NCG060374_COMPLETE FILE - HISTORICAL_20180716

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NUH I H UAHULiNA
Department of Environmental Qual

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
IV U& Ob O 3-7L/
DOC TYPE
HISTORICAL FILE
0 MONITORING REPORTS
DOC DATE
❑ ) g v -2 /1"
YYYYMMDD

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. yZ REGION 4
a a ATLANTA FEDERAL CENTER
o= 61 FORSYTH STREET
�F�TgL VROSkG~` ATLANTA, GEORGIA 30303-8960
Jul. 0 9 2018
CERTIIaIED MAIL 7017 1450 0000 7973 3349
RETURN RECEIPT „REQUESTED
Mr. Bobby Frye
President RECEI' /ED
Mount Olive Pickle Company, Inc.
One Cucumber Boulevard jut
Mount Olive, North Carolina 28365 Cr
Re: Administrative Order No. CWA 04-2017-4752
Mount Olive Pickle Company, Inc. - North Carolina
Dear Mr. Bobby Frye:
The purpose of this letter is to inform you that Mount Olive Pickle Company, Inc. has satisfied tale
requirements of the above referenced Administrative Order on Consent (AOC). By copy of this letter,
the AOC has been terminated. Please continue to work with the North Carolina Department of
Environmental Quality on all current and future construction projects.
Termination of the AOC shall not be deemed an election by the EPA to forego any administrative, civil
or criminal action or other appropriate relief under the Clean Water Act, nor will it relieve the company
of obligations to comply with any other applicable federal, state or local law.
Thank you for your cooperation in this matter. If you have any questions or problems, please contact
Lieutenant Commander Tara Levine I-Iouda at [e-mail].
Sincerely,
4.1eancanne M. Gettle, Director
Water Protection Division
cc: Ms, Annette Lucas RECEIVED
North Carolina Department of Environmental Quality
CENR-t.A ID QUALITY
STORhAVATER PERMITTING
Internet Address (URL) • http://www.epa.gov
RecycledlRecyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Posmonsumer)

Division of Energy, Mineral, and Land Resources
Land Quality Section / Stormwater Program
National Pollutant Discharge Elimination System (NPDES)
Energy. Mineral & PERMIT OWNER AFFILIATION DESIGNATION FORM
Land Resources
ENVIRONMENTAL QUALITY (Individual Legally Responsible for Permit)
Use this form if there has been:
FOR AGENCY USE ONLY
We Recci ed
Year Momb
Day
NO CHANGE in facility ownership or facility name, but the individual
who is legally responsible for the permit has changed.
If the name of the facility has changed, or if the ownership of the facility has changed,
do NOT use this form. Instead, you must fill out a Name -Ownership Change Form
and submit the completed form with all required documentation.
What does "legally responsible individual" mean?
The person is either:
• the responsible corporate officer (for a corporation); NOV7 '3r 11 j l
• the principle executive officer or ranking elected official (for a municipality, state, federal or other public
agency); 1
• the general partner or proprietor (for a partnership or sole proprietorship);
• or, the duly authorized representative of one of the above.
1) Enter the permit number for which this change in Legally Responsible Individual ("Owner Affiliation")
applies:
Individual Permit (or) Certificate of Coverage
N I c j s N c b 61013 '7y
1) Facility Information:
Facility name: lVe-. d /t yr /"; "-L/ C�
Company/Owner Organization:
Facility address: (,;„ Z :,C C2IV -
n Address
//
Cite State Zip
To find the current legally responsible person associated with your permit, go to this website:
http:/Idea.ne.gov/about/divisions/energw-mineral-land-resources/eneri2�y-mineral-land-permits/stormwater-program
and run the Permit Contact Summary Report.
3) OLD OWNER AFFILIATION that should be removed:
Previous legally responsible individual: 10,. T 0«&V1
First MI bast
4) NEW OWNER AFFILIATION (legally responsible for the permit):
Person legally responsible for this permit: e,,,�, �. _ e,rs, f/( //_
First MI last
Page I of 2
5WU-0WNIiRA1T11 23March2017

NPDES Stormwater Permit OWNER AFFILATION DESIGNATION Form
(if no Facility Name/Ownership Change)
1_ �
Tille i
Mailing Address
Dvn'� Q�Ve NL'
City State Zip
(1 i } e-S t 2S-3 S Cx t 322k
Telephone E-mail Address
Fax Number
5) Reason for this change:
A result of: Employee or management change
Inappropriate or incorrect designation before
❑ Other
If other please explain:
The certification below must be completed and signed by the permit holder.
PERMITTEE CERTIFICATION:
I, �LLTsUA &LT -a , attest that this application for this change in Owner Affiliation
(person legally responsible for the permit) has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this form are not completed, this change may not be
processed.
1. L___� " (jP-00
Signature I I Date
PLEASE SEND THE COMPLETED FORM TO:
Division of Energy, Mineral, and Land Resources
Stormwater Program
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
For more information or staff contacts, please call [phone] or visit the website at:
http://deq.nc gov/about/divisions/energy-mineral-land-resources/stormwater
Page 2 of 2
SWU-OWNERAFF11 23Mar2017

Compliance Inspection Report
Permit: NCGO60374 Effective: 10114/16 Expiration: 10/31/17 Owner : Mount Olive Pickle Company
SOC: Effective: Expiration: Facility: Mount Olive Pickle Company
County: Wayne 1 Cucumber Blvd
Region,. Washington
Mount Olive NC 28365
Contact Person: Fletcher Arritt Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09/13/2016
Primary Inspector: Thom Edgerton
Secondary Inspector(s):
Certification:
Phone:
EntryTime: 10:00AM Exit Time: 12:30PM
Phone: [phone]
Reason for Inspection: Other Inspection Type: Technical Assistance
Permit Inspection Type: FoodlTobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

Permit: NCGO60374 Owner Facility: Mount Olive Pickle Company
Inspection Date: 09/13/2016 Inspection Type : Technical Assistance Reason for Visit: Other
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage availabte at the site? ❑ ❑ 0 ❑
# Were all outfalls observed during the inspection? E ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Olvislon? ® ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment: This was a follow-up inspection, requested by the facility, to make the final_ determination of
SDO's to be monitoredlre resentative of the operation. The dischar es noted by EPA earlier
this Year were narrowed to 3 SDO's.
Outfall 001 - La down Area West Corner +35.12.17-78.03.33
Outfall 002 - Front Drive Loadin Docks Area +35A2.15-78.03.33
Outfall 003 - Southern Corner Alum Vinegar Unloading +35.12.12,-78_03.38
Page: 3

UNITED STATES ENVIRONMENTAL. PROTECTION AGENCY
�- 'Z REGION 4
A 0 ATLANTA FEDERAL CENTER
x� o� 61 FORSYTH STREET
�4T4t PR OTEC�\ ATLANTA, GEORGIA 30303-8960
CERTIFIED MAIL 7007 2680 0000 3272 1870
RETURN RECEIPT REQUESTED
Mr. Bobby Frye
President
Mount Olive Pickle Company
One Cucumber Boulevard
Mount Olive, North Carolina 28365
Re: Consent Agreement and Final Order
Docket No. CWA-04-2017-4500(b)
Mount Olive Pickle Company
Dear Mr. Frye:
MAR 2017
RECEIVED
,ERR 0 5 2017
DENR-LAND QUALITY
SMRMWATER PERMITTING
Enclosed please find a fully executed copy of the Consent Agreement and Final Order that has been
finalized by the U.S. Envirom-rental Protection Agency and the Regional Administrator. Please make
note of the provisions under Paragraph IV. Payment.
Should you have any questions or concerns regarding this matter, please contact LCDR Tara L. Houda at
[phone].
Sincerely,
SVl�alker
Director
Water Protection Division
Enclosure
cc: Mr. Bradley Bennett, Stormwater Permitting Program Supervisor
North Carolina Department of Environmental Quality
Ms. Amy P. Wang
Ward and Smith, P.A.
Internet Address (URL) • http://www.epa.gov
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: )
}
MOUNT OLIVE PICKLE COMPANY, INC)
MOUNT OLIVE, WAYNE COUNTY, }
NORTH CAROLINA }
}
RESPONDENT. }
-
w
C�
CONSENT AGREEMENT AND
FINAL ORDER
DOCKET NO. CWA-04-2017-4500(b)
CONSENT AGREEMENT
I. Statutory Authority
l . This is a civil penalty proceeding pursuant to Section 309(g)(2)(B) of the Clean
Water Act ("CWA"), 33 U.S.C. § 1319(g)(2)(B), and the Consolidated Rules of Practice
Governing the Administrative Assessment of Civil Penalties, Issuance of Compliance or
Corrective Action Orders and the Revocation, Termination or Suspension of Permits, published
at 64 Fed. Reg. 40,176 (July 23, 1999) and codified at 40 Code of Federal Regulations
("C.F.R.") Part 22.
2. The authority to take action under Section 309(g)(2)(B) of the CWA, 33 U.S.C.
§ 1319(g)(2)(B), is vested in the Administrator of the United States Environmental Protection
Agency. The Administrator has delegated this authority to the Regional Administrator, Region
4, who in turn has delegated this authority to the Director of the Water Protection Division, of
the EPA, Region 4 ("Complainant").
II. Allegations
3. Mount Olive Pickle Company, Inc. ("Respondent") is a corporation duly
organized and existing under the laws of the State of North Carolina and is therefore a "person"
within the meaning of Section 502(5) of the CWA, 33 U.S.C. § 1362(5).
4. At all times relevant to this action, the Respondent owned and/or operated an
Food and Kindred Products processor facility, as identified by Standard Industrial Classification
("SIC") Code 2035 Pickles, Sauces, and Salad Dressings, located One Cucumber Boulevard, in
Mount Olive, Wayne County, North Carolina ("Facility").
S. To accomplish the objective of the CWA, defined in Section 101(a) of the CWA,
33 U.S.C. § 1251(a), to restore and maintain the chemical, physical and biological integrity of
the nation's waters, Section 301(a) of the CWA, 33 U.S.C. § 131 l (a), prohibits the discharge of
pollutants by any person into waters of the United States except as in compliance with a National

Pollutant Discharge Elimination System ("NPDES") permit issued pursuant to Section 402 of the
CWA, 33 U.S.C. § 1342.
6. Section 402 of the CWA, 33 U.S.C. § 1342, establishes an NPDES Permit
Program authorizing the EPA or authorized states to administer the NPDES Permit Program,
including the issuance of NPDES permits allowing for the discharge of pollutants, including
stormwater, into navigable waters subject to specific terms and conditions. The EPA has granted
the State of North Carolina, through the North Carolina Department of Environmental Quality
("NCDEQ"), approval to issue NPDES permits pursuant to Section 402(b) of the CWA.
7. NCDEQ (formerly known as the North Carolina Department of Environment and
Natural Resources) issued the General Permit No. NCG060000 to Discharge Stormwater Under
the National Pollutant Discharge Elimination System for establishments primarily engaged in the
following activities: Food and Kindred ("Permit"), in accordance with the North Carolina
General Statute 143-215.1, and the CWA. The General Permit became effective December 1,
2012, and shall expire on October 31, 2017. Coverage under the Permit may be obtained by
submitting a Notice of Intent ("NO]") to NCDEQ and receiving a certificate of coverage.
8. The NCDEQ is responsible for the issuance, compliance and enforcement of the
North Carolina General Statute 143-215.1, and the approval of coverage under the Permit upon
submission and approval of a Notice of Intent ("NOI") requesting coverage.
9. The Permit is a North Carolina statewide NPDES general permit governing
stormwater point source discharges associated with industrial activities including Food and
Kindred Activities.
10. Pursuant to Section 402(p)(2)(B) of the CWA, 33 U.S.C. § 1342(p)(2)(B), a
NPDES permit is required for any "stonnwater discharge associated with industrial activity."
1 l . "Stormwater discharge associated with industrial activity," as defined at 40 C.F.R.
§ 122.26(b)(14), means the discharge from any conveyance that is used for collecting and
conveying stormwater and that is directly related to manufacturing, processing or raw materials
storage areas at an industrial plant.
12. Pursuant to 40 C.F.R. 122.26(b)(14)(xi), facilities under SIC Code 2035 are
considered to be engaging in "industrial activity" for the purposes of 40 C.F.R. 122.26(b)(14).
13. Barlow Branch is a tributary to the Northeast Cape Fear River, which is a
"navigable water" and a "water of the United States" as defined by Section 502(7) of the Act,
33 U.S.C. § 1362(7) and its implementing regulation 40 C.F.R. § 122.2.
14. Section 301(a) of the CWA, 33 U.S.C. § 131 I(a), prohibits the discharge of
pollutants by any person into navigable waters except in compliance with a National Pollutant
Discharge Elimination System (NPDES) permit issued pursuant to Section 402 of the CWA, 33
U.S.C. § 1342.

