing (2875), which makes the
property subject to NPDES stormwater permitting requirements pursuant to 40 CFR 122.26. Since
industrial activities conducted at the site are exposed to stormwater, SSC is required to either: 1) apply for
an Individual NPDES Stormwater Permit; or 2) make improvements to the site's industrial activities so the
activities are not exposed to stormwater and request an exclusion from NPDES permitting under a No
Exposure Certification (NEC). NC DEMLR imposed a 60-day deadline to complete either activity.
Mr. Jim Wright of SSC responded to the April 10 letter on May 2, 2017, with a request for an extension to
the 60-day deadline in order for SSC to: 1) identify, with NC DEMLR assistance, outfalls for potential
stormwater monitoring; 2) conduct the monitoring and obtain stormwater discharge analytical data for
inclusion in the NPDES permit application; and 3) discuss with NC DEMLR what site improvements need
to be made to qualify for a NEC. NC DEMLR, in a letter dated May 11, 2017, approved the request and
granted a compliance extension to July 31, 2017.
On May 24, 2017, SSC met with Thom Edgerton and Bill Moore of the NC DEMLR Stormwater NPDES
Permit Unit to: 1) walk the site; 2) identify areas of industrial activity that potentially impact stormwater;
3) identify outfalls that could be monitored; and 4) discuss site improvements that could be implemented
to prevent exposure of industrial activity to stormwater in order to qualify for a NEC. Based on the
observations made by SSC and NC DEMLR during that meeting, the consensus opinion is that a
NEC/permit exemption is a viable option, following implementation of the following measures:
• Ditch line on the southern border of the Butterball property, behind 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:
o construct a 25-foot vegetative filter that extends north from this ditch;

o fill in the existing drop inlet in the center of the gravel truck parking area;
o cap/plug the pipe that discharges from this inlet into the ditch; and
o have the truck parking area surveyed, 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.
• Bulk fertilizer building:
In order to prevent exposure of industrial activities to stormwater in the areas around this building:
o extend the roof over both the railcar and truck unloading areas on the northwestern corner
of the building, next to the hopper and conveyor; and
o pour a concrete pad beneath the roof extension to make it easier to implement housekeeping
measures in these areas.
Ditch along the rail spur on the northern border of the site:
Based on observations made by SSC and NC DEMLR during the May 24 site visit, this ditch does
not appear to be discharging off -site. There is evidence that there is standing water in the ditch
most of the year, and there is no clear outfall from this ditch. A stormwater drop inlet east of the
former fertilizer storage warehouse is currently not in use and may be connected to the ditch. To
eliminate future stormwater discharge from this drop inlet, SSC will cap the underground pipe
connected to this inlet that directs runoff from the portion of the site where the Butterball Mill is
located into the ditch. The former fertilizer building also has a rail car unloading pit that has not
been used for years. SSC will remove the equipment and fill the pit to remove the potential for
stormwater impacts.
Since SSC does not own the property, we have to request permission from Butterball before making the
proposed site modifications. While we would like to proceed with the facility improvements in order to
qualify for a NEC, we have been unable to meet with and obtain approval from Butterball in time to meet
the July 31 deadline. Therefore, we request an additional 30-day extension to August 31, 2017, to allow
time for discussions with Butterball.
We appreciate the cooperation of NC DEMLR in allowing us to work through this matter with the property
owner, comply with NPDES stormwater permit requirements, and achieve the best possible outcome for
all parties. If you have any questions, please feel free to call me at [phone] or e-mail me at
[e-mail].
Sincerely,
dv ��G
hn T. Madden
Vic President, Risk Management and Insurance Services
Cc: Washington Regional Office/ Thom Edgerton
Ben Gawron - SSC/Farmville
Lucas Householder - SSC
Suzanne Griffin - Butterball
Jayson Kilcoyne - Duncklee & Dunham