NCGNE1236_Letter from SSC_20170512

Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Va. 23230-1717
Mail Address: P.O.Box 26234
Richmond, Va 23260-6234
Telephone [phone]
SOUTHERN
May 2, 2017
STATES
Mr. Toby Vinson via e-mail, then U.S. Mail
Chief, Program Operations
Division of Energy, Mineral and Land Resources
512 N. Salisbury Street
Raleigh, NC 27699-1612
Re: Southern States Cooperative, Inc. (SSC)
Farmville Agronomy Center
Pitt County, Farmville, NC
Dear Mr. Vinson,
MAY 12 2017
!..AND QUALITY SECTION
Southern States received your April 10, 2017 letter on April 24, 2017. The letter
contained the NC DEQ's request that the referenced facility obtain an Individual
NPDES storm water permit. That request was based on the DEQ's determination that
the Standard Industrial Classification (SIC) code for the facility should be 2875 and
not 5191. SSC disagrees with that determination, but is willing to acquiesce to the
DEQ's request in this instance. The letter also instructed SSC to submit a permit
application within 60 days. SSC is concerned it will take longer than 60 days to
the following reasons: �•�
1. The location(s) of the Outfall(s) has not been established. ST�OF,y j�
'Q4
2. Storm water samples must be collected from the Outfall(s) during aFNOQ
measurable/qualifying storm event.
3. Analytical data obtained from the storm water samples must be included in the G'
permit application on EPA Form 3510-21'.
SSC will work as expeditiously as possible to meet the 60 day deadline. However, we
may request an extension if it becomes apparent that the deadline cannot be met.
Additionally, SSC requests a site meeting with representatives of the NC DEQ to;
• identify the location of the Outfall(s) and
• discuss what site improvements need to be done in order to obtain certification that
there is NO EXPOSURE of contaminates to storm water. If NO EXPOSURE is
not achievable, the improvements (or some variation thereof) can potentially be
included in the Storm Water Pollution Prevention Plan (SWP3).

Southern States Cooperative, Inc.
6606 West Broad Street
Richmond, Va. 23230-1717
Mail Address: P.O.Box 26234
Richmond, Va 23260-6234
Telephone [phone]
Please have someone on ;your staff call or e-mail me ([phone])
SOUTHERN (Jim. Wright(d�sscoop.com) to schedule the meeting.
STATES
In the meantime, please feel free to call me if you have any questions.
Sincerely,
le
L�l
Jim Wright, PE
Director of Environmental & Regulatory Compliance
Cc: Washington Regional Office / T. Edgerton (via e-mail only)
Ben Gawron — SSC/Farmville Ag (via e-mail only)
Lucas Householder — SSC (via e-mail only)