15. On February 10, 2016, the EPA and NCDEQ performed a Compliance
Stormwater Evaluation Inspection ("CSWEI") at the Facility to evaluate Respondent's
compliance with the requirements of sections 301 and 402(p) of the CWA, 33 U.S.C. §§ 1311
and 1342(p) and the regulations promulgated thereunder at 40 C.F.R. § 122.26.
16. During the CSWEI,"the EPA inspectors observed the following:
A. The Facility has several industrial areas with exposure to stormwater runoff,
including exposed storage area ("bone yard"), exposed storage area ("laydown
yard"), employee parking with tanker receiving, and loading dock area.
B. The Facility is a Food and Kindred Products processor (SIC Code 2035
Pickles, Sauces, and Salad Dressings), and in accordance with 40 C.F.R. §
122.26(b)(14)(xi), stormwater discharge associated with industrial activity, for
which a NPDES permit is required, includes discharge from facilities
identified by this SIC Code.
C. The Facility indicated that it failed to submit a Notice of Intent (NOD seeking
coverage under the permit,
17. From October 1, 1992 to July 5, 2016, stormwater associated with industrial
activity was discharged from the Facility through the outfalls at the parking lot on the south side
of the property by Vine Street and the southeastern side of the property on Cucumber Boulevard
of the site and through sheet flow along the material storage area on the western side of the
property by the National Guard Armory, and along the western side of the property from
outdoor material storage along the corner of Relish Street and Witherington Street. These
discharges go to the Town of Mount Olive Municipal Separate Storer Sewer System ("MS4"),
which ultimately discharges to Barlow Branch. At no point during this time did the Facility
submit an NOI to obtain coverage under the Permit. Such discharges of stormwater to waters of
the United States were not authorized by a NPDES permit and are therefore violations of
Sections 301 and 402(p) of the CWA, 33 U.S.C. §§ 1311 and 1342(p).
18. Therefore, the Respondent has violated Section 301 of the CWA, 33 U.S.C. §
1311, by discharging stormwater without proper authorization to waters of the United States.
19. After Respondent became aware of this violation, on July 6, 2016, Respondent
submitted an NOI to NCDEQ requesting coverage under the Permit at the Facility. The
authorization became effective on October 14, 2016, and will expire on October 31, 2017, and
requires Respondent to comply with all provisions of the Permit.
III. Stipulations and Findings
20. Complainant and the Respondent have conferred for the purpose of settlement
pursuant to 40 C.F.R. § 22.18 and desire to resolve this matter and settle the allegations

described herein without a formal hearing. Therefore, without the taking of any evidence or
testimony, the making of any argument or the adjudication of any issue in this matter, and in
accordance with 40 C.F.R. § 22.13(b), this Consent Agreement and Final Order ("CA/FO") will
simultaneously commence and conclude this matter.
21. For the purposes of this CA/FO, the Respondent admits the jurisdictional
allegations set out above and admits the factual allegations set out above.
22. The Respondent hereby waives its right to contest the allegations set out above
and its right to appeal the Final Order accompanying this Consent Agreement.
23. The Respondent consents to the assessment of and agrees to pay the civil penalty
as set forth in this CA/FO and consents to the other conditions set forth in this CA/FO.
24. By signing this CA/FO, the Respondent certifies that the information it has
supplied concerning this matter was at the time of submission, and is, truthful, accurate, and
complete for each such submission, response and statement. The Respondent realizes that there
are significant penalties for submitting false or misleading information, including the possibility
of fines and/or imprisonment for knowing submission of such information.
25. The EPA reserves the right to assess and collect any and all civil penalties for any
violation described herein to the extent that any information or certification provided by the
Respondent was materially false or inaccurate at the time such information or certification was
provided to the EPA.
26. Complainant and the Respondent agree to settle this matter by their execution of
this CA/FO. The parties agree that the settlement of this matter is in the public interest and that
this CA/FO is consistent with the applicable requirements of the CWA.
IV. Payment
27. Pursuant to Section 309(g)(2)(B) of the CWA, 33 U.S.C. § 1319(g)(2)(B), and
40 C.F.R. Part 19, and considering the nature of the violations and other relevant factors, the
EPA has determined that one hundred thirty-one thousand eight hundred fifty-six dollars
($131,856) is an appropriate civil penalty to settle this action.
28. The Respondent shall submit payment of the penalty specified in the preceding
paragraph within thirty (30) days of the effective date of this CA/F0 via a cashier's or certified
check, payable to the order of "Treasurer, United States of America." The check shall reference
on its face the name of the Respondent and the Docket Number of this CA/FO. Such payment
shall be tendered to:

U.S. Environmental Protection Agency
Fines and Penalties
Cincinnati Finance Center
P.O. Box 979077
St. Louis, Missouri 63197-9000
29. At the time of payment, the Respondent shall send a separate copy of the check,
and a written statement that payment has been made in accordance with this CA/FO, to the
following persons at the following addresses:
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
and
Ms. Mary Mattox .
U.S. Environmental Protection Agency, Region 4
Water Protection Division
Clean Water Enforcement Branch
Municipal and Industrial Enforcement Section
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
30. The penalty amount specified above shall represent civil penalties assessed by the
EPA and shall not be deductible for purposes of federal taxes.
31. Pursuant to Section 309(g)(9) of the CWA, 33 U.S.C. § 1319(g)(9), failure by the
Respondent to pay the penalty assessed by the CA/FO in full by its due date may subject the
Respondent to a civil action to collect the assessed penalty plus interest (at currently prevailing
rates from the effective date of this CA/FO), attorney's fees, costs for collection proceedings
and a quarterly nonpayment penalty for each quarter during which such failure to pay persists.
Such nonpayment penalty shall be in an amount equal to twenty percent (20%) of the aggregate
amount of such penalty and nonpayment penalty which are unpaid as of the beginning of such
quarter. In any such collection action, the validity, amount and appropriateness of the penalty
and of this CA/FO shall not be subject to review.
V. General Provisions
32. This CA/FO shall not relieve the Respondent of its obligation to comply with all
applicable provisions of federal, state, or local law, nor shall it be construed to be a ruling on, or
determination of, any issue related to any federal, state or local permit. Other than as expressed
herein, compliance with this CA/FO shall not be a defense to any actions subsequently
commenced pursuant to federal laws and regulations administered by the EPA.

33. Issuance of this CA/FO shall not be deemed as prohibiting, altering, or in any way
limiting the ability of the EPA to pursue any other enforcement actions available to it under law.
Such actions may include, without limitation, any administrative, civil, or criminal action to
seek penalties, fines, injunctive, or other appropriate relief, or to initiate an action for imminent
and substantial endangerment, under the CWA or any other federal or state statute, regulation,
or permit.
34. Except as otherwise set forth herein, this CA/FO constitutes a settlement by
Complainant and the Respondent of all claims for civil penalties pursuant to the CWA with
respect to only those violations alleged in this CA/FO. Except as otherwise set forth herein,
compliance with this CA/FO shall resolve the allegations of violations contained herein.
35. Nothing in this CA/FO is intended to nor shall be construed to operate in any way
to resolve any criminal liability of the Respondent, or other liability resulting from violations
that were not alleged in this CA/FO.
36. Each undersigned representative of the parties to this CA/FO certifies that he or
she is fully authorized to enter into the terms and conditions of this CA/FO and to execute and
legally bind that party to it.
37. This CA/FO applies to and is binding upon the Respondent and its officers,
directors, employees, agents, successors and assigns.
38. Any change in the legal status of the Respondent, including but not limited to any
transfer of assets of real or personal property, shall not alter the Respondent's responsibilities
under this CA/FO.
39. Each party shall bear its own costs and attorneys fees in connection with the
action resolved by this CA/FO.
40. In accordance with 40 C.F.R. § 22.5, the individuals below are authorized to
receive service related to this proceeding:
For Complainant:
Mrs. Kavita K. Nagrani
Associate Regional Counsel
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-9960
[phone]

For Respondent:
Ms. Amy P. Wang
Ward and Smith, P.A.
1001 College Court
New Bern, North Carolina 28562-0867
[phone]
41. The parties acknowledge and agree that this CA/FO is subject to the requirements
of 40 C.F.R. § 22.45(c)(4), which provides a right to petition to set aside a proposed CA/FO
based on comments received during the public comment period.
42. Pursuant to Section 309(g) of the CWA, 33 U.S.C. § 1319(g), and 40 C.F.R.
§ 22.38(b), Complainant represents that the State of North Carolina was provided a prior
opportunity to consult with Complainant regarding this matter.
43. Effective upon signature of this CA/FO by the Respondent, the Respondent agrees
that the time period commencing on the date of its signature and ending on the date the EPA
receives from the Respondent the payment required by this CA/FO shall not be included in
computing the running of any statute of limitations potentially applicable to any action brought
by the EPA related to the matters addressed in this CA/FO and that, in any action brought by the
EPA related to the matters addressed, the Respondent will not assert, and may not maintain, any
defense or claim based upon principles of statute of limitations, waiver, laches, estoppel, or
other defense based on the passage of time during such period. 1f the EPA gives notice to the
Respondent that it will not make this CA/FO effective, the statute of limitations shall begin to
run again commencing ninety days after the date such notice is sent by the EPA.
VI. Effective Date
44. The effective date of this CA/FO shall be the date on which the CAIFO is filed
with the Regional Hearing Clerk.

DOCKET NO. CWA-04-2017-4500(b)
AGREED AND CONSENTED TO:
For the RESPONDENT, Mount Olive Pickle Company, Inc.:
Date:
Mr. Bobby
President
For COMPLAINANT, U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4:
0
Director
Water Protection Division
U.S. EPA, Region 4
Date: J

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF:
MOUNT OLIVE PICKLE COMPANY, INC.)
MOUNT OLIVE, WAYNE COUNTY, }
NORTH CAROLINA }
RESPONDENT. }
}
CONSENT AGREEMENT AND
FINAL ORDER
DOCKET NO. CWA-04-2017-4500(b)
FINAL ORDER
In accordance with the Consolidated Rules qf Practice Governing the Administrative
Assessment of Civil Penalties, Issuance of Compliance or Corrective Action Orders and the
Revocation, Termination or Suspension of Permits, 40 C.F.R. Part 22, and authorities delegated
to me, the foregoing Consent Agreement is hereby approved and incorporated by reference into
this Final Order. Pursuant to Section 309(g)(2)(B) of the CWA, 33 U.S.C. § 1319(g)(2)(B), the
Respondent is hereby ordered to comply with the terms of the foregoing Consent Agreement,
U.S. ENVIRONMENTAL PROTECTION AGENCY.
MAR 3 0 2017
Date:
V. AnneHeard
Acting Regional Administrator

Docket NO. CWA-04-2017-4500(b)
CERTIFICATE OF SERVICE
The undersigned certifies that a true and correct copy of the attached CONSENT
AGREEMENT AND FINAL ORDER in the matter of MOUNT OLIVE PICKLE
COMPANY, INC., Docket No. CWA-04-2017-4500(b) (filed with the Regional Hearing Clerk
on 2017) was served on -^ 0 , 2017, in the manner specified to each
of the persons listed below.
By hand -delivery: Mrs. Kavita K. Nagrani
Associate Regional Counsel
U.S. Environmental Protection Agency; Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
By certified mail,
return receipt requested: Ms. Amy P. Wang
Ward and Smith, P.A.
1001 College Court
New Bern, North Carolina 28562-0867
Bradley Bennett, Stor nwater Permitting Program Supervisor
Stormwater Permitting Program
NC Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Patricia A. Bullock
Regional Hearing Clerk
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-8960
[phone]

J��eo styrFs
A UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
z REGION 4
Q ATLANTA FEDERAL CENTER
o� 61 FORSYTH STREET
�411C PR0'1161` ATLANTA, GEORGIA 30303-8960
MAR 07 2017
CERTIFIED MAIL 7016 1970 0000 8992 7103
RETURN RECEIPT REQUESTED
Mr. Bradley Bennett
Stormwater Permitting Program Supervisor
North Carolina Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Re: Administrative Order No. CWA-04-2017-4752
General Permit to Discharge Stormwater Under the National Pollutant Discharge Elimination System,
Permit No.: NCG060000
Mount Olive Pickle Company, Mt. Olive, North Carolina
Dear Mr. Bennett:
Pursuant to Sections 308 and 309(a) of the Clean Water Act (CWA), 33 U.S.C. §§ 1318 and 1319(a),
have determined that the above -referenced industrial facility is in violation of Section 402(p) of the
CWA, 33 U.S.C. § 1342(p). As a result, I have executed an Administrative Order on Consent (AOC), a
copy of which is enclosed for your reference. The AOC is presently being served.
Enclosure
Sincerely,
Mar/Sialker Director
Water Protection Division
JU
MAR 13 201
Internet Address (URL) • dttp://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
c� W REGION 4
i Q ATLANTA FEDERAL CENTER
61 FORSYTH STREET
�f41 aROZEc� ATLANTA, GEORGIA 30303-8960
MAR p 7 2017
CERTIFIED MAIL 7016 1970 0000 8992 7080
RETURN RECEIPT REQUESTED
Mr. Bobby Frye
President
Mount Olive Pickle Company, Inc.
One Cucumber Boulevard
Mount Olive, North Carolina 28365
Re: Administrative Order No.: CWA-04-2017-4752
Mount Olive Pickle Company, Mt. Olive, North Carolina
Dear Mr. Frye:
Enclosed, please find an executed copy of the Administrative Order on Consent (AOC), Docket No..
CWA-04-2016-4777, pertaining to the above referenced industrial facility, Please take note of Paragraph
23 of the AOC, which requires certain actions and submittals from Mount Olive Pickle Company, Inc.
The EPA appreciates your cooperation in this matter. If you have any questions concerning the enclosed
AOC, please contact Ms. Kavita Nagrani, Associate Regional Counsel,' at [phone] or via email at
[e-mail] or LCDR Tara L. Houda at [e-mail].
Sincerely,
. ra-g
Denisse D. Diaz, Chief
NPDES Permitting and Enforcement Branch
Water Protection Division
Enclosure
cc: Mr. Bradley Bennett
North Carolina Department of Environmental Quality
Ms. Amy P. Wang
Ward and Smith, P.A
MAR 13 2017
G;rd'i-LAt'-D
5T0> `V'j',,'A TER
Internet Address (URL) + htlp://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
IN THE MATTER OF: ) ADMINISTRATIVE COMPLIANCE
ORDER ON CONSENT
MOUNT OLIVE PICKLE COMPANY, INC. }
MT. OLIVE, NORTH CAROLINA, } DOCKET NO. CWA-04-2017-4752
}
RESPONDENT. )
ADMINISTRATIVE COMPLIANCE ORDER ON CONSENT
1. Statutory Authority
1. Section 309(a) of the Clean Water Act (CWA), 33 U.S.C. § 1319(a), provides that, whenever the
U.S. Environmental Protection Agency (EPA) finds that any person is in violation of any condition or
limitation which implements, inter ilia, Sections 301(a) and 402 of the CWA, 33 U.S.C. §§ 131 l (a) and
1342, the EPA may issue an order requiring such person to comply with such condition or limitation,
and shall specify a time for compliance that the EPA determines to be reasonable.
2. The following Findings of Fact and Determinations of Law are made and this Administrative
Compliance Order on Consent (A0Q is issued pursuant to the authority vested in the EPA by Section
309(a) of the CWA, 33 U.S.C. § 1319(a), as amended. This authority has been delegated to the Regional
Administrator of the EPA, Region 4, and further delegated by the Regional Administrator to the Director
of the Water Protection Division of the EPA. Region 4.
11. Findings of Fact and Determinations of Law
3., To accomplish the objective of the CWA, defined in Section 101(a) of the CWA,
33 U.S.C. § l 251(a), to restore and maintain the chemical, physical, and biological integrity of the
nation's waters. Section 301(a) of the CWA, 33 U.S.C. § 131 1(a), prohibits the discharge of pollutants
by any person into navigable waters except in compliance with a National Pollutant Discharge
Elimination System (NPDES) permit issued pursuant to Section 402 of the CWA, 33 U.S.C. § 1342.
4. Mount Olive Pickle Company, Inc. (Respondent) is a corporation duly organized and existing
under the laws of the State of North Carolina and is therefore a '`person" within the meaning of Section
502(5) of the CWA, 33 U.S.C. § 1362(5).
5. At all times relevant to this action, Respondent owned and/or operated a facility located at One
Cucumber Boulevard, Mount Olive, North Carolina 28365 (Facility). The Facility is a food processor
(SIC Code 2035 Pickled Fruits and Vegetables, Vegetable Sauces and Seasonings, and Salad Dressings).
The site is an industrial facility with multiple buildings, material storage areas, unloading areas, a tank
farm, and a wastewater treatment plant. Materials were observed uncovered outdoors. The Facility had

three outdoor industrial activities that discharge stormwater offsite to a municipal stormwater system.
Stormwater drains are located near the southern perimeter of the site along the railroad tracks and along
the western perimeter of the site.
6. Section 301(a) of the CWA, 33 U.S.C. § 131 1(a), prohibits the discharge of pollutants by any
person into waters of the United States except as in compliance with a NPDES Permit issued pursuant to
Section 402 of the CWA, 33 U.S.C.
§ 1342.
7. Section 402 of the CWA, 33 U.S.C. § 1342, establishes a NPDES Permit Program authorizing
the EPA or authorized states to administer the NPDES Permit Program, including the issuance of
NPDES permits allowing for the discharge of pollutants, including stormwater, into navigable waters
subject to specific terms and conditions. The EPA has granted the State of North Carolina, through the
North Carolina Department of Environmental Quality (NCDEQ), formerly known as the Department of
Environment and Natural Resources (NCDENR), approval to issue NPDES permits pursuant to Section
402(b) of the CWA, 33 U.S.C. § 1342(b).
$. The NCDENR issued the General Permit No. NCG060000 to Discharge Storinwater rattler the
National Pollutant Discharge Elimination System for establishments primarily engaged in Food and
Kindred, Permit No. NCG060000, (Permit) in accordance with the North Carolina General Statute §
143-215.1 and the CWA. The Permit became effective on December 1, 2012, and will expire on October
31, 2017. Coverage under the Permit is obtained by submitting a Notice of Intent (NOI) to
NCDENR/NCDEQ.
9. Pursuant to Section 402(p)(2)(B) of the CWA. 33 U.S.C. § 1342(p)(2)(B), a NPDES permit is
required for "a [stormwater] discharge associated with industrial activity."
10, "Stormwater discharge associated with industrial activity," as defined at 40 C.F.R.
§ 122.26(b)(14). means the discharge from any conveyance that is used for collecting and conveying
storm water and that is directly related to manufacturing, processing or raw materials storage areas at an
industrial plant.
11. Pursuant to 40 C.F.R § 12226(b)(14)(xi), "facilities under Standard Industrial Classifications
20," are considered to be engaging in `'industrial activity" for purposes of 40 C.F.R. § 12226(b)(14).
12. On February 10, 20t6, the EPA, in conjunction with the NCDEQ, performed it Compliance
Stormwater Evaluation Inspection (CSWEI) at Respondent's Facility to evaluate the Respondent's
compliance with the requirements of Sections 301.and 402(p) of the CWA, 33 U.S.C. §§ 1311 and
1342(p); the regulations promulgated thereunder at 40 C.F.R. § 122.26, and the Permit.
2

13. During the CSWEI, the EPA inspectors observed the following:
a. The Facility has several industrial areas with exposure to stormwater runoff, including
exposed storage area ("bone yard"), exposed storage area ("laydown yard"), employee
parking with tanker receiving, and loading dock area.
b. The Facility is a Food and Kindred Products processor (SIC Code 2035 Pickles, Sauces,
and Salad Dressings), and in accordance with 40 C.F.R. § 122.26(b)(14)(xi), storm water
discharge associated with industrial activity, for which the Permit is required, includes
discharge from facilities identified by this SIC Code.
c. The Facility indicated that it failed to submit an NO] seeking coverage under the Permit.
14. On June 28, 2016, the EPA issued a Notice of Violation, Inspection Report, and Opportunity to
Show Cause to the Respondent.
15. On July 6, 2016, Respondent submitted an NOI to NCDEQ requesting coverage at the Facility
under the Permit. NCDEQ issued to Respondent a Certificate of Coverage (COC) for the Facility under
the Permit on October 14, 2016.
16. On August 12. 2016, a Show Cause Meeting was held with the Respondent.
17. In accordance with Section 402(p) of the CWA, 33 U.S.C. § 1342(p), and its implementing
regulations, based on the CSWEI and due to the hydrology of the Facility and historic rainfall data, the
EPA has determined that from October 1. 1992 to July 5, 2016. stormwater associated with industrial
activity was discharged from the Facility through the outfalls at the parking lot on the south side of the
property by Vine Street and the southeastern side of the property on CUCumher Boulevard and through
sheet flow along the material storage area on the western side of the property by the National Guard
Armory, and along the western side of the property from outdoor material storage along the corner of
Relish Street and Witherington Street. These discharges go to the Town of Mount Olive Municipal
Separate Storm Sewer System (MS4), which ultimatelv discharges to Barlow Branch.
18. Barlow Branch, a 'water of the United States." is a tributary to the Northeast Cape Fear River,
which is a "navigable water" and a "water of the United States" as defined by Section 502(7) of the Act,
33 U.S.C. § 1362(7) and its implementing regulation 40 C.F.R. § 122.2.
19. Therefore, the Respondent has violated Section 301 of the CWA, 33 U.S.C. § 1311, by
discharging stormwater without proper authorization to waters of the United States.
3

Ill. Order On Consent
20. Based on the foregoing Findings of Fact and Determinations of Law and pursuant to the
authority of Sections 308 and 309(a) of the CWA, 33 U.S.C. §� 1318 and 1319(a), THE DIRECTOR
HEREBY ORDERS AND THE RESPONDENT HEREBY AGREES AND CONSENTS TO THE
PROVISIONS OF THE PARAGRAPHS BELOW:
21. The Respondent shall cease all unauthorized discharges of stormwater from industrial activity
from the Facility to waters of the United States without a CWA NPDES permit within ninety (90) days
of the Effective Date of this AOC.
22. If the Respondent chooses to comply by ceasing all unauthorized discharges, the Respondent
shall submit a work plan to the EPA within thirty (30) days of the Effective Date of this AOC detailing
the steps the Respondent must take to cease discharging. The work plan shall include projected dates for
achieving major milestones. The work plan should also include any interim controls necessary to
prevent discharges of industrial stormwater from the Facility and projected dates for establishing those
controls. Throughout the Respondent's implementation of the work plan, the Respondent shall submit a
progress report every thirty (30) days to the EPA. Each progress report shall include photographs and a
written description of the work completed since the previous progress report. The progress reports will
assist the EPA in determining whether the Respondent is abating the unlawful discharges and preventing
additional discharges.
23. If the Respondent intends to comply by discharging stormwater from the Facility under the terms
of the Facility's Permit, the Respondent shall:
A. Submit a copy of the: certificate of coverage (COC) to the EPA within thirty (30) days of the
Effective Date of this AOC. Perform the semi-annual sampling of Stormwater Discharge
Outfall (SDO) 002 for chloride. When the sampling results reflect chloride levels above 860
mglL at SDO 002, Respondent shall evaluate the area for potential exposed sources,
implement Best Management Practices (B VIPs) to reduce chloride concentrations, and
document actions in the Facility's Stormwater Pollution Prevention Plan (SPPP).
B. Establish and maintain a minimum 25 foot vegetated buffer from the fence line of Drainage
Area 2a (bone yard), in accordance with the COC. Monthly, provide two photos (one facing
west along the fence line and the other facing south from the top of the bone yard looking
towards the fence) of the status of the buffer area for at least the first three months after the
Effective Date of this AOC or until the vegetated buffer is completely established with
permanent vegetation, whichever comes second.
C. Take a grab sample, as defined by Part IV,12 of the Permit, at SDOs 001, 002 and 003 for
chlorides (using an EPA approved methodology) during three Measurable Storm Events, as

defined by Part IV.15 of the Permit, within the first four months of the effective date of this
AOC. A copy of the monitoring result(s) and associated rain fog(s) shall be submitted to the
EPA within 7 days of the first of the following month. The rain log shall include: every rain
event for the month, the time rain started. the total rainfall and the method for determining
total rainfall. The monitoring, result shall include: the time discharge started and the time the
sample was collected.
a. If none of the three chloride samples from an outfall is above 229 mg/L, no further
sampling is required.
b. if two or more chloride samples from an outfall is 230 mg/L or above, the Facility
shall evaluate the area for potential exposed sources and implement at least one
additional BMP to reduce chloride concentrations, and document actions in the
Facility's SPPP.
c. If any of the original three chloride samples from SDOs 001, 002, and 003 is 860
mg/L or above, the Facility shall collect an additional sample at that SDO after the
Facility has evaluated the area for potential exposed sources and implemented at least
one additional BMP to reduce chloride concentrations, and document the actions in
the Facility's SPPP.
d. If the additional sample taken in accordance with Paragraph 23,C.c also is 860 mg/L
or above, the Facility shall collect an additional sample at that SDO.
e. For SDO 001. if the sample in 23.C.d. is 860 mg/L or above. the Facility shall
evaluate the area for potenlial exposed sources and document the evaluation. After
this has been done, the Facility shall evaluate the feasibility of implementing at least
one structural BMP to reduce chloride concentrations. The feasibility assessment
shall include evaluation of at least 2 structural BMP options and shall not include re-
routing tilt; outfall to wastewater/pretreatment. The feasibility assessment Shall be
conducted by an engineer with knowledge of stormwater practices. Selection, or the
reason(s) for lack of selection, of any of the 2 or more evaluated structural BMPs
shall be documented in the Facility's amended SPPP.
D. Submit a copy of the Facility`s final SPPP, to include monthly self -inspections, to the EPA
within thirty (30) days of the Effective Date of this AOC.
24. The Respondent may submit a request, in writing, for an extension of time to comply with the
requirements of this AOC within seven (7) calendar days of the required completion date. Such request
must include the reason(s) for the extension request and a date when compliance will be achieved. Any
extension must be granted by the EPA in writing to be effective.

25. All reports, notifications, documentation, and submittals required by this AOC shall be signed by
a duly authorized representative of the Respondent as specified by 40 C.F.R. § 122.22 and shall include
the following statement:
"I certify under the 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 gather and evaluate 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
knowlcdge 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."
26. All reports, notifications, documentation, and submittals required by this AOC shall be sent by
certified mail or its equivalent to the following addresses:
LCDR Tara Houda
NPDES Permitting and Enforcement Branch
Water Protection Division
U.S. Environmental Protection Agency, Region 4
61 Forsyth Street, S.W.
Atlanta. Georgia 30303-8960
and
Mr. Bradley Bennett, Stormwater Permitting Program Supervisor
North Carolina Department of Environmental Qualitv
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
IV. Final Report and Termination of AOC
27. Within thirty (30) calendar days after Respondent has fully completed and implemented the
actions required by Section III of this AOC, Respondent shall submit for the EPA's review and approval
it final report (Final Report) that includes: (a) a description of all of the actions which have been taken
toward achieving compliance with this AOC; and (b) a summary table of all stormwater chloride
sampling conducted since the Effective Date of this AOC with it timeline and summary of any BMP
modifications conducted to address chloride samples over 229 mg/L. Items submitted to the EPA under

Paragraph 26 of this AOC shall also be submitted to NCDEQ.
28. If the EPA determines, after review of the Final Report, that all the requirements of this AOC
have been completed and implemented in accordance with this AOC, the EPA will provide notice to the
Respondent and this AOC shall be deemed terminated.
29. If the EPA determines that any requirement has not been completed and implemented in
accordance with this AOC, the EPA will notify the Respondent, provide a list of deficiencies, and may
require the Respondent to modify its actions as appropriate in order to correct such deficiencies. If so
required, the Respondent shall implement the modified and approved requirement(s) and submit a
modified Final Report in accordance with the EPA notice. Failure by the Respondent to implement any
of the approved modified requirement(s) shall be a violation of this AOC.
V. General Provisions
30. The Respondent's compliance with this AOC does not necessarily constitute compliance with the
provisions of the CWA, 33 U.S.C. § 1251 et seq., its implementing regulations, or with the Permit. The
Respondent shall remain solely responsible for compliance with the terms of the CWA, its implementing
regulations, this AOC, and the Permit.
31, Nothing in this AOC shall constitute a waiver, suspension, or modification of the terms and
conditions of the Permit, which remain in full force and effect.
32. Failure to comply with the requirements herein shall constitute a violation of this AOC and the
CWA, and may subject the Respondent to penalties as provided in Section 309(d) of the CWA, 33
U.S.C. § 1319(d).
33, This AOC shall not relieve the Respondent of its obligation to comply with all applicable
provisions of federal, state, or local law, nor shall it be construed to be a ruling on, or determination of,
any issue related to any other federal, state, or local permit. Compliance with this AOC shall not be a
defense to any actions subsequently commenced pursuant to federal laws and regulations administered
by the EPA.
34. Issuance of this AOC shall not be deemed as prohibiting, altering, or in any way limiting the
ability of the EPA to pursue any other enforcement actions available to it under law. Such actions may
include, without limitation, any administrative, civil, or criminal action to seek penalties, fines,
injunctive, or other appropriate relief, or to initiate an action for imminent and substantial endangerment
under the CWA or any other federal or state statute, regulation, or permit.

35. The EPA reserves all rights and remedies, legal and equitable, available to enforce any violation
cited in this AOC and to enforce this AOC.
36. Nothing in this AOC is intended to nor shall be construed to operate in any way to resolve any
criminal liability of the Respondent, or other liability resulting from violations that were not alleged in
this AOC.
37. This AOC applies to and is binding upon the Respondent and its officers, directors, employees,
agents, successors, and assigns.
38. Any change in the legal status of the Respondent, including but not limited to any transfer of
assets of real or personal property, shall not alter the Respondent's responsibilities under this AOC.
39. The Respondent admits to the jurisdictional allegations set forth within this AOC.
40. The Respondent waives any and all claims for relief and otherwise available rights or remedies
to judicial or administrative review which the Respondent may have with respect to any issue of fact or
law set forth in this AOC, including, but not limited to any right of judicial review of the AOC under the
Administrative Procedure Act, 5 U.S.C. §§ 701-706,
41. Each party shall bear its own costs and attorneys fees in connection with the action resolved by
this AOC.
42. Pursuant to Section 309(a)(4) of the CWA, 33 U.S.C. § 1319(a)(4), the EPA has sent a copy of'
this AOC to the State of North Carolina.
43. Each undersigned representative of the parties to this AOC certifies that he or she is fully
authorized to enter into the terms and conditions of this AOC and to execute and legally bind that party
to it.
V 1. Effective Date
44. This AOC shall become effective upon receipt by the Respondent's counsel of a copy of the fully
executed AOC.

IT IS SO AGREED,
BY:
.1 - ' - H - A""�
Wi ►am H. Bryan, Executive dhairnian
Mount Olive Pickle Company, Inc.
Date:
BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION 4:
Date:
Mary S. Walk r
Director
Water Protection Division
U.S. EPA, Region 4

1
Permit Number NCGO60374
Central Files: APS _ SWP _
10/14/2016
Permit Tracking Slip
Program Category
Status Project Type
NPDES SW
In review New Project
Permit Type
Version Permit Classification
FoodfTobacco/Soaps/Cosmetics/Public Warehousing Stormwater Discharge COC
COC
Primary Reviewer
Permit Contact Affiliation
Bethany.Georgoulias
Coastal SWRulo RECEIVED
Permitted Flow DCT202016
CENTRAL F1LGS
Facility
DWG, SECTION
Facility Name Major/Minor Region
Mount Olive Pickle Company Minor Washington
Location Address County
1 Cucumber Blvd Wayne
Mount Olive NC 28365
Owner
Owner Name
Mount Olive Pickle Company
Dates/Events
Facility Contact Affiliation
Fletcher Arritt
PO Box 609
Mount Olive NC 28365
Owner Type
Non -Government
Owner Affiliation
8 J. Occena
I Director Engineering Maintenance
Scheduled
Orig Issue App Received Draft Initiated Issuance
Public Notice Issue
Effective
Expiration
7/6/2016
`alb a{f ? pti
!
1 b /114?ylG
l013k f '2- ot7
Regulated Activities
Requested /Received Events
Food and kindred products manufacture
RO staff report requested
717116
RO staff report received
1013/16
Outfall 001
Waterbody Name Streamindex Number Current Class Subbasin
Barlow Branch 18-74-2 C;Sw 03-06-21
Outfall 002
Waterbody Name
Streamindex Number
Current Class.
Subbasin
Barlow Branch
18-74-2
C;Sw
03-06-21
Outfall 003
Waterbody Name
Streamindex Number
Current Class
Subbasin
Barlow Branch
18-74-2
C;Sw
03-06-21

Energy, Mineral
and Land Resources
ENVIRONMENTAL OVALITY
Mr. Fletcher Arritt
Mt. Olive Pickle Company
F.O. Box 609
Mount Olive, NC 28365
Dear Mr, Arritt:
PAT MCCRORY
2�
DONALD R. VAN DI_R VAAR'I'
October 14, 2016 T R A C Y DAVIS
Din-clur
Subject: General Permit No. NCG060000
Mt. Olive Pickle Company
NPDES Stormwater Permit Issuance
COC No. NCG060374
Wayne County
In accordance with your application for a discharge permit received on July 6, 2016, we are
forwarding herewith the subject certificate of coverage (COC) to discharge under the subject state —
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except upon approval of the
Division of Energy, Mineral, and Land Resources (DEMLR). The Division may require modification
or revocation and reissuance of the certificate of coverage.
Coverage under this General Permit is granted with the condition that the permittee performs
additional sampling requirements as outlined in the amended conditions to the COC. This COC
requires you to sample SDO 002 semi-annually for chloride, in addition to the other parameters
required at all outfalls. No benchmark applies, but levels above 860 mg/l should prompt the facility
to evaluate the area for potential exposed sources, implement Best Management Practices (BMPs) to
reduce chloride concentrations, and document actions in the facility's Stormwater Pollution
Prevention Plan (SPPP).
Chloride is a pollutant of concern resulting from the activities at this plant. The Division will
consider the data upon renewal of coverage under this General Permit to determine if coverage under
a different General Permit or an individual permit is more appropriate.
State of North Carolina I Environmental Quality I Energy. Mineral and Land Resources
1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699
919 707 9200 'r

If you have any questions concerning this permit, please contact Bethany Georgoulias at telephone
number [phone] or by email bethany.georgoulias a,nedenr. o .
Sincerely,
. for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral, and Land Resources
cc: Carl W. Scharfe, P.E. / The Wooten Company
Washington Regional Office 1 DEMLR 1 Bill Moore
Washington Regional Office I DWR 1 Scott Vinson
DWR Central Office I NPDES Permitting Program I Julie Gryzb
U.S. EPA Region 41 NPDES Permitting & Enforcement Branch 1 LCDR Tara Houda
Stormwater Program Files
Central Files
State of Norlh Carolina I Environmental Quality I energy. Mineral and Land Resources
1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699
919 707 9200 T

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060374
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, and the North
Carolina Administrative Code in NCAC 15A 02H .0114(b)(1), as amended,
Mt. Olive Pickle Company
is hereby authorized to discharge stormwater from a facility located at
Mt. Olive Pickle Company
One Cucumber Blvd
Mt. Olive
Wayne County
to receiving waters designated as Barlow Branch, a class C; Sw water in the Cape Fear River
Basin, in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, I1, I11, and IV of General Permit No. NCG060000 as attached,
and as amended in pages 2-3 of this Certificate of Coverage.
Amended conditions
1. This Certificate of Coverage is an enforceable part of the permit.
2. In accordance with 15A NCAC 02H .0114(b)(1), the monitoring program in Part 11
Section B Table 1 Analytical Monitoring Requirements of this permit is amended
as follows:

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NCG060374
S
Map Scale 1: 24, 000
Mt Olive Pickle Company
Mt Olive, NC
Latitude: 350 12' 14" N
Longitude: 780 3' 36" W
County: Wayne
Receiving Stream: Barlow Branch
Stream Gass: C;S%y
Sub -basin: 03-06-21 (Neuse river Basin)
lrllf lt�f+t,"c
Facility Location

Geor oulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, October 17, 2016 11;43 AM
To: 'Kevin Campbell; Moore, Bill
Cc: Edgerton, Thom; Vinson, Scott; Bennett, Bradley; 'Carl Scharfe'
Subject: RE: Mt. Olive Pickle stormwater
Attachments: NCG060374_COC.pdf, NCG060374_coverletter.pdf; NCG06 Permit Print Package
2012.pdf
Kevin and Bill,
On Friday we finalized Mt. Olive Pickle's coverage under General Permit NCG060000. Attached is a copy of the cover
letter and amended Certificate of Coverage (COC), which augments monitoring under NCG06 with additional chloride
sampling at the stormwater outfall designated as SDO 002 (drainage area 5). A hard copy along with a full permit
package (also attached) will go out to the company later today. I realized just now that the standard DIOR forms do not
include a space for chloride sampling, I will try to modify one for Mt. Olive and send it later this week. Alternatively you
may just write in the results in the space after the last parameter for SDO 002.
I have also just sent a copy to EPA Region 4 so they are aware that the site's discharges are now covered under an
NPDES Stormwater Discharge Permit.
Bill and Scott, please print the attached letter and permit for WaRO's permit records for this facility.
Carl, thank you for your assistance through this process as we determined the best path forward for Mt. Olive Pickle
following EPA's inspection and findings. Attached is also your copy of the letter and COC for your records.
If any of you have any questions or concerns, please let us know.
Best regards,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethanygeor god ulias a ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http:l/deg,ne.gov/about/divisions/enert;y-mineral-land-resources/stormwater
Nothing Compares.—„
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, October 17, 2016 11:24 AM
To: 'Houda, Tara'
Cc: Bennett, Bradley; Grzyb, Julie; Vinson, Toby
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Attachments: NCG060374_COC.pdf; NCG060374_coverletter.pdf
Tara,
Coverage was issued to Mt. Olive Pickle on Friday 10/14 under the NPDES Stormwater NCG060000 General Permit, with
amended requirements to include chloride sampling at one of the outfalls. Regional office staff visited the site before
we finalized the permit to help determine the most appropriate sampling points. Please see the cover letter for more
details. The hard copies will be mailed out to the permittee later today.
If you have any questions, please let us know.
Best regards,
Bethany Georgoulias
I?nvironmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.georgoulias@nc dear.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.ne.gov/about/divisions/energy-mineral-land-resources/stormwater
fc. �i' othing Compares,—,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Houda, Tara [mailto:[e-mail]]
Sent: Friday, August 12, 2016 7:31 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Bennett, Bradley <[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
I'm reviewing Mt. Olive Pickle's.response to our 308 information request and noticed
something that will likely be of interest to your office. Page 2 of their NOI states that'Barlow

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
Mr. Fletcher Arritt
Mt. Olive Pickle Company
P.O. Box 609
Mount Olive, NC 28365
Dear Mr. Arritt:
PAT MCCRORY
DONALD R, VAN DER VAART
secri°ml:7 .
October 14, 2016 T R A C Y DAVIS
Uirecrur
Subject: General Permit No. NCG060000
Mt. Olive Pickle Company
NPDES Stormwater Permit Issuance
COC No. NCG060374
Wayne County
In accordance with your application for a discharge permit received on July 6, 2016, we are
forwarding herewith the subject certificate of coverage (COC) to discharge under the subject state --
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental protection Agency dated October 15, 2007 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except upon approval of the
Division of Energy, Mineral, and Land Resources (DEMLR). The Division may require modification
or revocation and reissuanee of the certificate of coverage.
Coverage under this General Permit is granted with the condition that the permittee performs
additional sampling requirements as outlined in the amended conditions to the COC. This COC
requires you to sample SDO 002 semi-annually for chloride, in addition to the other parameters
required at all outfalls. No benchmark applies, but levels above 860 mg/l should prompt the facility
to evaluate the area for potential exposed sources, implement Best Management Practices (BMPs) to
reduce chloride concentrations, and document actions in the facility's Stormwater Pollution
Prevention Plan (SPPP).
Chloride is a pollutant of concern resulting from the activities at this plant. The Division will
consider the data upon renewal of coverage under this General Permit to determine if coverage under
a different General Permit or an individual permit is more appropriate.
State of North Carolina I Environmental Quality I Energy. Mineral and Land Resources
1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699
919 707 9200 T
A�"Q� � �' :».��'�...=T2'.�'E��,C-Ci..�� t R,y,�,• t3,�.. 't � ,.a., r rv7� r i�� 1„*` -

If you have any questions concerning this permit, please contact Bethany Georgoulias at telephone
number [phone] or by email bethany.;zeor og uliasPncdenr.gov.
Sincerely,
,for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral, and Land Resources
cc: Carl W. Scharfe, P.E. / The Wooten Company
Washington Regional Office / DEMLR / Bill Moore
Washington Regional Office / DWR / Scott Vinson
DWR Central Office / NPDES Permitting Program / Julie Gryzb
S. EPA Region 4 / NPDES Permitting & Enforcement Branch / LCDR Tara Houda
rStormwater Program Files
Central Files
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resaurces
1612 Mail Service Center 1 512 N. Salisbury St, J Raleigh, NC 27699
919 707 9200 T
.,.Fr ?F'r"� 'YTm`Yr ..M1.,l4�v 7�.-r.L.,�':-,:1 �a i:a y; rcw - y.• .

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENERGY, MINERAL, AND LAND RESOURCES
GENERAL -PERMIT NO. NCGO60000
CERTIFICATE OF COVERAGE Ng, NCG060374
STORMWATER DISCHARGES
NATIONAL PQLLUTAN DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, and the North
Carolina Administrative Code in NCAC 15A 02H .0114(b)(1), as amended,
Mt. Olive Pickle Company
is hereby authorized to discharge stormwater from a facility located at
Mt. Olive Pickle Company
One Cucumber Blvd
Mt. Olive
Wayne County
to receiving waters designated as Barlow Branch, a class C; Sw water in the Cape Fear River
Basin, in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, 11, III, and IV of General Permit No. NCG060000 as attached,
and as amended in pages 2-3 of this Certificate of Coverage.
Amended conditions
1. This Certificate of Coverage is an enforceable part of the permit.
2. In accordance with 15A NCAC 02H .0114(b)(1), the monitoring program in Part 11
Section B Table 1 Analytical Monitoring Requirements of this permit is amended
as follows:

NCG060374
Map Scale 1: Z9, 000
Mt Olive Pickle Company
Mt Olive, NC
Latitude: 350 12' 14" N
Longitude: 780 3' 36" W
County: Wayne
Receiving Stream: Barlow Branch
Stream Class: C;Sw
Sub -basin: 03-06-21 (Meuse River Basin)
T T��IIi��`i��� �•�y*yr�
Facility Location

Georgoulias, Bethany
From: Kevin Campbell <[e-mail]>
Sent: Tuesday, October 04, 2016 10:23 AM
To: Moore, Bill
Cc: Georgoulias, Bethany; Edgerton, Thom
Subject: RE: Mt. Olive Pickle stormwater
Good Morning Bill,
Yes, Mt. Olive Pickle Company agrees to the vegetative buffer approach for area 2a. We will relocate items in this area
to at least 25 foot from the fence line and establish vegetative cover (grass) as we discussed during your site visit.
Kevin
From: Moore, Bill [mailto:[e-mail]]
Sent: Monday, October 03, 2016 12:13 PM
To: Kevin Campbell
Cc: Georgoulias, Bethany; Edgerton, Thom
Subject: RE: Mt. Olive Pickle stormwater
Good Morning Kevin,
We are OK with the designated 001, 002, & 003 stormwater outfalls as discussed during our site visit & listed in your
email.
Drainage area 2a (bone yard): Mostly sheet flow; vegetated buffer along fence line needs work. We discussed a
practical approach for this area: construct & maintain a minimum 25 ft vegetated buffer with sheet flow. Kevin, if you
agree, send me an email response, briefly stating this as MOP approach for this drainage basin. We will include this
along with the application to explain that this area does not have a designated sw outfall.
Drainage area 2b (storage building & gravel parking — NW portion of site): currently no regulated activity occurs in this
area; therefore, not a designated outfall/no sampling required at this time. We can discuss/revisit this question if MOP
engages in some future activity in this area.
Your site map included with your SP3 plan should show these designated outfall locations & descriptions. Let me know
if you have questions.
Bill Moore, Environmental Engineer
Land Quality Section
943 Washington Square Mall
Washington, NC 27889
[phone]
bill. [e-mail]
From: Kevin Campbell [mailto:kcampbell@mtolive_pickles.com]
Sent: Tuesday, September 13, 2016 12:57 PM

ONSEO 6Tq�
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
* REGION 4
ATLANTA FEDERAL CENTER
�y �s 61 FORSYTH STREET
.1 nnoTE ATLANTA, GEORGIA 30303-8960
CERTIFIED MAIL 7015 1730 0001 8044 3040 MAY 0 Z 2016
RETURN RECEIPT REQUESTED
Mr. Doug Brock
Vice President, Operations
Mount Olive Pickle Company
One Cucumber Boulevard
Mount Olive, North Carolina 28365
Re: Compliance Stormwater Evaluation Inspection
Mount Olive Pickle Company
Permit No.: NCG060000
Dear Mr. Brock:
On February 10, 2016, the U.S. Environmental Protection Agency Region 4 conducted a Compliance
Stormwater Evaluation Inspection (CSWED at the industrial facility, known as Mount Olive Pickle
Company, located at One Cucumber Boulevard, Mount Olive, Wayne County, North Carolina, 28365
for which Mount Olive Pickle Company, is the Owner and Operator. The purpose of the CSWEI was to
evaluate Mount Olive Pickle Company's compliance with the requirements of Sections 301 and 402(p)
of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p); the regulations promulgated thereunder
at 40 C.F.R. § 122.26; and the State of North Carolina's General Permit No.: NCG060000 to Discharge
Stormwater under the National Pollutant Discharge Elimination System for establishments primarily
engaged in Food and Kindred.
Enclosed is the EPA's CSWEI report. The EPA is continuing to analyze observations made during the
CSWEI and to evaluate Mount Olive Pickle Company's compliance with the CWA. As a result, the
EPA may be in further contact with Mount Olive Pickle Company in the future.
While a response from you is not required at this time, if you do wish to respond to the CSWEI report,
provide additional information, or otherwise discuss the report, please contact LCDR Tara Houda at the
above address or at [phone].
Sincerely,
Daniel J. O'Lone, Chief
Stormwater and Residuals Enforcement Section
NPDES Permitting & Enforcement Branch
Enclosures
cc: Mr. Bradley Bennett
North Carolina Department of Environmental Quality
GIRL Internet Address a htlpJ/www.epa.gov
Recycled/Recyclabla • Primed with Vegetable W l3md inks an Recycled Paper {Minimum 30% Postconsumer]

U.S. Environmental Protection Agency, Region 4
$ 61 Forsyth Street SW, Atlanta, GA 30303
Water Compliance Inspection
„,.�. P Pe Report
NPDES ID: NCG060000 Effective Date: 12/01/12 Ex iration Date: 10/31/17
Facility Name: Mount Olive Pickle Company__SIC Code: 2035
Address: One Cucumber Blvd., Mt. Olive, NC 28365
On -Site Representative(s), Title, Phone Number: Responsible Official, Title, Phone Number, Mailing Address:
Doug Brock, Vice President — Operations Doug Brock, Vice President — Operations
919-658-2535 919-658-2535
One Cucumber Blvd., Mt. Olive, NC 28365
INSP
Entry Date/Time: 2/10/2016 3:13 pm Exit Date/Time: 2110C2016 5:40 pm
Tara Houda (EPA), Kenneth Kwan (EPA), Jodi Pace (NCDENR), Evangelyn Lowery -Jacobs (NCDENR)
Permit Self-Com liance Program Pretreatment
Records Compliance Schedule Pollution Prevention
Facility Site Review Laboratory X Storm Water
Effluent / Receiving Waters Operations & Maintenance Combined Sewer Overflow
Flow Measurement Sludge Handlinr Sanitary Sewer Overflow
The facility pickles cucumbers in open air tanksivats. The facility has 2 cooling water permits, 1 wastewater permit, and no industrial
stormwater permit (NCG060000). Vehicle maintenance is conducted onsite. The site stated that they treated 86 million gallons of
rainwater last year from the tank area that drains to wastewater. Treated wastewater goes to city stormwater and then. to Barlow
Branch. Uncovered dumpsters containing filter press solids drain towards the east and then south via stormwater drains. One exposed
storage area ("bone yard") drains westward offsite towards the armory and a ditch. A second exposed storage area ("laydown yard")
drains westward offsite toward Chestnut Street. The area for employee parking outside of wastewater drainage received 1-3 tanker
trucks of vinegar per day and I tanker truck of alum every couple of weeks and does not have a spill kit. This area has 2 storm drains
that letive the site. Storm drains on the southeastern side of the site drains operations involving rail cars. According to a facility
representative, stormwater runoff from the boneyard discharges to the city storm system (see photo DSCN079I), The stormwater
from the vinegar and alum unloading area drains to the city storm system (see photos DSCN0801 and DSCN0802). The facility has
industrial activities exposed to stormwater (see laydown yard photos DSCN0792, DSCN0794-0796, corn syrup car photos
DSCN0809-0810, and vinegar and alum unloading area photos DSCN0801-0803). Based on these observations, preliminary review
indicates int source die s and exposed industrial activities.
Inspector. Signature/Name Office/Phone Number Date
44-ec.. A244=
USEPA Region 4/WPD-CWEB-SRES
404-562-9762
Tara Houda, Environmental Scientist
USEPA Region 41WPD-CWEB-SItE5
404-562-9752
Kenneth Kwan, Environmental Engineer
Management Signawre/N a
Office/Phone Number
Date
USEPA Region 4/WPD-CWEB-SITES
404-562-9434
Daniel J. O'Lon-e hief
Stormwater and Residuals Enforcement Section
Page 1 of 2

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Mount Olive Pickle Company Industrial
Stormwater Inspection
Unpenmitted
Febuary 10, 2016
U5 EPA - Region 4
Overview Me
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,�' 'V7�ti CK� y Otis +' !�;'`•'tki%.' �� ;' r�,.�. 'i'.' :','F'..
Mount Olive Pickle Company
Page 1 of 36

Georgoulias, Bethany
From: Moore, Bill
Sent: Monday, October 03, 2016 12:13 PM
To: Kevin Campbell
Cc: Georgoulias, Bethany; Edgerton, Thom
Subject: RE: Mt. Olive Pickle stormwater
Good Morning Kevin,
We are OK with the designated 001, 002, & 003 stormwater outfalls as discussed during our site visit & listed in your
email.
Drainage area 2a (bone yard): Mostly sheet flow; vegetated buffer along fence line needs work. We discussed a
practical approach for this area: construct & maintain a minimum 25 ft vegetated buffer with sheet flow. Kevin, if you
agree, send me an email response, briefly stating this as MOP approach for this drainage basin. We will include this
along with the application to explain that this area does not have a designated sw outfall.
Drainage area 2b (storage building & gravel parking — NW portion of site): currently no regulated activity occurs in this
area; therefore, not a designated outfall/no sampling required at this time. We can discuss/revisit this question if MOP
engages in some future activity in this area.
Your site map included with your SP3 plan should show these designated outfall locations & descriptions. Let me know
if you have questions.
Bill Moore, Environmental Engineer
Land Quality Section
943 Washington Square Mall
Washington, NC 27889
[phone]
[e-mail]
From: Kevin Campbell (mailto:[e-mail]]
Sent: Tuesday, September 13, 2016 12:57 PM
To: Moore, Bill <[e-mail]>; Edgerton, Thom <[e-mail]>
Cc: Fletcher Arritt <farritt@mtolivepickles. com>
Subject: Mt. Olive Pickle stormwater
Bill and Thom,
Thank you for your time and assistance this morning. I believe we all agreed that Mt. Olive Pickle Company will have 3
stormwater discharge outfalls. The first outfall, labeled 001, will be the laydown yard located in the west corner of the
property. The sample will be collected from the drop inlet located in the area. The second outfall, labeled 002, will be
located in the front of the property. The sample will be collected from the drop inlet already used for our non -contact
cooling water sample collection. The third outfall, labeled 003, will be located in the southern portion of the property at
the corner of the administrative parking lot across from the gift shop. The sample will be collected from the drop inlet
located there and will give a representative sample of the vinegar and alum unloading area. The remaining issues from

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Friday, September 23, 2016 2:44 PM
To: Moore, Bill
Cc: Edgerton, Thom; Dumpor, Samir; Bennett, Bradley; Grzyb, Julie
Subject: RE: Mt. Olive Pickle stormwater
2M
See my responses below. Let's talk next week when you are in the office.
Thanks,
Bg
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.georL,oulias@nedenr.p,ov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://porta1.ncdenr.org/web/Ir/stormwater
z
Nothing Cornpares,-,-
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Moore, Bill
Sent: Thursday, September 22, 2016 10:12 AM
To: Georgoulias, Bethany<[e-mail]>
Cc: Edgerton, Thom <[e-mail]>; Dumpor, Samir <[e-mail]>
Subject: FW: Mt. Olive Pickle stormwater
Good Morning Bethany, hope all is well with the SW group,
Thom & I visited Mt Olive Pickle last week. We looked at the drainage basins & outfalls and agreed on the (3) designated
outfalls referenced in Kevin's email. There were a couple of drainage basins that raised some questions & we wanted
input from CO.
First let me make sure I have the outfalls correct from Kevin's confirmation. Here's what they sound like to me:
001—that isolated corner used as a laydown yard, labeled as Drainage Area 7 (DA7) on the site plan.

Bill Moore, Environmental Engineer
Land Quality Section
943 Washington Square Mall
Washington, NC 27889
[phone]
[e-mail]
From: Kevin Campbell[mailto:[e-mail]]
Sent: Tuesday, September 13, 2016 12:57 PM
To: Moore, Bill <[e-mail]>; Edgerton, Thom <[e-mail]>
Cc: Fletcher Arritt <fa rritt@ mtolivepickles.com>
Subject: Mt. Olive Pickle stormwater
Bill and Thom,
Thank you for your time and assistance this morning. I believe we all agreed that Mt. Olive Pickle Company will have 3
stormwater discharge outfafls. The first outfall, labeled O01, will be the laydow_n yard located in the west corner of the
property. The sample will be collected from the drop inlet located in the area. The second outfall, labeled 002, will be
located in the front of the property. The sample will be collected from the drop inlet already used for our non -contact
cooling water sample collection'The third outfall, labeled 03, wilfbe located in the southern portion of the property at
the corner of the administrative_parking lot across from the gift shop. The sample will be collected from the drop inlet
located there and will give a representative sample of the vinegar and alum unloading area. The remaining issues from
the EPA site inspection have either been addressed or are in the process of being addressed, and we will take your
advice regarding the vegetative buffer areas.
Please let me know what decisions are made concerning area 2b.
SDO 001 35" 12'
17"
N 78" 3' 45"
W
SDO 002 35° 12'
15"
N 780 3' 33"
W
SDO 003 35° 12'
12"
N 78' 3' 38"
W
Thanks again,
Kevin

Georgoulias, Bethany
From: Moore, Bill
Sent: Thursday, September 22, 2016 10:12 AM
To: Georgoulias, Bethany
Cc: Edgerton, Thom; Dumpor, Samir
Subject: FW: Mt. Olive Pickle stormwater
Good Morning Bethany, hope all is well with the SW group,
Thom & I visited Mt Olive Pickle last week. We looked at the drainage basins & outfalls and agreed on the (3) designated
outfalls referenced in Kevin's email. There were a couple of drainage basins that raised some questions & we wanted
input from CO.
(1) Drainage ar. a 2B I sated at NW corner of site is an existing metal bldg. &gravel parking. This area is not in use
(no process,i o•exposure issues); sw sheet flows across gravel drive to adjacent grassed ditch. We could say that
this area represents a different use from the other drainage basins and maybe should be sampled. MOP could
establish a reasonable sample point, do the qualitative monitoring & report no discharge 2/yr. Or, should we
tell them as long as no processing/no exposure; eliminate this as a designated outfall. My question is have we
allowed othe:2AA
stries to eliminate designated outfalls based on similar circumstances?
(2) Drainage ar a I sated at NW corner of site is an existing open yard laydown area used to store various
materials. a is used on a continuing basis & does have exposure. SW runoff is sheet flow thru an
existing vegetated buffer that is somewhat established; but, would need some additional work to claim sheet
flow along entire length of fenced area. Should we tell MOP establish & maintain a minimum 30 ft veg buffer
with sheet flow & eliminate this drainage basin from sampling requirements ? MON other choice would be
construct collection system & direct sw back to WWTP. What do you think ?
Do we call Ken back for a consult ? I am in the office today. [phone], or 809-3388 cell.
Bill Moore, Environmental Engineer
Land Quality Section
943 Washington Square Mall
Washington, NC 27889
[phone]
[e-mail]
From: Kevin Campbell[mailto:[e-mail]]
Sent: Tuesday, September 13, 2016 12:57 PM
To: Moore, Bill <[e-mail]>; Edgerton, Thom <[e-mail]>
Cc: Fletcher Arritt <[e-mail]>
Subject: Mt. Olive Pickle stormwater'�
Bill and Thom,
Thank you for your time and assistance this morning. I believe we all agreed that Mt. Olive Pickle Company will have 3
stormwater discharge outfalls. The first outfall, labeled 001, will be the laydown yard located in the west corner of the
property. The sample will be collected from the drop inlet located in the area. The second outfall, labeled 002, will be
located in the front of the property. The sample will be collected from the drop inlet already used for our non -contact
cooling water sample.collection. The third outfall, labeled 003, will be located in the southern portion of the property at
IIJlvS
1�

Georgoulias, Bethany
From: Grzyb, Julie
Sent: Monday, August 15, 2016 10:13 AM
To: Georgoulias, Bethany
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
The Chloride standard for C waters is still 230 mg/L and it is the only parameter that the action level policy still applies
too. However, when the next Triennial Review goes through we expect to lose the action level policy for chloride as
well. The only reason it was maintained was due to an error in the way it was listed in the 2007-2014 Triennial Review.
(ie. It was a fluke)
So when I say Mt. Olive Pickle has a chloride variance (which is the way it has been presented to EMC and I don't know
why) it really is being relieved of passing it's toxicity tests. Of course, it is failing because of the chlorides so it's all
connected.
The current chloride limitations in the permit are 13,055 Ibs/day as a monthly average and 22,622 Ibs/day as a daily
max. At a permitted flow of 0.40 MGD this translates to:
13,055 ibs/day _ (0.40 MGD * 8.34) = 3913.4 mg/L as monthly average,
And
22,622 Ibs/day : (0.40 MGD * 8.34) = 6781.2 mg/L. as a daily max
It's only listed as Ibs/day in the permit.
Hope this answers your question.
Julie
From: Georgoulias, Bethany
Sent: Monday, August 15, 2016 9:52 AM
To: Grzyb, Julie <[e-mail]>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Julie,
What's the standard for chloride in a C stream that Mt. Olive has a variance on? We have a benchmark value based on
EPA's recommended water quality criteria. There was an action level (230 mg/1) in the past... I'm not sure if this is even
current anymore after Triennial Review. Is that 230 mg/l what applies to these receiving waters?
Thanks,
Bg
13ethauy Georgoulias
isnvironmental 1 ngineer
StormNvater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of l nvironmental Quality
919 807 6372 office
bethany.georizouhas a ncdenn rov

From: Grzyb, Julie
Sent: Friday, August 12, 2016 2:24 PM
To: Georgoulias, Bethany<[e-mail]>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Keep in mind they have a variance for chlorides{ toxicity tests.
Julie
From: Georgoulias, Bethany
Sent: Friday, August 12, 2016 9:14 AM
To: Houda, Tara <Houda,Tara epa.gov>
Cc: Bennett, Bradley <bradle .bennett ncdenr. ov>; Grzyb, Julie <iulie-grzub@ncde�nr.gov>; Lin, Jing
<iin .Iin ncdenr. ov>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Thank you, Tara. I believe the mercury TMDL is a statewide one (to address all NC waters) and references source
reductions being achieved through air quality projected reductions in emissions (and thus air deposition to waters). It's
been a while since I was involved with that, but it's not something we typically address in NPDES stormwater permits
except for potential direct discharge sources we regulate (e_g., power plants)_ We will consider supplementing
monitoring with chlorides at at least some of the stormwater outfails at Mt. Olive.
Thanks,
Bethany
I3ethany Georgoulias
I-Invironmental 13ngineer
Storinwater Program, Division ol' Energy, Mineral, and Land Resources
N.C. Depailment of Environmental Quality
919 807 6372 office
bethany.geor og ulias(@ nedenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Streel, Raleigh, NC 27604 (location)
Websitc: http://12ortal,ncdenr.org/web/Ir/stormwater
NC_ -!:�Nothing Compares..%,
En7ail correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Houda, Tara [[e-mail]
Sent: Friday, August 12, 2016 7:31 AM
To: Georgoulias, Bethany <bethan eor oulias ncdenr. ov>
Cc: Bennett, Bradley <bradley.bennett@ncdenr.g v>; Grzyb, Julie <iulie. rzyb@ncdenr. ov>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection

To: Pickle, Ken <[e-mail]>; Georgoulias, Bethany<[e-mail]>
Cc: Kwan, Kenneth <[e-mail]>; Wahlstrom-Ramler, Meghan <Wahlstrom-Ramler.Me han a a. ov>; Olone,
Dan <[e-mail]>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Ken & Bethany,
I've been working on the Mount Olive Pickle Company case a bit more and had another
thought about their obtaining industrial stormwater permit coverage that I want to share.
Table I of the general Food Permit (NCG060000) includes Analytical Monitoring for pH, Total
Suspended Solids, Oil & Grease, Fecal Coliform, Entercococci, Chemical Oxygen Demand, &
Total Rainfall. There is no mention of Chlorides. Considering the history of the Chlorides
impairment in the receiving waterbody and the history of a Chlorides limits in their
wastewater permits, it seems likely that it would be appropriate to include monitoring &/or a
benchmark for Chlorides in their industrial stormwater permit coverage.
From: Houda, Tara
Sent: Wednesday, May 11, 2016 9:10 AM
To: 'Pickle, Ken' <ken.pickle@ncdenr. ov>; Georgoulias, Bethany<[e-mail]>
Subject: copy of Mt Olive Inspection report
Please see the attachment.
6]

Geor oulias, Bethany
From: Georgoulias, Bethany
Sent: Friday, August 12, 201610:30 AM
To: 'Carl Scharfe'
Cc: Grzyb, Julie; Moore, Bill; Vinson, Scott; Tankard, Robert; Kevin Campbell
Subject: NOI information for Mt. Olive - Barlow Branch
Hi Carl,
We noticed on the NOI for the NCG06 General permit that the form noted Barlow Branch with no impairments or
TMDLs. I'm not sure if you were aware of where to find those, but if not, I wanted to share the map viewer on DWR's
website where you can search for that information (303(d)/Integrated Report viewer).
Barlow Branch is actually impaired for chlorides, as you can see in the screen shot below. (It is impaired for mercury,
too, but there's a statewide TMDL to address that, and it's mostly attributable to air deposition from emissions coming
from elsewhere —so not as much of an issue in this particular case.)
NC
2014 Overall Category NC
AU #: 18-74-2 Sul
Stream Barlow Branch
ro Name:
1 Overall Cat.: Impaired (Cat 4)
Classification: C,Sw
Subbasin: Northeast Cape Fear
River
1
Zoom to • • •
i

Georgoulias, Bethany
From: Houda, Tara <[e-mail]>
Sent: Friday, August 12, 2016 7:31 AM
To: Georgoulias, Bethany
Cc: Bennett, Bradley; Grzyb, Julie
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
I'm reviewing Mt. Olive Pickle's response to our 308 information request and noticed
something that will likely be of interest to your office. Page 2 of their NOI states that Barlow
Branch is not 303(d) listed and does not have TMDLs. I believe Barlow Branch (Waterbody ID
NC18-74-2) has 2 impairments (Chlorides and Mercury) and has a TMDL for Mercury. Just an
FYI for whomever is working on their permit coverage. Probably another good reason to
require them to sample Chlorides as part of their stormwater permit.
From: Georgoulias, Bethany[mailto:[e-mail]]
Sent: Thursday, July 07, 2016 9:00 AM
To: Houda, Tara <[e-mail]>
Cc: Kwan, Kenneth <[e-mail]>; Wahlstrom-Ramler, Meghan <[e-mail]>; Olone,
Dan <[e-mail]>; Bennett, Bradley <[e-mail]>; Grzyb, Julie <[e-mail]>
Subject: RE: unpermitted Mt Olive industrial stormwater inspection
Ta ra,
I wanted to update you on Mt. Olive. We received our copy of EPA's NOV to Mt. Olive earlier this week. We also
(finally) received Mt. Olive's NOI for coverage under General Permit NCG060000 in our office yesterday. I'll be working
with Julie Gryzb in DWR's NPDES Wastewater Permitting program as we process this application; she is working on the
company's wastewater individual permit renewal for this plant.
Also, just as an FYI — Ken Pickle retired on June 30", so I'm the primary Stormwater Program contact for this project.
Best regards,
Bethany
13etlsas4y Georgoulias
Environniuntal Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. I]epailinenl of I-nvironmenud Quality
919 907 6372 office
bet hany.geor god, uliasnnedenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Wcbsite: http://portal.ncdenr.org/web/Ir/stonnwater

THE Memorandum
W O OT E N TO: Julie Grzyb, NCDEQ NPDES Permitting
COMPANY Bethany Georgouhas, NCDEQ Stormwater Permitting
Bobby Frye, The Mt. Olive Pickle Company
E N G I N E E R I N G Fletcher Arritt, The Mt. Olive Pickle Company
Bill Bryan, The Mt Olive Pickle Company
P L A N N I N G Kevin Campbell, The Mt Olive Pickle Company
A R C H I T E C T U R E FROM: Carl Scharfe, The Wooten Company
Peter Galan, The Wooten Company
DATE: July 21, 2016 Conference Call
SUBJECT: NCG060000 General Storm Water Permit for Mt. Olive Pickle
Company Main Production Plant
A Notice of Intent (NO]) for a general storm water permit was submitted by The Wooten
Company on behalf of the Mt. Olive Pickle to the NCDEQ stormwater permitting section
on July 6, 2016. This conference telephone call was held between the people listed above
to clarify issues related to the NOI and the nature of industrial activities and storm water
flows at the Main Production Plant. The drainage areas on the site map submitted with
the NO] was referenced during the call. This memo details the decisions reached
regarding The Mt. Olive Pickle Company's stormwater permit at this time. The main
discussion points were as follows:
• Drainage Area 2a: This area has sheet flow for storm runoff and Ms. Georgouhas
indicated that due to this fact this area does not need to be included in the
stormwater permit coverage area. Bethany will seek concurrence on this
detennination (as necessary) with EPA.
• Drainage Area 5: This area needs to be sampled and covered in either the NPDES
wastewater permit or the general stormwater permit. The quantity and location
of sampling points will be determined upon a future visit from representatives of
the DEQ Washington Regional Office. Emphasis will be on determining
representative storm water inlets that can be used to sample stormwater before it
mixes with process water.
• Drainage Area 6: This majority of this area is an employee parking lot not
associated with industrial activity. However, there is a vinegar and alum
unloading area located in Area 6. Mt. Olive is concerned with spills/runoff from
this area and proposed redirecting this flow to the WWTP (— 7,000 gallons for
120 North Boylan Avenue the I0-year 24-hr storm event). However, Ms. Grzyb is not in favor of sending
Raleigh NC 27603-i423 more flow to the WWTP and instead indicated utilizing BMPs for this unloading
operation and including the area in the general stormwater permit. A single
sampling point representative of potential impact from the unloading area would
919.828.0531 be selected. A single sampling point near the unloading will have to be
lax 919.834.3589

Georgoulias, Bethany
From: Grzyb, Julie
Sent: Monday, July 25, 2016 12:26 PM
To: Tankard, Robert; Moore, Bill
Cc: Vinson, -Scott; Bullock, Robert; Georgoulias, Bethany
Subject: I.Jnpermitted Storm water discharges at Mt. Olive Pickle
Robert and Bill,
Bethany is out on vacation this week and she asked that I let you know about the conference call we had with Mt. Olive
Pickle personnel. Here is an update on Mt. Olive Pickle and the unpermitted storm water discharges:
On July 6, 2016 Storm Water received an application (NOI) for General Permit NCG060000 from Mt. Olive Pickle.
July 21, 2016 — Conference call between Bethany Georgoulias and Julie Grzyb of DWR and Bobby Frye, Kevin Campbell,
Fletcher Arritt, and Bill Bryan of Mt. Olive Pickle and their consultants Carl Scharfe and Peter Galan of Wooten Co.
The Company's goal in this application was to divert most of the storm water to the Wastewater treatment plant. DWR
asked if this was contaminated storm water and why they would want to divert uncontaminated storm water to the
already over loaded WWTP during heavy rainfall events. Mt. Olive Pickle did not have data on the unpermitted
discharges and they did not want to do extra sampling. They were informed that the storm water would have to be
sampled and covered, in either permit (wastewater or storm water), and that a BMP program needed to be inserted into
a permit and implemented.
Some misunderstandings were cleared up — Mt. Olive Pickle was informed that storm water permits do not have permit
limits but instead have benchmark goals. Further they were informed that if sampling showed contamination in
discharges that could not be fixed with adequate BMP procedures the storm water could then be considered for
diversion to the WWTP.
The conversation concluded with the following agreement:
Storm water discharges from Drainage Areas 6 (the unloading pad) and 7 would be put under the General Permit
NCG060000. Mt. Olive Pickle is concerned with the runoff from the unloading pad in Drainage Area 6 and was
considering redirecting the runoff to the WWTP; DWR suggested that they implement a BMP program at this unloading
pad and keep it under the storm water General Permit for now.
Storm water from Drainage area 2a is considered sheet runoff and does not appear to require a permit. This is to be
verified by DWR staff.
Storm water in Drainage Area 5 needs to be sampled and covered in either the NPDES wastewater permit or the storm
water General Permit. Bethany recommended that either she or other storm water staff go visit the site to see if
representative storm water outlets can be appropriately sampled prior to mixing with process water.
Bethany and I will follow-up on this when she returns from vacation — the week of August 15t
Julie A Grzyb
Environmental Engineer
NC DEQ / Division of Water Resources 1 Water Quallity Permitting
NPDES Complex Permitting, Wastewater Branch

J�`j�a srgT�s
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
QW,
z REGION 4
ATLANTA FEDERAL CENTER
: o= 61 FORSY-111 STREET
��?qE AIiOSF.�` ATLANTA, GEORGIA 30303-8960
CERTIFIED MAIL 7015 1730 0001 8044 3521
RETURN RECEIPT REQUESTED RECEIVED
Mr. Doug Brock JUL 0 5 2016
Vice President— Operations
Mount Olive Pickle Company, Inc. DENR-LAND QUALITY
One Cucumber Boulevard STORMWATER PERMITTIING
Mount Olive, North Carolina 28.365
Re: Notice of Violation, Opportunity to Show Cause, and Information Request Pursuant to Section 308
of the Clean Water Act (CWA) for Mount Olive Pickle Company, Inc., in Mt. Olive, North Carolina,
Pursuant to Section 309(a) of the CWA, 33 U.S.C. §§ 1319(a) and 1318
Dear Mr. Brock:
On February 10, 2016, the U.S. Environmental Protection Agency Region 4 conducted a Compliance
Stormwater Evaluation Inspection (CSWEI) at the facility located at One Cucumber Boulevard, Mount
Olive; Wayne County, North Carolina, 28365 (Facility), known as "Mount Olive Pickle Company," for
which Mount Olive Pickle Company, Inc. (Mount Olive), is both the Owner and Operator. The purpose
of the CSWEI was to evaluate Mount Olive's, compliance with the requirements of Sections 301 and
402(p) of the Clean Water Act (CWA), 33 U.S.C. §§ 1311 and 1342(p) and the regulations promulgated
thereunder at 40 C.F.R. § 122.26.
The CSWEI, as described in the report mailed on May 2, 2016, and subsequent investigative efforts
have revealed that Mount Olive failed to comply with the requirements of Section 301 of the CWA, 33
U.S.C. § 1311, and its implementing regulations at 40 C.F.R. § 122.26. Specifically, the EPA hereby
notifies Mount Olive, pursuant to Section 309(a) of the CWA, 33 U.S.C. § 1319(a), of the following
findings of violations;
From October 1, 1992 to May 11, 2016, stormwater associated with industrial activity generally
discharged from the Facility via an MS4 into navigable waters, as defined by Section 502(7) of
the CWA, 33 U.S.C. § 1362(7), and its implementing regulation 40 C.F.R. § 122.2. Section
301 (a) of the CWA, 33 U.S.C. § 1311(a), prohibits the discharge of pollutants by any person into
navigable waters except in compliance with a National Pollutant Discharge Elimination System
(NPDES) permit issued pursuant to Section 402 of the CWA, 33 U.S.C. § 1342. Such discharges
of stormwater to waters of the United States were not authorized by a NPDES permit and,
therefore, are violations of Section 301 of the CWA, 33 U.S.C. § 1311.
Internet Address (URL) • ht1p7//www.epa.gov
Recycled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (MInimum 30% Postconsumer)

Mount Olive should be prepared to provide all relevant information with supporting documentation
pertaining to the violations, including but not Jimited to any financial information which may reflect an
inability to pay a penalty.
All information submitted in response to the information request and/or during the show cause meeting
must be accompanied by the following certification that is signed by a duly authorized official in
accordance with 40 C.F.R. § 122.22.
"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 gather and evaluate 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. 1 am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for -
knowing violations."
Please be aware that the EPA may use information provided during the meeting or telephone conference
and/or in response to this information request in any enforcement proceeding related to this matter.
Notwithstanding the scheduling of show cause meeting, the EPA retains the right to bring further
enforcement action under Section 309 of the CWA, 33 U.S.C. § 1319, for the violations cited herein or
for any other violation of the CWA.
Enclosed is a document entitled U.S. EPA Small Business Resources -Information Sheet to assist Mount
Olive in understanding the compliance assistance resources and tools available to it. Any decision to
seek compliance assistance at this time, however, does not relieve Mount Olive of its obligation to the
EPA nor does it create any new rights or defenses and will not affect the EPA's decision to pursue
enforcement action.
In addition, the Securities and Exchange Commission (Commission) requires its registrants to
periodically disclose environmental legal proceedings in statements fled with the Commission. To assist
Mount Olive, the EPA has also enclosed a document entitled Notice of Securities and Exchange
Commission Regisirants 'Duly to Disclose Environmental Legal Proceedings.
Please contact Ms. Houda at [phone] to arrange a show cause meeting, and to address any
questions or concerns you may have. Legal inquiries should be directed to Ms. Kavita K. Nagram,
Associate Regional Counsel, at [phone].
Sincerely,
James D. Giattina
Director
Water Protection Division
Enclosures
cc: See Attached Mailing List

ENCLOSURE A
INFORMATION REQUEST PURSUANT TO SECTION 308 OF THE CLEAN WATER ACT
Instructions
] . Identify the person(s) responding to this Information Request.
2. Please provide a separate narrative response to each and every Question and subpart of a
Question set forth in this Information Request.
3. Precede each answer with the text and the number of the Question and its subpart to which the
answer corresponds.
4. All documents submitted must contain a notation indicating the Question and subpart of the
Question to which they are responsive.
5. In answering each Information Request Question and subpart thereto, identify all documents and
persons consulted, examined or referred to in the preparation of each response, and provide true
and accurate copies of all such documents.
6. If information not ]mown or not available to you as of the date of submission of a response to
this Information Request should later become known or available to you, you must supplement
your response to the EPA. Should you find at any time after the submission of your response that
any portion of the submitted information is false or misrepresents the truth, you must notify the
EPA as soon as possible.
7. For each document produced in response to this Information Request, indicate on the document,
or in some other reasonable manner, the number of the Question to which it responds.
8. Where specific information has not been memorialized in a document, but is nonetheless
responsive to a Question, you must respond to the Question with a written response.
9. If information responsive to this Information Request is not in your possession, custody or
control, then identify the person from whom such information may be obtained.
10. If you have reason to believe that there may be persons able to provide a more detailed or
complete response to any Question or who may he able to provide additional responsive
documents, identify such persons and the additional information or documents that they may
have.
11. The EPA requests that all documents provided in an electronic format be compatible with pdt:
12. The EPA requests that all spreadsheet information be in an electronic format and compatible
with MS Excel,
13. If any Question relates to activities undertaken by entities other than the recipient of this
Infornnation Request, and to the extent that you have information pertaining to such activities,
provide such information for each entity.

uestions
Identify the names and addresses of the current owner(s) of the Facility properties. Specify the
legal name with the exact spelling of each owner. Provide the mailing address and phone number
for each owner. Specify the state of incorporation and principal place of business for each
corporate owner. If incorporated, provide the name and mailing address of' the registered agent.
Additionally, provide a copy of the deeds of ownership of the Facility properties.
2. Specify the number of acres of the Facility.
3. Provide the number of employees that work at this Facility.
4. Provide the number of Facilities owned or operated by Mount Olive Pickle Company, the
address of each Facility, the applicable SIC Code(s), permit numbers of any applicable industrial
stormwater NPDES permits, and the type of ownership.
5. Provide the date the Facility began operation at this location.
6. Provide the names of any known receiving waterbodies and/or Municipal Separate Storm Sewer
Systems (MS4s). Provide the names of waterbodies and/or MS4s listed in other Clean Water Act
permits that app]y to this facility and the associated permit name and number.
7. Provide a copy of any existing maps that contain wastewater, cooling; water, or stormwater pipes
and/or direction of flow information. Describe the means by which the water is discharged (i.e.
pipe, ditch, Swale, etc.).
8. Provide any internal compliance audits or environmental assessments regarding; stormwater
issues and runoff controls.
9, Provide a copy of any Facility inspection reports, notices of violations, administrative orders,
cease and desist orders, and any related correspondence from local, State or federal agencies
related to industrial stormwater activities at the Facility.
10. Provide a copy of any permit(s) issued by the United States Army Corps of Engineers (Corps)
related to construction activities at the Facility, copies of any applications for such permit(s) and
any related correspondence with the Corps.
11. Provide all documentation pertaining, to delineation of wetlands at the Facility, whether prepared
by the Corps or by another entity.
12. Provide the current state of industrial stormwater permit coverage.
a. if permit application is ongoing, provide a copy of documents associated with obtaining;
authorization under the current Permit.
b. Provide a copy of the NPDES coverage notice obtained from the Slate of North Carolina.
c. If no permit was obtained, provide a detailed explanation of the reason(s) for not
obtaining authorization under an NPDES permit.
d. Identify any currently know expected capital costs and/or operation and maintenance
costs associated with obtaining and complying with the Permit_

Georgoulias, Bethany
From: Grzyb, Julie
Sent: Monday, July 25, 2016 12:47 PM
To: Carl Scharfe ([e-mail]); [e-mail]
Cc: Georgoulias, Bethany; Tankard, Robert; Moore, Bill; Vinson, Scott; Bullock, Robert
Subject: Unpermitted Storm water discharges at Mt. Olive Pickle
Carl and Kevin,
Bethany was leaving for vacation last Friday but she was hoping I could summarize the conclusion we discussed on the
conference call with Mt. Olive Pickle. The purpose of the call was to discuss the application (NOI) received from Mt.
Olive Pickle on July 6, 2016 for a Storm water General Permit NCG060000.
July 21, 2016 — Conference call between Bethany Georgoulias and Julie Grzyb of DWR and Bobby Frye, Kevin Campbell,
Fletcher Arritt, and Bill Bryan of Mt. Olive Pickle and their consultants Carl Scharfe and Peter Galan of Wooten Co.
The conversation concluded with the following agreement:
Storm water discharges from Drainage Areas 6 (the unloading pad) and 7 would be put under the General Permit
NCG060000. Mt. Olive Pickle is concerned with the runoff from the unloading pad in Drainage Area 6 and was
considering redirecting the runoff to the WWTP; DWR suggested that they implement a BMP program at this unloading
pad and keep it under the storm water General Permit for now. A sampling point will have to be agreed upon when
DWR staff visit. DWR does not want additional storm water sent to the WWTP if it can be avoided. Mt. Olive Pickle has
stated in the past that "any reduction in the daily maximum chloride discharge limitation would be a serious hardship,"
citing rainfall events as producing a spike in this figure. DWR has reduced the daily maximum chloride discharge
limitation with every permit renewal and expects to do the same with the next renewal.
Storm water from Drainage area 2a is considered sheet runoff and does not appear to require a permit. This is to be
verified by DWR staff.
Storm water in Drainage Area 5 needs to be sampled and covered in either the NPDES wastewater permit or the storm
water General Permit. Bethany recommended that either she or other storm water staff go visit the site to see if
representative storm water outlets can be appropriately sampled prior to mixing with process water.
Bethany and I will follow-up on this when she returns from vacation —the week of August 111.
Please let me know if you have any comments or concerns with my summary.
Thanks,
Julie
Julie A Grzyb
Environmental Engineer
NC DEQ 1 Division of Water Resources 1 Water Quallity Permitting
NPDES Complex Permitting, Wastewater Branch
919 807 6389 office
919 707 9000 main office
[e-mail]
Physical Address: 512 North Salisbury St.,Raleigh, NC, 27604
Mailing Address: 1617 Mail Service Center, Raleigh, NC, 27699-1617

July 6, 2016
Ms. 13ethany Georgoulias
TfT Environmental Engineer
THEStormwater Permitting Unit Program
Division Q of I-ncrgy, Mineral, and [.,arid Resource
WOOTEN s
NCDE
1612 Mail Service Center
COMPANY
Raleigh, NC 27699-1612
ENGINEERING
Ite: NOI for NCG060000
P L A N N I N G The Mt. Olive Pickle Company Main Production F,.icility
Mount Olive, North Carolina
ARCh41TE0TURE TWCNo. 2395-0
Dear Ms. Georgoulias:
On behalf of The Mt. Olive Pickle Company, please find enclosed for your review
and approval the Notice of Intent (NOI) for coverage under the National PDllution
Discharge Elimination System Stormwater General Permit NCG060000 for the
above referenced project. Also enclosed is a project map showing existing
stormwater drainage areas for the facility. The existing stormwater discharge points
that are associated with industrial activity are labelled with an asterisk on this map.
The Mt, Olive Pickle Company Production Plant site has been divided up into eight
(8) drainage areas based on the topography and paved areas on the site. Of the eight
drainage areas on the site, Drainage Areas 1, 2b, 3,7and 4 "do not require permit
coverage, as storniwatcr flow from these areas is redirected to the on -site
wastewater treatment plant (WWTP) for treatment and discharge under the existing
wastewater NPDES discharge permit. A description of all the facility drainage
areas is provided below:
• Drainage Area l includes the paved area to the rear of the production plant
and the majority oftlre main building roof. A combination of collection pits
and lift stations pump stormwater runoff from this drainage area to the on -
site W WTP where the stormwater is treated (along with process water) in
the treatment plant. Some of the stormwater runoff from Drainage Area 1
can be diverted to Storm Ponds 3 and 4 (see the attached map) during heavy
storms and then be bled back into the wastewater treatment ponds.
• Drainage Area 2a is located on the northwest corner of the site property,
southeast of' Drainage Area 2b. This is a grass} area used to stare empty
stacked plastic bins.. wood pallets, old process tanks (not currently in use),
dunipstcrs tised to store scrap wood, and miscellaneous empty plastic drums
(referred as the lay down yard or boncyard). Because these items were once
used in production, the EPA views this area as part of the industrial process.
120 North Boylan Avenue Stormwater from this lay down yard flows in general overland sheet flow to
Raleigh NC 27603-1423 the south and then onto the adjacent property owned by the North Carolina
National Guard Armory. The laydown yard is a potential source of impact
919.828.0531
tax 919.834.3589

to stormwater that falls and runs off of this area. Drainage Area 2b is composed of the storage
building located at the northwest corner of the property. Any stormwater generated here flows by
overland flow off the property to the northwest. However, there are no activities in this area
associated with industrial activity. Drainage Area 2b is separated from Drainage Area 2a by a
chain link fence installed on higher ground: as this fence line is constructed at an elevated point
relative to Drainage Area 2a, it acts as a runoff divide between Drainage Areas 2a and 2b.
• Drainage Area 3 is composed of the area around the treatment ponds for the W WTP and the
ponds themselves. The terrain is contoured such that stormwater drains directly into these ponds
From the top of the berms.
• Drainage Area 4 is also composed of the area around a treatment pond, and it also includes the
WWTP and all of the structures associated with it. 'fhcre are a number of open top dumpsters
located near the edge of the Drainage Areas - stormwater that falls on these dumpsters drain to
the pond. Any stormwater falling in this area is contained in the ponds/tank or is sloped towards
the ponds.
• Drainage Area 5 is the paved area south of the main plant (including; the part of the main building
roof sloped towards this area). Stormwater runoff in Drainage Area 5 drains to the storm inlets in
the area and then to the main conveyance pipe running; parallel to the Main Building. The main
drainage pipe also receives non -contact cooling water from the production processes (Outfall 02
and 03) and the effluent from the WWTP (Outfall 01)..I'hc plant receives high fructose corn
syrup delivered by train car (at the end of the railroad spur) and via tanker truck deliveries. The
train car parks in this area to unload via a pumping; system and delivers approximately 18,000
gallons per delivery. The unloading process is considered an industrial activity. Drainage Area 5
also contains seven truck loading concrete pads that receive fnished goods from the plant for
shipment; the handling of finished goods is considered an industrial activity. The activities
surrounding the WWTP's sludge dewalering press as well as the dumpsters for the dried solids
are now located on the new concrete pad under a new metal roof structure. Thus, the process is
now under a roof and sludge residuals are not in direct contact with rainfall.
• Drainage Area 6 comprises a number of employee parking; lots and the roadways employees
drive on to enter and exit the property. There is also a gravel unloading area where delivery
trucks park to unload vinegar and alum into tanks located near the main building. This area
drains into drop inlets located in the gravel parking lot. Stormwater runoff flows off the parking
lot to storm ditches/inlets along Vine Street. The primary industrial process in this area is
unloading; vinegar and alum into the storage tanks in this area. The loading; stand has a metal
yellow railing to prevent trucks from backing up into the unloading pipe connections. This
unloading; area is a potential spill area that could impact storm water runoff.
• Drainage Area 7 is located on the westernmost corner of the property. 'There is both gravel and
grass in this area. Any storin water that falls in this area drains to drop inlets that flow into off -
site Town of Mount Olive -owned storm pipes. This area is it lay down yard used by maintenance
to store pipes, empty dumpsters, wood, and some empty process equipment/tanks. There is a
storm water drain located near the property line that exits the property. This equipment and
storm drainage pipes are considered part of the industrial process and are in contact with rain that
falls in this area.

The Mt. Olive Pickle Company has been evaluating potential methods and changes to address the off -
property stormwater discharge points from Drainage Areas 2a, 5, 6, and 7. 'these changes would be
aimed at reducing potential impacts on stormwater quality or redirecting flows to the WWTP. 'These
proposed changes are listed below:
• To address stormwater runoff in Drainage Area 2a, it is proposed to construct an earthen berm
that will redirect stormwater runoff from its current routing offsite td Drainage Area 1, Doing so
will allow stormwater runoff from this area (which comes in contact with industrial processes) to
be treated by the WWTP.
• To address stormwater runoff in Drainage Area 5, and specifically at the corn syrup unloading -
area, it is proposed to add a number of non-struetural BMPs, including using storni drain covers,
improving the loading and unloading procedures used by The Mt. Olive Pickle Company
employees, and having spill containment and spill prevent ionic lea nup kits at the area around the
train car.
• To address stormwater runoff in Drainage Area 6, the unloading area where trucks park during
unloading would be paved pad area with a central drain (extending west of the existing pulrtp pad
area). New drain pipe from the pad drain would be installed and connected to an existing trench
drain which into the WWTP. do this way, spills from unloading operations would be captured on
the new pad area and would be treated by the WWTP rather than flowing into storm drains over
on Ville Street.
• To address stormwater runoff in Drainage Area 7, it is proposed to re -pipe flow from the storm
inlet leading off -site to a new structure with a sump, pump and discharge line to pump runoff to
an existing lift station in Drainage Area 1. The lift station in Drainage Area I pumps to the
WWTP. Thus, rather than leaving the site, the stormwater in Drainage Area 7 would be treated
in the WWTP.
The above changes are being incorporated into a future Stornlwater Pollution Prevention Plan (SPI'P)
under the general permit program and implemented under the SPPP. The Mt, Olive Pickle Company has
already started this plan to be proactive in addressing stormwater issues at the facility. One of the aims
of the above changes would be to reduce or eliminate stormwater discharge flowing offsite that would
need to be sampled and regulated as Stormwater Discharge Outfalls (SDOs).
I trust the above information is sufficient for this application; however, it'you should have any questions
or require additional information oil any of the above items, please do not hesitate to call me at (919)
828-0531.
Sincerely,
Carl W. Scharf, P.I-.
THE WOOTEN COMPANY
Cc: Fletcher Arritt, Kevin Campbell, The Mt. Olive Pickle Company
Enclosures: Notice of Intent for General Permit NCG060000, Facility Map, USGS Quad Map

Division of Energy, Mineral and Land Resources
Land Quality Section
I NCDENR National Pollutant Discharge Elimination System
.H maw D,� NCG060000
NOTICE OF INTENT
FOR AGENCY USE ONLY
Date Received
Year
Mmidt Do
Ceilifi= ofcovemsze
Pem+it AsAwd to
National Pollutant Discharge Elimination System application for coverage under General Permit
NCGO60000:
STORMWATER DISCHARGES associated with activities classified as:
SIC (Standard Industrial Classification) 20 Food and Kindred Products
SIC 21 Tobacco Products
SIC 263 Drugs
SIC 284 Soaps, Detergents, & Cleaning Preparations; Perfumes, Cosmetics, & Other Toilet Preparations
SIC 422 Public Warehousing and Storage (except 4226)
For questions, please contact the DEMLR Regional Office for your area. See page 4.
Do Not use this NOl for renewals.
(Please print or type)
1) Mailing address of owner/operator (address to which all permit correspondence will be mailed):
Name Fletcher Arritt
Street Address One Cucumber Blvd. PO Box 609
City Mount Olive State NC ZIP Code 28365
Telephone No. 919 581-3634 Fax: [phone]
2) Location of facility producing discharge:
Facility Name
Facility Contact
Facility Address
Facility City
Facility County
Telephone No.
Email
Mt. Olive Pickle Company
Fletcher Anitt
One Cucumber Blvd. PO Box 609
W. Olive State NC ZIP Code 28365
farritt mtolive is les.co
3) Physical Location Information:
Fax: [phone]
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). From Interstate 40,. take N.C. Highway 55 east ,to,the Town
of Mount Olive, then take_U_S. Highway 117 alternate south, then turn left on W. Park Ave. The facility is approximately
500 NE of the intersection of NE Center St. and W. Park Ave., on the north side of the Railroad.
(A copy of a county map or USGS quad sheet with the facility clearly located must be submitted with this application)
4) Latitude 35e12'14.04"N Longitude 78' 3'36.27"W (deg, min, sec) "A5J0 �--
5) This NPDES Pe iCfrdp' plies to which of the following:
❑ New or Propo eFacility Date operation is to begin
® Existing JUL 0 6 2016
J)EMR-LAND QUALITY
STORMWXl.ER pE,RMllPage 1 of 4
�1 g. 05 13�
SWU-221
Last revised 6124114

N0006DOOO N.O.I.
6) 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 0 3 5
7) Activities
a) Provide a brief narrative description of the types of industrial activities and products manufactured
at this facility: This facility manufacturers pickled cucumbers, pickled peppers, and
relishes. Its primary deliveries are cucumbers and peppers, high fructose corn syrup,
vinegar, and alum.
b) Check all activities occurring at this Facility:
❑ use or process meats !J use or process animal fats/byproducts
B) Discharge points I Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? Ia
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? Barlow Branch
Receiving water classification: W
Is this a 303(d) listed stream? No Has a TMDL been approved for this watershed? No
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). NIA
S) Does this facility have any other NPDES permits?
❑ No
M Yes
If yes, list the permit numbers for all current NPDES permits for this facility: NCO001074
10) Does this facility have any Non -Discharge permits (ex: recycle permit)?
X No
❑ Yes
if yes, list the permit numbers for ail current Non -Discharge permits for this facility:
11) Does this facility employ any best management practices for stormwater control?
❑ No
X Yes (Show any structural BMPs on the site diagram.)
If yes, please briefly describe: The facility has a spill prevention and response plan in pI,ra,, gg.
12) Does this facility have a Stormwater Pollution Prevention Plan?
® No
❑ Yes
If yes, when was it Implemented?
13) Are vehicle maintenance activities occurring at this facility?
F1 No 1 Yes All maintenance activities occur in Drainage Area 1, stormwater
runoff' drains to WVVfP for treatment in this area. See "Vehicle
Maintenace Area" cailout on attached site map.
Page 2 of 4
5WU-221 Last revised 6124l14

NCG060000 N.O.I.
14) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
® No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste generated per month) of
hazardous waste?
❑ No IN Yes
c) Is this facility a large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
® No ❑ Yes
d) Is hazardous waste stored in the 100-year flood plain?
® No ❑ Yes If yes, include information to demonstrate protection from flooding.
e) If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste: Used full and partially full COD vials - test kit size
How is material stored: Contained in 5-gallon buckets, stored for 5-6 mo
Where is material stored: Wastewater Treatment Plant Laboratory
How many disposal shipments per year: 2
Name of transport 1 disposal vendor: Heritage Environmental Services
Vendor address: 550 Guff Dr. Charlotte, NC 28208
Is) Certification:
North Carolina General Statute 143-216.6B (1) provides that:
Any person who knowingly makes any false statement, represertation, or certification in any application, record, report,
plan, or other document flied 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 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),
I hereby request coverage under the referenced General Permit. I understand that coverage under this permit
will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as an
individual permit.
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 rime of Person Signing: _ _ _ MTT-
Title: VIXZ PM> WW, 1-0:wart& 0u0rro'r
11111b
of Applicant) (D to rgned)
This Notice of Intent must be accompanied by a check or money order for $100.00, made payable to:
NCDENR. Do not send the check or money order separately.
Page 3 of 4
SWU-221 Last revised 0/24/14

NCG060000 N.0.1.
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
® Check for $100 made payable to NCDENR. Must be included with this application (not sent separately).
® This completed application and all supporting documents.
® A site diagram showing, at a minimum, (existing or proposed):
(a) outline of drainage areas, (b) stormwater management structures, (c) location of stormwater outfalls
corresponding to the drainage areas, (d) runoff conveyance features, (e) areas where materials are stored,
loaded, and unloaded, (f) impervious areas, (g) site property lines.
Copy of county map or USGS quad sheet with the location of the facility clearly marked on the map.
Mail the entire package to:
Stormwater Permitting Unit 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 coverage under the General Permit.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Realonal Office Contact Information:_
Asheville Office ...... (828) 29SA500
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...
(252) W-6481
Wilmington Office ...
[phone]
Winston-Salem ,.....
[phone]
Central Office .........
[phone]
Page 4 of 4
SWU-221 Last revised 6/24/14

o 6 2016
[,,EKi.R-LAiqD QUALITY
.S 1 dR{n�kTER PEFO{ i TING

Georgoulias, Bethany
From: Grzyb, Julie
Sent: Wednesday, July 13, 2016 4:23 PM
To: Carl Scharfe
Cc: Kevin Campbell; Georgoulias, Bethany
Subject: Re: storm water application
Ca rl,
I would recommend that you come in and review the Mt. Olive Pickle file and previous permits and variance
approvals. Each time this permit has been renewed a decrease in the chloride limitation has occurred. A
variance is granted only for the term of the permit and each time the Permittee must demonstrate reductions
are occurring if possible and all other treatment methods or process changes in the pickle industry that could
result in a decrease of chlorides have been reviewed and considered for implementation. In addition, EPA has
revised the rules for a variance this past year and I am not completely sure how these new rules will impact
the process.
Julie
From: Carl Scharfe <[e-mail]>
Sent: Wednesday, July 13, 2016 8:22:53 AM
To: Grzyb, Julie
Cc: Kevin Campbell; Georgoulias, Bethany
Subject: RE: storm water application
Julie: Attached is the Main Production Plant Map from the NOI and the quad map. I assume you got the cover letter to
Bethany explaining the existing storm water drainage areas and where the stormwater flow goes. The Production Plant
site map is relatively easy to read when zoomed to 75% on my computer screen. Currently, all of the stormwater in
Drainage Areas 1, 3 and 4 discharge to the WWTP. This water was diverted to address past stormwater runoff off the
site that had brine (covering the whole industrial activity area in Drainage Area 1 is very costly.
I was not aware that the new permit would have a reduction in the chloride limits. I thought one of the purposes of the
chloride variance was to allow the same chloride discharge levels in the future as it was shown that treatment of
chlorides was very expensive in the variance request.
From: Grzyb, Julie [mailto:julie.grzyb@ncdenr,gov]
Sent: Tuesday, July 12, 2016 6:11 PM
To: Carl Scharfe
Cc: Georgoulias, Bethany
Subject: storm water application
Carl,
Bethany dropped off a copy of the Storm water application sent in for Mt. Olive Pickle.
Much of the information refers to the map; however, the map is too small for me to read. Can you send me an
electronic copy of the map? Also, do the Storm Ponds typically get bled back into the WWTP?
One last concern — when this permit was renewed last, Mt. Olive Pickle had complained about a peak flow problem
during storm events which sometimes lead to difficulties in meeting their chloride discharge limitation. Each year Mt.
Olive Pickle is required to submit a Chloride Variance review and for the last four years have stated in that review that
since the issuance of the last variance, Mt. Olive Pickle has completed — separation of storm water and process water.

.rear.¢alr.:an•rane:rl,r.r.rnur:ram . .
■army a.af a,��fr ■ � i ��.,. •.io�litii'
First Citizens Bank °;054118
www.lirsicitizens.com
The WOOtQn.COnlpi�ny 66-003010531
120 N',Boylan?AvenLe' irzsnreiPCheck Fm
Raleigh; NC 27603 Protection for Business
PIW{10TENCDIVPAkY 919-828-0531 CHECK DATE July 6, 2016
PAY One'Hundred and•.001100 Wllars•-
AAAMI ANT a1 nn nn
TO NCDEQ
1628 Mail Servlce Center
Raleighr,NC 27699-1628
!E[V�,IY fEaNRE�INC,.UNRb UK.fai�80N ItACN
VIDS1, L

TVT
THE WOOTEN COMPANY
F N014F,i Al NS Vt ANN ING AR CH4 T i C I U 9 F
120 North 80an knntm Raleigh NC 27603.1423
919.828.0531 iaY 919.83s.35W
LETTER OF
TRANSMITTAL
DATE 7I612016
JOB NO. 2395-0
TO: BETHANY GEORCOULIAS, ENGINNER
DE - STORM WATER PERMITT] NG UNIT PROGRAM
RE: NO] for NCG060000
Mount Olive Pickle Company
WE ARE SENDING. ❑ Attached ❑ Under separate cover via the following items:
❑ Shop Drawings ❑ Prints ❑ flans ❑Samples ❑ Specifications
❑ Copy of Letter ❑ Change Order Other:
COPIES
DATE
NO.
DESCRIPTION
1
716116
NO] for NCG060000, Mount Olive Pickle Company
1
7/6116
Review Fee- S100 Cheek
THESE, ARE -TRANSMITTED as checked below:
® For Approval ❑ Reviewed ❑ Revise and resubmit
❑ For your use ❑ Rejected ❑ Submit copies for distribution
❑ As Requested ❑ Corrected ❑ Return corrected print
❑ For Review and comment ❑
❑ I.OR BIDS DUE j J ❑ PRINTS RE`CURNED AFTER LOAN TO US
REMARKS:
SIGNED: V i r vti�
COPY TO: TWC. Adrienne Smit , Project Administrator
/D
206
STpRtftA ER PRmir
LNG
RECEIVE
JUL 06 2016
QNP-LAND QUALITY

ftEC61VEtIlP1G�E�11
MAR 31,2016
water Quality
Permitting Section
March 28, 2016
Mr. Tom Belnick
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
Subject: Chloride Variance Review
NPDES No. NC0001074
Mount Olive Pickle Co.
Wayne County
Dear Mr. Belnick:
In compliance with the Variance Requirements, Mount Olive Pickle Company continues
its efforts to study and evaluate chloride removal technology and chloride reduction
technologies. Since the mid 1980's Mount Olive Pickle Company has spent
approximately $10.0 million on salt reduction and wastewater improvements. As noted in
our most recent Variance Request (October 2010), there have not been any breakthroughs
in chloride removal technologies for removing salt from pickle brines.
Figure 1 shows the impact the changes made over the last 30 years 'on the chloride
concentration of the effluent- The largest drop occurred in the 1980's when the first major
breakthrough occurred in brining technology. It was discovered that calcium chloride
could serve as a partial replacement for salt in the brining process. Since the issuance of
the variance we have completed:
• wooden tank replacement program
• separation of storm water and process water
• recycling of fermentation brines
• replacement of blauchers
The reductions since 1990 are due primarily to the wooden tank replacement program
and the brine recycling program. We are currently recycling over 4.5 million gallons of
used fermentation brine each year. The chloride concentration in the effluent has leveled
off in recent years, with no noticeable change over the last 10 years.
Mount Olive Pickle Company,' ic. Corner of Cucumber & Vine • P.O, Box 609 • Mt. Olive, N.C. 28365
Phone: 1-9IM58-2535 FAX: 1-91M58-6296 • Website: www,mtolivepickles.com

An.
March 17, 2014
Mr. Tom Belnick
Division of Water Quality
North Carolina Department of
Environment and Natural Resources
P.O. Box 29535
Raleigh, NC 27626-0535
Subject: Chloride Variance Review
NPDES No. NCO001074
Mount Olive Pickle Co.
Wayne County
Dear Mr. Belnick:
In compliance with the Variance Requirements, Mount Olive Pickle Company continues
its efforts to study and evaluate chloride removal technology and chloride reduction
technologies. Since the mid 1980's Mount Olive Pickle Company has spent
approximately $10.0 million on salt reduction and wastewater improvements. As noted in
our most recent Variance Request (October 2010), there have not been any breakthroughs
in chloride removal technologies for removing salt from pickle brines.
Figure 1 shows the impact the changes made over the last 27 years on the chloride
concentration of the effluent. The largest drop occurred in the 1980's when the first major
breakthrough occurred in brining technology. It was discovered that calcium chloride
could serve as a partial replacement for salt in the brining process. Since the issuance of
the variance we have completed:
• wooden tank replacement program
• separation of storm water and process water
recycling of fermentation brines
replacement of blanchers
The reductions since 1990 are due primarily to the wooded: tank replacement program
and the brine recycling program. We are currently recycling over 4.5 million gallons of
used fermentation brine each year. The chloride concentration in the effluent has leveled
off in recent years, with no noticeable change over the last 10 years.
Mount Olive Pickle Company, Inc. • Corner of79rcumber & Vine • One Cucumber Boulevard • P.O. Box 609 • Mount Olive, NC 28365
Phone: [phone] • Fax: [phone] • www rntolivepicldes.com